APPLICATION No:	         04/48900/HYBEIA

APPLICANT:	Peel Investments (North) Limited

LOCATION:	Land West Of Worsley Bounded By M60, East Of Astley Green And Landfill Site, South Of Boothstown Leigh Road Worsley    

PROPOSAL:	A Forest Park comprising a Forest Centre including Eco Village, Timber Initiative and Woodland Wildlife Centres, timber workshop, children's woodland adventure play area and treetop walkway; equestrian centre; all weather and turf track racecourse and equestrian eventing area; cross country eventing course; grandstand and associated buildings; refurbishment of Malkins Wood farmhouse to residential accommodation for equestrian centre manager; refurbishment of Moss House Farmhouse and conversion and extension of two barns to form a hotel (80 guests); golf course and clubhouse and change of use of agricultural building for golf course maintenance; footpath and riding trails and cyclepaths; roads and connection to J13 M60, replacement canal bridge, new canal bridge and bridge over Shaw Brook; car parking; landscaping including ground remodelling creation of water bodies and woodland planting; site infrastructure including fencing, lighting, services and sub stations; and site accommodation works including culverts and watercourse diversions.

WARD:	Panel Members

EXECUTIVE SUMMARY

Introduction

For ease of reference, this report is split into three sections.  Firstly, the background report contains details on the context of this application, a description of the proposed works, along with the consultation exercise undertaken and relevant national, regional and local policies.  Secondly, the planning appraisal and thirdly, Appendix A provides a full summary of each of the consultation responses, listed in alphabetical order.

Appeal

The applicant lodged an appeal with the Planning Inspectorate on 12th November 2008 against the non- determination of this planning application.  As a result of the appeal being lodged the City Council is now not able to formally determine this application. The Panel does, however, have to advise as to how they would have determined the application at this moment in time if they were able to do so. This will then form the basis of the Council’s case to be presented at the Inquiry and considered by the Inspector and subsequently by the Secretary of State.  

Site description

The proposed development is referred to by the applicant as Salford Forest Park and in total extends to an area of some 696 hectares situated on land bounded to the east by the M60, the south by the M62 and Manchester – Liverpool railway, the west by farmland giving way to landfill, and to the north and north east by Boothstown and Worsley.  A full description of the site and surroundings can be found in paragraphs 2 to 2.8 of the background report.  The site straddles the boundary between Salford City Council and Wigan MBC, 684 hectares of the site lie within Salford and 12 hectares within Wigan. 

An Article 10 application in respect of the Wigan application was submitted to SCC for consideration in January 2008 (application reference: 08/55887/ART10), this will be considered separately within the same agenda.

Description of development

In summary, the applicant seeks consent for a forest park comprising a forest centre including eco village, timber initiative and woodland wildlife centres, timber workshop, children’s woodland adventure play area and treetop walkway, equestrian centre, all weather and turf track racecourse and equestrian eventing area, cross country eventing course, grandstand and associated buildings, refurbishment of Malkins Wood farmhouse to residential accommodation for equestrian centre manager, refurbishment of Moss House farmhouse and conversion and extension of two barns to form a hotel (80 guests), golf course and clubhouse and change of use of agricultural building for golf course maintenance, footpath and riding trails and cyclepaths, roads and connection to J13 of the M60, replacement canal bridge, new canal bridge and bridge over Shaw Brook, car parking, landscaping including ground remodelling, creation of water bodies and woodland planting, site infrastructure including fencing, lighting, services and sub stations, and site accommodation works including culverts and watercourse diversions.  A full description of the proposed development can be found in paragraphs 3 to 3.58 of the background report.

An outline application (reference: 01/43043/OUT) for the same development was submitted in 2001.  This was withdrawn in 2004 as a result of the significant number of comments received.  A full history of the site can be found on paragraph 8 of the background report.

The current application is a ‘hybrid’ planning application in that the proposal contains elements where full planning permission is sought in addition to elements where only outline planning permission is sought. The outline elements seek consent for access with layout, scale, appearance and landscaping reserved for future consideration.  The outline elements include the forest centre buildings consisting of the eco village buildings, the woodland wildlife centre, the timber initiative centre and timber workshops.  A table clearly showing which of the elements is in full and which is in outline can be found in table 1 (Entitled  - Form of each Element of the Proposal) in section 3 of the background report.

Supporting documents

The applicant submitted the original application and associated Environmental Statement in June 2004. After significant consultation the applicant submitted a supplement to the original ES in May 2007.  The applicant has submitted the following supporting documents:

•	Transport assessment;
•	Needs assessment;
•	Planning support statement;
•	Introduction and method statement;
•	Scheme description;
•	Alternative sites assessment;
•	Non-technical summary; 
•	Paper on very special circumstances in relation to Green Belt issues; and
•	Construction plan.

A summary of each of these documents can be found in paragraphs 5 to 7.4 of the background report.

Consultations

There have been two key stages of consultation, the first stage was July/August 2004 when the original ES was submitted, and the second stage was carried out when amendments were made to the application in May 2007 as part of the Environmental Statement Supplement submission.  The following consultees were notified of the planning application:

•	Barton Aerodrome 
•	Boothstown Residents Association 
•	British Horseracing Board 
•	Council for Protection of Rural England 
•	Countryside Agency 
•	Economic Development – Chief Executive Salford City Council 
•	English Heritage 
•	Environment Agency 
•	Forestry Commission 
•	Government Office 
•	Greater Manchester Archaeological Unit 
•	Greater Manchester Bird Recording Group 
•	Greater Manchester Ecology Unit 
•	Greater Manchester Passenger Transport Executive
•	Greater Manchester Police Architectural Liaison Officer
•	Health and Safety Executive
•	Highways Agency
•	Lancashire Aero Club
•	Manchester Ship Canal Company
•	National Farmers Union North West
•	National Grid Company PLC / British Gas Transco
•	Natural England (formerly English Nature)
•	Network Rail
•	North West Development Agency
•	4NW – The Regional Leaders Forum (formerly known as North West Regional Assembly)
•	RAGE – partnership between Worsley Village Community Association, Boothstown Residents Association and Worsley Civic Trust and Amenity Society
•	Ramblers Association - Manchester and High Peaks Area
•	Red Rose Forest
•	Royal Society for Protection of Birds
•	United Utilities
•	Urban Vision Environment
•	Wildlife Trust – Lancashire, Manchester and Merseyside
•	Worsley Civic Trust and Amenity Society
•	Worsley Village Community Association

A short summary of each consultation response can be found in table 2 (Entitled - Summary of Consultee Responses) in section 9 of the background report.  A full summary of the consultation responses is attached within this agenda at Appendix A.

Publicity and representations

In terms of publicity, site notices were displayed on site, press notices were published and neighbours were notified of the proposals by letter in June 2004 and May 2007. The second consultation exercise followed the submission of additional details by the applicant. A full list of those neighbours consulted can be found in section 10 of the background report.

A total of 501 letters of objection have been received to date.  These are split between June 2004 (373 representations) and May 2007 (128 representations).  The key areas of concern raised by local residents relate to the development of Green Belt land, increased air pollution, impact on valuable wildlife habitats, impact on existing transport infrastructure, racecourse / golf course / hotel not needed, increase in noise pollution, increase in light pollution, and the visual impact of the grandstand.  A full summary of the issues raised can be found in section 11 of the background report.

Planning Policy Documents

National Planning guidance (Planning Policy Guidance- PPG / Planning Policy Statement - PPS) The Regional Spatial Strategy (RSS), Salford Unitary Development Plan (UDP) and Supplementary Planning Documents (SPD) provide the policy framework by which the application should be determined.  The relevant policies to be considered in the determination of the application are listed in paragraphs 12 to 12.6 of the background report and summarised within paragraphs 12.7 to 12.83.

Planning appraisal

The key issues to be considered in the determination of this application are:

•	Impact of the development on Green Belt – including an assessment of any Very Special Circumstances advanced;
•	Visual impact and design quality;
•	Impact of the development on ecology;
•	Access, parking, traffic and transportation;
•	Impact of the development on recreation;
•	Impact of the development on noise;
•	Impact of the development on air quality / dust;
•	Impact of the development on flooding and drainage;
•	Impact of the development on ground conditions;
•	Impact of the development on mineral resources;
•	Impact of the development on the economy;
•	Impact of the development on tourism;
•	Impact of the development on agriculture;
•	Impact of the development on archaeology and cultural heritage;
•	Impact of the development on design and crime; 

Impact of the development on Green Belt

This section can be found within paragraphs 3 to 3.127 of the planning appraisal.  The site is located entirely within the Salford Green Belt, and as such Planning Policy Guidance Note 2 - Green Belt (PPG2), and policy EN1 of the Salford Unitary Development Plan (UDP) provide the planning policy framework against which the development is assessed here.  Relevant appeal decisions are discussed in paragraphs 3.14 to 3.21 of the planning appraisal.  It is concluded that the golf course, golf course maintenance depot, cross country and eventing area, and the racecourse track (not including the grandstand and associated development on the scale outlined in the application) could be said to represent appropriate development in the Green Belt. Despite this a substantial and significant number of elements represent inappropriate development. On that basis it is concluded that the development as a whole represents inappropriate development in the Green Belt.  

With regard to Green Belt policy, inappropriate development is by definition harmful to the Green Belt.  Such development should not be approved except in very special circumstances.  Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness and any other harm is clearly outweighed by other considerations. The onus is on the applicant to demonstrate that very special circumstances exist.  The applicant has provided a paper on very special circumstances which is summarised under 11 headings in paragraphs 4 to 4.45 of the planning appraisal.  It is concluded that the applicant has failed to demonstrate very special circumstances and therefore the development represents inappropriate development within the Green Belt. It should be noted that the applicant has only recently accepted that the whole of the development is inappropriate and is still reserving their position within the Grounds of Appeals, maintaining a stance that the development is appropriate but accepting for the sake of argument and to advance the appeal that it may be inappropriate. This has caused significant difficulty in discussions and obtaining information, particularly financial information that may help advance the very special circumstances put forward.

Visual impact and design quality

This section can be found within paragraphs 5 to 5.16 of the planning appraisal.  Key policies in relation to this section are Planning Policy Statement 1 - Delivering Sustainable Development (PPS1), PPG2, Planning Policy Statement 7 - Sustainable Development in Rural Areas (PPS7) and policies DES1 and EN17 of the UDP.  The applicant has carried out a visual assessment, which forms the basis of the discussion.  The built form of the proposed development is discussed together with the changes in intensity and activity and the result of this on the visual amenities of the Green Belt.  The issue of ‘sky glow’ from lighting columns and its impact on both the Green Belt and neighbouring residential properties is discussed within this section.  

In conclusion, it is acknowledged that the applicant has made attempts to reduce the visual impact of the development through careful siting of the development.  Despite this it is considered that the proposed development, with particular reference to the grandstand and the lighting columns would significantly change the existing open character of the area and appearance of the site. 

Impact of the development on ecology

The key policies considered within this heading are: Planning Policy Statement 9 - Biodiversity and Geological Conservation (PPS9); policies EN7, EN8, EN10 and EN12 of the UDP; the Conservation and Biodiversity - Supplementary Planning Document (SPD); and policy EM1(D) of the Regional Spatial Strategy (RSS).

The key topics considered are: Summary of habitats and species (paragraph 6.2); habitats (paragraph 6.15); Sites of Biological Interest (paragraph 6.22); mature plantation woodland / broad-leaved semi-natural woodland (paragraph 6.32); swamps (paragraph 6.33); ponds (paragraph 6.36); watercourses (paragraph 6.39); farmland habitat (paragraph 6.42); management plans (paragraph 6.47); species (paragraph 6.50); birds of conservation interest (paragraph 6.51); great crested newts (paragraph 6.53); water voles (paragraph 6.58); bats (paragraph 6.62); badgers (paragraph 6.67); brown hares (paragraph 6.68); and Japanese knotweed (paragraph 6.71).

The Environment Agency has withdrawn their objection on ecological grounds but the Greater Manchester Ecological Unit maintains its objection to the application despite the recent submission of revised details. There is also no objection from Natural England. Due to this uncertainty it is considered that the nature conservation and ecological impacts of the development are finely balanced and there is not sufficient time to resolve this uncertainty. It is therefore considered inappropriate to take a view on ecology issues, particularly having regard to the fact that this matter is to be heard at appeal.   

Access, parking, traffic and transportation

It is concluded within this section (paragraphs 7 – 7.10) that the modelling undertaken by the applicant is unacceptable and insufficient information has therefore been submitted to demonstrate that the proposal would not have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation.  As such, the proposal is contrary to PPG13, policies A1, A2 and A8 of the UDP and policies RT2 and RT9 of RSS.

Impact of the development on recreation

In summary, this section (paragraphs 8 to 8.5) identifies that the location of the site, on the urban fringe would help to meet greenspace standards and provide a range of accessible leisure and sporting activities for the people of Salford and the wider region.  However, there is no evidence brought forward by the applicant as to why the site could not be opened up without the proposed development.  
Key policy considerations are: PPS7 and Planning Policy Guidance 17 – Planning for Open Space, Sport and Recreation (PPG17); policy ST10 of the UDP; and policies EM4, DP2 and W7 of RSS.

Impact of the development on noise

This section can be found within paragraphs 9 to 9.13 of the planning appraisal.  It is concluded that the mitigation measures proposed would provide an appropriate and satisfactory level of amenity protection for affected residents. The mitigation measures would be implemented by planning condition.

Relevant policy considerations include Planning Policy Guidance 24 – Planning and Noise (PPG24) and policy EN17 of the UDP.

Impact of the development on air quality / dust

This section can be found within paragraphs 10 to 10.14 of the planning appraisal.

The applicant would be required to submit a Dust Management Plan to cover the construction phase of the development. The Dust Management Plan would apply to all areas and activities on the site for the duration of the construction phase. The dust management plan could be secured by a suitable planning condition. 

With regards to air quality, the proposals are considered to accord with policy EN17 of the UDP, subject to the implementation of conditions relating to the dust management plan and the green travel plan. It is also recommended that a payment towards air quality management be secured through a S106 agreement.

Impact of the development on flooding and drainage

In conclusion, although the development would result in a reduction of flood storage capacity the applicant has successfully assessed the flood risk and the run off implications of the development and would provide an acceptable amount of replacement flood capacity storage on site. In relation to policy EN19 of the UDP and Planning Policy Statement 25 – Development and Flood Risk (PPS25), it is considered that the flood risk posed by the development is adequately mitigated for within the details of the proposals submitted by the applicant.  This section can be found within paragraphs 11 to 11.5 of the planning appraisal.

Impact of the development on ground conditions

Planning Policy Statement 23 – Planning and Pollution Control (PPS23) and policy EN16 of the UDP are the key policy considerations within this section which can be found at paragraphs 12      to 12.6 of the planning appraisal.  It is concluded that the development would comply with the requirements of these policies subject to compliance with a number of conditions.

Impact of the development on mineral resources

It is concluded within this section (paragraphs 13 to 13.2) that although there is not sufficient evidence to prove the presence, or otherwise, of any viable mineral resource within the application area the application is unlikely to result in the sterilisation of such potential minerals due to the design and siting of the built development.  The proposal would therefore comply with policies M1 and ST17 of the UDP.

Impact of the development on the economy

Policy ST3 of the UDP is relevant in the consideration of this section (paragraphs 14 to 14.3).  The application would create a number of new jobs, however a development of this size cannot be considered to be a major generator of jobs when providing 260-270 full time equivalent jobs.

Impact of the development on tourism

It is summarised that the proposal can be considered to be in accordance with policy W7 of RSS and policy E6 of the UDP in that it would improve the region’s overall tourism offer, the applicant has not demonstrated that there is a need for this type of facility in Salford that would override the harm to the openness of the Green Belt.  This section can be found at paragraphs 15       to 15.4 of the planning appraisal.

Impact of the development on agriculture

This section can be found at paragraphs 16 to 16.8 of the planning appraisal.

The loss of the Best and Most Versatile (BMV) agricultural land (Grades 1, 2 or 3a) development will only be permitted where it can be demonstrated that there are no appropriate alternative sites available on lower grade agricultural land or on non-agricultural land.  An analysis of the agricultural land within the site identifies that 2% of the land is classified as Grade 2 and 75% of the land is Grade 3a.  

The development would result in a number of reversible and irreversible development features which are detailed within the section.  DEFRA do not object to the development in terms of its impact on BMV land.  A number of mitigation measures are proposed and the application proposes the creation of an Agricultural Management Plan.  The proposed development is considered to be in accordance with PPS7 and policy EN3 of the UDP in respect of the impact of the development on agriculture.

Impact of the development on archaeology and cultural heritage

This section is considered at paragraphs 17 to 17.3 of the planning appraisal.

The applicant has carried out a study to describe the impact of the proposed development on the cultural heritage and the likely impact on palaeoecological deposits.  Subject to a condition requiring archaeological mitigation through a programme of evaluation the application is considered to be in accordance with policy CH5 of the UDP.

Impact of the development on design and crime

This section can be found at paragraphs 18 to 18.1 of the planning appraisal.
Subject to a condition ensuring that all new and refurbished buildings should be completed to ‘Secured by Design’ standards, it is considered that the proposals would comply with policy DES11 of the UDP and the Design and Crime SPD. 

Conclusion 

It is concluded within section 19 that the development is inappropriate development within the Green Belt. The applicant has, until recently, refused to accept that the development is inappropriate and has therefore not advanced any very special circumstances of substance. The failure of the applicant first of all to accept that the application is inappropriate development in the Green Belt, and then to justify the proposal adequately in terms of very special circumstances, means that there is no alternative but to recommend refusal of the application at this moment in time.

The Highways Agency has indicated that it is likely to lift its Holding Direction preventing the Local Planning Authority from making a decision. It is understood that the applicant's consultants have undertaken more modeling work to justify the scheme, but until that has been submitted and assessed there is no alternative but to recommend refusal on highway grounds.

In terms of the appraisal on ecology, the position is more finely balanced, with Natural England and the Environment Agency not objecting to the application, but the GM Ecology Unit still having significant concerns. The view of officers as set out above is that it is difficult in the time available and the fact that this matter is to be tested at appeal to come to a firm conclusion on ecological matters and therefore it would be difficult to justify objecting on ecological grounds.

Recommendation

That the Planning Inspectorate be advised that on the basis of the information that is currently before the City Council in the consideration of this application, the Council would resolve to refuse planning permission for the following reasons. 

1.	Green Belt

The proposal represents inappropriate development within the Green Belt and as such is contrary to PPG2: Green Belts and policy EN1 of the Salford City Council Unitary Development Plan. 

To date, very special circumstances have not been demonstrated that would override the harm arising as a result of the inappropriate nature of the development and the harm to Green Belt policy.  

2.	Highways

The modeling undertaken by the applicant is unacceptable and insufficient information has therefore been submitted to demonstrate that the proposal would not have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation.  As such, the proposal is contrary to PPG13, policies A1, A2 and A8 of the UDP and policies RT2 and RT9 of RSS. 

BACKGROUND REPORT

DEVELOPMENT CONTEXT 

APPEAL

The applicant has lodged an appeal with the Planning Inspectorate on 12th November 2008 against the non- determination of this planning application and accordingly the Panel are not able determine this application. Panel can nevertheless advise how they would have determined the application if they were able to do so which can then form part of the Council’s case to be considered by the Inspector.  

The Planning Inspectorate and the Department for Communities and Local Government have decided that the application is of more than local significance and have decided that the Secretary of State will make the decision.  This means that the inquiry will be heard by an Inspector who will deliver a report with a recommendation to the Secretary of State.  The Secretary of State will make a decision on the basis of that report.

ABBRIEVATIONS

SFP – Salford Forest Park
EIA – Environmental Impact Assessment
ES – Environmental Statement
ESS – Environmental Statement Supplement
NTS – Non-Technical Summary
SBI – Site of Biological Interest
SSSI – Site of Special Scientific Interest
UTA – Updated Transport Assessment
PPS – Planning Policy Statement
PPG – Planning Policy Guidance
RSS – Regional Spatial Strategy
VSC – Very Special Circumstance
BAP – Biodiversity Action Plan
GMAU – Greater Manchester Archaeological Unit
GMEU – Greater Manchester Ecological Unit
GMGU – Greater Manchester Geological Unit
EA – Environment Agency

1.	BACKGROUND

1.1	The development site forms part of the former Bridgewater Estate, located to the west of Worsley and was the former home of some of the most energetic and innovative figures of the industrial revolution. The development proposes opening up large areas of inaccessible estate lands for recreation, and the provision of a wide range of new sporting and recreational facilities in a woodland park context.

1.2	An outline planning application (application reference: 01/43043/OUT) was submitted to Salford City Council in 2001. The application was for a grandstand, ancillary buildings for new racecourse; equestrian, woodland visitor, timber initiative and youth activities centres; eco village, hotel, public house; golf course, driving range & clubhouse; new access from Junction 13 M60.  The application was subject to widespread consultation, which resulted in a significant number of comments being received. The applicant withdrew the application in 2004.  The applicant took into account the range of comments received and made a number of revisions to the proposed scheme in light of these. 

1.3	The applicant has stated that the Salford Forest Park (SFP) scheme is designed to become a fully sustainable rural recreational resource on the doorstep of the Greater Manchester conurbation. It aims to complement other provision in the region, contribute positively to the image and tourism potential of Worsley and Salford and the wider sub-region, and deliver significant new opportunities for informal woodland recreation for residents.       

2.	SITE DESCRIPTION

2.1	The site comprises 684 hectares of land located within the Salford Green Belt.  The land is broadly bounded to the east by the M60, the south by the M62 and Manchester-Liverpool railway, the west by farmland giving way to landfill, and to the north and north east by Boothstown and Worsley. The Bridgewater Canal passes through the site from east to west, and this separates the land to the north and the south of the site. Access within the site is limited by the three existing crossings over the canal, which carries only farm and foot traffic, and no public highway access into the land to the south of the Canal. Access to the north of the canal is via three points; the listed gates on the A572 Leigh Road; a lane leading south from a cul-de-sac at the A572 Leigh Road at Boothstown which terminates at Worsley Hall Nurseries; and from an existing access from the A580 East Lancashire Road gyratory junction at Chaddock Lane (located in Wigan) into the farmland to the north of the canal. 

2.2	The topography of the site is essentially flat and low lying, but the site rises in gradient from the canal up towards Leigh Road. In terms of ground conditions the soils to the south of the site include extensive areas of peat with outliers of clay. To the north of the canal the rising land is underlain by coal measures. There are three areas of former landfill immediately adjacent to the canal on its south side, adjacent to Moss House Farm, Hollin Wood and the grandstand enclosure. This area has been raised artificially above adjacent areas, which has resulted in slightly domed landforms next to the canal. Whitehead landfill site is located to the west of the application site and lies partially within Salford and Wigan. The proposed site has been disturbed by opencast workings and is now being landfilled. Once this process is complete this area will be raised above the surrounding ground levels and used as a country park. 

2.3	The current principle land use is agriculture and woodland, although variations exist across the entirety of the site. The woodland at Middlewood is mostly made up of deciduous hardwoods, although larch exists within this part of the site. The area of land to the south of the canal is used for grazing and substantial beech hedges exist here. Botany Bay Wood and Bitterns Pits and Hollin Wood are mixed plantations with some areas of conifers and some areas of native hardwoods including oak, beech and birch and some extensive areas of rhododendron understorey. Within this part of the site there are two triangular fields, which are used for arable agriculture. The area of the site know as Grange Farm is in arable management, and is mostly grade 3a, with some grade 4 and a small area of grade 2. Woodside Farm comprises a small sliver of farmland, which lies immediately adjacent to the railway at the southern boundary of the site. The land is not currently within active agricultural management. Land to the north of the canal is currently used as an informal recreation area, and playing fields. West of Boothstown the landscape comprises small-scale fields in agricultural management, which are generally well hedged. 

2.4	The development site supports a number of habitats and species of nature conservation interest. Of particular note is the Botany Bay Wood Site of Biological Importance (SBI), habitats for local and national biodiversity (lowland bog, ponds, water bodies, mature mixed broadleaved woodland), location of species of biodiversity value including protected species and others which are known to be of conservation concern such as “Red List” farmland birds. Middlewood and the associated land north of the canal is a designated SBI. The site consists of a range of habitats; principally open farmland (arable/grass/set-aside), mature woodland, ditches, and ponds. The sites formally designated for ecological reasons are inhabited by woodland birds, grey herons, lowland bog and woodland flora. The areas of undesignated farmland have features of value including ponds, ditches, and field margins.

2.5	There are three farmsteads within the site boundary all to the south of the canal; these include Malkins Wood Farm in the West, Moss House Farm in the north, and Grange Farm in the east. All of the buildings are supplied with domestic water and electricity, but are not connected to the mains foul drainage system.  

2.6	The site is crossed by two major infrastructure service lines, these include the Thirlmere Aqueduct, which passes through the woodland core across land at Grange Farm; and two high pressure gas mains, one coming into the site from the north and the latter crosses east-west on a route parallel to The Avenue. 
   
2.7	The application side straddles the boundary between Salford City Council and Wigan Metropolitan Borough Council (MBC), 12 hectares of the application site lies within Wigan MBC.  A planning application (application reference: A/04/61939) has been submitted to Wigan MBC and an appeal in respect of the non-determination of this application has also been lodged.  The proposal is for the construction of an access road and associated junction off the A580 East Lancashire Road together with a screen mound and woodland planting (as part of the proposed racecourse, golf course and forest centre, golf course and forest centre development on adjoining land in Salford).  An Article 10 application in respect of this application was submitted to SCC for consideration in January 2008 (application reference: 08/55887/ART10), this will be considered separately.

2.8	An application has recently been submitted and is still under consideration for a United Utilities pipeline that runs through the site (application reference: 08/56842/EIA.)  A response is awaited in respect of the applicant’s position on this issue.

3.	DESCRIPTION OF THE PROPOSALS 

3.1	The application is a ‘hybrid’ planning application in that the proposal contains elements where full planning permission is sought in addition to elements where only outline planning permission is sought. The outline elements seek consent for access with layout, scale, appearance and landscaping reserved for future consideration.  Table 1 below clarifies the position in respect of each principle element of the proposed scheme as follows:-

Table 1 – Form of each element of the proposal

Element of development	Full/Outline	Other Comments	
Racecourse and equestrian eventing area	Full	(1)	Council to impose a Condition reserving for further approval the landscaping associated with this element
(2)	Parameters have been provided relating to landscape structure	
Grandstand and related buildings/facilities	Full	As above	
Hotel	Full	As above	
Equestrian centre and related building/facilities	Full	As above	
Cross country eventing course	Full	As above	
Internal road network and connections to public highway network	Full	As above	
Forest Centre Buildings. Namely, the Eco Village buildings, the Woodland Wildlife Centre, the Timber Initiative Centre and timber workshops	Outline	Parameters have been provided relating to:-
•	Area for siting
•	Height
•	Design
•	External appearance
•	Landscape Structure	
Treetop walkway	Full	(1)	Council to impose a condition reserving for further approval the location, design and external appearance of the structure
(2)	Parameters have been provided relating to height, location and range of materials to be employed in construction	
Children’s woodland adventure play area	Full	As above	
Golf Course	Full	(1)	Council to impose a Condition reserving for further approval the landscaping associated with this element
(2)	Parameters have been  provided relating to landscape structure	
Club house for golf course	Full	As above	
Change of use of building for golf course maintenance depot	Full		
Bridges	Full	(1)	Council to impose condition reserving for further approval the precise routing of such paths and trails within woodland areas.
(2)	Parameters have been provided relating to landscape structure	
Footpath trails, riding trails and cycle paths	Full	(1)	Council to impose condition reserving for further approval the precise routing of such paths and trails within woodland areas.
(2)	Parameters have been provided relating to: no loss of mature trees, avoidance of heronry area and no use of invasive construction methods around tree roots.	
Car parking areas	Full	(1)	Council to impose a Condition reserving for further approval the landscaping associated with this element.
(2)	Parameters have been provided relating to landscape structure.	
Change of use (insofar as the Section 75 (2) or (3) of the Town and Country Planning Act 1990) of application site to a Forest Park comprising Forest Centre, Racecourse, Hotel, Equestrian Centre, cross country eventing course, golf course, footpath trails, riding trails, cycle paths and car parking	Full		

3.2	The applicant submitted the original application and associated Environmental Statement in June 2004. After significant consultation the applicant has submitted a supplement to the original ES. The Environmental Statement Supplement (ESS) outlines the various adjustments made to the SFP proposals and provided an updated assessment of the environmental effects of the scheme. The submission includes the following:  

•	An update of the Planning Policy context of the scheme
•	Confirmation that roads onto the landfill car parking areas would be open to vehicles only on race days or for annual three day eventing meetings
•	Proposals for controlling closure of permissive paths
•	Further proposals for watercourse, water vole and amphibian mitigation
•	Explanatory information regarding flood storage close to Keepers Cottage
•	Details of potential noise mitigation measures at Keepers Cottage by agreement with the property owners
•	A Green Travel Plan Discussion document
•	Further information on the requirements for ancillary facilities for the racecourse
•	Further information on the operation of the Forest Park Centre
•	Further information on detailed aspects of the golf course

3.3	As part of the ESS submission, the following changes were made to the original scheme: 

•	Minor amendments to proposed A580 junction to improve pedestrian crossing facilities
•	One metre reduction in ridge height of golf clubhouse roof
•	Deletion of proposal to allow horses through Bridgewater Park
•	Amendment to configuration of M60 Junction 13 western roundabout and new access road 
•	Reduction in building footprint of the proposed stable lads hostel
•	Additional channel to supplement Sniggley Brook culvert for improved water vole habitat
•	Deletion of proposal to floodlight the outdoor arena at the equestrian centre
•	Amended proposals for racetrack lighting fittings to ensure light spillage is minimised
•	Change to the design of equestrian centre to reduce built footprint without comprising arena size

3.4	The application site can be divided up into seven areas, which reflect the landscape character areas identified in Figure 7.2 of Part 5, Volume 1, Chapter 7: Physical Landscape of the Environmental Statement (June 2004). The following description of the proposal takes account of the information contained within both the ES and the ESS.  

Middlewood 

3.5	This part of the development site is located to the north of the canal where the natural landform rises. The northeast corner of the site is 60m above ordnance datum (AOD). Access to the site off the M60 motorway at junction 13 will be provided by a signal controlled improved roundabout with a new access arm. The scheme includes the provision of a controlled pedestrian crossing facilities and highway capacity improvements. A broad central reservation between the inward and outward lanes of the SFP access at the site entrance will be landscaped with a new entrance sculpture and entrance signage to complement the character of the locality.

3.6	A number of internal access roads cross this part of the site heading towards the Forest Park Centre, golf clubhouse and small car park at Middlewood. The eastern access road would descend south from the new entrance and reduces in width to a three carriageway road providing access to the informal woodland car park, before continuing south as a two lane road with reinforced grass verge. 700 linear metres of new hedging will line the road corridor through the woodland. Some tree clearance will be required for both the road and car park. The road would pass through a larch plantation resulting in some larch tree loss. The car park would be sited partially within an area of former parkland. Where the access road crosses the open land, across the future golf course the road will be constructed without kerbs and with swales alongside to provide drainage in order to create a countryside character. The road will not be lit, other than at the site entrance and at the canal crossing. A separate cycle path will be constructed to the west of the new road passing through the larch plantation to the new car park, then along the route of a historic track within the wood before emerging out into the open fields. The track will replace the existing concessionary footpath that currently runs along the motorway boundary of the woodland area.       

3.7	A new concrete bridge will be constructed to cross over the Bridgewater Canal, details of which are found in figures 5.9 and 5.10 of the site description. The bridge will provide two lanes for traffic, with separate paths to accommodate the cycle route and pedestrians on the west side, and golfers on the east side. The bridge approaches will be lit from columns, and lighting will be provided across the bridge deck either from bollard lights or from lighting within the vehicle barrier on the bridge. The bridge will over-sail the canal towpath routes in order to maintain an open aspect along the canal corridor. The bridge embankments will be graded to suit the needs of the golf course. The bridge will have a simple smooth finish, reinforced concrete deck with cantilevered walkways with a 1.15m high-inclined parapet of horizontal steel rod. The bridge abutments are simple, smooth-finish reinforced concrete to match the deck. The bridge soffit will be designed to accommodate bats. The new bridge will result in the loss of existing birch trees from the canal embankments, although these will be re-planted upon completion of the construction. 

3.8	Figure 11.1A and 11.3A of the ESS identifies the arrangements and layout for the proposed golf course and the clubhouse plans and elevations. The floor plans for the golf clubhouse indicate that the footprint of the building would be a maximum of 52m x 21.5m and the maximum ridge height of 11metres (see fig. 11.3A of ESS). The proposed materials are brick and timber, with areas of glazing and mono-pitched slate roofs. The building would be two-storey, with access to the first floor via two projecting staircases at each end of the building. The ground floor of the building would accommodate male and female changing accommodation, golf pro-shop (with associated office/store), a spikes bar with external terrace, an office, staff room, store, plant room and beer cellar. At first floor, a restaurant/function suite and a separate member’s lounge are proposed, both with bars and external roof terraces. In addition to this, kitchen and toilet facilities will be provided. 

3.9	Externally, a 56 space surfaced car park is proposed to the south of the club house, in addition, a reinforced grass surfaced area is proposed as an overflow parking area for up to 100 cars. Hedgerow planting is proposed immediately to the south of the overflow parking areas, beyond which, woodland planting is proposed. Woodland planting is also proposed to the north of the clubhouse site. There is an area of existing woodland to the southeast of the golf clubhouse site.

3.10	The golf course maintenance depot is located to the south of the canal, close to the M60 motorway boundary. The depot will be located in an existing barn at Carrs Meadow, from which the general upkeep of the golf course will be carried out. The equipment store floor will cover an area of 265m2. 

3.11	The proposed golf course would be an 18-hole (with practice area) par 72-championship course. The arrangements and layout for the golf course are shown in Figure 11.1A of the ESS and the grading plan is shown in Figure 11.2 of the ES. The course would occupy open areas of land used for grazing and set aside to the north of the canal and former parkland to the south of the canal. Earth remodelling is proposed (cut and fill) and wetland areas/pools are also proposed, 7 wetland areas to the north of the canal and 4 lakes to the south. Approximately 7.8ha of planting is proposed. The development will incorporate a crossing adjacent to the 4th fairway and will utilise the existing farm culvert crossing. A further crossing will also be constructed close to the point where Shaw Brook enters the culvert under the Bridgewater Canal similar in design to that shown on figure 11.7 of the ESS. Ball-stop fencing is proposed in two locations, to the north of the practice area to prevent injury to pedestrians using the concessionary path to the south of the garden centre and around the 11th green, adjacent to the proposed access road where it crosses the canal. The fencing proposed will be 4-5 metres in height and is outlined in figure 11.5 of the ESS. 

3.12	The proposals for the Middlewood Garden Project are not provided in detail at this stage of the application process. It is proposed to restore the structure of the former gardens at Worsley New Hall in conjunction with Salford City Council and other interested parties, including English Heritage, Greater Manchester Archaeological Unit (GMAU) and representatives from local history groups. The project will be developed through a number of phases, of which the Applicant will fund phases 1 and 2. A new footpath/cyclepath will be laid out within the 1955 plantation, and a clearing created to accommodate informal parking for around 50 cars for visitors will be provided. Phase 1 of the project will involve the establishment of the project framework, including the establishment of a steering group and a management/restoration plan for the site. Phase 2, subject to agreement of the management/restoration plan may include clearance of rubble from the footprint of the house; investigation of the structural condition and potential for restoration of engineering features and structures; the relocation of the historic gates from Leigh Road; selective clearance of regenerated sycamore and birch scrub from the terrace areas; selective clearance of the lake and investigation of the potential to re-establish the larger water body; re-establishment of the original footpath routes within or around the terraced gardens; and selective clearance of scrub and trees. 

Bittern Pitts Wood/Hollin Wood

3.13	This area is described as the ‘forest core’ and comprises fields bounded by Botany Bay Wood to the south, Bittern Pitts Wood in the east, Hollin Wood to the west and the Bridgewater Canal to the north. The Forest Park would be provided in this area. The main proposals include the Timber Initiative building, the Eco-village and Forest car park. The eastern access road passes through this area and crosses Shaw Brook, before continuing towards the racecourse.

3.14	The Forest Park Centre is comprised of the Eco Village, Timber Initiative, and Woodland Wildlife Centre. Within these buildings the following visitor facilities will be provided:-

•	Education and conference facilities;
•	Restaurants/catering facilities;
•	Exhibition areas; 
•	Themed bookshops;
•	Sustainable development resource centre;
•	Timber craft workshops and gift shop outlets;
•	Community toolchest/Centre for conservation volunteers;
•	Bike hire or alternative transport hire;
•	Sculpture gallery and external sculpture trail;
•	Central gift shop/souvenir outlet;
•	Central health/bathroom facilities for campers and for the support of hard outdoor pursuits;
•	Short stay eco accommodation for specialist visitor use, or for use in conjunction with residential courses, conferences or workshops; and
•	Manager’s accommodation and office space.

3.15	Around the main built centres the following is proposed:-

•	Top quality adventure play space for children;
•	Tree-top walkway;
•	Extensive trails for walking, biking, horse riding and running;
•	Nature reserve and nature area;
•	Outdoor exhibition and event areas;
•	Parking and picnic spaces;
•	Overnight camping; and
•	Individual workshops for larger scale timber crafts.

3.16	The Forest Park Centre would be located at the northern end of Botany Bay Wood. The centre is accessed via The Avenue and it is envisaged that this would provide opportunities for casual horse riding. An area of new “wet woodland” would be created around the Forest Park Centre. The Forest car park is located in a triangular area of land located to the north east of Botany Bay Wood within glades, created by woodland planting. Only the hard surfaced car parking areas would be used during the winter months when the grass glades would be closed off to vehicles. During the summer season, management would be in place to control usage of the grass glade areas, which would be opened on a rotation principle to accommodate low key picnic activities, with the minimum number of areas opened on a rotation principle to accommodate demand. Full use of all grass glade areas at any one time would be rare, and would only be required in association with any popular seasonal educational events staged at the Forest Centre. The grass glade parking areas would not be available for use during race meetings. The woodland at the Forest Park Centre car park would have a landscape treatment. The new woodland would utilise the native species of trees and herbs and would include a non-invasive species rhododendron shrub under storey to create a seasonal display. The car park would cover an area of 350m x 350m x 350m and the surface would be constructed of reinforced grass. Parking would be informal and would cater for up to 820 cars.  

3.17	The Eco Village, Timber Initiative, and Woodland Wildlife Centre would be grouped in close proximity to each other at the northeast tip of Botany Bay Wood. The Timber Initiative Centre would be located at the corner of the eastern field. The Eco Village Centre would occupy the field to the north of The Avenue and south of the Bridgewater Canal. The Woodland Wildlife Centre would be located in a small clearing at the north-eastern corner of the wood. The Children’s Forest Play Space and the treetop walkway would be laid out to the south west of the Woodland Wildlife Centre within the northern most part of Botany Bay Wood. Access to the Forest Park Centre buildings for maintenance and service vehicles would be via stone maintenance tracks and would make use of the existing stone tracks around the site as much as possible. 

3.18	Public access around the Forest Park Centre would be controlled so that the Timber Initiative and Woodland Wildlife Centre would be open during normal working hours and at weekends but would close at dusk in the winter. Visitors would be allowed to roam in the woodland between the Woodland Wildlife Centre and the Play Space but outside this area public access would be restricted to designated pathways. Any public evening events in the Forest Centre buildings would be restricted to the buildings and associated curtilage only.   

Eco Village Centre – Outline element

3.19	A number of buildings are proposed in this area, alongside the Eco Village Centre three earth sheltered buildings are proposed and would be located on the north side of the lake. Two of the buildings would provide overnight accommodation for participants of workshops or courses and tourists. The buildings would be 7m high to the ridge, including the earth sheltering of the mound. Two of the buildings would face south towards the lake and would provide ten double bedrooms each. Each would be 40m x 9m and would be linked by a conservatory. 

3.20	The third building would be built to the north of the lake and would provide permanent residential accommodation for the Forest Park Manager. The footprint of this building would be a maximum of 13m x 9m. Soil for the building would be won from the construction of the lake. The building would be 7m high to the ridge, including the earth sheltering of the mound.

3.21	A 50-space campsite attached to the Eco Village would be located to the southwest of the lake. New woodland planting would create an enclosure and structure for the site. A washroom block, 10m x 10m x 5m in height is proposed. The building would be constructed using straw bale and adobe techniques. A growing area/exhibition area is proposed to the north of the Eco-Village Visitor Centre and adjacent to the Forest Centre Manager’s residential unit.  The area would be used for demonstration crop growing or permaculture exhibitions. The Events Space area would be to the east of the growing area.  It would be laid out as a meadow and available for events and exhibitions and other open-air activities. The applicant has indicated that they would be willing to limit the use of camping between March and October. The events space and its usage would usually be one-day activities with an educational bias and would be primarily used during the summer season. 
 
3.22	The Visitor Centre would be located to the south of the Eco-Village area, close to the proposed Woodland Wildlife Centre and Timber Initiative Centre. The total floorspace created would be 1450m2 and uses within the building would include exhibition space, auditorium, resource centre, bookshop, produce shop, restaurant, classrooms, flexible workspaces, office and toilet facilities.

Timber Initiative and Car Park – Outline element

3.23	The Timber Initiative Centre would provide a display/workshop area for larger-scale timber-based or other rural crafts. The building would be sited at the confluence of several routes through the wood. Four smaller existing buildings in this area would be removed.  It would be a maximum of two-storeys and would have a maximum ridge height of 8.5m. The building is shown to have a curved footprint of approximately 15m x 55m. The building would utilise sustainable timber construction techniques and would incorporate a turf roof. The total floorspace created would be 1015m2 and uses within the building would include exhibition space, demonstration space, classroom, retail, offices, toilet facilities, bike hire and storage. A secure yard area of approximately 24m x 27m would be provided. Vehicular access would be via an existing track and would be restricted to workers/deliveries. A plaza is proposed to the front (west) of the building, where a footpath would link to plazas and footpaths providing pedestrian access to the Eco-Village and Woodland Wildlife Centre.  Adjacent to the Timber Initiative a surfaced car park is proposed to the east of the building, with space for 40 cars, 11 coaches and disabled parking. The remainder of the area would be laid out to have a woodland structure with glades of reinforced grass available as picnic space. Stone drainage rafts would underlie the grass glades.

Woodland Wildlife Centre and play areas – Outline element

3.24	The Woodland Wildlife Centre would be a visitor attraction, located at the northern edge of Botany Bay Wood. Sustainable timber construction techniques are proposed, with a turf roof and may include straw bale and adobe wall construction. The building may be circular in form and would be a maximum of two storeys in height, with a maximum ridge height of 8.5m. The building is shown to have a circular footprint of approximately 16m diameter. The treetop walkway would be supported by timber poles and would be accessible via the Woodland Wildlife Centre building; a lift within the building would provide disabled access to this part of the facility. The total floorspace of the building would be 975m2 and uses within the building include exhibition space, gift shop, cafes, office, meeting room and toilet facilities.

3.25	The Forest Play Space and Treetop Walkway would be located at the northern edge of Botany Bay Wood, adjacent to the proposed Woodland Wildlife Centre. The play space would cover an area of approximately 100m x 75m. Play equipment would be timber and rope based. The tree top walkway would circle the play area and link to picnic space in the wood. The walkway will reach 8.1 metres to the highest point. Stair towers on either side of the central track through the wood would provide a means of access to this highest point. It would descend gradually to ground level through the woodland compartment to the west of the central track. The route of the tree top walkway is shown in Figure 10.4 of the ES. The applicant has also provided photos of the wooden walkways as examples of the type that may be used in this development (Appendix USD 10.1 of ESS).   

Botany Bay Wood – Outline element

3.26	This area includes Botany Bay Wood, which is a 126ha woodland containing a range of species. Planting and management have taken place within the woodland since the late 19th century. The southern part of the wood contains a large heronry.
 
3.27	As part of the Timber Initiative one other area has been identified further south in the woodland as a display/workshop area for larger scale timber based or other rural crafts. The existing buildings connected with the Clay Pigeon Shoot would be redeveloped to accommodate a small-scale timber workshop for the manufacture of garden furniture and fencing using processing wood obtained on-site from the management of Botany Bay and the other woodlands. The workshop would be sited at the confluence of several routes through the wood and would provide a point of interest on the circular trails. The workshop would include a secure external yard suitable for small scale saw milling operations, and an internal workshop for the maintenance of bulky items. The building would be a traditional timber framed barn with a built footprint of 15 metres by 8 metres and a maximum height to the ridge of 10 metres. Vehicular access to the timber workshop would be along the existing central track through the wood, but would be restricted to key worker and deliveries only, with times of deliveries controlled to minimise any conflict with casual visitors to the woodland.  

Grange Farm 

3.28	This area comprises flat, open, agricultural land and is bounded by the M60 to the east and the M62 to the south. Botany Bay Wood is located to the western boundary. The proposals would have no physical impact on the Grange Farm area other than the provision of a 60-metre length of footpath, and the construction of approximately 200 metres of shared use cycle, bridle and footpath to provide connections from the existing farm tracks into Botany Bay Wood. The new paths are aligned along the boundaries of existing arable fields, and would enable the use of the existing tracks around the farm as concessionary paths.

Agricultural land north of Botany Bay Wood

3.29	This area comprises the low-lying, relatively flat agricultural landscape to the north of Botany Bay Wood and south of the former landfills. Two existing farms, Moss House Farm at the southern edge of the former landfill and Malkin’s Wood Farm to the west, are included within this area. The Avenue, a tree-lined historic route leads from Malkin’s Wood Farm towards Worsley. Moss House Farm Brook runs through the area. There are a number of proposals in this area, mostly associated with the provision of the racecourse and associated buildings and other equestrian uses. The eastern access road from the A580 also enters this area from the north.

Racecourse Enclosure

3.30	The racecourse enclosure, (including grandstand and associated car park, parade rings, saddling stalls, concourse and ticket office, stables, stable lads accommodation, and horse box parking) would be sited in the northeast of this area of land to the north of Botany Bay Wood. The area is subject to flooding and as such, ground re-modelling is proposed to create ‘build’ and ‘flood’ areas, creating an undulating landscape. To the west of the buildings, three low-lying flood basin areas are proposed, these would be maintained as grass areas and in dry conditions used for temporary stands or tent accommodation for premium events. Permanent lighting is proposed – a mixture of 5m high columns, low level bollards and wall mounted lighting, this will be turned off when there is no activity at the grandstand. 

Grandstand

3.31	The grandstand would be positioned at the finish line of the racecourse, with the winners enclosure to the front and two parade rings to the rear. The footprint of the building would be 102m x 48m, with a maximum height of 25m. The roof of the building would have a curved profile. The proposed materials are a mixture of metal profiled sheeting and cladding and translucent sheeting. Uses are provided over six floors, as follows: ground floor: concourse/toilets, bar, exhibition space, weighing room, medical room, betting kiosks, refreshment outlets; mezzanine: lounge, 1st floor: tiered restaurant on three levels; 2nd floor: spectator lounge, 3rd floor: 28 corporate boxes, 4th floor: roofspace/plant room, racing officials, police control room. The grandstand would also incorporate spectator terracing to the front. The total capacity of the grandstand and terrace would be for 8,935 people. On non-race days, the buildings would be used to host events such as conferences, trade fairs and wedding receptions. This type of activity would occur irregularly on non-race days throughout the year.

Winner’s enclosure rings and saddling stalls

3.32	The applicant sets out the proposed dimensions as follows: main parade ring: 54m x 28m; pre- parade ring: 38m x 32m and winners enclosure: 18m diameter. uPVC fencing would bound the winner’s enclosure. Rubberised all weather surfaces would link the winner’s enclosure rings and saddling stalls/stables. 

3.33	The saddling stalls would be located to the northwest of the grandstand. The saddling stalls comprise 6 enclosed stalls and 8 open stalls to the rear, and 9 open stalls to the front. The footprint of the building would be slightly curved with an overall footprint of 33m x 8m and would be 4m in height. The proposed materials for the stalls to the rear are rendered block work walls, with the enclosed stall constructed from cedar boarding. The stalls to the front would be separated from each other with clear glass walls.  

Stable blocks

3.34	The stable blocks would be located to the northwest of the grandstand. Five double-sided stable blocks and two single blocks are proposed. In total 110 stables would be provided. The individual blocks would be 3.5m x 35.5m and 4m in height. The walls would be part block work render, part cedar boarding. A small security lodge is also located within this part of the site. The lighting in this area is described as ‘a mixture of amenity type lighting columns, typically 5m high, low level bollards and wall mounted lighting.   

Stable lads accommodation

3.35	The footprint of the stable lads accommodation was reduced in sized from 833.8m² to 553.7m² in the May 2007 updated scheme description. The development would comprise of 62 bedrooms within a two-storey building.  The central lobby would be flat roofed and 6 metres in height. The building would be constructed from facing brickwork configured into pier and panel bays with coated aluminium frames to the windows and glazed lobby areas.   

Entrance and arrival concourse

3.36	The entrance and arrival concourse areas are located between the parade rings and the main racecourse car parks. The arrivals concourse would be paved and would incorporate bus drop-off points. The entrance would be gated and fenced and would include a canopy. Three pedestrian bridges, each 15m wide would connect the entrance concourse with the grandstand area. The lighting design information describes the lighting in this area as a mixture of amenity type lighting columns, typically 5m high, low-level bollards and wall mounted lighting.   

Ticketing kiosk

3.37	The ticketing kiosk would be located to the north of the grandstand within the concourse area. The building would be 10m x 10m and clad in timber boarding, with a hipped steel roof that overhangs to provide a canopy.

Racecourse track

3.38	The racecourse track is an oval shape, with 140m radius bends and would be positioned to the north of the Avenue. The track would comprise a 20m wide turf oval inner track, a 23m wide outer oval all-weather track, with a 6-furlong straight, in addition to a 6-furlong turf straight outside the all-weather straight. The all-weather surface would be made from shredded rubber, fine fibrous elastic, sand and Vaseline and would have a sandy colour. A 3.5m wide metalled service road would run on the inside of the track and 6-furlong straight. Track fencing would comprise white uPVC running rails at 1.2m in height. A wire mesh fence would be positioned under the rail in front of the grandstand area. 

Temporary arena

3.39	The western part of the racetrack interior would be shaped to create an area for temporary arenas for show jumping and the eastern part of the interior would be used for the start and finish of the cross-country tracks. The interior of the tracks would be managed as grasslands. The heart of these trails would be within the racetrack. Up to 40 obstacle jumps would be created, but these would generally be temporary in nature. Permanent jumps may be provided to the south of the Avenue, but planning permission would be required as part of a future planning application. Ground modelling would be undertaken in the interior of the track, using excavated soils from the racetrack construction. 

Racetrack Lighting

3.40	Following on from discussions with the Council the applicant amended the 2004 proposals for racetrack lighting. The racetrack would be illuminated using column-mounted banks of directional floodlights. These would be fitted with total light control (TLC) canopies during evening race meetings. The applicant indicates that the TLC canopies would reduce sky-glow by 50% compared to conventional floodlighting, and this would control up to 95% of glare light levels. Lighting would be controlled around the perimeter of the track, so that only those lengths of the track that require illumination would be. The applicant indicates that evening race meetings would be relatively infrequent, however where these do occur races would finish by 9.00pm therefore reducing the level of lighting required.  

Racing Events

3.41	The applicant states that the racing profile of the site would consist of around 30 days hosting race events per year, which would be divided as follows:

•	One day per year with a premium event which could attract up to 20,000 spectators;
•	Three days per year of flagship events which could attract up to 15,000 spectators; and
•	Around ten days per year of lower attendance standard events with around 7,000 spectators.

Equestrian Centre 

3.42	It is anticipated that a wide variety of equestrian events would occur on the site. The scale of the events would vary from a number of small local events, attracting from a few hundred to 2,000+ visitors up to a single large-scale regional event, attracting up to 10,000 visitors over a four-day weekend event. 

3.43	The Equestrian Centre (indoor arena and stables) is to be located at Malkin’s Wood Farm. The existing livery stables at Moss House Farm (accommodating approximately 95 horses) would be relocated here. Malkin’s Wood Farmhouse would provide accommodation for the equestrian centre manager. It is proposed that all of the existing supporting farm buildings are removed. The existing trees, walls and hedges around the garden of the farmhouse would be retained, as will an existing copse of birch trees to the west of the outdoor arena. Native woodland planting is proposed to the south and east of the indoor arena. 

3.44	Stables are proposed in three areas of the site, providing accommodation for 80 horses. Six terraces of seven stables are proposed to the north of the farmhouse, twenty-one stables are proposed to the south west of the farmhouse and nineteen to the west. Each stable is 3.6m x 3.6m, with a tack room of 3.6m x 1.2m alongside. Roofs are either mono-pitch or duo-pitch and a maximum height of 3.7m. Proposed materials are a combination of block work walls with render and cedar boarding. A shavings store is also proposed that would measure 13m x 8m and 6.3m to the ridge. The proposed materials are the same as for the stables.  

3.45	The design of the indoor arena was amended as a result of the May 2007 ESS submission. The main equestrian centre building would be rectangular in form with an overall footprint of 4631m2. The building would be screened on the west sides by earth mounding, above which a curved roof profile would be visible. The front elevation of the building would incorporate a flat roof with glazing above to capture north light.     

3.46	The outdoor arena measures 60m x 40m and would have an all weather surface (similar to the racetrack). The sides of the arena would be fenced. Some landscaping works would be carried out and existing trees, walls and hedging around the garden of the existing farmhouse would be retained, and a new barn owl roost box and 2 bat hibernation boxes would be installed in the mature trees. The earth banks to the indoor arena would be planted with a native woodland mix. 

3.47	The equestrian centre management area would include 74 hectares of land to the east of the centre. This land would provide at least 24 hectares of summer grazing, together with haylage and straw crop areas. 

Hotel

3.48	The hotel would be located where the existing Moss House Farm exists to the north of the proposed racecourse, and at the foot of the raised landfills adjacent to the Bridgewater Canal. The total footprint of existing buildings at Moss House Farm amounts to 3,545m2. As part of the application process consideration was given to the qualities of all the buildings, their historical merit, constructional integrity and their potential for reuse. The applicant carried out a preliminary survey of buildings at Moss House Farm. As part of this assessment it was decided that many of the existing buildings on the site would be removed as they are considered to be unsuitable for retention and/or are considered to have little architectural or historical merit due to their physical constraints. Some of the buildings would also require an almost complete rebuild to rectify the decay that they have suffered. Details of the buildings to be removed can be found in Appendix SD11 of the ES.  

3.49	The survey of buildings at Moss House Farm indicate that three buildings are proposed for conversion and reuse on the site as follows:-

•	The original farmhouse (MH10)
•	The two-storey barn (MH5)
•	The two-storey element of the “A” shaped gable-arched barn (MH7)

3.50	The retained farmhouse would be re-used as support facilities for the hotel. The design proposal shows office accommodation and staff changing facilities on the ground floor with staff accommodation to the first floor. Pebble dashing would be removed from the external walls and structural and cosmetic repairs would be carried out as necessary. Bat friendly architectural features would be incorporated into the refurbished building, access to the loft spaces using bat bricks, and ventilation tiles would be used as would external bat bricks that would be situated along the eaves. Plinths would be provided on eaves of one elevation to encourage swallows and house martins to nest. 

3.51	The first floor of the two-storey barn on the north side of the courtyard would be removed to create a two-storey height space with repairs to some external sections of walls as required. These sections of walls would be rebuilt in materials that are in keeping with the original building. The interior of the barn would be fitted out as a function suite overlooking the courtyard to the south. 

3.52	The two-storey element of the “A” shaped gable-arched barn would be retained. The barn would be converted into the hotel gym and fitness centre reception area. An independent mezzanine floor would be constructed at the western end of the barn for the first floor conference suite. The existing concrete roof tiles would be replaced with more traditional slates and a new concrete floor and structural ties would be added to ensure the integrity of the construction. 

3.53	The new build parts of the hotel would be constructed with a principle of preserving and enhancing the original character of the 19th Century farm building. The new elements would be constructed using brickwork fin walls to divide the bedrooms, horizontal timber boarding taken from sustainable sources for the main elevations with glass “walls” to define stair enclosures, the reception and the outward facing elevations of the bedroom and function spaces. The western gable end of the main bedroom block would be fitted with bat bricks and a barn owl nest box to encourage wildlife. All of the buildings would have pitched slate roofs, and the new blocks would have a ridge height of 9.85 metres. The restaurant would be located on the ground floor within the footprint of the former stable building opening on to the courtyard with new bedrooms built over and to the west of the spine wall. A new two-storey bedroom block has been designed to the south and west of the courtyard. This extends in front of the retained barn to house the pool and changing facilities at first floor level. The hotel reception would be located within the old courtyard with an adjacent short-term parking and drop off zone. The main hotel car park would be located to the rear of the farmhouse and has provision for 120 cars including a minimum of 4 spaces for drivers with disabilities. The service yard would be located to the northwest of building MH5. The total footprint of the new buildings would total 2965 square metres.   

3.54	The hotel would include 80 beds to serve the needs of visitors to the racecourse and the wider forest park. The café/lounge would provide accommodation for approximately 80 people, and the restaurant would sit 80-90 diners. The hotel would also incorporate a 150-space conference function suite, a fitness centre, gym, small pool, and small conference facilities for 40 to 50 delegates. The exiting track to Moss House Farm from Boothstown would be retained as a footway/cycleway.

Restored Landfills

3.55	This area comprises former landfill sites located immediately to the south of the Bridgewater Canal, extending from Vicars Hall Bridge in the west to Boothstown Marina in the east. The landfill sites are presently grassed and cover approximately 36ha. The former site access road runs along the northern side of the central and eastern landfill areas. The proposals in this area are for the main racecourse car park and two overflow car parks.

3.56	All three car parks would have a reinforced grass surface and would only be designated for parking on a temporary basis for event days only. The main western and eastern access roads would connect to form a road along the northern boundary of the parking areas. These car parks will also be used when there are large events at the equestrian centre. The applicant provides an indication of the parking provision for each area as follows: 

•	Primary car park: 2,700 cars, 180 disabled parking spaces, 180 coaches 
•	Overspill 1: 2,300 cars 
•	Overspill 2: 2,200 cars

3.57	The total provision on the landfill car parks would therefore total 7,200 cars, 180 disabled parking and 180 coaches. Overspill parking area 2, is only expected to be used for premium events and Overspill 1 is only expected to be used approximately 20 times per year.

Astley/Boothstown Urban Fringe

3.58	This area lies to the north of the Bridgewater Canal. A western access road from the A580 is proposed in this area, the northern part of this access falls within Wigan MBC’s jurisdiction. The proposed works comprise a widened circulatory carriageway, widened eastbound approach and central section, realignment of the southern circulatory section and the signalisation and widening of the existing priority access into the site. Once on site the access would consist of a 9m wide tarmac-surfaced carriageway with lighting for approximately 100m. Pedestrian and cycle access into the site from the A580 takes a route parallel to the road, but separated from it. Vicars Hall Bridge would be improved to provide a 6-metre carriageway width across the bridge deck. The bridge would provide for pedestrian, cycle and bridleway use on the eastern side, along a 3-metre wide shared-use path separated from the carriageway by vehicles barriers. The bridge approaches would be lit and low-level lighting would be provided on the bridge deck itself. The embankments on the northwest and southeast sides of the bridge would be planted using native woodland tree species, and the bridge would incorporate bat roosting in the bridge soffit.

4.	ENVIRONMENTAL STATEMENT

4.1	The nature of the SFP proposal means that it falls within the definition of projects for which an Environmental Assessment must be undertaken under the requirements of the Town and County Planning (Environmental Impact Assessment) Regulations 1999 – SI No 293. The Environmental Impact Assessment (EIA) regulations indicate that the applicant must describe the proposed development and assess the impacts across a range of environmental issues and where appropriate an examination of the mitigation of the identified impacts. This process has been undertaken by the applicant and has been reported in the form of an Environmental Statement. The applicant submitted an Environmental Statement (ES) in 2004 and as a result of the consultation process an Environmental Statement Supplement (ESS) was produced in 2007.  The applicant has submitted the following documents as part of the required ES and ESS: -

4.2	Environmental Statement (June 2004)
•	Introduction and Method Statement 
•	Scheme Description 
•	Alternative Sites Assessment 
•	Transport Assessment 
•	Environmental Assessment 
•	Non-Technical Summary 

4.3	Other Supporting Documents (June 2004)
•	Need Statement 
•	Planning Support Statement 
	
4.4	Environmental Statement Supplement (May 2007)
•	Introduction and Method Statement 
•	Updated Scheme Description 
•	Updated Transport Assessment 
•	Updated Environmental Assessment Reviews 
•	Updated Non-Technical Summary 

4.5	Other Supporting Documents 
•	Updated Needs Assessment (April 2007)
•	Updated Planning Supporting Statement (May 2007)
•	Updated Paper on Very Special Circumstances in relation to Green Belt Issues (October 2007)

4.6	The following section provides a brief summary of the contents of the above documents.  This summary does not represent the officers’ view / assessment of the various issues at this stage. 

5.	ENVIRONMENTAL STATEMENT NON TECHNICAL SUMMARY 

5.1	As required by the Regulations the applicant also produced a Non Technical Summary (NTS). This provides a brief and concise summary of the findings of the Environmental Assessment. The applicant has submitted two subsequent supplements to the ES and hence there are two supplementary NTS documents. 

Non Technical Summary Documents 

5.2	The applicant has produced two non-technical summary documents; the first as part of the original submission in June 2004 and the second as part of the Environmental Statement Supplement submission in May 2007. 

Environmental Statement – Non-Technical Summary (NTS) June 2004

5.3	The NTS outlines the current nature and scale of the proposed development site. Details are provided within the NTS relating to the equestrian sporting proposals and an overview of the parameters of which the Environmental Assessment covers are also provided. 

5.4	The following text outlines the applicant’s conclusions relating to the impact of the development in relation to land and land use, operational effects, and social effects. The applicant outlines the mitigation measures that would be appropriate to reduce any negative environmental impacts. 

Effects on Land and Land Use

Geology and soils

5.5	The peat soils are not considered to have any realistic potential for restoration to raised bog habitat. Some disturbance and/or removal of peat soils are anticipated for the development of the racetrack and the Forest Park Centre. Most other features are located over clay soils or landfill and will have no adverse impact on geology and soils. Mitigation measures will be carried out so that at worse there will be a neutral impact on landfills. 

Hydrology and drainage 

5.6	No significant impacts on the water environment are identified in the assessment.

Archaeology and cultural heritage 

5.7	There will be no significant adverse impacts on archaeological sites despite the presence of peat resources, as mentioned previously.

Agriculture

5.8	Just over 10% of the site will be rendered unsuitable for future agricultural use, which is assessed as a major negative impact on agriculture. Viable agricultural management will continue through the re-organisation of tenancies and this will become a feature of the Forest Park. 

Forestry 

5.9	42ha of new woodland will be planted as part of the scheme, which represents 18% of the yearly average of new planting within the Red Rose Forest area and will contribute towards sustainability of woodland resources within Greater Manchester. The new woodland planting will have a major beneficial impact on forestry. 

Ecology
 
5.10	Thirty-nine valued ecosystem components are identified in the assessment, including designated sites, types of habitat, various species of birds in different categories, amphibians and mammals. The scheme will have negligible up to major positive beneficial impacts on each of the designated sites, and on a wide variety of habitats and species. Only four species will experience a minor adverse impact as a result of the proposed changes to management practice or increased disturbance. Sixteen habitats and species identified in the UK and Greater Manchester Biodiversity Action plan priority targets will experience a beneficial impact as a result of the scheme. Improvements include the heronry at the southern end of Botany Bay Wood, ponds, swamp, and marshy grassland habitats, which will be increased as a result of the scheme.  

Landscape and Visual Impacts

5.11	The landscape and visual impact assessment carried out by the applicant indicates that the landscape will retain an open countryside character but will be re-structured and improved, and new management put in place. The assessment indicates that there will be a range of minor to major beneficial impacts on the landscape structure of each part of the site. 

5.12	The applicant stresses that the new buildings that will be constructed will be appropriate to their settings, and the scheme will have a neutral or negligible impact on the majority of existing views towards the site. Although the grandstand and the lighting columns will be visible in a range of distant views, the applicant feels that this will only form a very small element in the panorama, which will not affect the general openness of the view obtained.  
 
Combined impacts on land and land use

5.13	The applicant feels that change of land use will lead to both positive and negative effects. The change from agricultural land uses to recreational uses will have major beneficial impacts in terms of landscape structure, many aspects of ecology, and forestry. The peat soils, agriculture and archaeological resource are slowly wasting due to the existing agricultural management; the applicant feels that SFP scheme offers a way of reducing this effect. 

Operational Effects

Traffic and Transport 

5.14	The traffic assessment carried out by the applicant has been based upon a number of assumptions that are designed to simulate worst-case scenarios. The operational assessment of the access junctions, according to the applicant demonstrate that the proposed junction improvements would accommodate the traffic demands generated by the Racecourse with acceptable conditions even with the most stringent attendance tests and worse-case assumptions. In the event of a premium race meeting, only the A580 junction would be required to operate at overcapacity. The model indicates that this scenario would only occur once per year for a period of one hour. The applicant indicates that this is considered to be an acceptable minor adverse impact. 

5.15	Due to access improvements on the M60 and A580 junctions the applicant indicates that these improvements will improve capacity so on non-race days there will be an improvement to traffic flows at all times, including the AM and PM peak hours. Off site there would be no regular material impacts on any part of the network. 

Air Quality  

5.16	It is anticipated that due to junction improvements capacity benefits will be realised which will result in less queuing and stop-start driving which will lead to a reduction in the generation of emissions on normal, non race days. 

Noise

5.17	The applicant has carried out an assessment of the likely noise impacts that may arise from traffic, car parking areas, crowd noise and from the public address system. The assessment indicates that there will be no adverse noise impacts of greater than ‘marginal significance’ predicted for the closest receptors in Boothstown as a result of the main events. Properties around the southern edge of Boothstown will experience minor adverse impacts on race days. Keepers Cottage Kennels will also experience short-term adverse impacts from the noise created from the scheme. There is predicted to be no adverse impact on the heronry from the racecourse or any other noise generated by the scheme. 

Lighting

5.18	The visibility and ecology sections of the applicant’s submission indicate that no significant adverse effects are identified in relation to the effects of the Equestrian Centre and the racetrack. The assessment provides further detail that states that the locations from which lighting will be seen tend to be distant from the site and relatively few, and the low level of skyglow and strongly directional focus of the lighting will have a neutral effect on views. The assessment considers that there will be no adverse impact on the general residential amenity of Boothstown, although the assessment does note that the tops of the lighting columns will be seen from properties around the southern edge of Boothstown. This impact will however be reduced as new tree planting becomes more established. Keepers Cottage Kennels will also suffer from adverse impacts from the lighting columns, despite this; the applicant considers this to represent a minor adverse impact. 

Social Effects  

Public access and recreation

5.19	The applicant’s assessment indicates that there will be no loss of length or connectivity of any part of the existing footpaths, either statutory or concessionary, and all will retain a ‘countryside’ character. The assessment does however recognise that there will be a minor adverse impact on two field footpaths which will be crossed by the western access road, and for which safe crossings will be provided. 

5.20	The scheme is judged to have a major beneficial impact on the accessibility of the land, through the provision of a network of 11 miles of recreational cycleways, 8 miles of riding trails and almost 20 miles of pedestrian trails. Formal and informal activities in the area will increase with an increased emphasis on family orientated recreational activities in the woodland. The existing scout camp and angling at Middlewood will continue within the improved management framework of the larger Salford Forest Park scheme. 

5.21	The facilities connected to horse racing and the equestrian facility will be of a regional and local importance that will complement the network of existing recreational provision in the area, and will make a significant contribution to the recreational resources of the North West. The assessment concludes that the proposed SFP will bring about a major beneficial impact on the recreational potential of the site and the wider area. 

Socio-economic effects 

5.22	The economic assessment of the scheme indicates that SFP will create between 260 and 270 full time equivalent gross on-site jobs, focused around catering, retail, hospitality, nature conservation and security sectors. The scheme will also bring about benefits relating to health, social inclusion and lifelong learning.  

Environmental Statement Supplement Non Technical Summary (NTS) May 2007

5.23	This non-technical summary document reports the main findings from the Environmental Statement Supplement. The document highlights the key modifications, which have been made to the scheme, and the changes in environmental impacts compared to the 2004 assessment. The fundamental objectives of the scheme however remain unaltered. 

Operational Effects

Traffic and Transport

5.24	The 2007 NTS highlights the amended layout of the M60 Junction 13 western roundabout and site access. The amended road layout highlights the new signal controlled roundabout with a new arm that provides access into the SFP site. The new scheme includes the provision of controlled pedestrian crossing facilities as well as highway capacity improvements. The scheme has been designed to mitigate against the busiest traffic periods of SFP. It is envisaged that the scheme will help to reduce existing queues and delays at the junction, particularly the M60 off slip arm. The road layout amendments have been assessed in the Updated Transport Assessment (UTA) and it is considered that the junction improvements will lead to capacity benefits at the junction during the regular weekday AM and PM peak hours when regular SFP activities would generate relatively low levels of traffic. The UTA indicates that there is no change to the original Transport Assessment conclusion. 

Effects on Land and Land Use

Ecology 

5.25	The applicant has submitted proposals to improve initial water vole arrangements at Sniggley Brook. It is envisaged that by providing a new length of open wet watercourse around the racetrack start it will provide an open channel habitat for water voles presently using Sniggley Brook. This will be achieved by cutting a channel from Sniggley Brook to Hollin Wood where it will turn southwards around the end of the racetrack straight, and continue westwards to re-join Sniggley Brook. As part of this proposal a few low quality trees will be lost from the perimeter of Hollin Wood, however new trees will be planted around the new channel as part of the mitigation scheme.        

Watercourses

5.26	The proposed amendments will not have any further impact on geology and soils, hydrology and drainage, archaeology and cultural heritage, agriculture or forestry than what was described previously in the initial proposals. The improvements to Sniggley Brook are considered by the applicant as a way to ameliorate a previously identified major negative impact to a minor negative impact. The amendments provide further commitment to ecological enhancement, mitigation and management, and benefits in relation to water vole habitats. Due to this, the net impact on the watercourses and the water vole remains moderate positive and major positive respectively and is considered to be more favourable than in the original ES.     

Visual Assessment

5.27	The applicant has submitted an additional visual assessment of the golf clubhouse, which highlights a moderate adverse impact on views from the concessionary footpath, which passes immediately alongside the proposed clubhouse and car park. The applicant states that there will be no adverse impacts identified as a result of the lighting at the golf clubhouse. 

Air Quality

5.28	In relation to air quality the impacts in relation to NO2 and PM10 would be negligible to slight on Annual Mean Concentration Objectives, the Daily Mean Objective (PM10 only), and the Hour Mean Objective (NO2 only). This results in their being no effect on the conclusion of the assessment. 

Noise

5.29	The NTS indicates that there will be further commitments made to noise mitigation at Keepers Cottage Kennels that will mitigate any potential adverse impact at this property. 

Lighting

5.30	The racetrack lighting design has been reviewed and it is considered that this will ensure that sky glow and light spillage is minimised. 

Social impacts 

5.31	The scheme amendments are not considered to have any effect on the social benefits of the scheme, including economic activity and employment, health benefits, educational benefits, community cohesion and civic pride, and image enhancement for the City and the wider region.

6.	OTHER SUPPORTING DOCUMENTS 

6.1	In addition the applicant has submitted a range of other supporting documents. The following text will provide a brief overview of these. 

Transport Assessment (June 2004) (Prepared by RPS)

6.2	The report examined the traffic and highway related implications of the SFP development. The racecourse component will only operate on a relatively infrequent basis with impacts confined to short periods immediately before and after a race event. The race events will be spread throughout the year and held at various times throughout the week meaning that there would be no regular or frequent ‘race event’ traffic impact on the local or strategic highway network. 

6.3	The scheme has been designed to minimise race day traffic and amenity impacts within the residential areas of Boothstown and the locations where largest concentration of trips would occur. The non-racecourse components of the scheme would generate ‘regular’ traffic and transport demand, albeit with some seasonal variation.

6.4	Six scenarios, incorporating a number of robust and worst case assumptions have been examined to evaluate the ‘regular’ and ‘infrequent’ traffic implications and conditions. Trip generations for the majority of the uses proposed within the scheme have been derived by reference to a national trip information database. Trip generations for the racecourse have been derived from first principles making use of racecourse survey data and other background information. 

6.5	The examination of potential access locations has involved detailed consideration of impacts and amenity for nearby residential areas, including Boothstown. A significant factor in the selection of access locations to minimise traffic impact has been the likely catchment of the Forest Park and the associated gravity model work. This model has enabled trip distributions and assignments to be examined to ensure that the traffic demand associated with SFP is provided via access from the primary route network at the earliest possible opportunity, thereby reducing traffic implications on the local road network and the more sensitive residential areas.    

6.6	The vast majority of trips would travel via the A580(T) East Lancashire Road and the M60, both of which lie adjacent to the site boundary. The primary access for the site is proposed at the A580(T)/A572 signalised gyratory junction and the M60 J13. Both of these junctions would be improved significantly. The applicant states that these improvements will not only provide capacity benefits but will also update the junctions to accord with modern standards of safety and design. 

6.7	The primary access routes from the local road network consists of two tarmac surfaced lanes for tidal flow conditions, an additional lane, which would be provided via a reinforced verge. The applicant indicates that the on-site tidal flow system has been designed to maximise capacity whilst minimising physical construction impacts. Three vehicular lanes for each access route will be provided, one of which would be used to cater for tidal changes in directional traffic flow. This design will assist in accommodating peaks in traffic activity whilst minimising new construction. At the end of the race meeting, the central lane of the tidal flow system would be dedicated to bus and coach use in order to provide public transport priority to enable such vehicles to bypass queuing traffic leaving the site.  
 
6.8	The greatest parking demand for the site will occur during race days. It is proposed that this ‘infrequent’ demand will be catered for through the use of temporary parking areas situated on a former landfill site to the south of the Bridgewater Canal. The treatment of the access routes and parking areas would equate to new hard standing of less than 1% of the total site area.  

6.9	The operational assessments of the access junctions have established that the proposed improvements would accommodate the traffic demands generated by the Forest Park with acceptable conditions even with the most stringent attendance tests and worse case assumptions. The TA indicates that the improvements will provide capacity benefits at times when the regular Forest Park activities would generate low levels of traffic, including the AM and PM peak hours. Off site junctions would operate with relatively modest increases in queuing at most junctions except for some of the infrequent high attendance race scenarios. There would be no regular material impacts on any part of the network. 

6.10	The TA indicates that the site is within an area where access by public transport and other non-car modes is good. The proposals incorporate a network of on-site pedestrian and cycle routes to connect with the off site provisions at the access points. Public transport access to the site would be catered for and given priority. Off site shuttle buses are proposed to better connect the SFP scheme with existing rail services at Walkden, Patricroft and Eccles Metrolink stations. The proposals offer a realist choice of access by public transport and non-car modes. 

Updated Transport Assessment (May 2007) (Prepared by RPS)

6.11	The Updated Transport Assessment (UTA) was produced as part of the ESS and contains only additional information or details of amendments. One of the key amendments to the scheme proposals relates to the form of access and highway improvement at M60 Junction 13. This now consists of a signal-controlled improvement with a new arm providing access to the SFP site. The scheme would include the provision of controlled pedestrian crossing facilities as well as highway capacity improvements. The highway improvements will not only mitigate against the busiest traffic periods of SFP but will also reduce existing queues and delays at the junction, particularly the M60 off-slip arm. 

6.12	The A580 access has been amended to incorporate controlled pedestrian crossing facilities on the western arm of the A580 and pedestrian and cycle facilities on the western arm of the A580 and pedestrian and cycle facilities through the junction in and out of the site. Operational assessments including the sensitivity tests, of access junctions have established that the proposed improvements would accommodate the traffic demands generated by the SFP proposals with acceptable conditions even with the most stringent attendance tests and worse case assumptions. These improvements will also provide capacity benefits at times when the regular SFP activities would generate low levels of traffic, including the regular weekday AM and PM peak hours.

6.13	Assessments, including sensitivity tests, demonstrate that the off-site junctions would operate with relatively modest increases in queuing at most junctions except for some of the infrequent high attendance race scenarios. There would be no regular material impacts on any part of the network.  

6.14	A Travel Plan discussion document has been produced which describes the measures, which are proposed as part of the development to encourage and promote sustainable travel to and from SFP. The conclusion of the original Transport Assessment remains valid - that there are no traffic or highway related reasons which should prevent planning permission from being granted.   

Need Statement (June 2004) (Prepared by Regeneris) 

6.15	This document seeks to highlight the principle rationale for the scheme based upon the consideration of relevant national, regional and local planning policy; quantifiable evidence of need drawn from a range of social, environmental and economic statistics; and results from survey research to ascertain views and perspectives locally on the proposed scheme. The document assesses the main components of the scheme taking into consideration the Forest Park elements and general enhancement of open space; the racecourse; the equestrian centre including the eventing course; and the hotel. The statement highlights the fundamental need for additional economic activity in this area. The document indicates that the scheme will generate jobs directly and provide uplift to the general image of Salford and the surrounding area. This document is considered in detailed in the planning appraisal.   

Updated Needs Assessment (April 2007) (Prepared by Regeneris) 

6.16	This document should be viewed as a replacement of the previous statement. This document sets out the applicant’s principle rationale for the scheme. The applicant bases the needs case on a combination of the following:

•	Strong support from the relevant national, regional and local policy framework
•	Quantifiable evidence of need drawn from a range of social, environmental and economic statistics
•	Financial evidence demonstrating the ways in which certain parts of the scheme will enable the development of other parts
•	The findings of survey research

6.17	The needs statement addresses each of the main component parts of SFP scheme including:

•	The new and improved woodland areas, new wetland and grassland habitats, country park trails and associated open space enhancement
•	The Forest Park visitor centre and the associated eco-village accommodation
•	The racecourse
•	The equestrian centre, including the eventing course
•	The hotel

6.18	The statement highlights the need for additional economic activity in this area. The SFP scheme will generate jobs directly and enable improvements to Salford’s and the surrounding areas image.  

Planning Support Statement (June 2004) (Prepared by Peacock and Smith)

6.19	The statement provides an assessment of the submitted scheme against relevant national, regional and local planning policy. The document examines the reasons why the proposals should proceed and the recreation, economic and tourism benefits that would arise from the proposed development. The document arrives at a number of broad conclusions as follows; the SFP scheme is a “one off” opportunity due to the scale and breadth and should be seen to be of at least sub-regional significance and importance. The scheme offers an unrivalled opportunity to enhance the recreational, sporting and tourism based profile of Salford. The applicant judges that all the elements of the scheme are in conformity with current Government policy, including that which deals with the Green Belt. The applicant aims to demonstrate “very special circumstances” that are sufficient to outweigh any harm. The document identifies a shortfall in horseracing provision in the North West, which SFP will help meet. There is a shortfall in equestrian cross-country eventing facilities, which SFP will meet. SFP will satisfy the identified shortfall in publicly accessible woodland and general country park provision. SFP will provide increased public access across an area of countryside where access is currently limited. The SFP scheme provides an opportunity to raise the profile of Salford and the wider region through the development of an international quality facility. SFP will contribute to tourism aims through the provision of tourist facilities (including hotel, earth sheltered accommodation at the Eco Village and rural camping). The development will provide an opportunity to create a range of rural based employment opportunities in a deprived largely urban location. SFP will enhance the wildlife and nature conservation value of an extensive site, contributing towards BAP targets for priority species and habitats. The scheme will provide an opportunity to bring sport, recreation and youth activity together in a Rural Park. The scheme will provide an opportunity to move towards realising the concept of a Regional Park resource.        

Updated Planning Supporting Statement (May 2007) (Prepared by Peacock and Smith)

6.20	This document provides an update of the original Planning Support Statement by reviewing the more recent up to date policy sources relevant to the SFP scheme including PPS1: Delivering Sustainable Development; PPS7: Sustainable Development in Rural Areas; PPS9: Biodiversity and Geological Conservation, Circular 06/2005, PPS11: Regional Spatial Strategies; PPS12: Local Development Frameworks; The Good Practice Guide on Planning for Tourism; PPS22: Renewable Energy; PPS23: Planning and Pollution Control; PPS25: Development and Flood Risk; Circular 11/2005; Draft RSS for the North West; The City of Salford Unitary Development Plan 2003-2016; The Wigan Unitary Development Plan 2002-2016; Northwest Regional Economic Strategy 2006; The Strategy for Tourism in England’s North West 2003-2010; Marketing the Natural Environment of the Northwest 2006; The Agenda for Growth – The Regional Forestry Framework for England’s Northwest; The Countryside in and Around Towns 2005; and Delivering a New Urban Fringe 2006. 

6.21	The document concludes that national planning policy is supportive of SFP; the relevant regional and local planning policies provide a favourable policy climate for the development; and there is growing focus upon the benefits to be derived from capitalising upon the natural environment assets of the Northwest.    

Updated Paper on Very Special Circumstances in relation to Green Belt Issues (October 2007) (Prepared by Peacock and Smith)

6.22	This paper focuses on the VSC’s put forward by the applicant in relation to Green Belt issues. The paper sets out and discusses a series of VSC’s identified by the applicant as follows:

•	The unique nature of the site and the need for enhanced public accessibility on a significant scale
•	The current under-provision for horseracing and related facilities in the north west
•	The horse racing industry need for further facilities
•	The enabling effect of the racecourse and related facilities for the delivery of the recreational and educational benefits of the scheme
•	The fact that no credible alternative site for a racecourse could be found elsewhere around the conurbation
•	The need for and benefits of the significant recreational, educational and sporting provision proposed in addition to the racecourse
•	The need for and benefits of increases in woodland cover, protection of the natural environment and the introduction of ecological management across the site
•	The socio-economic benefits of the proposal
•	The potential contribution to tourism through the interpretation of the social history of Salford
•	The enhancement of the image of Salford and Greater Manchester which supports urban regeneration in the wider area; and
•	Wider policy support for the proposal

6.23	The document concludes that the SFP scheme has the potential to exert a positive influence on sport, leisure, recreation, tourism and education. It is considered that the scheme will have a beneficial impact at the local level, as it will provide a wide range of opportunities for people to access the site on a day-to-day basis. The development will deliver sporting and recreational facilities that will provide benefits on the sub regional level. The VSC’s outlined above are judged by the applicant to justify inappropriate development.   

7.	CONSTRUCTION PLAN 

7.1	The applicant, as part of the ESS submitted an outline construction plan based upon current information relating to ground conditions on site and construction techniques. The subsequent ESS provided an updated construction plan, which takes into account comments made by the Environment Agency and Greater Manchester Ecology Unit and provides more details of the mitigation strategy for water vole and amphibians.  The main details of the construction plan are outlined below.  

7.2	During the first year;
•	Management and habitat creation would be undertaken;
•	The main construction access into the site from the A580 would be established;
•	Vicars Hall Bridge would be reconstructed;
•	The western roundabout at Junction 13 would be reconfigured;
•	Ground investigations would be carried out so that final civil engineering and structural design solutions can be developed;
•	Work would commence on the re-shaping of the golf course;
•	Some advanced planting would be undertaken to the north of the canal, alongside the new access road, and in the land to the south of the Avenue;
•	Revised routes of concessionary paths through Middlewood to the canal would be established;
•	September: Survey entire complex of ditches north of the Avenue for water voles. Map latrines, burrows, feeding signs etc. Mark any burrows in potentially affected sections using canes at banktop;
•	November to December: Desilting and management of watercourses north of the Avenue specifically to increase vole capacity in those ditches that would not be affected by development; and
•	November to December: Creation of new habitats in areas not subject to future landform modification – specifically including the proposed section of new meandering channel north of the Racetrack. New watercourse to be cut to existing groundwater levels. Turfing and aquatic planting, installation of coir bank-toe rolls. 

7.3	During year two;
•	Remodelling of the golf course to the north of the canal, and of the golf course land to the south of the canal, would be completed to enable all areas to be seeded and planted by the end of year two;
•	The new roads to the north of the canal would be completed and main internal road network to the south of the canal would be formed as haul roads;
•	The new bridge crossing over the canal at Middlewood will be formed;
•	Remedial works as necessary for the landfills will be undertaken together with ground improvements to establish the reinforced car parking which would be re-seeded in year two;
•	The land area around the grandstand would be re-modelled to create the development platforms together with the reshaping of Moss House Brook to create reed beds and flood control;
•	Work would commence on building the racetrack and re-modelling the surrounding landscape;
•	Services infrastructure would be installed;
•	Building construction would commence at the grandstand, equestrian centre, hotel, and golf club house;
•	Forest Park Centre grass car parking areas to be laid out and planted and new tree planting would be undertaken to compensate for losses in Bittern Pits/Hollin Wood areas and to frame up the Eco Village landscape; 
•	Spring: New habitats managed to encourage vole cover. Existing habitats to be retained also managed to encourage bankface cover (e.g. restriction of grazing);
•	September: Check qualities of new habitats are up to required standards, if they are then suitable proceed, otherwise defer until spring of year three;
•	September/October: Implement Displacement and Re-location Programme; and 
•	November: Cleared ditches handed over to Main Contractor.

7.4	During year three to four;
•	Final re-configuration of A580 roundabout;
•	Re-configuration of M60 J13 eastern roundabout;
•	All works to the internal access roads would be completed;
•	Completion of the grandstand and ancillary buildings, and racetrack with all associated landscape treatments and new tree planting to the north of the Avenue;
•	Completion of the hotel, equestrian centre, and golf course (ready for play);
•	Construction of the Forest Park Centre buildings;
•	Construction of children’s play space and tree top walkway;
•	Final landscape treatments to Forest Park Centre including Eco Village Lake and campsite; and
•	Year three onwards: Monitoring the success of translocation by repeat vole surveys in autumn.

8.	SITE HISTORY 

01/43043/OUT - Outline application for grandstand, ancillary buildings for new racecourse; equestrian, woodland visitor, timber initiative and youth activities centres; eco village, hotel, public house; golf course, driving range and clubhouse; new access from J13-M60 – Application withdrawn. 

95/33737/FUL - Layout of 2 golf courses, change of use and extension of existing farm buildings to hotel, conference and leisure facilities incorporating golf clubhouse, provision of car parking - Land adjacent Worsley Old Hall and 163 hectares either side of Leigh Road, Worsley – Approve 28.03.1996 – N.B. The golf course at SFP is the southern of two courses, which were granted planning permission as part of a single planning consent. The northern golf course is now operating as part of the Marriot hotel development. 

99/39149/TEL - Prior Notification for the installation of telecommunications equipment to include a cabinet, six antennae and three microwave dishes - Electricity Pylon on land west of Granary Lane Worsley – No objections 13.04.1999 

99/40192/TEL28 - Prior notification for telecommunications installation on existing pylon with ground based equipment cabin - Electricity Pylon on land west of Granary Lane, Worsley - No objections 20.12.1999 

02/44356/TEL56 - Prior Notification for the erection of 1.8m high timber board fence, enclosing telecommunications equipment cabin - Electricity Pylon on land west of Granary Lane, Worsley –Refused 01.08. 

95/34250/COU - Change of permitted clay pigeon shooting from a maximum of 4 hours on any day between 10am and 9pm and 10am and 6pm at weekends, and no more than 156 days in any year to unlimited shooting Wednesdays to Sundays from 10am to 4pm - Botany Bay Wood, Grange Road, Winton, Eccles – Refused 28.09.1995

00/41461/OUT - Demolition of existing cottages and outline planning application for the erection of one-pair of replacement semi-detached dwellings with detached single garages - Malkins Wood Farm, Vicars Hall Lane, Boothstown, Worsley – Approve 22.12.2000

03/47092/REM - Details of the siting design external appearance means of access and landscaping for the demolition of existing cottages and the erection of one pair of replacement semi-detached dwellings with detached single garages - Malkins Wood Farm, Vicars Hall Lane, Boothstown, Worsley – Approved 18.12.2003

9.	CONSULTATION RESPONSES 

9.1	There have been two key stages of consultation, the first stage was July/August 2004 when the ES was submitted, and the second stage was carried out when amendments were made to the application in May 2007 as part of the Environmental Statement Supplement submission.  The following consultees were notified of the planning application:

•	Barton Aerodrome
•	Boothstown Residents Association
•	British Horseracing Board
•	Council for Protection of Rural England – Lancashire Branch
•	Countryside Agency
•	Economic Development – Chief Executive Salford City Council
•	English Heritage
•	Environment Agency
•	Forestry Commission
•	Government Office
•	Greater Manchester Archaeological Unit
•	Greater Manchester Bird Recording Group
•	Greater Manchester Ecology Unit
•	Greater Manchester Passenger Transport Executive
•	Greater Manchester Police Architectural Liaison Officer
•	Health and Safety Executive
•	Highways Agency
•	Lancashire Aero Club
•	Manchester Ship Canal Company
•	National Farmers Union North West
•	National Grid Company PLC / British Gas Transco
•	Natural England (formerly English Nature)
•	Network Rail
•	North West Development Agency
•	4NW – The Regional Leaders Forum (formerly known as North West Regional Assembly)
•	RAGE – partnership between Worsley Village Community Association, Boothstown Residents Association and Worsley Civic Trust and Amenity Society
•	Ramblers Association - Manchester and High Peaks Area
•	Red Rose Forest
•	Royal Society for Protection of Birds
•	United Utilities
•	Urban Vision Environment
•	Wildlife Trust – Lancashire, Manchester and Merseyside
•	Worsley Civic Trust and Amenity Society
•	Worsley Village Community Association

Table 2 - Summary of Consultee Responses

9.2	Each consultation response is summarised within table 2 below.  A full summary of the consultation responses is attached within this agenda at appendix A.

CONSULTEE	SUMMARY OF RESPONSE
	
Barton Aerodrome	No objection.  The Hazard Assessment Plan identifies the potential hazards arising from the development and the mitigation required during the design stages and the continuous management of the development site.	
Boothstown Residents Association	A number of comments are made relating to PPG2, traffic and congestion, access, traffic modelling, travel plans, noise and wildlife issues.  The submission highlights the significant visual impact of the development.  The application does not assist urban regeneration.	
British Horseracing Board	The proposal is considered to be an opportunity to expand the sport of British thoroughbred horseracing to a market of untapped potential considering the affluence and population of the Greater Manchester area.	
Council for Protection of Rural England – Lancashire Branch	Support the idea of a development that opens up Botany Bay Wood and the surrounding area for public access.  However, concerned about the possibility of the site being further developed or redeveloped.  More consideration required to public transport arrangements.	
Countryside Agency	The proposal does not meet the restricted criteria for detailed comments as outlined in the Countryside Agency’s publication ‘Planning Tomorrow’s Countryside’. 	
Economic Development – Chief Executive Salford City Council	Supportive of the application.  Consideration should be given to local economic benefit and implementation of a S106 for contributions for local employment supply as outlined in the Planning Obligations SPD.	
English Heritage	No objection.  Concerns regarding the impact of the proposal on peat, which may contain buried palaeoenvironmental and cultural remains.  A mitigation programme is recommended in advance of determination.	
Environment Agency	No objection subject to the applicant agreeing to appropriate planning obligations or conditions to deal with the long term management of the ecological features on site.	
Forestry Commission	The proposals carry merit both in terms of existing woodlands, proposed woodlands and those who may use them. The woodland proposals and the interpretative developments would offer substantial added value to the Red Rose Forest and the overall initiative in Salford, west Manchester and the wider sub-region of the Mersey Belt.	
Government Office	Acknowledge receipt of information.	
Greater Manchester Archaeological Unit	Recommend that a condition is attached based on PPG16 relating to a programme of archaeological work. The Unit generally agrees with the mitigation strategy in the ES.	
Greater Manchester Bird Recording Group	Object to the proposal.  The application should be considered alongside other large developments in the area.  Would result in urbanisation of the area.  The area is well catered for in terms of golf courses and racecourses.  Red listed and amber listed birds are likely to be lost.  Extensive resurveys will be required if the proposals are implemented as current survey results will be at least 5 years out of date.	
Greater Manchester Ecology Unit	The cumulative impacts of the proposal are greater in total than the sum of any individual species or habitat impacts.  The impacts should be considered significant on a District scale.  Concern is raised given the sheer scale of the development proposals and the consequent mitigation schemes that there is a significant degree of uncertainty regarding their achievability and the consequent carrying capacity of any retained / recreated habitats either immediately post development or in the long term under any management plans.	
Greater Manchester Passenger Transport Executive	Development, submission, implementation and monitoring of the Travel Plan should be attached as conditions of any planning consent.   The Travel Plan should include information on employment travel and other leisure travel to the on-site facilities or recreational travel to the Country Park as well as on race days. A developer contribution should be included to extend existing commercial services that currently terminate at Boothstown or Worsley, a staff minibus and a weekend shuttle bus for leisure visitors	
Greater Manchester Police Architectural Liaison Officer	No objection to the proposals but any buildings constructed should be built to Secured by Design standards, and should be conditioned to any planning permission granted.	
Health and Safety Executive	HSE no longer provides Land Use Planning advice.	
Highways Agency	The TR110 Holding Direction is valid until 12th December 2008.  The Highways Agency have received the results on a final report (Working Note 7) and as a result have confirmed that they intend to remove the holding objection subject to conditions relating to: full implementation of the Site Travel Plan; full implementation of the Traffic Management Strategy; Implementation of the Agreed Highway works, complete with High Occupancy Vehicle Lanes, access control and ramp metering on the M60 slip roads; agreed thresholds to the scope and frequency of events; provision of a formal site steering group; provision of traffic management strategy for major events; provision of shuttle buses and event ‘race day specials’; and management of the internal highway network during ‘normal’ (non-event) operation. 	
Lancashire Aero Club	Does not want to be held responsible for noise disturbances to future users of the development, by the continuation of current established operations in the vicinity of the aerodrome. 	
Manchester Ship Canal Company	No objection to the application and register full support for the proposed development. 	
National Farmers Union North West	Object to the application.  The site includes land within designated Green Belt.  The proposal would result in the loss of grade 1 and 2 agricultural land, which is deemed to be the best and most versatile.  The application potentially fragments viable agricultural holdings.  May jeopardise the long term security of the tenants.  Enhanced access may compromise farm security and the requirements of quality assurance scheme.  Concern is raised regarding the speculation of the proposed golf course hosting the Ryder Cup.	
National Grid Company PLC / British Gas Transco	National Grid does have Major Accident Hazard Pipelines in the vicinity, Astley Green – Worsley and Blackrod – Warburton Tunnel North. The pipelines are laid in legally negotiated easements to which certain conditions apply. It is essential that access to the pipelines is not restricted, particularly in the event of an emergency. There must be no obstructions within the pipeline’s maintenance easement strips, which would limit or inhibit essential maintenance works on the pipelines.	
Natural England (formerly English Nature)	No objection.  Are not aware of any statutory designated sites, which will be significantly affected by the proposals. Botany Bay Wood, has been identified for some time a pSSSI, and this designation is unlikely to change in the foreseeable future. Strongly recommend mitigation for any proposals likely to cause disturbance to the heronry, but would also be pleased to see opportunities for general habitat enhancement included. Satisfied in respect of protected species mitigation, and would encourage maximising opportunities for habitat creation and enhancement. Strongly recommend that implementation of mitigation proposals be achieved through the use of appropriate and enforceable planning conditions, and long-term management be secured through a Section 106 or similar agreement.	
Network Rail	No objection. The developer must provide a suitable trespass-proof fence of at least 1.8m in height where the application site borders the rail boundary. 	
North West Development Agency	No comments with regard to the application.	
4NW – The Regional Leaders Forum (formerly known as North West Regional Assembly)	NWRA support the comments and recommendations made by the Highways Agency in relation to the amendment to the configuration of M60/Junction 13 western roundabout and new access road.  Consideration should be taken into account in relation to biodiversity, i.e. Sniggley Brook. Policy EM1 indicates that plans, strategies and proposals should protect areas of wildlife and encourage their protection. 	
RAGE – partnership between Worsley Village Community Association, Boothstown Residents Association and Worsley Civic Trust and Amenity Society	Object.  The proposal is contrary to RSS policy EC8 – Town Centres – Retail, Leisure and Office Development and policy EC9 – Tourism and Recreation.  The grandstand, other racecourse facilities, equestrian centre, hotel, golf clubhouse, forest park centre and timber workshop represent inappropriate development in the Green Belt.  Very special circumstances have not been demonstrated.  Concern regarding residential amenity in respect of traffic congestion, fly parking, noise from traffic, light pollution, air pollution and general disturbance.  The overall impact upon issues of nature conservation have not been sufficiently recognised.  The proposal would have a negative impact on protected species or designated sites and is therefore contrary to policies EN5, EN6 and EN24 of the UDP.	
Ramblers Association - Manchester and High Peaks Area	In terms of rights of way/access more could be done; but as long as regulations and UDP policies are compiled with, the proposal favourably is considered favourably. Very Special Circumstances do not apply in relation to Green Belt issues and as such the proposals will have to be amended or rejected.	
Red Rose Forest	The Forest Park Centre is an essential part of the development proposals and the concept of sustainability is supported. A condition that the details of landscaping along the M60 and M62 routes be subject to detailed reworking is recommended. The improved access to the site is supported. The whole 16ha area of Manor Farm near Boothstown and the land adjacent to the application area near Boothstown and to the north of the Bridgewater Canal should be dedicated rights of way. New access routes should be dedicated Public Rights of Way and should form strategic linkages to existing routes alongside the Bridgewater Canal, and across the M60 by “The Grange” connecting to the community woodland across the M62. 	
Royal Society for Protection of Birds	The development contains incompatible elements in relation to Green Belt policy, including the car park developments, racecourse, grandstand, hotel, holiday chalets and the associated infrastructure. Cumulative effects from neighbouring developments should be considered strategically.  The development of car parks, hotel, chalets, golf course and racecourse will result in displacement of grey partridge, curlew, lapwing, skylark, yellowhammer, water vole, brown hare and great crested newt. The proposal provides no mitigation for the loss of these species except for wildlife friendly farming measures, which will be difficult to enforce in the long term.  Botany Bay Wood is a Grade A SBI, and as such part of the site should be fenced off year-round to prevent public access and disturbance to these species. All land management mitigation should be being made the subject of Section 106 agreements with provision of funds to enable all works to be carried out. Astley Moss East should be used as a suitable strategic compensation site through the restoration of lowland raised mire which will benefit biodiversity that visitors to SFP could enjoy.	
United Utilities	No objection.  Applicant should have regard to underground and overhead electricity assets and ensure that maintenance and/or access rights are maintained. The applicant should consider the potential difficulties caused by trees and consider this when carrying out planting near to overhead line/underground cables.  The Thirlmere Aqueduct crosses the site, and access for operation and maintenance of it is required. United Utilities will not permit any development in close proximity to the mains. Ground levels over and adjacent to the pipelines must not be altered without discussion. Water mains will need extending to serve any development on the site. Site must be drained on a separate system, only foul drainage connected into the foul sewer. Any proposals resulting in an increase in river levels, or trade effluent discharge to a public sewer will need to be discussed with UU	
Urban Vision Environment	Noise – Construction Phase - No objection - Although noise issues are identified as being a problem during the construction phase of the development for residents of Keepers Cottage, mitigation measures are proposed that are considered to acceptably reduce the level of this impact. The Construction Noise Management Plan will ensure that all identified areas of the site and site operations where noise may be generated and also identify control methods to ensure that noise does not create a nuisance.
Dust – Construction Phase - No objection. Potential exists for dust issues, although appropriate measures to control dust will be contained within a dust management plan.
Contaminated Land and Landfill Gas Issues - Issues to be addressed through any future detailed investigations should include: the durability of the proposed grass paving on the landfill sites; details relating to  the weight of the traffic on top of the landfill in relation to lateral migration; an investigation into the existing passive venting system; spreading of material on the moss from the construction of the canal, disposal of mine arisings from botany mine, general agricultural contamination including diesel spillages, pesticides, fertilisers, burial of farm wastes; gas monitoring of each proposed structure on site under or within the footprint of the building to assess the gas protection needed; The production of a long term gas protection management system. This should be implemented via planning condition or S106; and carrying out any contamination investigations in a phased approach as recommended in current best practice and ease of assessment due to the large area covered and differing previous uses and proposed end uses. 
Odour – Construction Phase - No objection - Odour from the construction works is likely to be minimal.
Air Quality – Operational Phase - If funding is secured through a S106 agreement for Salford City Council to fulfill it’s obligations for Air Quality Management then the development would be acceptable in air quality terms. A method to guide the level of S106 contribution is identified, although it is acknowledged that this figure will alter depending upon the air quality scenario modeled i.e. flagship event, regional event etc. A contribution of £52,500 is identified as a guide for the appropriate level of contribution.     
Noise – Operational Phase - No objection – Issues relating to locations for noise monitoring resolved. Without the implementation of appropriate noise mitigation measures for Keepers Cottage the noise impact during the operational phase of the development is considered to be unacceptable. However, the applicant has agreed with the Council suitable noise mitigation measures that are considered acceptable to the resident and the Council.  
Minerals - No objection - The supplementary assessment of geology in the ESS indicate that the development will not result in sterilisation of mineral resources. 	
Wildlife Trust – Lancashire, Manchester and Merseyside	Public access at all times of the year should be restricted in the heronry area to avoid disturbance. Concerns exist that the development of car parks, racecourse and golf course will result in the displacement of Red and Amber listed bird species, and that no mitigation is proposed. Consider overall that the development will enhance the wildlife and nature conservation value of the site and contribute towards Biodiversity Action Plan (BAP) targets and priority species habitats. The management of the park needs to be underpinned by legal agreements. All management plans should be made subject to Section 106 Agreements.  In terms of conservation the application should be considered in relation to the proposed developments of the sports stadium, the inter modal freight interchange and Astley Moss East, which in particular will have significant impact upon the ecology of the region. It is essential that there should be adequate mitigation for the loss of habitat for important species, especially birds, and for the loss of Green Belt. 	
Worsley Civic Trust and Amenity Society	Object.  Principle concerns relating to the development are the additional traffic in and around Worsley, exacerbating existing severe congestion, and the overt use of Green Belt land for commercial purposes. Concerns also exist relating to additional problems of light pollution from the floodlights and the nuisance of off-site parking. It is considered that for the site to be viable the facility will need to be used more than the 30 days racing per year that is expected. It is anticipated that the racecourse operators will attempt to attract bookings such as truck rallies, monster truck racing, steam fairs, conferences, weddings, exhibitions and concerts which are incompatible with green belt policy. The application makes little reference to public transport.  Consideration needs to be given to pollution issues from traffic fumes, noise levels (large crowd noise, the public address system, and helicopters and light aircraft used by jockeys and officials), and light pollution. Access to the site for emergency services is difficult.	
Worsley Village Community Association	Object. The development represents inappropriate use of green belt land. . In relation to traffic: J13 is one of busiest on the M60 motorway network with 180,000 vehicles passing daily. To put anymore traffic on this junction will result in standing traffic for a radius of 10 miles adding to existing congestion. The area has an existing pollution problem caused by standing traffic; race day traffic will only add to this. Safety issues exist for children crossing the slip road in Worsley Village to reach school. Application makes no provision for public transport. Opposition to the grandstand, as this will dominate the skyline both from Worsley Village and Boothstown. It will have corporate facilities and used for other non-racing activities	

9.3	No responses have been received from Trafford MBC, Hawk and Owl Trust, South Lancashire Bat Group, Cycling Project for the North West, Peak and Northern Footpath Society, Sport England, The Open Spaces Society and the British Horse Society.

10.	PUBLICITY

Site notices were displayed on site.

Press notices were published in 2004 and on the 31st May 2007.
The following neighbour addresses were notified in June 2004 and May 2007

Godmondhall Drive	1-39(o), 2-28(e)
Highclove Lane		1-21 (o), 45-95 (o), 14-80 (e)
Kepplecove Meadow	2-28 (e), 1-9 (o)
The Borrans		1-7 (o), 2-4 (e)
Fellfoot Close		1-9 (o), 2-8 (e)
Millcrest Close		1-17 (o), 2-24 (e)
Amberhill Way		1-7 (o), 43-47 (o), 2-46 (e)
Cringlebarrow Close	2-12(e), 1-17 (o)
The Chaddock Level	1-23(o), 2-16(e)
Bleasefell Chase	2-16(e), 1-7(o)
Gleyknotts 		1-7 (o), 2-16 (e)
Ridge Green		1-10 (inc)
Old Cott Close		1-6 (inc)
Ploughfields		1-25 (o)
Cleabarrow Drive	2-8 (e), 1-7 (o)
Boothshall Way		101-115 (o), 110-130(e)
The Moorings Phase
Holme Park Gardens 	1-5 (inc)
Casterton Way		2-16 (e), 1-5 (o)
Thorns Villa Gardens	1-21 (o), 2-14 (e)
Bridgefoot Close	1-9 (inc)
Boothstown Drive	1-41 (o), 2-48 (e), 2A, 2B
Reddington Close	1-11 (inc)
Redwater Close		1-9 (o), 2-14 (e)
Booths hall Paddock	1-5 (inc)
Booths hall
Firtree Avenue		1-20 (inc)
Pleasant Close		1-5 (inc)
Booths hall Road	4-14 (e)
Avenue House 
Pheasant House
The Barn
Swallows Cottage
Dove Cottage
Saddleback Close	1-6 (inc)	
Landrace Drive		2-30 (e), 1-11 (o)
Booths Hall Grove 	1-13 (0), 2-16 (e)
Quayside Close		1-11 (o)
Waterdale Close	1-19 (o), 2-14 (e)
Portside Close		2-8 (e), 1-5 (o)
Boothsbank Avenue	2-32 (e)
Hilton Crescent		2-48 (e), 1-23 (o)
Hollinswood Road	2-12 (e), 1-15(o)
Sandringham Road 	1-63 (o), 2-64 (e), 11A
Leigh Road		12-30 (e), 44-50 (e), 80-92 (e), 92A, 92B, 92C,
			94-102 (e), 162-218 (e), 218A, 320A, 220-256 (e),
			256A, 258-312 (e), 312A, 314, 1-223 (o)
Worsley Hall Nurseries
West Lodge
Booths Bank Farm
Alderwood
Point Chase		1-21 (o), 2-20 (e)
Falconwood Chase	1-45 (o), 2-38 (e)
Randsclough Drive	1-59 (o), 2-48 (e)
Stetchworth Drive	1-57, (o), 2-58 (e)
Ellenbrook Road	1A, 1-23 (o), 25A, 25-87 (o), 6-42 (e),
			308,310,320, 58-66 (e)
Moss House Lane
Moss House Farm
Chapel Meadow 	1-23 (o)
Orchard Avenue	1-12 (inc), 14-52 (e), 15-21 (o)
Haydock Drive		1-43 (o), 2-24 (e)
Braemar Lane		1-12 (inc)
Wyre Drive		1-175 (o), 2-112 (e)
Windlehurst Drive	2-28 (e), 1-31 (o)
Lymefield Drive	2-96 (e), 15-91 (o), 91A, 93-99 (o)
Maplefield Drive	1-25 (o), 2-16 (e), 16A, 18-28 (e)
Bankfield Drive 	2-22 (e), 1-7 (o)
Meadowfield Drive 	1-25 (o), 2-12 (e)
Barnfield Drive		1-17 (o), 2-16 (e)
Woodfield Drive	2-28 (e), 1-31 (o)
Leafield Drive		2-12 (e)
Standfield Centre	1-14 (inc)
Standfield Drive	2-108 (e), 1-97 (o)
Hillfield Drive		1-11 (o), 2-12 (e)
Birchfield Drive	2-68 (e), 1-91 (o)
Beech Avenue		1-26 (inc)
Simpson Grove		1-33 (o), 2-8 (e)
Irvine Avenue		1-11 (o), 2-38 (e)
Brindley Drive		2-6 (e), 1-7 (o)
Simpson Road		1-26 (e), 7-13 (o)
The Maples
Community Centre 
Library
Vicars Hall Lane	2A, 2B, 2-12 (e), 12A, 14-24 (e), 
			34-88 (e), 110-112 (e), 120-170 (e),
			180, 11-69 (o), 99-103 (o)
Grove Farm
St Andrews Primary School
Keeper Cottage
Victoria Street		1-23 (o)
Victoria Close		1-11 (inc)
Vicars Hall Gardens 	1-120 (e), 122A, 122-132 (e), 
			1-71 (o), 117-135 (o)
Stirrup Brook Grove	1-5 (inc)
Stirrup Brook Cottage
Grove Hill 		1-17 (o), 2-18 (e)
Haile Drive		1-17 (o), 2-18 (e)
Lorton Close		1-7 (o), 2-10 (e)
Brookfield Drive	2-32 (e), 1-37 (o)
Brett Road		2-12 (e), 1-39 (o)
Linden Road		1-17 (o), 19A, 19-21 (o), 21A, 23, 23A,
			25-49 (o), 2-44 (e)
Ridgemont Drive	1-35 (o), 2-52 (e)
Ashford Avenue	2-40 (e), 1-63 (o)
Chaddock Lane		1-125 (o), 18-166 (e), 168,
			168A, 172
Boothstown Methodist School
Boothstown Methodist church
Boothstown Doctors Surgery
Sterndale Road		1-17 (o), 2-6 (e)
Hutton Avenue		2-18 (e), 1-29 (o)
Southdown Drive	2-42 (e)
Linkfield Drive		1-31 (o), 2-16 (e)
Ribble Drive		2-14 (e), 1-15 (o)
Langley Drive 		1-11 (o), 2-12 (e)
Devonshire Drive	2-8 (e), 1-11 (o)
Greenleaf Close		1-3 (o), 2-6 (e)
Leckenby Close		2-6 (e), 1-9 (o)
Springburn Close	1-5 (o), 2-12 (e)
Borderbrook Lane	1-65 (o), 2-72 (e)
Mosley Common Road	306-334 (e), 239-271 (o)
Homelea	
Mill Street		7-27 (o)
Moorfield		1-11 (o), 2-16 (e)
Crosslands Road	1-43 (o), 18-36 (e)
East Lancs Road	880-902 (e), 920-938 (e)
East Moor		2-58 (e), 1-29 (o)
Edenvale		2-72 (e), 20A, 20B, 46A, 66A, 1-51 (o)
Thornway		1-13 (o), 2-26 (e)
Arkholme		2-26 (e), 1-29 (o)
Lightwood		2-14 (e), 1-7 (o)
Marrowdale		1-7 (o), 2-20 (e)
Averhill 		1-11 (o), 2-8 (e)
Rose Acre		1-15 (o), 2-14 (e)
Queen Ann Drive	2-12 (e), 1-25 (o)
Crombouke Fold	2-10 (e), 1-11 (o)
Cannel Fold		1-5 (inc)
Penrice Fold		1-6 (inc)
Inglesfold		1-5 (o), 2-8 (e)
New City Road		1-27 (o)
Brandwood Close	1-11 (o), 2-36 (e)
Lindburn Drive		1-45 (o), 2-50 (e)
Bridgewater Road	Boundary Stone Phase
Morston Close		
Ellenbrook Close	102-108 (e), 481, 491-493 (inc)
			89-117 (o), 117A, 119-121 (o), 499,500,501
St Mary’s Church
Red Lion Pub
Herevale Grange	1-10 (inc)
Bunting Mews		1-21 (inc)
Redpoll Close		1-21 (inc)
Oriole Close		11-41 (o), 1-3 (o), 2-4 (e), 20-40 (e)
Blackcap Close		1-12 (inc), 14 
Goldcrest Close		1-11 (inc)
Firecrest Close		1-8 (inc)
Stonechat Close		1-22 (inc)
Gatemere Close		1A, 1-5 (o), 2-12 (e)
Ellendale Grange	2-28 (e), 1-17 (o)
Ladymere Drive	
Langtree Close		1-23 (o), 2-26 (e)
Helmclough Way	1-23 (o), 2-18 (e)
Gambleside Close	1-17 (o), 2-12 (e)
Woodshaw Grove 	1-7 (o), 2-12 (e)
Howbridge Close	1-10 (inc)
Newearth Road		Ellenbrook Primary School
Longwall Avenue	
Goodshaw Road	1-32 (inc)
Spindlepoint Drive	2-14 (e), 1-9 (o)
Reedley Drive		2-42 (e), 1-33 (o)
Edge Green		1-6 (inc)
Smallbridge Close	1-5 (o), 2-10 (e)
Bellpit Close		2-30 (e), 1-47 (o)
Habergham  Close	1-17 (o), 2-30 (e)
The Chanters 		1-11 (inc)
Cornlea Drive		1-11 (o), 2-22 (e)
Ellerbeck Crescent	1-19 (o), 64-68 (e), 78-88 (e)
Sixpools Grove		1-8 (inc)
Wrenswood Drive	1-11 (o), 15-25 (o), 2-26 (e)
Doefield Avenue	1-21 (o), 2-20 (e)
Ladyhill View		1-51 (inc)
Hawfinch Grove	1-19 (o), 2-26 (e)
Greylag Crescent	1-49 (o), 57-63 (o), 2-18 (e), 26-66 (e)
Nutharch Avenue	1-12 (inc)
Woodpeck Place	1-9 (o), 2-14 (e)
Wagtail Close		1-4 (inc)
Gadwall Close		2-12 (e), 1-17 (o)
Redstart Grove		1-11 (o), 2-4 (e)
Harrier Close		1-9 (o), 2-24 (e)
Leconfield Road	1-16 (inc)
Grange Road		2-42 (e), 1-33 (o)
The Grange 
The Bungalow

Eccles
The Nook 		1-43 (o), 2-28 (e)
Hastings Road		1-17 (o), 2-20 (e)
Botany Road		1-11 (o), 2-24 (e)
Alderforest Avenue	1-17 (inc)
Alder Street		1-11 (inc)
Hartington Road	1-23 (o), 2-18 (e), 2A
Grosvenor Road	1-6 (inc)
Boothfield Road	1-57 (inc)
Blantyre Street		2-36 (e), 5-31 (o)
King William Street Pub (26)
Worsley Road		363-393 (o), 403-497 (o)
Barton Moss Road
Nursery Farm, Brighton Grange
Moss View Farm, Chat Moss House
Moss Lane Farm, Woodside Farm	
Manor farm, Birch Farm
Malkinswood Farm, Keepers Cottage
Rawsons in ‘th’ Nook
The Mews		1-12 (inc)
Leigh Road		Middlewood Scout Camp
Walkden Road		315, 301, 362-394 (e), 404-478 (e),
			319-345 (o)
Esso Service Station, The cock Hotel,
Ellesmere Sports Club, The Spinney,
Old Warke, St Marks Vicarage, 
Worsley Marriot Hotel, Worsley Old Hall,
Ladyhill
Delaford Avenue	1-9 (inc), 11-13 (inc)
Glenvilla Avenue	1-4 (inc)
The Avenue
The Bungalow, Greenways
Woodside, Roundoak, Mino
Old Hall Lane		1-11 (inc)
The Paddock		1-4 (inc)
Woodlands Close	1-3 (inc)
Worsley Brow, John Gilbert Public House,
Novotel Hotel
Lumber Lane		1-5 (o), 17-77 (o), 2-6 (e),
			2-6 (e), 6A, 8-36 (e)
Sisley Cottage, Littlewood Cottage
Mesne Lea Grove	1-10 (inc)
Wood Lea		1-15 (inc)
Greenleach Lane	8-30 (e), 1-39 (o), 63-197 (o)
			40-46 (e), 46A, 48, 50, 60,
			78-116 (e), 112A
Kempnough Hall Road	2-30 (e), 1-23 (o), 246-249 (inc)
Kempnough Hall
Ashbourne Grove	1-2 (inc)
Ashford Grove		2-4 (e)
The Retreat		1-2 (inc)
Hardy Grove		1-9 (inc)
Brereton Drive		1-5 (inc)
Briarfield Road		1-24 (inc)
Woodlands Road	1,3,2,6
Leaconfield Road	1-18 (inc)
Aviary Road		2-8 (e), 1-7 (o)
Ryecroft Childrens Home, St Marks Primary School
The Warke		1-11 (o), 11A, 15, 2-8 (e)
Crossfield Drive	1-25 (o), 31-45 (o), 2-52 (e)
Peel Grove		1-6 (inc)
Pine Grove		2-12 (e)
Beesley Green		250, 251, 252, 253, 253A, 254
Thornbank, Orchard House, Roe Green Cricket Club,
Beesley Green Community Centre
Meadowgate		1-34 (inc)
Moorfield		2-8 (e), 1-5 (o)
The Nook (Worsley) 	1,2 
The Coppice (Old Clough Lane), Greenland,
Brookdale, Newholme, Newstead, 2, 4
Old Clough Lane	226-256 (e)
Roe Green		6,8,8A, 10-42 (e), 58-70 (e), 
			78-82 (e), 86-100 (e)
Roe Green Church
Blandford Avenue	2-26 (e), 1-15 (o)
Wesley Drive		1-27 (inc)
Crawford Avenue	1-20 (inc)
Lyon Grove		5-29 (o), 2-28 (e)
Lyndene Avenue	1-17 (o), 2-12 (e)
Mayhill Drive		1-9 (o), 2-4 (e)
Wardley Hall Lane	1-49 (o), 2-70 (e)
Roe Green Avenue	1-87 (o)
Egerton Court 
(Glen Avenue)		1-9 (inc)
Glen Avenue		1-39 (o), 39A, 41-67 (o), 2-34 (e)
Mulgrave Road		2-42 (e), 3-41 (o)
Manthorpe Avenue	1-21 (o), 2-74 (e)
Forrester Street		1-6 (inc)
Starkle Street		2-12 (e), 1-3 (o)
Summerfield Road	1-11 (inc)
Parrfield Road		2-12 (e), 1-9 (o)
Alfred Avenue		1-31 (o), 2-22 (e), 22A, 24-44 (e)
Mabel Avenue		2-26 (e), 1-11 (o)
Elm Crescent		2-8 (e), 8A, 10-14 (e), 1-9 (o)
Hawthorn Drive		8-26 (e), 1-11 (o), 15-17 (o)
Sanderson Close	1-7 (o), 2-12 (e)
Beechwood Drive	1-7 (inc)

Worsley
Worsley Road		2-14 (e), 3, 5, 16, 20-26 (e), 123-129 (o)
Bridgewater School, The Lodge,
Worsley Grange, Worsley Court House,
Rock House, Worsley Library
School Brow		2, 3, The School House
Mill Brow		110, 110A, 111-117 (inc)
			1-3, 19, 21, Highfield House
Waterbridge		1-6 (inc)
Greenside		1-12 (inc)
Baytree Avenue		1-17 (o), 2-14 (e)
Woodstock Drive	1-17 (o), 27, 43-47 (o), 2A, 2-44 (e)
Sefton Drive		2-30 (e), 1-25 (o)
The Crescent 		11-41 (o)
The Green		128-135 (inc), 135A, 136-157 (inc)
The Bungalow
Dukes Wharf		1-7 (inc)
Drywood Avenue	1-11 (o), 15-53 (o), 2-12 (e)
The Sidings		1-5 (inc)
The Moorings		1-3 (o), 2-6 (e)

Chandlers Row (Stablefold)
The Gatehouse		1-5
Waterside House	2-24 (e)
Northbank House	1-33 (o)
Stablefold		2-24 (e)
Lower Brook Lane	1-15 (inc)
Stirrup Gate		1-19 (inc)
The Chase		1-7 (inc)
Riding Fold Lane	1-81 (o), 2-48 (e)
Turfnell Way		1-11 (o), 2-18 (e)
Barton Road		2-8 (e), 6A, 10-16 (e), 50, 1, 1A,
			3-5 (o), 7A, 7-11 (o), 31-53 (o), 59-71 (o)
Penny Black Chambers	1-7
Worsley Methodist Church
Elmwood		73-75 (o)
Kenwood Lane		1-11 (o), 2-14 (e)
Heathfield 		11 (inc)
Farm Lane		1-51 (o), 12-64 (e)
Dellcott Lane		1-27 (o), 2-20 (e)
Woodgarth Lane	1-33 (o), 2-20(e)
Beanfield Terrace	1-3 (inc)
Beanfields		1-17 (o), 46-60 (inc)
Meadow Lane		2-20 (e), 1-35 (o)
Parkstone Lane		1-23 (o), 2-30 (e)
Edenfield Lane		1-31 (o), 2-44 (e)
Greenacre Lane		1-43 (o), 2-26 (e)
Ryecroft Lane		1-41 (o), 2-38 (e)
Granary Lane		2-16 (e), 5-37 (o)
Chapel Street, Worsley
Miners Mews
Ellenbrook Road	41
Abbots Fold Road	
Stetchworth Drive	58
Parkside Close		6
Landacre Drive		8
Quayside Close		The Moorings (2)
Leigh Road		284
The Mews		11
St Marks Church, Walkden Road							
St Marks Rectory, Walkden Road
Old Hall Lane		10, 8, 11
Marriot Manchester Hotel and Country Club
Wilders Moor Close
Herevale Grange	10
Lawndale Drive		All
The Old Leading Room, Winton Cricket Club, 
Worsley Dry Dock Company, Worsley Road
The Wharfside, Worsley Road
Eccles, Swinton, Worsley Sea Cadets
Unit 11 Worsley Boat Yard
Egerton Narrow Boats 
The Sidings 		5
The Green		132
Granary Lane		2,1
Drywood Avenue	39
Stirrup Gate 		12-14
Worsley Road, Eccles	337-341

11.	REPRESENTATIONS

11.1	The consultation process for the application involved two main consultation periods, one in June 2004 and the other during May 2007.  A total of 501 letters of objection to date have been received.  These are split between June 2004 (373 representations) and May 2007 (128 representations).  

11.2	In terms of the frequency, local residents main concerns relate to development of Green Belt land, increased air pollution, impact on valuable wildlife habitats, impact on existing transport infrastructure, racecourse / golf course / hotel not needed, increase in noise pollution, increase in light pollution, and the visual impact of the grandstand. All responses received during the June 2004 consultation period are summarised below. 

11.3	Environment
•	Green Belt: loss of; inappropriate development in; lead to more development if allowed; no use for commercial development
•	Loss of woodland
•	Destruction / adverse impact on valuable wildlife habitat  
•	Loss of a rural area / countryside
•	Loss of agricultural land and homes
•	Building on peat soils will result in water logging and as such the green areas proposed will be removed to deal with the water logging
•	Welcome additional tree planting
•	Open up the countryside
•	Maintain all Public Rights Of Way
•	Brownfield sites should be used first
•	Few jobs created-does not outweigh harm to environment

11.4	Pollution
•	Increased air pollution from car fumes
•	In another wise "dark" area significant increase in light pollution to detriment of the area and living conditions of residents

11.5	Traffic and Transportation
•	Traffic / Highway infrastructure issues: The existing motorway and local road network (A580, A572, Barton / Worsley Road, Walkden Road, Chaddock Lane, Leigh Road) are all heavily congested and at saturation point and very fragile. The proposed development (in particular the racecourse) will only add more traffic leading to more congestion-gridlock-chaos-more accidents-and danger to pedestrians
•	Challenge robustness of traffic modelling  
•	Traffic generation and capacity issues: Have to factor in other major developments in the area, e.g. Port Salford, Red City Developments and development on Trafford side- Chill Factor
•	No access should be allowed via Grange Road either for construction or operational vehicles
•	In an otherwise tranquil area significant increase in noise from road traffic/grandstand and use of racecourse
•	Find alternative vehicle access either from A580 away from houses and the M62
•	Parking will take place in residential areas to avoid paying and/or queues  
•	Inconvenience and disruption whilst accesses are constructed
•	Public transport links are poor
•	Nuisance for helicopters landing
•	A580 access point: needs landscaping and move further away from houses to reduce noise and visual impact
•	The racecourse parking on landfill sites will disturb the clay cap
•	Should make use of the railway line for access
•	J13 / A580 improvements will improve none race day traffic flows and pedestrian safety
•	Needs Metrolink in place
•	Congestion makes the area less competitive therefore less jobs and investment if congestion gets worse
•	Emergency evacuation proposals need to be submitted
•	Police presence on race days will not cope with the traffic
•	J13 and Courthouse roundabout improvements will deface the village
•	It will prevent any bypass of the M60 / M62 being considered and implemented

11.6	Visual Impact
•	Grandstand is an eyesore; very high and an incongruous feature
•	Canal bridge visual impact  
•	Spoil view

11.7	Impact on residential amenity 
•	Boothstown and Worsley will lose their unique identity  
•	Devalue property
•	Stray golf balls-danger to local residents and users of Leigh Road
•	Lead to more supporting development in the village

11.8	Economic 
•	Job creation
•	Jobs too remote from those most needy
•	Golf course should be affordable
•	Leisure activities will be beyond the financial means of local young people
•	The development will increase waste disposal and policing costs leading to increased community charge
•	Object to gambling

11.9	Miscellaneous 
•	Racecourse / golf course / hotel not needed
•	Increase in crime
•	Development incompatible with World Heritage status
•	Viability of Grange Farm affected by opening up public access; lead to vandalism and arson attacks; the proposed footpaths and bridle ways would use narrow tracks also used by farmers with no passing places and adjacent to deep dykes danger to public users and conflict with daily farm usage (heavy machinery). Open up farmland to trespass as not keep to paths and bridleways   
•	Eco village is an hotel by another name  
•	Place pressure on local hospitals
•	Excellent leisure facility for the area
•	Good for City's image

11.10	The responses below related to the May 2007 consultation period. In terms of the frequency, local resident’s main concerns relate to loss of or inappropriate use of the green belt, the impact that the development will have on congestion and road safety, traffic noise and pollution, impact on wildlife, and traffic impacts on Junction 13 of the M60. All responses received during the May 2007 consultation period are detailed below. 
 
11.11	Environment 
•	Need to protect the last open green space in Salford
•	Loss of and / or inappropriate use of Green Belt
•	Loss of farmland
•	Destruction of forest
•	Negative impact on onsite wildlife populations
•	Applicant has not fully investigated wildlife significance of Botany Bay Wood – birds
•	Development will encroach onto areas designated as Nature Areas and will be subsumed in to a massive retail / residential / leisure area
•	Disturbance of Kingfisher habitats
•	Disturbance to heron population
•	Proposed walkways across the heronry are inappropriate
•	Populations of buzzard, Tawny Owl in wood will be negatively effected 
•	Negative effect on the whole ecology of the area generally
•	Development and opening of the area for community use such as wildlife/equestrian centre, improved woodland area etc

11.12	Access 
•	The use of internal farm tracks as bridleways and cycle ways is incompatible with the existing farm usage bearing in mind the construction and constraints of those access tracks and would therefore be dangerous for the public to use them
•	Existing farm spine driveway is not sufficiently wide enough to accommodate traffic and bicycles and horse riders
•	Fencing track ways to effectively fence in horse riders / bicycle riders or footpath users will reduce the ability of farm vehicles to drive along the track
•	Loss of footpaths into Astley
•	Future proposed access arrangements to Moss House Farm via bridleway considered to be unacceptable 

11.13	Visual Impact
•	Height of Grandstand

11.14	Pollution
•	Significant increase in light pollution to detriment of the area and living conditions of residents
•	Traffic noise and pollution
•	Air pollution
•	Noise pollution from the racecourse and attendees
•	Unacceptable level of noise pollution on meet days
•	Noise impacts will be heard 1 mile away
•	Lighting on the roads will be much greater and will effect residents sleep
•	Impact on Air Quality
•	Concern with the air quality assessment on the site

Traffic and Transportation 
•	Additional traffic will exacerbate the existing traffic problems
•	Traffic impacts relating to congestion and road safety
•	Cumulative effect of all other developments in this area on road network
•	Access should be from M62
•	Increased traffic on the A580, A572 and M60 J13
•	There are only two points of access M60 junction and A580 / Chaddoock Lane junction
•	Development of the guided busway along the A580 will impede traffic flow
•	Proposed new road from Queens Arms on the A580 will change the rural character of the land between Boothstown and Astley
•	Concern that the road between the A580 and the Forest Park car park will be used not just on race days
•	Creation of an access road from East Lancs Road (A580)
•	Expected traffic generation will exacerbate the current situation in relation to A580 junctions at Chaddock Lane and Mosley Common Road and the roundabouts adjacent to Worsley Church
•	Congestion at J13 M60 exacerbated by proposed plans
•	Addition of one new additional road at J13 insufficient
•	Traffic impacts on Junction 13 - Dangerous queue length on slip road
•	The proposed construction at J13 will encroach upon the adjacent woodland
•	Traffic issues have not been resolved relating to Worsley turning (J13) off the M60 in a southerly direction
•	Adding an access to J13 will make things more complicated
•	Difficulty exiting Grange Road at weekends currently due to volume of traffic; parking on double yellow lines, high number of future HGV movements
•	Existing traffic impacts on Ellenbrook Road - congestion issues relating to rush hour.
•	Reduction of capacity for cars if one lane is used for buses
•	Traffic impacts relating to Barton Road and Worsley Road to access and egress the Forest Park on event days on Winton
•	Traffic impacts relating to East Lancs / Chaddock Lane / Leigh Road
•	Grange Road is an unsuitable access point
•	Impact of traffic / parking on Moorings Estate
•	Traffic using East Lancashire Road will be increased and drivers will use Old Clough Lane as a short cut for obtaining access to the racecourse and other local areas
•	Greatly increased traffic congestion affecting Worsley, Boothstown and immediate surrounding areas
•	Traffic lights on both roundabouts will not alleviate congestion / improve capacity / cause further safety problems
•	Impact of traffic on historic buildings
•	Issues with highways modelling
•	Number of car park spaces has increased to 7,200 vehicles from 6,500
•	Is building car parks on landfill sites safe?
•	Local streets used for parking and dangers associated with this / avoid parking costs e.g. Vicars Hall Lane, Bridgewater Canal
•	Road infrastructure is inadequate for traffic requirements
•	Development requires a Green Travel Plan
•	Inadequate public transport, development dependant on cars for access
•	Site only accessible by car. No good public transport routes / new ones are needed bus as a route has been taken away due to current levels of congestion
•	Improved access to the site
•	Traffic chaos won't be an issue; it will be a good neighbour

Residential Amenity 
•	Change the character of the Worsley Area
•	Massive impact on local residents
•	Noise disturbance of people leaving the site
•	The proposals outlined and the type of development is inappropriate for Boothstown / Worsley areas
•	Disruption and inconvenience to residents during construction phase.
•	Impact of helicopter use on local residents
•	Development will destroy Worsley's chance of becoming a World Heritage Site

Economic
•	New jobs will go to migrant workers
•	Employment opportunities created will be for low wage jobs only
•	Development will provide new jobs 
•	Development will bring money into Salford

Miscellaneous 
•	Use of racecourse facilities for alternative uses e.g. car boot sales, concerts etc, development not viable otherwise
•	Current scheme is not viable therefore may be used for residential or industrial uses in the future
•	Impact on the current sewage system - not able to cope
•	Area does not need a racecourse
•	Attendant facilities and golf course not needed
•	Problems with litter and fire if area is opened up to the public
•	Do not need more hotels
•	Impact of HGV's / earth moving equipment/dust and mud on the roads / construction noise
•	Potential loss of stable facilities at Moss House Farm
•	Land should be used for housing
•	An Anti-Aircraft Operations Room exists on site and should be protected
•	Impact of increased crime
•	Location of golf course is a danger to traffic, people and property
•	Equestrian centre will be for professionals only and will not provide anything to the local community
•	The development will be used for other activities other than those stated
•	Development will give nothing to Salford people
•	Issue of litter
•	There is a need for an all weather course
•	Development will raise the profile of Salford
•	Development will create recreation facilities

12.	PLANNING POLICY DOCUMENTS

12.1	National Planning guidance (Planning Policy Guidance- PPG / Planning Policy Statement - PPS) The Regional Spatial Strategy (RSS), Salford Unitary Development Plan (UDP) and Supplementary Planning Documents (SPD) have been used to provide the policy framework by which the application should be determined. The policies outlined below indicate the policies that will be considered in the determination of the application.  

12.2	Regional Spatial Strategy (adopted 30th September 2008)

DP1 – Spatial Principles
DP2 – Promote Sustainable Communities
DP7 – Promote Environmental Quality
RDF4 – Green Belts
W6 – Tourism and the Visitor Economy
W7 – Principles for Tourism Development
RT2 – Managing Travel Demand
RT9 – Walking and Cycling 
EM1 – Integrated Enhancement and Protection of the Region’s Environmental Assets
EM3 – Green Infrastructure
EM4 – Regional Parks

12.3	Other relevant planning documents

Regional Economic Strategy 2006 - North West Development Agency (January 2006)
The Strategy for Tourism in England’s North West 2003-2010 - Developing the Visitor Economy – North West Development Agency (Revised 2007)
Marketing the Natural Environment of the North West – North West Development Agency (February 2006)
The Agenda for Growth: The Regional Forestry Framework for England’s North West – North West Regional Forestry Framework (October 2005)
The Countryside in and Around Towns – Countryside Agency/Groundwork (January 2005)
Delivering a New Urban Fringe – Natural England (April 2006)
Salford Tourism Strategy – Salford City Council (November 2003)

12.4	Salford Unitary Development Plan (adopted 21st June 2006)

ST3 - Employment Supply
ST5 – Transport Networks
ST6 – Major Trip Generating Development
ST10 – Recreation Provision
ST11 – Location of New Development
ST13 – Natural Environmental Assets
ST15 – Historic Environment
ST17 – Mineral Resources
DES1 – Respecting context
DES2 – Circulation and Movement
DES6 – Waterside Development
DES9 – Landscaping
DES10 – Design and Crime
DES11 – Design Statements
E6 – Tourism Development
S2 – Retail and Leisure Development Outside Town Centres and Neighbourhood Centres
A1 – Transport Assessments and Travel Plans
A2 – Cyclists, Pedestrians and the Disabled
A8 – Impact of Development on the Highway Network
A10 – Provision of Car, Cycle and Motorcycle Parking in New Developments
EN1 – Development Affecting the Green Belt
EN3 – Agricultural Land
EN4 – Farm Diversification
EN8 – Nature Conservation Sites of Local Importance
EN10 – Protection of Species
EN11 – Mosslands
EN12 – Important Landscape features
EN17 – Pollution Control 
EN18 – Protection of Water Resources
EN19 – Flood Risk and Surface Water
EN23 – Environmental Improvement Corridors
CH5 – Archaeology and Ancient Monuments 
R2 – Provision of Recreation Land and Facilities
R3 – Regional Park
R5 – Countryside Access Network
R7 – Recreational Use of Waterways
DEV5 – Planning Conditions and Obligations
M1 – Protection of Mineral Resources

12.5	Salford Supplementary Planning Documents

Design and Crime (Adopted July 2006)
Trees and Development (Adopted July 2006)
Nature Conservation and Biodiversity (Adopted July 2006)
Planning Obligations (Adopted March 2007)
Sustainable Design and Construction (Adopted March 2008)
Design (Adopted March 2008)

12.6	National Statements and Guidance 

Planning Policy Statement 1 (PPS1): Delivering Sustainable Development (ODPM February 2005)
PPS1: Planning and Climate Change. Supplement to PPS1 (December 2007)
Planning Policy Guidance Note 2 (PPG2): Green Belts (DoE, January 1995)
PPG4: Industrial and Commercial Development and Small Firms (DoE, November 1992)
Consultation Paper on PPS4: Planning for Sustainable Economic Development (CLG, December 2007)
PPS6: Planning for Town Centres (ODPM, March 2005)
Proposed Changes to Planning Policy Statement 6: Planning for Town Centres Consultation (DCLG, July 2008)
PPS7: Sustainable Development in Rural Areas (ODPM, July 2004)
PPS9: Biodiversity and Geological Conservation (ODPM, August 2005)
PPG13: Transport (DETR, March 2001)
PPG15: Planning and the Historic Environment (DoE, September 1994)
PPG16: Archaeology and Planning (DoE, November 1990)
PPG17: Planning for Open Space, Sport and Recreation (ODPM, July 2002)
PPG24: Planning and Noise (DoE, September 1994)
PPS25: Development and Flood Risk (CLG, December 2006)
Good Practice Guide on Planning for Tourism (May 2006)
MPS1: Planning and Minerals (November 2006)

Regional Planning Policy

Spatial Principles

12.7	Policy DP1 sets out eight principles that underpin the RSS, and all other regional, sub-regional and local plans and strategies and all individual proposals, schemes and investment decisions should adhere to these eight principles as follows; promote sustainable communities; promote sustainable economic development; make the best use of existing resources and infrastructure; manage travel demand, reduce the need to travel, and increase accessibility; marry opportunity and need; promote environmental quality; mainstreaming rural issues; and reduce emissions and adapt to climate change.

12.8	Policy DP2 aims to promote sustainable communities to meet the diverse needs of existing and future residents, promote community cohesion and equality and diversity, be sensitive to the environment, and contribute to a high quality of life by integrating and phasing the provision public services (including lifelong learning) and facilities to meet the current and future needs of the whole community, ensuring that those services are conveniently located, close to the people they serve, and genuinely accessible by public transport; and by promoting physical exercise through opportunities for sport and formal / informal recreation, walking and cycling.

12.9	Policy DP7 indicates that environmental quality should be protected and enhanced by understanding and respecting the character and distinctiveness of places and landscapes; the protection and enhancement of the historic environment; promoting good quality design in new development and ensuring that development respects its setting taking into account relevant design requirements, the NW Design Guide and other best practice; reclaiming derelict land and remediating contaminated land for end-uses to improve the image of the region and use land resources efficiently; maximising opportunities for the regeneration of derelict or dilapidated areas; assessing the potential impacts of managing traffic growth and mitigating the impacts of road traffic on air quality, noise and health; promoting policies relating to green infrastructure and the greening of towns and cities; maintaining and enhancing the tranquillity of open countryside and rural areas; maintaining and enhancing the quantity and quality of biodiversity and habitat; ensuring that plans, strategies and proposals which alone or in combination could have a significant effect on the integrity and conservation objectives of sites of international importance for nature conservation are subject to assessment, this includes assessment and amelioration of the potential impacts of development (and associated traffic) on air quality, water quality and water levels.

Regional Spatial Framework

12.10	Policy RDF4 states that the overall general extent of the Region’s Green Belt will be maintained and that there is no need for any exceptional strategic change to Green Belt and its boundaries in the North West within Greater Manchester before 2011. After 2011 the presumption will be against exceptional substantial strategic change to the Green Belt in Greater Manchester. 

Working in the North West – Achieving a Sustainable Economy 

12.11	Policy W6 indicates that plans, strategies, proposals and schemes should seek to deliver improved economic growth and quality of life, through sustainable tourism activity in the North West. 

12.12	Policy W7 states that plans and strategies should ensure high quality, environmentally sensitive, well-designed tourist attractions, infrastructure and hospitality services, which improve the region’s overall tourism offer, increasing the market share of attractions; meet the needs of a diverse range of people and are easily accessible by sustainable means; support the provision of distinct tourism resources that harness the potential of sites and their natural attributes, including built heritage and cultural facilities; encourage and facilitate regeneration; promote facilities which will extend the existing visitor season; harness the potential of sport and recreation, particularly the role of major sporting events; improve the public realm; are viable in market and financial terms; help to relieve pressure on locations vulnerable to the impacts of climate change; respect the environmental sensitivity of the coast, particularly the undeveloped coast along with other sensitive areas, and ensure that the integrity of sites of international importance for nature conservation are maintained through assessment of proposals and through careful visitor management and restrictions on visitor access where necessary; promote eco-tourism in areas of high natural value in a way that minimises any adverse effect on the natural assets that visitors seek to experience.

12.13	The maintenance and enhancement of existing tourism development will be supported, providing that improvement, intensification and expansion proposals meet environmental and other development control criteria.

Transport in the North West – Connecting People and Places

12.14	Policy RT2 indicates that plans and strategies should incorporate maximum parking standards that are in line with, or more restrictive than those outlined in table 8.1, and define standards for additional land use categories and areas where more restrictive standards should be applied. Parking for disabled people and for cycles and two-wheel motorised vehicles are the only situations where minimum standards will be applicable.

12.15	Policy RT9 indicates that Local Authorities should work with partners to develop integrated networks of continuous, attractive and safe routes for walking and cycling to widen accessibility and capitalise on their potential environmental, social and health benefits. Local authorities should ensure that proposals and schemes for new developments incorporate high quality pedestrian and cycle facilities, including secure cycle parking. Routes should connect with those in nearby developments, and provision of all facilities should take into consideration integration with likely future development. When considering improvements to the region’s transport networks, scheme promoters should take the opportunity to enhance walking and cycling provision, including crossings, signage, lane markings, allocation or re-allocation of road space, and off-road routes wherever possible.

Environment, Minerals, Waste and Energy 

12.16	Policy EM1 indicates that the Region’s environmental assets should be identified, protected, enhanced and managed. Plans, strategies, proposals and schemes should deliver an integrated approach to conserving and enhancing the landscape, natural environment, historic environment and woodlands of the region. Where proposals and schemes affect the region’s landscape, natural or historic environment or woodland assets, prospective developers and/or local authorities should first avoid loss of or damage to the assets, then mitigate any unavoidable damage and compensate for loss or damage through offsetting actions with a foundation of no net loss in resources as a minimum requirement.

12.17	Plans, strategies, proposals and schemes should identify, protect, maintain and enhance natural, historic and other distinctive features that contribute to the character of landscapes and places within the North West.

12.18	Plans, strategies, proposals and schemes should secure a ‘step-change’ increase in the region’s biodiversity resources by contributing to the delivery of national, regional and local biodiversity objectives and targets for maintaining extent, achieving condition, restoring and expanding habitats and species populations. This should be done through protecting, enhancing, expanding and linking areas for wildlife within and between the locations of highest biodiversity resources, including statutory and local wildlife sites, and encouraging the conservation and expansion of the ecological fabric elsewhere.

12.19	Plans, strategies, proposals and schemes should: support the aims and priorities of the North West Regional Forestry Framework and sub-regional forestry strategies; encourage a steady targeted expansion of tree and woodland cover and promote sustainable management of existing woodland resources to enable the delivery of multiple benefits to society; support the continued role of community forestry; identify and protect ancient semi-natural woodland and veteran trees.

12.20	Policy EM3 states that plans, strategies, proposals and schemes should aim to deliver wider spatial outcomes that incorporate environmental and socio-economic benefits by: conserving and managing existing green infrastructure; creating new green infrastructure; enhancing its functionality, quality, connectivity and accessibility.

12.21	Policy EM4 states that there are three areas of search for Regional Parks; The North West Coast; The Mersey Basin; and East Lancashire. A strategic framework will be developed by the NWRA and partners and this will set out an assessment of assets, opportunities, functions and potential to meet overall objectives of regional parks; provide a broad vision and objectives; and outline guiding principles for projects being promoted within its area of search. The policy indicates that plans and strategies should have regard to the Strategic Frameworks and for each specific regional park it should identify the locations and boundaries; and secure successful delivery and management arrangements.    

Local Planning Policy

12.22	The UDP includes a Spatial Framework for the city, which recognises that the opportunities and the need for development, regeneration and environmental protection vary in their scale and nature across the city. The Spatial Framework splits the city into five sub-areas. The application is located within the “Urban Fringe and Countryside” area, where an emphasis is placed on the protection and sustainable use of the city’s open land resource. This area accounts for nearly a third of Salford’s land area, and is a major environmental asset of ecological, landscape, recreation and agricultural importance. The area incorporates the Green Belt and other areas of open land such as the Worsley Greenway and country parks. This area of land is protected from inappropriate development, whilst maximising its environmental, economic and social benefits for the city. A strong emphasis is placed on developing the area’s recreation potential, linking this to the regeneration of surrounding areas, to ensure that the city’s residents have good access to a wide range of recreation opportunities. The development of the Regional Park concept is supported, with eight key recreational areas identified. Despite this the UDP will ensure that the essential character and environmental quality of the Urban Fringe and Countryside is protected, particularly in terms of its openness, landscape, and wildlife value. 

Strategic Policies 

12.23	Policy ST3 relates to employment supply and requires that a good range of local employment opportunities will be secured by enabling the diversification of the local economy and by using planning obligations to secure local labour contracts and training opportunities.

12.24	Policy ST5 states that transport networks will be maintained and improved through a combination of measures including the extension of the network of pedestrian and cycling routes; the expansion and improvement of the public transport system and the enhancement of support facilities; the maintenance and improvement of the highway network; the provision of new road infrastructure where this will support the city's economic regeneration; requiring development proposals, highway improvement schemes and traffic management measures to make adequate provision for the needs of the disabled, pedestrians and cyclists, and, wherever appropriate, maximise the use of public transport; and the protection and enhancement of rail and water-based infrastructure to support the movement of freight and passengers. 

12.25	Policy ST6 states that development that would generate major travel demand will only be permitted in locations that are currently, or will as a result of the development be, well served by a choice of means of transport.

12.26	Policy ST8 confirms that development will be required to contribute towards enhanced standards of environmental quality through the achievement of high standards of design, amenity, safety and environmental maintenance and management.

12.27	Policy ST10 seeks to provide a comprehensive range of accessible recreation opportunities through a number of means. The policy highlights seven opportunities; 1) through the protection, improvement and reorganisation of existing recreation sites; 2) through the development of a regional park; 3) through developing a network of Key Recreation Areas; 4) through the provision of new recreation facilities on sites allocated for this purpose in the UDP; 5) through the development of a series of Local Nature Reserves; 6) through improvement of access between urban areas and the Countryside, in particular through the network of existing and proposed Strategic Recreation Routes; 7) through the use of planning obligations to provide new and enhanced recreation facilities. This policy is underpinned by a comprehensive audit of urban open space carried out in 2001/2, and a playing pitch assessment carried out for sports pitches in 2000/1 

12.28	Policy ST11 seeks to ensure that new development is located on the most sustainable sites within the city and that less sustainable sites are only brought forward where necessary. This approach is in line with Policy DP1 of the RSS and requires that sites for development will be brought forward in the following order: 1) The re use and conversion of existing buildings; 2) Previously-developed land in locations that i) are, or as part of any development would be made to be, well-served by a choice of means of transport, particularly walking, cycling and public transport; and ii) Are well related to housing, employment, services and infrastructure; 3) Previously-developed land in other locations, provided that adequate levels of accessibility and infrastructure provision could be achieved; 4) Previously undeveloped land in locations that i) Are, or as part of any development would be made to be, well-served by a choice of means of transport, particularly walking, cycling and public transport; and ii) Are well related to housing, employment, services and infrastructure.

12.29	Policy ST13 states that development that would result in an unacceptable impact on any of the city's natural environmental assets will not be permitted. The reasoned justification for this policy conforms that the city contains many assets which contribute towards its overall biodiversity and natural environmental quality, which include the Mosslands, Sites of Biological Importance, wildlife corridors, and other areas that are or could become important for wildlife; the city's many water features such as the River Irwell, streams, reservoirs, lakes and ponds; extensive areas of trees and woodlands; and large tracts of best and most versatile agricultural land. These assets are worthy of protection in their own right and it is important that they should not be unnecessarily lost or damaged as a result of development.

12.30	Policy ST15 states that historic and cultural assets that contribute to the character of the city will be preserved and wherever possible and appropriate, enhanced. 

12.31	Policy ST17 states that known mineral resources will be safeguarded and their exploitation will only be permitted where there are no appropriate secondary sources and the environmental impact of the mineral workings is minimised. An adequate supply of aggregates will be maintained. 

Design 

12.32	Policy DES1 requires development to respond to its physical context, respect the positive character of the local area in which it is situated, and contribute towards local identity and distinctiveness. In assessing the extent to which any development complies with this policy, regard will be had to a number of factors including the impact on, and relationship to, the existing landscape and any notable landscape or environmental feature or species; the impact on, and quality of, views and vistas; the scale of the proposed development in relationship to its surroundings; the potential impact of the proposed development on the redevelopment of an adjacent site; and the functional compatibility with adjoining land uses.

12.33	Policy DES2 states that the design and layout of new development will be required to ensure that the development is fully accessible to all people, including the disabled and others with limited or impaired mobility; maximise the movement of pedestrians and cyclists to, through and around the site, through the provision of safe and direct routes; enable pedestrians to orientate themselves, and navigate their way through an area by providing appropriate views, vistas and visual links; enable safe, direct and convenient access to public transport facilities, and other local amenities such as retail and community facilities, including where appropriate the incorporation of a bus route or turning facility within the site; and minimise potential conflicts between pedestrians, cyclists and other road users, for example by incorporating speed reduction measures and through the careful design of car parking areas.

12.34	Policy DES6 requires that all new development adjacent to the Bridgewater Canal will be required to facilitate pedestrian access to, along and, where appropriate, across the waterway by the provision of: 1) A safe, attractive and overlooked waterside walkway, accessible to all and at all times of the day, where this is compatible with the commercial role of the waterway; 2) Pedestrian links between the waterside walkway and other key pedestrian routes; and 3) Where appropriate, ground floor uses that generate pedestrian activity, and larger waterside spaces to act as focal points for public activity. Where the commercial role of the waterway makes it inappropriate to provide a waterside walkway, an alternative route shall, where possible, be provided. Such a route should be well designed and effective; accessible and safe for users and, so far as practicable, near to the waterside; and linked to any existing waterside walkways and other key pedestrian routes. This policy also requires development to protect, improve or provide wildlife habitats (where possible); to conserve and complement any historic features (where possible); to maintain, and preferably enhance, waterside safety; and not affect the maintenance or integrity of the waterway or flood defences. The policy also requires all built development along the waterway to face onto the water, and incorporate entrances onto the waterfront (where appropriate); be of the highest standard of design, creating a positive addition to the waterside environment and providing an attractive elevation to it; be of a scale sufficient to frame the edge of the waterside; and enhance views from, of, across and along the waterway, and provide visual links to the waterside from surrounding areas. 

12.35	Policy DES9 requires developments to incorporate appropriate hard and soft landscaping provision, where appropriate. And that where landscaping is required as part of a development, it must be of a high quality in terms of design and materials; reflect and enhance the character of the area and the design of development; be sited and designed so as not to detract from the safety and security of the area, create an obstruction to pedestrians, or detract from attractive built features; be designed to complement or form an integral part of the development; be easily maintained, and have provision made for its maintenance; respect adjacent land uses, buildings and other structures; and wherever possible make provision for the creation of new wildlife habitats.

12.36	Policy DES10 states that development will not be permitted unless it is designed to discourage crime, anti-social behaviour and the fear of crime, and support personal and property security. In particular, development should clearly delineate public, communal, semi-private and private spaces, avoiding ill-defined or left over spaces; allow natural surveillance, particularly of surrounding public spaces, means of access, and parking areas; avoid places of concealment and inadequately lit areas; and encourage activity within public areas. Crime prevention measures should not be at the expense of the overall design quality, and proposals will not be permitted where they would have a hostile appearance or engender a fortress-type atmosphere.

12.37	Policy DES11 requires all applicants to submit a design statement for all major proposals and development that could impact on a sensitive location. The applicant in these instances will be required to demonstrate how their development takes account of need for good design. 

Employment and the Economy 

12.38	Policy E6 sets out a six point criteria associated with tourism development. Permission will be granted providing that 1) the site is accessible by a choice of means of transport, 2) the development would not have an unacceptable impact on the highway network, 3) the development would not have an unacceptable impact on any existing tourism asset, 4) the development would not have an unacceptable impact on residential amenity, 5) the development achieves a high standard of design appropriate to its context, 6) the development is consistent with other policies and proposals of the UDP.  

Retail and leisure development 

12.39	Policy S2 states that planning permission will only be granted for retail and leisure where it can be clearly demonstrated that: there is a quantitative and, where appropriate, qualitative need for the development; there are no more appropriate sites or buildings available; there would be no unacceptable impact on the vitality and viability of any town or neighbourhood centre; the site will be well served by a choice of means of transport; the development would not give rise to unacceptable levels of traffic congestion; the development would be of an appropriate scale; the development would be of a high standard of design; and that the development would not have an unacceptable impact on environmental quality or residential amenity.

Accessibility 

12.40	Policy A1 states that planning applications for developments likely to give rise to significant transport implications will not be permitted unless they are accompanied by a transport assessment and, where appropriate, a travel plan. Developers will be required to undertake or secure the implementation of any mitigation measures identified in a transport assessment, as well as any other measures considered necessary to achieve an acceptable level of accessibility by public transport, cycling and walking, in accordance with Policy DEV5 (Planning Conditions and Obligations).

12.41	Policy A2 requires that development proposals, road improvement schemes and traffic management measures will all be required to make adequate provision for safe and convenient access by the disabled, other people with limited or impaired mobility, pedestrians and cyclists. The policy also requires that development that would result in the diversion or extinguishment of an existing public right of way will only be permitted where it can be demonstrated that adequate levels of access for the disabled, pedestrians and cyclists will be maintained to, around, and where appropriate, through the site; and in the case of a public right of way that forms part of the city’s Countryside Access Network, the proposal fully accords with Policy R5 of this UDP.

12.42	Policy A8 states that development will not be permitted where it would have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation, access, parking or servicing arrangements.

12.43	Policy A10 requires development to make adequate provision for disabled drivers, cyclists and motorcyclists, in accordance with the council’s maximum standards. It also states that the maximum car parking standards should not be exceeded.

Environmental Protection and Improvement 

12.44	Policy EN1 relates to development affecting Green Belt. The policy states that the carrying out of engineering and other operations and the making of material changes in the use of land are inappropriate development unless they maintain openness and do not conflict with the purposes of including land in the Green Belt. Planning permission will not be granted for development within or conspicuous from the Green Belt that might be visually detrimental by reason of its siting, materials, or design, even where it would not prejudice the purposes of including land in the Green Belt. Planning permission will be granted for the working of minerals, provided that high environmental standards are maintained, the affected sites are well restored, and the development is consistent with other policies and proposals of the Plan.

12.45	Policy EN3 states that development that would involve the loss of the best and most versatile agricultural land (Grades 1, 2 or 3a) will only be permitted where it can be demonstrated that there are no appropriate alternative sites available on lower grade agricultural land or on non-agricultural land.

12.46	Policy EN4 outlines 6-point criteria for proposals involving the diversification of farms into non-agricultural activities. The policy indicates that proposals will be permitted where 1) a contribution is made to sustainable development objectives of the UDP, 2) the development helps to sustain rather than replace agricultural enterprise, 3) the development is consistent in their scale with their rural location, 4) the development will not result in excessive expansion and encroachment of built development into the countryside, 5) the development results in the reuse or replacement of existing buildings where feasible, 6) the development  would not have an unacceptable impact on the amenity of nearby residents, other rural businesses, or recreational users of the area. 

12.47	Policy EN8 relates to nature conservation sites of local importance and states that development that would adversely affect the nature conservation value of a Site of Biological Importance, a Local Nature Reserve, or a priority habitat for Salford as identified in the Greater Manchester Biodiversity Action Plan, will only be permitted where the benefits of the development clearly outweigh the reduction in the nature conservation interest for which the site is protected or identified as a priority habitat; the detrimental impact on the nature conservation interest of the site has been minimised as far as is practicable; and appropriate mitigation is provided to ensure that the overall nature conservation interest of the area is not diminished. Where appropriate, conditions or planning obligations will be used to ensure the protection, enhancement and management of the nature conservation interest of these sites and habitats.

12.48	Policy EN9 states that development that would affect any land that functions as a wildlife corridor, or that provides an important link or stepping stone between habitats, will not be permitted where it would unacceptably impair the movement of flora and fauna. Where development is permitted, conditions or planning obligations may be used to secure the protection, enhancement and/or management measures designed to facilitate the movement of flora and fauna across or around the site.

12.49	Policy EN10 states that development proposals will only be permitted where mitigation measures are put into place for developments likely to have an adverse impact on legally protected species. Mitigation measures will be expected to maintain the population level of the species at a favourable conservation status within it natural range. If the proposed development was to adversely affect a European protected species, it will need to be demonstrated that 1) there is no satisfactory alternative, in terms of the form of, or location for the development, that would have a lesser negative impact on the species; and 2) there are imperative reasons for the development of overriding public interest. 
 
12.50	Policy EN11 relates to development in the Mosslands. Development on land that cannot practicably be restored to lowland raised bog habitat will be permitted provided it would not prevent the restoration of other land to that habitat. In every case, the overall nature conservation interest of the Mosslands will be maintained.

12.51	Policy EN12 states that development that would have a detrimental impact on, or result in the loss of, any important landscape feature will not be permitted unless the applicant can clearly demonstrate that the importance of the development plainly outweighs the nature conservation and amenity value of the landscape feature and the design and layout of the development cannot reasonably make provision for the retention of the landscape feature. Landscape features include, amongst other things, trees (single or grouped), copses, woodland, hedges, ponds, streams, ditches and lakes. Such features play a vital part in creating an attractive and pleasant environment for the people of Salford, and help to support an abundance of wildlife. If the removal of an important existing landscape feature is permitted as part of a development, a replacement of at least equivalent size and quality, or other appropriate compensation, will be required either within the site, or elsewhere within the area.

12.52	Policy EN16 states that development proposals on sites known or thought to be contaminated will require the submission of a site assessment as part of any planning application, identifying the nature and extent of the contamination involved, the risk it poses to future users/occupiers of the site, and the practical remedial measures proposed to deal with the contamination. Planning permission for development on or near to contaminated land will only be granted where the development would not expose the occupiers of the development and neighbouring land uses to unacceptable risk; lead to the contamination of any watercourse, water body, or aquifer; or cause the contamination of adjoining land or allow such contamination to continue. Remedial measures agreed as part of any planning permission will be required to be completed as the first step of the development.

12.53	Policy EN17 stipulates that development proposals that would be likely to cause or contribute towards a significant increase in pollution to the air (including dust pollution), water or soil, or by reason of noise, odour, artificial light or vibration, will not be permitted unless they include mitigation measures commensurate with the scale and impact of the development. When assessing such proposals, particular regard will be had to the proximity of the development and its effect upon environmentally sensitive uses, buildings, features, areas and considerations, such as housing. Consideration will also be given to the cumulative effect of pollution, having regard to the effects of existing sources of pollution and any balancing benefits of the development. In areas where existing levels of pollution exceed local or national standards, planning permission will be granted for environmentally sensitive developments only where the development incorporates adequate measures to ensure that there is no unacceptable risk or nuisance to occupiers, and that they are provided with an appropriate and satisfactory level of amenity.

12.54	Policy EN18 states that development will not be permitted where it would have an unacceptable impact on surface or ground water in terms of its quality, level or flow.

12.55	Policy EN19 states that development, including the alteration of land levels, will not be permitted where it would be subject to an unacceptable risk of flooding; materially increase the risk of flooding elsewhere; or result in an unacceptable maintenance liability for the City Council or any other agency in terms of dealing with flooding issues. In determining the potential impact of the proposed development on the risk of flooding elsewhere, particular regard will be had to the extent to which the development is located within or impacts upon a functional floodplain or floodzone; incorporates protection, attenuation or mitigation measures, and the use of source control techniques and sustainable drainage systems; and provides adequate access to watercourses for maintenance purposes. Development will not be permitted unless adequate provision is made for the discharge of foul and surface water associated with the proposal.

12.56	Policy EN23 states that development along any of the city’s major road, rail and water corridors will be required to preserve, or make a positive contribution to the corridor’s environment and appearance. In determining the extent to which a development would achieve this, regard will be had in particular to the quality of design and landscaping, particularly in terms of elevational treatments and the impact on views; the impact on the quality, management and maintenance of the public realm; the contribution that would be made towards air quality improvement and accessibility, particularly by promoting improved public transport and access by foot and cycle; and the extent to which wildlife habitats are protected and improved.

The City’s Heritage 

12.57	Policy CH5 states that where planning permission is granted for development that will affect known or suspected remains of local archaeological value, planning conditions will be imposed to secure the recording and evaluation of the remains and if appropriate their excavation and preservation and/or removal prior to the commencement of development.

Recreation 

12.58	Policy R2 indicates that planning permission for recreational development will be granted unless the development would have an unacceptable impact on residential amenity, have an unacceptable impact on highway safety, fail to make provision for cyclists, pedestrians and disabled people, have an unacceptable impact on the quiet enjoyment of the countryside, have an unacceptable impact on sites or features or archaeological ecological, geological or landscape value, or have an unacceptable impact on existing recreational facilities. The policy seeks to ensure that all households are within set distances of a range of facilities, and that there is at least 0.73ha of high quality managed sports pitches per 1,000 population, 0.25ha of equipped children’s playspace per 1,000 population, and adequate amenity open space.

12.59	Policy R3 indicates that a Strategic Regional Park will be established with the Countryside and Urban Fringe of Salford and the Irwell Valley. Any contribution made to the achievement of this aim will be considered as a material consideration in the determination of proposals within it. Development which would unacceptably prevent or inhibit the achievement of those objectives will not be permitted. 

12.60	Policy R5 relates to the Countryside Access Network. This policy states that planning permission will not be granted for development that would result in the permanent obstruction or closure of any part of the Countryside Access Network, unless an alternative route is provided that is equally attractive and convenient. New development that is proposed on a site needed for the provision of a new route or link as part of the Countryside Access Network will be required to incorporate that route/link as part of the development.

12.61	Policy R7 states the cities waterways will be developed for recreational and leisure uses so long as developments maintain high levels of personal safety and security, they do not have an unacceptable impact on any commercial use of the waterway, and they maximise public accessibility to the waterway and the associated recreation and leisure opportunities.  

Development 

12.62	Policy DEV5 states that development that would have an adverse impact on any interests of acknowledged importance, or would result in a material increase in the need or demand for infrastructure, services, facilities and/or maintenance, will only by granted planning permission subject to planning conditions or planning obligations that would ensure adequate mitigation measures are put in place.

Minerals

12.63	Policy M1 states that known mineral resources that are, or could realistically in the future be, capable of being worked in accordance with Policy M2 will be protected from sterilisation by other forms of development. Where a development could sterilise such resources, planning permission will only be granted if the extraction of the mineral resource is secured prior to development.

National Statements and Guidance

PPS1: Delivering Sustainable Development 

12.64	PPS1 states that sustainable development is the core principle underpinning planning. Planning should facilitate and promote sustainable and inclusive patterns of urban and rural development by: making suitable land available for development in line with economic, social and environmental objectives to improve people’s quality of life; contributing to sustainable economic development; protecting and enhancing the natural and historic environment, the quality of the countryside and existing communities; ensuring high quality development; and supporting existing communities and contributing to the creation of safe, liveable and mixed communities with good access to jobs and key services for all. On sustainable economic development, local authorities should recognise that economic development can deliver environmental and social benefits; that they should also recognise the wider sub regional and regional economic benefits and that these should be considered alongside any adverse local impacts.

PPS1: Planning and Climate Change. Supplement to Planning Policy Statement 1 (December 2007)

12.65	On the 18th of December 2007 the Government published this PPS supplement which sets out how planning should contribute to reducing emissions and stabilising climate change and take into account the unavoidable consequences. Tackling climate change is a key Government priority for the planning system and applicants for planning permission should now consider how well their proposals for development contribute to the Government’s ambition of a low-carbon economy and how well adapted they are for the expected effects of climate change. Planning Authorities should ensure proposed development is consistent with the policies in this PPS and should avoid placing requirements on applicants that are inconsistent. Planning has a key role in achieving a number of key planning objectives. Planning Authorities are now required to adhere to a number of principles in determining planning applications as follows; controls under the planning, building control and other regulatory regimes should complement and not duplicate each other; information sought should be proportionate to the scale of the proposed development, its likely impact on and vulnerability to climate change and be consistent with that needed to demonstrate conformity with the development plan and this PPS; Specific and standalone assessments of new development should not be required where the requisite information can be made available to the planning authority through the submitted Design and Access Statement or forms part of any environmental impact assessment or other regulatory requirement; and the planning authorities should have regard to this PPS as a material consideration, which may supersede the policies in the development plan. Any applicant for planning permission to develop a proposal that will contribute to the delivery of the Key Planning Objectives should expect expeditious and sympathetic handling of the planning application.  

PPG2: Green Belts (DoE, January 1995)

12.66	The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. Green Belts can shape patterns of urban development at sub-regional and regional scale, and help to ensure that development occurs in locations allocated in development plans. There are five purposes of including land in Green Belts: 

•	To check the unrestricted sprawl of large built-up areas;
•	To prevent neighbouring towns from merging into one another;
•	To assist in safeguarding the countryside from encroachment;
•	To preserve the setting and special character of historic towns; and
•	To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

12.67	Once Green Belts have been defined, the use of land in them has a positive role to play in fulfilling the following objectives: 

•	to provide opportunities for access to the open countryside for the urban population; 
•	to provide opportunities for outdoor sport and outdoor recreation near urban areas; 
•	to retain attractive landscapes, and enhance landscapes, near to where people live; 
•	to improve damaged and derelict land around towns; 
•	to secure nature conservation interest; and 
•	to retain land in agricultural, forestry and related uses. 

12.68	There is a general presumption against inappropriate development within Green Belts and such development should not be approved, except in very special circumstances. Paragrapgh 3.2 clearly states that, “Inappropriate development is, by definition, harmful to the Green Belt. It is for the applicant to show why permission should be granted. Very special circumstances to justify inapproproate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. In view of the presumption against inappropriate development, the Secretary of State will attach substantial weight to the harm to the Green Belt when considering any planning application or appeal concerning such development. The visual amenities of the Green Belt should not be injured by proposals for development within or conspicuous from the Green Belt which, although they would not prejudice the purposes of including land in Green Belts, might be visually detrimental by reason of their siting, materials or design.

PPG4: Industrial and Commercial Development and Small Firms (DoE, November 1992)

12.69	The information contained within this guidance note encourages continued economic growth, compatible with environmental objectives. Policies should provide for choice, flexibility and competition. The guidance states that Local Authorities should aim to ensure that there is sufficient land to meet needs and which is readily capable of development and well served by infrastructure. There should be a variety of sites and sufficient choice to meet differing business and industrial needs. Development plans should also encourage the development of sites in locations which minimise car journeys, congestion and environmental impact, and which offer opportunities of alternative modes of transport. 

Consultation Paper on PPS4: Planning for Sustainable Economic Development (CLG, December 2007)

12.70	On the 18th of December 2007 the Government published a consultation paper on a new Planning Policy Statement 4. This draft aims to build on the objectives for the planning system set out in PPS1: Delivering Sustainable Development and to provide the tools to plan effectively and proactively for the economic growth needed to help create and maintain sustainable communities. The Statement indicates that Local Authorities should adopt a positive and constructive approach towards proposals for economic development, operating within the context of the plan-led system. When considering development proposals, Local Planning Authorities are required to; adopt an evidence- based approach to proposals which do not have the specific support of plan policies; consider proposals favourably unless there is good reason to believe that the economic, social, and/or environmental costs of development are likely  to outweigh the benefits; ensure they take full account of the longer-term benefits as well as the costs pf development such as job creation or improved productivity, including wider benefits to national, regional or local economies.  

PPS6: Planning for Town Centres (ODPM, March 2005)

12.71	The Government’s key objective for town centres is to promote their vitality and viability by: planning for the growth and development of existing centres; and promoting and enhancing existing centres by focussing development in such centres and encouraging a wide range of services in a good environment, accessible to all. . There are other Government objectives which need to be taken account of in the context of the key objectives highlighted above, namely: enhancing consumer choice by making provision for a range of shopping, leisure, and local services which allow genuine choice to meet the needs of the entire community, and particularly socially excluded groups; supporting efficient, competitive and innovative retail, leisure and other sectors with improving productivity; and improving accessibility, ensuring that existing or new development is ,or will be accessible and well served by a choice of means of transport.  In considering planning applications for developments that include main town centre uses the following main policy considerations apply: the need for the development; securing an appropriate scale of development; applying the sequential approach to site selection; assessing impact and ensuring locations are accessible.

Proposed Changes to Planning Policy Statement 6: Planning for Town Centres Consultation (DCLG, July 2008)

12.72	Published for consultation on 10th July 2008 for a 12-week period. The guidance retains the town center first approach, although the changes reflect the recommendations in various recent publications, including Kate Barkers Review of land Use Planning and 2007’s Planning White Paper. The proposals reinforce the town centre first approach to ensure that development continues to take place in town centers and promote the vitality and viability and character. The sequential test is retained, however new proposals are set out that remove the ‘need test’ for proposals outside town center and introduce a new and broader impact test to take better account of economic, social and environmental factors. The proposals link design quality and climate change considerations to the impact test, ensuring that developments are better designed and greener. The policy continues to reinforce the principle that development should be accessible by a range of transport modes; that it should promote greater consumer choice and retail diversity; and that it should encourage investment and job creation in disadvantaged areas.  

PPS7: Sustainable Development in Rural Areas (ODPM, July 2004)

12.73	PPS7 sets out the Governments planning policies for rural areas, including country towns and villages and the wider, largely undeveloped countryside up to the fringes of larger urban areas. Guidance is provided relating to the location of new development beyond urban areas. The statement places a focus on local services centres and the maintenance of vitality and viability of smaller towns and villages. Encouragement is given to Local Authorities to be supportive of small-scale development where it provides the most sustainable option in villages that are remote from, or have poor transport links with service centres. Support should be given to a wide range of economic activities in rural areas especially in areas of decline. Support should be provided for employment and economic regeneration. People living in rural areas should have decent access to a range of services and facilities. The retention of existing facilities should be supported through development plan polices. Details are provided within the guidance relating to guidance for residential development, and countryside designations. Farm diversification is supported through the guidance, and it is recognised that non-agricultural activities are vital to the continuing viability of many farm enterprises. In Green Belt locations diversification should be supported as long as the proposals does not conflict with the purposes of including land within the Green Belt. Where the proposal would result in ‘inappropriate development’ the Statement considers that the wider benefits may contribute to the ‘very special circumstance’ required by PPG2 to justify the grant of planning permission. In relation to tourism the statement recognises the important potential role that tourism can play in the rural economy. The guidance encourages Local Authorities to provide policies that support such proposals, whilst recognising the need to protect the countryside and encouraging the principles of sustainable development. Tourist accommodation should be provided within or adjacent to existing towns and villages. In rural areas, where a demand can be demonstrated, the re-use of rural buildings will be supported. 

PPS9: Biodiversity and Geological Conservation (ODPM, August 2005)

12.74	The Government’s objectives for planning are to promote sustainable development; to conserve, enhance and restore the diversity of England’s wildlife and geology and to contribute to rural renewal and urban renaissance. Key principles of PPS9 require that planning decisions are based on up to date information about the environmental characteristics of the area; policies and planning decisions should aim to maintain, and enhance, restore or add to biodiversity and geological conservation interests. In taking decisions appropriate weight should be attached to designated sites of international, national and local importance; protected species; and to biodiversity and geological interests in the wider environment. Plan policies on the form and location of development should take a strategic view on nature conservation enhancement and restoration of biodiversity. Beneficial biodiversity and geological features should be incorporated into the design of development. The aim of planning decisions should be to prevent harm to biodiversity and geological conservation interests. Where planning permission would result in harm to those interests local planning authorities will have to be satisfied that the development cannot reasonably be located on any alternative sites that would result in less or no harm. In the absence of no alternatives adequate mitigation measures should be put in place. Where a planning decision would result in significant harm to biodiversity, which cannot be prevented or adequately mitigated appropriate compensation measures should be sought. Failing this permission should be refused. On specific points PPS9 advises that the reuse of previously developed land for new development makes a significant contribution to sustainable development. However where such sites have significant biodiversity interests of recognised local importance the aim should be to retain this interest or incorporate it into any development of the site. On protected species planning authorities should protect such species from the adverse effects of development where appropriate by using conditions or obligations. Permission should be refused where harm to the species or habitat would result unless the need for and benefits of the development clearly outweigh that harm.

PPG13: Transport (DETR, March 2001)

12.75	The main objective of this guidance is to promote more sustainable transport choices for both people and for moving freight. It aims to promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling and reduce the need to travel by car. For retail and leisure policies should seek to promote the vitality and viability of town centres, which should be the preferred locations for new retail and leisure development. Preference should be given first to town centres then edge of centre and then on out of centre sites in locations which are (will be) well served by public transport.

PPG15: Planning and the Historic Environment (DoE, September 1994)

12.76	Requires authorities considering applications for planning permission which affect a listed building to have special regard to certain matters, including the desirability of preserving the setting of the building. The setting is often an essential part of the building's character, especially if a garden or grounds have been laid out to complement its design or function.

PPG16: Archaeology and Planning (DoE, November 1990)

12.77	This guidance sets out the Government’s policy on archaeological remains on land and how they should be preserved or recorded. It presumes in favour of preservation, especially where nationally important remains exist. However, it acknowledges that cases involving remains of lesser importance will not always be so clear cut. It advises that local planning authorities will need to weigh the relative importance of archaeology against the need for the proposed development.

PPG17: Planning for Open Space, Sport and Recreation (ODPM, July 2002)

12.78	This guidance reinforces the Governments objective to promote accessibility to good quality sports and recreational facilities, highlighting the potential for such facilities to provide opportunities for social inclusion and community cohesion. In terms of stadia and major sports development, proposals which will accommodate large numbers of spectators, or which will also function as a facility for community based sports and recreation should only be granted where they are located in areas with good access to public transport. PPG17 also requires local planning authorities to give very careful consideration to any planning application that involves development on playing fields. It recognises that development on playing fields can be permissible where replacement provision is made. 
 
PPS23: Planning and Pollution Control (ODPM, 2004)

12.79	Advises that any consideration of the quality of land, air and water and potential impacts arising from development, possibly leading to impacts on health, is capable of being a material planning consideration, in so far as it arises or may arise from or may affect any land use. The planning system plays a key role in determining the location of development which may give rise to pollution and in ensuring that other uses and developments are not affected by major existing or potential sources of pollution. The presence of pollution in land can present risks to human health and the environment but development presents opportunity to deal with these risks successfully. Appendix A to the PPS lists a number of matters that may be material in the consideration of planning applications where pollution considerations arise and include: the possible impact of potentially polluting development on land use, including effect on health, the natural environment or general amenity; the sensitivity of the area to the adverse effect of pollution; the environmental benefits that the development may bring such as resulting reductions in the need to travel, accompanying improvements to transport infrastructure, restoration of former habitats, enhancement or creation of habitats and the remediation of past contamination; the economic and wider social need for development such as the creation of new jobs; the existing and likely future air quality in an area (including AQMAs); the need for compliance with any statutory environmental quality standards or objectives (air quality); the possible adverse impacts on water quality; existing action and management plans with a bearing on environmental quality (air quality area action plans) and the need to limit and where possible reduce the adverse impact of light pollution.

PPG24: Planning and Noise (DoE, September 1994)

12.80	The impact of noise can be a material planning consideration. PPG24 recognises that it is hard to reconcile some land uses with housing and some other activities which generate high levels of noise but stresses that wherever practicable noise generating development are separated from major sources of noise. Development involving noisy activities should if possible be sited away from noise sensitive uses. Where this is not possible there is a need to consider what can practically be controlled to reduce noise levels or mitigate noise through conditions and planning obligations.

PPS25: Development and Flood Risk (CLG, December 2006)

12.81	All forms of flooding and their impact on the natural and built environment are material planning considerations.  The aims of planning policy on development and flood risk are to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk.  Where new development is, exceptionally, necessary in such areas, policy aims to make it safe without increasing flood risk elsewhere and where possible, reducing flood risk overall.

Good Practice Guide on Planning for Tourism (May 2006)

12.82	This document has replaced Planning Policy Guidance 21, published in 1992. Although the guidance does not carry the weight of a PPG or PPS, it can still be a material consideration when making decisions. This document stresses the importance of tourism at national, regional and local levels. The guidance indicates that, “where the attraction or facility is one which lends itself to an urban location, the local planning authority will seek to ensure a town centre location wherever possible”. Tourism developments offer the opportunity for landscape enhancement and the possibility of re-using historic buildings or improving derelict or unattractive sites.  

MPS1: Planning and Minerals (November 2006)

12.83	This minerals policy statement provides the overarching planning policy document for all minerals in England. The document provides advice and guidance to planning authorities and the minerals industry to ensure that the need by society and the economy for minerals is managed in an integrated way against its impact on the environment and communities. This document is accompanied by the ‘Planning and Minerals: Practice Guide’ and should be read alongside MPS1, and sets out how the policies in the statement might best be implemented. MPS1contains four annexes; aggregates; brick clay; building and roofing stone; onshore oil and gas. MPS1 aims to provide an adequate, steady and sustainable supply of minerals through the hierarchical approach (reduce use; recycled and secondary material; and remainder from new primary extraction) and the Integrated approach (social, environmental and economic factors). MPS1 highlights a number of national objectives including; minimisation of new primary extraction; conservation of mineral resources; safeguarding mineral resources; prevention or minimisation of waste; prevention or reduction of environmental and health impacts; protection of designated landscapes; supply within environmental limits; high standards of restoration; and the use of high quality resources appropriately.

PLANNING APPRAISAL

INTRODUCTION     

The applicant lodged an appeal with the Planning Inspectorate on 12th November 2008 against the non- determination of this planning application.  The Planning Inspectorate and the Department for Communities and Local Government have decided that the application is of more than local significance and have decided that the Secretary of State will make the decision.  This means that the inquiry will be heard by an Inspector who will deliver a report with a recommendation to the Secretary of State.  The Secretary of State will make a decision on the basis of that report.

As a result of the appeal being lodged the City Council is now not able to formally determine this application. The Panel does, however, have to advise as to how they would have determined the application at this moment in time if they were able to do so. This will then form the basis of the Council’s case to be presented at the Inquiry and considered by the Inspector and subsequently by the Secretary of State.  

1.	DESCRIPTION OF PROPOSAL

1.1	The application is a ‘hybrid’ application in that the proposal contains elements where full permission is sought in addition to elements where only outline planning permission is sought.

1.2	The applicants seek consent for a Forest Park comprising a Forest Centre including Eco Village, Timber Initiative and Woodland Wildlife Centres, timber workshop, children's woodland adventure play area and treetop walkway; equestrian centre; all weather and turf track racecourse and equestrian eventing area; cross country eventing course; grandstand and associated buildings; refurbishment of Malkins Wood farmhouse to residential accommodation for equestrian centre manager; refurbishment of Moss House Farmhouse and conversion and extension of two barns to form a hotel (80 guests); golf course and clubhouse and change of use of agricultural building for golf course maintenance; footpath and riding trails and cyclepaths; roads and connection to J13 M60, replacement canal bridge, new canal bridge and bridge over Shaw Brook; car parking; landscaping including ground remodelling, creation of water bodies and woodland planting; site infrastructure including fencing, lighting, services and sub stations; and site accommodation works including culverts and watercourse diversions.

2.	PLANNING APPRAISAL

2.1	The context of this application, a description of the proposed works, along with the consultation exercise undertaken and relevant national, regional and local policies are contained within the background report provided within this agenda.

2.2	The key issues to be considered in the determination of this application are:

•	Impact of the development on Green Belt and assessment of Very Special Circumstances;
•	Visual impact and design quality;
•	Impact of the development on ecology;
•	Access, parking, traffic and transportation;
•	Impact of the development on recreation;
•	Impact of the development on noise;
•	Impact of the development on air quality / dust;
•	Impact of the development on flooding and drainage;
•	Impact of the development on ground conditions;
•	Impact of the development on mineral resources;
•	Impact of the development on the economy;
•	Impact of the development on tourism;
•	Impact of the development on agriculture;
•	Impact of the development on archaeology and cultural heritage;
•	Impact of the development on design and crime; 

2.3	All of these issues will be assessed, in turn against the policies in the development plan as required by Section 38(6) of the Planning and Compulsory Purchase Act 2004 in order to identify the extent to which the project complies or conflicts with planning policy or if there are any other material considerations which may outweigh any harm to policy if harm is identified.

3.	IMPACT OF THE DEVELOPMENT ON GREEN BELT 

3.1	The site is located entirely within the Salford Green Belt, and as such PPG2: Green Belts, and policy EN1 of the Salford UDP provide the planning policy framework against which the development will be assessed. 

3.2	PPG2 indicates that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and further more the most important attribute of Green Belts is their openness. ‘Openness’ should be considered as, essentially, the absence of built or operational development and not the visibility of the development or its visual openness.

3.3	The five purposes of including land in the Green Belt are highlighted in paragraph 1.5 of PPG2, and are as follows:-  

•	to check the unrestricted sprawl of large built-up areas;
•	to prevent neighbouring towns from merging into one another;
•	to assist in safeguarding the countryside from encroachment;
•	to preserve the setting and special character of historic towns; and
•	to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

3.4	The use of these designated Green Belt areas have a positive role to play in fulfilling the six specified objectives of Green Belt land, as identified in paragraph 1.6 of PPG2, which are as follows:

•	to provide opportunities for access to the open countryside for the urban population;
•	to provide opportunities for outdoor sport and outdoor recreation near urban areas;
•	to retain attractive landscapes, and enhance landscapes, near to where people live;
•	to improve damaged and derelict land around towns;
•	to secure nature conservation interest; and
•	to retain land in agricultural, forestry and related uses

3.5	The purposes of including land in the Green Belt are of paramount importance to their continued protection and should take precedence over land use objectives. This confirms that whilst a development may contribute towards the achievement of Green Belt objectives, it may not be acceptable if it conflicts with the fundamental purposes of including land in the Green Belt. In short PPG2 aims to protect the essential permanent openness of the Green Belt and maintain a presumption against inappropriate development. 

3.6	PPG2, paragraph 3.4 indicates that the siting of new buildings on Green Belt land is inappropriate development unless the new buildings are for the following uses:-  

•	agriculture and forestry; 
•	to provide essential facilities for outdoor sport and outdoor recreation, for cemeteries, and for other uses of land which preserve the openness of the Green Belt; 
•	to provide limited extension, alteration or replacement of existing dwellings;
•	to provide limited infilling in existing villages and limited affordable housing for local community needs; and 
•	to allow limited infilling or redevelopment of major existing developed sites identified in adopted local plans.

3.7	Further guidance on the phrase ‘essential facilities for outdoor sport and outdoor recreation’ is given in paragraph 3.5 of PPG2, which states that ‘essential facilities’ should be genuinely required for uses of land which preserve the openness of the Green Belt and do not conflict with the purposes of including land in it.  The guidance states that possible examples of such facilities include ‘small changing rooms or unobtrusive spectator accommodation for outdoor sport, or small stables for outdoor sport and recreation’.  The important issues to be noted is that the land use itself has to preserve openness and not conflict with the purposes of including land within the green belt as set out in paragraph 1.5 of PPG2.

3.8	The presumption against inappropriate development in the Green Belt is central to the management of development within it. PPG2 and policy EN1 of the UDP highlight this presumption against inappropriate development in the Green Belt. Paragraph 3.2 of PPG2 states that, “Inappropriate development is, by definition, harmful to the Green Belt. It is for the applicant to show why permission should be granted. Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. In view of the presumption against inappropriate development, the Secretary of State will attach substantial weight to the harm to the Green Belt when considering any planning application or appeal concerning such development”.

3.9	In addition to this, paragraph 3.8 of PPG2 states that the re-use of buildings located within the Green Belt does not represent inappropriate development providing that:-

•	it does not have a materially greater impact than the present use on the openness of the Green Belt and the purposes of including land in it;
•	strict control is exercised over the extension of re-used buildings, and over any associated uses of land surrounding the building which may conflict with the openness of the Green Belt and the purposes of including land in it (e.g. because they involve extensive external storage, or extensive hardstanding, car parking, boundary walling or fencing);
•	the buildings are of permanent and substantial construction, and are capable of conversion without major or complete reconstruction; and
•	the form, bulk and general design of the buildings are in keeping with their surroundings. 

3.10	The applicant considers each development component of the site in terms of its appropriateness and also considers the site as a single entity. The applicant states that the individual development components should be regarded as ‘appropriate’ development in the Green Belt and therefore when considered as a single entity the proposals also represent ‘appropriate’ development. The applicant states that the actual activity of horseracing must be regarded as an acceptable open Green Belt use and indicates that for any new facility required to serve the Greater Manchester population it would be highly likely that such a facility would need to be located in the Green Belt when considering the location of a number of other racecourses across the country. The applicant’s position in relation to each of the scheme components is considered along with the Council’s position, and is detailed later in the appraisal.

3.11	PPG2 paragraph 1.6 highlights support in relation to the use of Green Belt land to provide opportunities for outdoor sport and outdoor recreation. However this is clarified in PPG2, paragraph 3.4 where it states that if new buildings are involved in uses for outdoor sport and outdoor recreation they will not be appropriate unless such buildings provide ‘essential’ facilities for a land use that preserves the openness of the Green Belt and does not conflict with the purposes of including land within it. This is further clarified in PPG17: Planning for Open Space, Sport and Recreation, paragraph 30 which states that, “planning permission should be granted in Green Belts for proposals to establish or to modernise essential facilities for outdoor sport and recreation where the openness of the Green Belt is maintained. Development should be the minimum necessary and non-essential facilities (e.g. additional function rooms or indoor leisure) should be treated as inappropriate development. Very Special Circumstances which outweigh the harm to the Green Belt will need to be demonstrated if such inappropriate development is to be permitted.” 

3.12	Paragraph 26 of PPS7 states that while the policies in PPG2 continue to apply in Green Belts, local planning authorities should ensure that the particular land use issues and opportunities to be found in the countryside around all urban areas are addressed, recognising that it provides the nearest and most accessible countryside to urban residents.  Planning authorities should aim to secure environmental improvements and maximise a range of beneficial uses of this land, whilst reducing potential conflicts between neighbouring land uses.  This should include improvement of public access (e.g. through support for country parks and community forests) and facilitating the provision of appropriate sport and recreation facilities.

3.13	Planning legislation is interpreted by the Courts who make judgments on planning matters and as a result planning case law is formed. When determining planning applications it is important to take into consideration primary legislation and case law, as consideration of both will help develop an informed judgment. The term ‘essential’ has been considered in a number of appeal cases resulting in greater clarity in terms of its use in Green Belt applications. The appeal examples below provide a background to the consideration of this application, of particular note, the London City Racecourse appeal which raises some useful issues.

London City Racecourse - APP/W5780/A/00/1045425 

3.14	The following planning application should not be considered to be a comparable proposal to SFP as the details of the two applications differ, however the case does raise some interesting considerations in relation to ‘openness’. 

3.15	This proposal was an outline application for the development of a new leisure park at Fairlop Waters on Green Belt land. The development was to provide an all weather racecourse, grandstand, stables, hotel, night club, health and fitness centre, ancillary development including a hostel for grooms, veterinary facilities, enclosures, parking for cars and coaches, internal estate roads and landscaping. The existing sailing club, boatyard and lakeside restaurant and bar would be retained. The proposals also comprise alterations to the public highway for pedestrians and vehicles. The Secretary of State (SoS) highlighted the following issues relating to ‘openness’

•	Even if the restaurant and fitness buildings were excluded from the proposal, the SoS considered that the grandstand building and associated car parking would constitute inappropriate development due to its large scale. The grandstand would have a harmful impact on the openness of the Green Belt and conflict with the purposes of including land within it. The overall form of the grandstand would curve up from both sides to a maximum height of 29.8 metres at its apex. The proposed grandstand would have had a floorspace of 9,233sq m. It should be noted that this is a significantly larger grandstand proposal than that for Salford Forest Park. 
•	SoS considers that buildings of such dimensions would inevitably reduce the openness of the Green Belt and that the effects from certain points relatively close by would be dramatic. 
•	SoS took into account that the applicant sought to mitigate the harm caused to the Green Belt through the careful siting of the development. He, however, disagrees with the notion that limiting the degree to which the openness of the Green Belt would be compromised is a material factor in favour of the Appeal, since the development overall still has a negative impact on openness. Overall, the SoS attaches considerable weight to his concerns about the impact of the proposals on the openness of the Green Belt.
 
South Tyneside BC 10/11/03 (http://www.dcp-online.co.uk/DCP/faces/dcslinktemp.jspDCS No. 048-575-524)

3.16	It was proposed to construct a training facility in a Green Belt area to be used by students attending the Sunderland Football Club Academy. The scheme included the construction of a student hostel, which would be occupied by footballers training at the adjoining academy and the club argued that the additional training and accommodation facilities were essential in order to achieve the required level of excellence for premier division players. It was determined that the scale of the football clubs need did not support the size of buildings proposed. It was determined that the appropriate level of essential small scale activities would be a groundsmans store and a perimeter fence although the latter should be re-sited where it did less Green Belt harm. 

Dacorum BC 17/3/98 (http://www.dcp-online.co.uk/DCP/faces/dcslinktemp.jspDCS No. 034-240-184)

3.17	A larger pavilion was required in connection with an outdoor ropes course. An inspector noted that in addition to the facilities that one would normally expect such as changing rooms, toilets, equipment store and possibly a small communal refreshment area, there was a main training room, a recreation area/club room, two offices, store and a medical room. This was much more than the provision of basic necessities for the use of the outdoor ropes course and neither was it a small building. The Secretary of State concluded that the development resulted in a conflict with Green Belt policy and was therefore dismissed.  

3.18	The following case clarifies the PPG2 term ‘openness’, however it should be noted that any assessment as to whether ‘openness’ would be preserved is a matter of judgement based upon the merits of each case. 

Rossendale DC 14/2/03 (DCS No.045-533-145)

3.19	A proposal involved a hotel within Twine Valley Country Park in Rossendale. The scheme had the support of the local planning authority and the appellant argued for very special circumstances in that there was a need to promote Rossendale as a focal point for tourism activity within Lancashire's Hill Country and to create a sure base for tourism related employment. As to the effect of the development on green belt openness the inspector studied the "visual envelope" of the development and concluded that although much of this area was not land open to the public, the proposed buildings would be relatively distinctive built features when viewed from a number of vantage points. It was concluded that there would be significant harm to the openness of this green belt area particularly within the period when any landscaping was maturing. Even when fully screened the building would still constitute inappropriate development.

3.20	The applicant has assessed the appropriateness of each of the individual components of the scheme in PPG2: Green Belt terms. The site has been divided into seven areas to reflect the landscape character areas of the site as discussed earlier in the report. Each character area has been assessed taking into consideration the following:

•	New Buildings – whether the new buildings can be considered to be i) essential facilities for outdoor sport and outdoor recreation and for other uses of land which ii) preserve the openness of the Green Belt and iii) do not conflict with the purposes of including land in Green Belt. Whether the development is visually detrimental by reasons of its siting, materials or design.
•	Re-Use of Buildings – whether the proposed use of each existing building does not have a materially greater impact than the present use on the openness of the Green Belt and the purposes of including land in it; whether strict control would be exercised over the extension of re-used buildings, and over any associated uses of land surrounding the building which may conflict with the openness of the Green Belt and the purposes of including land in it; whether the buildings are of permanent and substantial construction, and are capable of conversion without major or complete reconstruction; and whether the form, bulk and general design of the buildings are in keeping with their surroundings. Whether the development is visually detrimental by reasons of its siting, materials or design.
•	Other Uses of Land – whether they maintain openness and do not conflict with the purposes of including land in the Green Belt. Whether the development is visually detrimental by reasons of siting, materials or design. 
 
3.21	Each of the components have been assessed as to whether the development represents appropriate development in relation to the five purposes of including land in the Green Belt and six objectives of using land in the Green Belt as outlined in PPG2 paragraphs 1.5 to 1.6.  

Impact on Green Belt

3.22	Golf Course – Planning permission for a golf course in this locality was approved in combination with the granting of permission for a golf course to the north of Leigh Road in 1997 (planning permission 95/33737/FUL). Due to the requirement for vehicular access from Junction 13 the previously agreed golf course layout has been amended to reflect this change in circumstance. The applicant states that the golf course would assist in preserving the openness of an additional area of Green Belt, and would also ensure that the course itself remains workable, so ensuring the provision of a significant recreational facility. The applicant states that including land to the south of the canal would assist in preserving the openness of the Green Belt and will ensure the golf course remains workable. The applicant considers that the establishment of the golf course would serve the purposes of including land within it by checking the unrestricted sprawl of large built up areas; preventing neighbouring towns from merging into one another, and assisting in safeguarding the countryside from encroachment. The applicant considers that the golf course development would assist in fulfilling the land use objectives of including land within the Green Belt, in particular to provide opportunities for access to open countryside for the urban population; to provide opportunities for outdoor sport and outdoor recreation near urban areas; to retain attractive landscapes and enhance landscapes, near to where people live; and to secure nature conservation interest.

3.23	It is acknowledged that the establishment of a golf course would itself serve the purposes of including land within the Green Belt and would also assist in fulfilling the land use objectives set out in paragraph 1.6 of PPG2 and therefore represents appropriate development in the Green Belt. Ball stop fencing would be used at two locations alongside the new access road close to the Bridgewater Canal crossing to protect users of the road, and alongside the practice green to protect users of the concessionary footpath, which runs in this location as well as along the length of the practice green that would be 4-5 metres in height and up to 275 metres in length. The fencing would be located in an area that would be partially screened by existing and proposed planting or located where the proposed embankment for the road bridge over the canal would be. Despite this it is not considered that the issue of ‘non-visibility’ is a relevant consideration in respect of the impact of a development on the openness of the Green Belt and it is therefore considered that this element of the golf course represents inappropriate development in the Green Belt. 

3.24	Golf Course Clubhouse - The applicant considers that the clubhouse represents an essential facility for outdoor sport and would not conflict with the purposes of including land within the Green Belt and on that basis the applicant concludes that it is appropriate development. The applicant considers that the new clubhouse, by virtue of ensuring that the southern golf course is constructed, would provide opportunities for access to open countryside for the urban population and to retain attractive landscapes and enhance landscapes, near to where people live and therefore has a positive role to play in fulfilling Green Belt objectives as stated in paragraph 1.6 of PPG2. 

3.25	It is considered that a certain level of clubhouse provision is necessary for a golf course to function, as it provides opportunities for outdoor sport and recreation near urban areas. Despite this, the clubhouse proposed is a large, two storey building incorporating changing facilities on the ground floor and a member’s lounge and restaurant/function room with terraces at first floor. The use as a function suite suggests that its use could be for purposes other than those directly associated with playing golf and as such, could be used in a stand-alone capacity, with guests visiting the site solely to use the restaurant/function room and not the golf course. This is not therefore considered to be ‘essential’ to the operation of the golf course.

3.26	The golf course clubhouse would be partially screened by existing tree planting and additional proposed planting to the north and south of the development. Despite the positive impact on mitigating the new building form it is not considered that ‘non-visibility’ is a relevant consideration in respect to the impact of a development on the openness of the Green Belt. It is considered that the size, scale and height of the proposed building and extent of the surfaced areas surrounding the building would have an urbanising effect on the area and would erode and not preserve the Green Belt’s openness.  

3.27	Whilst it is considered that the design and proposed materials are of a relatively high standard, it is considered that the position of the clubhouse and the site topography is such that it would be clearly visible from medium to long range view points and as such the scale and height of the building would be visually obtrusive.

3.28	It is considered that the golf clubhouse would have a detrimental and harmful impact upon the openness of the Green Belt; and would conflict with the purposes of including land within the Green Belt. The clubhouse in its proposed form and scale cannot be considered as an essential facility for outdoor sport and recreation and for other uses of land that preserve the openness of Green Belt land. The relatively high standard of the design is not considered to be a material circumstance or very special circumstance that outweighs the harm to Green Belt policy. The clubhouse is therefore considered to be inappropriate development.  

3.29	Golf Course Maintenance Depot – The applicant indicates that the maintenance depot will be located within an existing barn at Carrs Meadow. There would be no material change in the usage of the outside storage space compared to the existing position. The applicant considers that any golf course requires a maintenance base to house all the machinery necessary to sustain a top quality facility. The building is described as an agricultural building that can be re-used for the intended use without ‘major adaptation’.

3.30	A building condition survey has been produced as part of the ESS submission, which indicates that internally the building is in a reasonable condition, although externally some aspects of the building are in poor condition and require replacement. The building condition survey indicates that only minor works are required, without major or complete reconstruction. This existing building is an isolated building, not located amongst other agricultural buildings and the design is functional rather than of a particularly high standard.

3.31	The development will result in no material change in the usage of the outside storage space compared to the existing barn position. Taking this into consideration, these factors would indicate that the use of the existing building as a golf course maintenance depot would not have a materially greater impact than the present use as a barn to house farm animals. The only alteration to the external appearance will be a change to the external cladding. Taking PPG2, paragraph 3.8 into consideration this element is considered to represent appropriate development.

3.32	Worsley New Hall Garden Project and Woodland Car Park - The proposals for the garden project are likely to include selective clearance of scrub areas, re-establishment of terraces, re-establishment of original footpaths, clearance of rubble etc. that are unlikely to constitute operational development or engineering operations. The proposals do however include the creation of a clearing to accommodate a car park for 50 cars. The car park will be a small stone-surfaced car park, for use by visitors to the Worsley New Hall Garden Project. The car park is centred on a beech tree and is surrounded by existing woodland. The applicant states that the siting of the car park is partially obscured by the existing tree cover within this area and would not be visually detrimental.

3.33	Despite the existing tree coverage and the proposed planting ‘non-visibility’ is not considered to be a relevant consideration in respect of the impact of a development on the openness of the Green Belt. The scale and extent of the surfaced area for car parking would have an urbanising effect, which would erode the Green Belt’s openness. As a result it is considered that the woodland car park would result in encroachment of the countryside and as such, would conflict with the purposes of including land within the Green Belt. It is therefore considered that this element of the development is inappropriate.

3.34	Access Road from M60 Junction 13 – The layout of the M60 Junction 13 western roundabout and site access was amended as part of the ESS submission. The access arrangement consists of a signal-controlled improvement with a new arm providing access to the SFP site. 

3.35	The scale and coverage of the proposed access point would result in the generation of a significant level of activity and would introduce suburban characteristics and clutter. This is considered to represent inappropriate development in the Green Belt as it will result in the generation of a significant level of activity and would introduce suburban characteristics and clutter from vehicles into an area, which is presently considered to be open countryside. It is considered that the proposed road would have an urbanising effect and would erode the Green Belt’s openness.        

3.36	Bridgewater Canal Crossing – South of Middlewood – The road crosses the canal on a new two lane bridge with cycle and pedestrian path on the west and golfers path on the east side. At each side of the canal, the road would rise gradually up to 7 metres over a distance of approximately 70 metres to the bridge. The bridge approaches will be lit from columns and lighting will be provided across the bridge deck either from bollard lights or from lighting within the vehicle barrier of the bridge. The bridge would cross the canal and towpaths, with supporting columns behind the towpaths to maintain an open aspect along the canal. The canal embankments would be planted with native woodland species. The design and dimensions of the proposed bridge crossings and the associated illumination of parts of the road are distinctly urban features. The development would result in the generation of a significant level of activity and would introduce suburban characteristics and clutter, from vehicles, into an area, which is presently considered to be open countryside. The proposed bridge crossings will conflict with the purposes of including land within the Green Belt and would result in the introduction of urban characteristics and clutter resulting in sprawl into an area that is considered to be open countryside, therefore impacting on openness. This is therefore considered to represent inappropriate development in the Green Belt.  

Bittern Pitts Wood/Hollin Wood

3.37	Timber Initiative Centre – The applicant indicates that the intention is that this facility, combined with the Eco-Village and Woodland Wildlife Centre would offer a coherent tourist/visitor attraction. The applicant describes this as a low-key structure that will employ green technology in its construction. The applicant argues that such a facility is inextricably linked with the woodland park within which it is located and that its siting and low-key construction is such that it would preserve the openness of the Green Belt. The applicant considers that it is appropriate development on the basis that it fulfils a forestry purpose, in the sense that it provides a recreational/educational facility directly associated with a modern commercial forestry enterprise and is an essential facility for outdoor recreation, which does not conflict with the purposes of including land within the Green Belt.

3.38	It is considered that the linked usage of this facility for a forestry purpose is tenuous due to the proposed visitor centre uses within the building. PPG2 advises that the construction of new buildings for agriculture and forestry are appropriate, however it is not considered that the proposed use falls within the definition of ‘forestry’. Forestry is defined in planning law as meaning, “the growing of a utilisable crop of timber”. It may also be taken to mean ‘the cultivating of forests and the management of growing timber would include the felling of trees and the extraction of the timber from plantations’. Whilst PPG2 advises that the construction of new buildings for agriculture and forestry to be appropriate, no form of business/commercial forestry development is included within this proposal. It is therefore concluded that this is not a ‘forestry’ use and as such, cannot be considered as appropriate development in relation to PPG2.

3.39	The proposed development would result in sprawl and encroachment into an open countryside area and as such, would conflict with the purposes of including land within the Green Belt and impact on openness. The use of green technology in its construction is not considered to constitute either a significant material consideration or very special circumstance that would outweigh the harm to Green Belt policy which is caused by this element of the development. It is therefore considered that the proposed development would represent inappropriate development in the Green Belt. 

3.40	Eco-Village – Visitor Centre – The applicant states that this visitor facility would provide a particular focus for the interpretation of sustainable technologies by providing exhibition space, classrooms, a book shop and resource centre and other ancillary facilities including a restaurant. The facility would also provide an interpretation of the social history and heritage of the Worsley Estate. The intention is to add a cultural/educational perspective to visitors’ enjoyment of the broader recreational resource, which would be created. The applicant considers the Eco Village Visitor Centre to be an essential facility for outdoor recreation. The applicant concludes that the low-key appearance, use of natural materials and sensitive siting within an existing woodland area ensures that it preserves the openness of the Green Belt. It is considered that the erection of any structure, however unobtrusive would harm the openness of the Green Belt, as no building can preserve the openness of the Green Belt, and as such the applicant’s conclusion on this issue is contended.  

3.41	Although the area and the woodlands would be opened up for recreation use it is considered that the nature of the proposed uses within the centre and the scale of the development is significantly in excess of what could be considered as providing ‘essential’ facilities for outdoor sport and recreation. The size and scale of the proposed building would erode the Green Belt’s openness. In addition the applicant has not brought forward any evidence that the opening up of the Green Belt for public access is not dependent upon the development of the Eco-Village Visitor Centre, and therefore can be achieved without this. 

3.42	The nature of the proposed use would generate considerable activity and would introduce suburban characteristics and clutter into an area, which is considered to be open countryside. This element of the proposed development is considered to constitute sprawl and encroachment of the countryside. As such it is considered that the proposed building would conflict with the purposes of including land within the Green Belt.

3.43	Eco-village – Earth Sheltered Overnight Accommodation – The applicant states that this facility would provide accommodation for those wishing to stay within Salford Forest Park and that the intended site occupies a secluded location, enclosed by Bittern Pitts Wood, Botany Bay Wood, Hollin Wood and the reed embankment of the Bridgewater Canal. Additional tree planting would enhance the existing sense of enclosure. The applicant states that this would be a low-key facility, providing 20 rooms (40-50 bed spaces) of short stay accommodation. Green technology will be employed, with an emphasis on natural materials. The applicant considers that this element of the proposal represents essential facilities for outdoor sport and recreation and it preserves the openness of the Green Belt and does not conflict with the purpose of including land within it. The applicant feels that the low-key appearance, use of natural materials and sensitive siting within an area already enclosed by woodland ensures that it preserves the openness of the Green Belt.  

3.44	It is considered that the link between providing overnight accommodation as an essential facility for outdoor sport or recreation is tenuous. The provision of trails in this area and the surrounding woodlands would result in the provision of an outdoor recreation use of sorts. Despite this the scale and nature of the buildings are not considered to provide ‘essential’ facilities for outdoor sport and recreation.

3.45	Although the applicant states that this component of the development would be enclosed by woodland it is not agreed that the openness of the Green Belt would be preserved as non-visibility of development is not a determining factor in considering whether the openness of the Green Belt would be preserved. Regardless of the existing and proposed planting, it is not considered that ‘non-visibility’ is a relevant consideration in respect of the impact of a development on the openness of the Green Belt. Regardless of the proposed materials, the size and scale of the proposed buildings would erode the Green Belt’s openness. The scale, nature and use of the proposed buildings are such that that they would result in sprawl and encroachment of the countryside.

3.46	It is not considered that the proposed Eco-village overnight accommodation buildings provide essential facilities for outdoor sport and recreation. It is considered that the proposed building would have a suburbanising effect, which would erode the Green Belt’s openness and would result in sprawl and encroachment on the countryside. As such, the proposed buildings would conflict with the purposes of including land within the Green Belt and represent inappropriate development.

3.47	Eco-Village – Forest Park Manager’s Accommodation – The applicant considers that a new recreation and sporting facility of this scale warrants the presence of a full-time park-manager. The applicant argues that this can be seen as comparable with a dwelling which might be justified on either agricultural or forestry grounds and that such a dwelling would be tied to the estate by means of a legal obligation.

3.48	PPG2 advises that the construction of new buildings for agriculture and forestry is appropriate, however it is considered that the proposed residential accommodation for a park manager is not related to either agriculture or forestry uses and as such must be considered to be inappropriate development in relation to PPG2. The presence of a Forest Park Managers accommodation on site is not considered essential and could easily be located off site in Boothstown for example. In addition to Green Belt considerations the managers dwelling should be considered against the advice in PPS7: Sustainable Development in Rural Areas. Annex A of PPS7 sets out the process by which an occupational dwelling in the countryside (including the Green Belt) should be assessed. The onus is on the applicant to demonstrate that there is a functional need for the dwelling that cannot be met either by utilising another building on the site or elsewhere in the locality. The applicant has failed to meet this test. In addition there is a requirement to demonstrate that the proposed use is financially viable. If the use is new then there is the ability to grant planning permission for a temporary dwelling for 3 years to allow the financial viability of the business to be properly tested and assessed. The applicant has applied for a permanent dwelling and failed to address the financial test set out in PPS7.    

3.49	Eco-Village – Campsite, events space and growing area – A 50-space campsite would be located to the southwest of the lake. The applicant states that new woodland planting would create an enclosure and structure for the site. A washroom block 10m x 10m x 5m high is proposed. The building would be constructed using straw bale and adobe techniques. A growing area/ exhibition area is proposed to the north of the Eco-Village Visitor Centre and adjacent to the Forest Centre Manager’s residential unit. The area would be used for demonstration crop growing or permaculture exhibitions. The Events Space area is to the east of the growing area. It would be laid out as a meadow and made available for events and exhibitions and other open-air activities. 

3.50	The applicant has not included details of the opening times of the campsite in the application although the applicant has indicated in discussions that this use would be limited from March to October only. Limiting the use of the campsite during this specified period would reduce the level of activity and clutter over a significant area compared to using it continuously all year. Regardless of the existing and proposed planting, it is not considered that ‘non-visibility’ is a relevant consideration in respect to the impact of a development on the openness of the Green Belt as discussed previously. It is considered that the scale of camping proposed would introduce a significant level of activity and would introduce clutter over a significant area. It is therefore considered that this element of the development would represent inappropriate development in the Green Belt. 

3.51	Forest Car Park - The use would generate considerable activity and would introduce urban characteristics and clutter into an area, which is considered to be open countryside. Regardless of whether or not there is limited visibility of this area from outside of the application site boundary, it is considered that the parking of vehicles throughout such an extensive area of land would have a detrimental impact on the openness of the Green Belt.

3.52	It is considered that the use of land for car parking would conflict with the purposes of including land within the Green Belt. The parking of vehicles on such extensive areas of land would represent sprawl and encroachment into the countryside. Although the applicant proposes using a reinforced grass surface to minimise the visual impact, it is considered that this would generate considerable activity and introduce urban characteristics and clutter into an area considered to be rural countryside. Taking this into consideration, it is considered that this represents inappropriate development in the Green Belt.

3.53	Access road from Bittern Pitts Wood and the Hollin Wood/Shaw Brook bridge crossing - The road would be routed through two existing gaps in the trees. In the open area, the road crosses the Thirlmere Aqueduct. Bollards are proposed to prevent cars parking on the line of the aqueduct. The proposed road passes to the north of the proposed eco-village. At the north-western boundary of the Eco-village, the proposed access road passes through a woodland area to cross Shaw Brook. The bridge is a low-level deck type structure that is 9 metres wide (3 lanes). On race days, pedestrians and cyclists would be diverted along a new footpath through the Avenue.

3.54	The proposed road network would introduce roads that are capable of carrying more substantial amounts of traffic. The design and dimensions of the proposed roads and bridge crossings are urban features. The proposed access route would introduce suburban characteristics and clutter, from vehicles, into an area that is presently considered to be open countryside. The proposed access routes would conflict with the purposes of including land within the Green Belt, in that the development would result in encroachment of the countryside. It is therefore considered that this represents inappropriate development in the Green Belt.

Botany Bay Wood

3.55	Timber Workshop – The applicant states that the introduction of a modest amount of new built form is balanced by the existing structures, used by the Clay Pigeon Club (now vacated), which will be replaced. The applicant considers that this use is an appropriate facility within a working forest and that it accords with paragraph 3.4 of PPG2, in that it is a facility for agriculture and forestry and accordingly it constitutes appropriate development in the Green Belt.    

3.56	PPG2 advises that the construction of new buildings for agriculture and forestry is appropriate, however no form of business/commercial forestry development is specifically included in the scheme. As discussed previously ‘forestry’ is defined in planning law as meaning, “the growing of an utilisable crop of timber”. It may also be taken to mean ‘the cultivating of forests and the management of growing timber would include the felling of trees and the extraction of the timber from plantations’. Timber processing and manufacture, such as that proposed, is likely to fall within a B2 (business) Use Class. It is concluded that this is not a ‘forestry’ use and as such, it is inappropriate development in the Green Belt. 

3.57	Woodland Wildlife Centre – The applicant states that the intention is to provide (in combination with the Timber Initiative Centre and Eco-Village Centre) a recreational and/or educational resource for local people, schools, other groups and tourists. The applicant argues that its particular siting and construction will preserve the openness of the Green Belt. The applicant also considers it to represent appropriate development on the basis that it would fulfill a forestry purpose providing a recreational / educational facility directly associated with a modern commercial forestry enterprise. The applicant states that the Woodland Wildlife Centre is an essential facility for outdoor recreation, which does not conflict with the purposes of including land within the Green Belt. The applicant has provided no evidence to demonstrate that there is a requirement within the area for this type of facility.   

3.58	It is considered that the applicant’s indication that this facility would fulfil a ‘forestry’ purpose is tenuous, especially given the nature of the proposed visitor centre style uses within the building. The area and woodlands would be opened up for recreation use, however it is considered that the nature of the proposed uses within the centre and the scale of the development are significantly in excess of what could be considered as providing ‘essential’ facilities for outdoor sport and recreation and it is therefore considered to represent inappropriate development in the Green Belt. 

3.59	Regardless of the existing and proposed planting, it is not considered that ‘non-visibility’ is a relevant consideration in respect of the impact of a development on the openness of the Green Belt. It is considered that the size, scale and height of the proposed building would erode the Green Belt’s openness. The development of the Woodland Wildlife Centre would encroach on the countryside and result in sprawl and as such, would conflict with the purposes of including land within the Green Belt.

3.60	The proposed Woodland Wildlife Centre cannot be considered to fall within the definition of a ‘forestry’ use and as such, it cannot be considered as appropriate development. The building does not provide essential facilities for outdoor sport and recreation. The proposed building would have an urbanising effect, which would erode the Green Belt’s openness and result in sprawl and encroachment on the countryside. As such, the proposed building would conflict with the purposes of including land within the Green Belt.

3.61	Forest Play Space and Treetop Walkway – The applicant states that the intention of this component is to provide an attraction for visitors. The applicant states that all proposed play facilities would be sensitively designed, using natural materials to a large extent, in a way that reflects the forest setting. On this basis, the applicant does not consider that such low-key facilities raise any policy issues in relation to the Green Belt, in that it would maintain openness and would not conflict with the five purposes of including land in the Green Belt. The applicant states that the structure of the building would be completely screened from view, other than at the very closest quarters and on this basis, considers that it maintains the openness of the Green Belt and would not impact upon the purposes of including land within it.  

3.62	It is considered that the proposed use would generate considerable activity and would introduce suburban characteristics and clutter into an area that is considered to be open countryside. It is therefore considered that this element of the proposed development would not maintain the openness of the Green Belt and would constitute encroachment of the countryside.  
Grange Farm

3.63	This area comprises flat, open, agricultural land and is bounded by the M60 to the east and the M62 to the south. Botany Bay Wood is located to the western boundary. The proposals for this area comprise a new footpath and a shared cycle/bridle/footpath that would comprise of three metre wide stone surfaced paths. It is considered that these elements of the scheme represent appropriate development in the Green Belt. 

Agricultural land North of Botany Bay Wood

Racecourse enclosure - (Racecourse, Grandstand and Associated Car Park, Parade Rings, Saddling Stalls, Concourse and Ticket Office, Stables, Stable Lads Accommodation, Horse Box Parking) – 

3.64	The applicant states that horse riding is an outdoor sport that preserves the openness of the Green Belt and does not conflict with the purposes of including land within it. Whilst this is accepted in principle it is necessary to draw a distinction between casual horse riding within the countryside and the formal commercial racecourse proposed in this instance. The argument put forward by the applicant is considered to be overly simplistic. On the basis of their argument, the applicant states that the test is whether the grandstand is an essential facility genuinely required for the use involved. 

3.65	The footprint of the grandstand building is 102m x 48m, with a maximum height of 25m and the building would be positioned within an area of hard standing. The grandstand building should also be considered in combination with the other proposed developments in this area, including the stable lads accommodation (66m x 23m x8m), 12 stable blocks (each 3.5m x 35.5m x 8m), saddling stalls (33m x 8m x 4m), parade ring (54m x 28m), pre-parade ring (38m x 32m), winners enclosure (18m diameter), concourse areas (max. 150m x 80m) with three pedestrian bridges (each 15m wide), ticket kiosk (10m x 10m) horsebox parking area (65m x 75m) and surface car park (approx. 45m x 15m).  

3.66	Viewed as a whole, in association with lighting, this constitutes a significant area and scale of built development, which would replace a presently open and rural landscape. Due to the size and scale of the grandstand it is considered that this results in a detrimental impact on the openness of the Green Belt.  It is considered that as a consequence of such a significant amount of built development associated with the grandstand there would be an inevitabe reduction in the openness of the Green Belt. These elements of the proposed development would also generate considerable activity and would introduce urban characteristics and clutter into an area, which is presently considered to be open countryside. The grandstand and associated developments would conflict with the purposes of including land within the Green Belt, as the scale of the built development would result in significant encroachment into the countryside and sprawl. 

3.77	The applicant states that the concept of ‘essential facilities’ would be very much dictated by the operational requirements associated with a new, modern, state of the art racecourse and that central to those requirements would be the need for an appropriate grandstand. The applicant considers that the proposed floor plans and uses of the grandstand represent an essential level of provision that is genuinely required for a racecourse development that preserves the openness of the Green Belt. They argue that the structure, by virtue of its particular location within the context of an introverted yet expansive landscape, would be ‘relatively unobtrusive’ and would not conflict with the five Green Belt purposes. The applicant also argues that the grandstand is necessary in respect of the second objective for the use of land in Green Belt.

3.78	In the London City Racecourse (LCR) Appeal, the SoS stated, “there is no question that the race track itself would not be inappropriate in the Green Belt, and that a large grandstand is essential to the racecourse. Therefore the question of appropriateness depends mostly on the purpose and scale of buildings”. In their statement of case, the London Borough of Redbridge stated that: “Even though a building such as a grandstand may possibly be considered to be an essential facility its proposed size may nonetheless render it inappropriate in Green Belt terms. The Appeal proposal clearly does not constitute unobtrusive spectator accommodation as contemplated in paragraph 3.5 of PPG2. Whilst typical grandstands traditionally accommodate 25% of racegoers, the LCR grandstand is proposed to accommodate up to 50% of racegoers.”  

3.79	In consideration of this, the SFP proposals state that the total capacity of the grandstand and terrace is 8,935 people. On this basis, the grandstand would accommodate approximately 40% of race-goers to a premium event (1 day/year), 60% of race-goers to a flagship event (3 days/year), 90% of race-goers to a high attendance event (16 days/year) and 100% of race-goers spectators to lower attendance events (10 days/year). It is therefore questionable whether the size and scale of the proposed grandstand, which would only be used for 30 days of race events per year, can be considered appropriate and essential.  

3.80	Consideration must also be given to the other uses of the grandstand on non-race days. The applicant states that the buildings would be used to host events such as conferences, trade fairs and wedding receptions. The applicant indicates that such events would occur ‘irregularly’, but provides no further details. In theory, outside the race meetings, this could be up to 335 days a year. It is clear that the intention to use the building for purposes other than those directly associated with the outdoor sport/recreation use, with the building being used as a venue for functions in a stand-alone capacity exist. The restaurant is significant in size and could accommodate 828 people. 

3.81	It is considered that a racecourse could function without any grandstand facility. The applicant’s argument seems to imply that the grandstand is essential to the financial success of the operation, which is clearly not the same as providing an essential facility for outdoor sport and recreation.  For the above reasons, whilst modest, unobtrusive spectator facilities could be construed as ‘essential’, the size and scale of the proposed grandstand and the infrequency of its use in association with the racecourse is such that it is not considered to be an ‘essential’ facility for outdoor sport and recreation and is therefore inappropriate development.

3.82	The applicant states that the ancillary facilities serving the racecourse are located close to the grandstand for operational reasons and that all structures have been set down beneath the more dominant landform of the restored landfill areas to the north. The applicant argues that these facilities represent the minimum necessary to enable racing events to be properly planned, organised and presented to the spectators and in certain instances are important from a health and safety perspective. The applicant concludes that these are therefore essential facilities for outdoor sport and outdoor recreation uses and so constitute appropriate development; they are not obtrusive and they do not conflict with the five purposes of including land within the Green Belt. 

3.83	With regards to the ancillary facilities serving the racecourse, which include the stabling, saddling enclosure, stable lads accommodation and ticket kiosk, the applicant argues that these facilities represent the minimum necessary to enable racing events to be properly planned, organised and presented to the spectators and concludes that these are essential facilities for outdoor sport and outdoor recreation uses and constitute appropriate development. It is accepted that whilst such facilities as stables could be considered to be essential facilities for outdoor sport and outdoor recreation uses, associated with the provision of a racecourse, the scale and level of the proposed provision is questioned. The proposals indicate that stable lads accommodation would be provided, which would include some 62 en-suite bedrooms, in addition 110 stables are proposed. The applicant does not provide any evidence to demonstrate why such a high level of provision is required or whether this level of provision is comparable to that of other existing racecourses. The nature of this residential use and the size and scale is such that it is not considered to be an ‘essential’ facility for outdoor sport and recreation and is therefore inappropriate development within the Green Belt. 

3.84	It is considered that the grandstand and associated developments conflict with the purposes of including land within the Green Belt, as the scale of the built development would result in significant encroachment into the countryside and sprawl. The submitted plans, elevations and photomontages indicate that the proposed grandstand would fulfil its purpose as a landmark building and demonstrate a high standard of design and use of materials.  However, it is not considered that this would offset the harm caused by the proposals in terms of its urbanising effect on the Green Belt.

3.85	Equestrian Centre – Outdoor Arena and Car Park – The applicant states that the arena lies at the heart of the Malkins Wood Farm complex, in a position where it is screened by existing trees to the north, south-west and east and accordingly, bearing in mind that it would be a ground level facility, would maintain the existing openness of the Green Belt. For the same reasons, the applicant suggests that there would be no conflict with the purposes of including land within the Green Belt. The proposed parking will be constructed from reinforced grass, which the applicant considers will maintain the openness of the Green Belt. 

3.86	The Council does not consider ‘non-visibility’ to be a relevant consideration in respect of the impact of a development on the openness of the Green Belt. Up to 50 cars and 50 horseboxes within the parking areas would result in visual clutter and a significant level of activity, considerably over and above the current use as a farm. It is considered that the scale and extent of the surfaced arena area, along with the activity associated with the comings and goings to the car park would have an urbanising effect, which would erode the Green Belt’s openness. 

3.87	It is considered that the proposed outdoor arena and car park would reduce the openness of the Green Belt and would constitute inappropriate development. The proposals would also result in sprawl and encroachment of the countryside and as such would conflict with the purposes of including land within the Green Belt.  

3.88	Equestrian Centre – Indoor Arena and Stables - The applicant considers that the visual benefits of the demolition of the ‘large, unsightly, corrugated-clad’ buildings and their replacement with a single new structure and low-key stable buildings to be beneficial. The applicant considers that the design of the indoor arena would result in the openness of the Green Belt being preserved. The applicant states that the provision of a modern indoor arena is an element of a modern equestrian facility. Whilst PPG2 refers to outdoor recreation and the equestrian centre is an indoor facility, the applicant believes that it nevertheless constitutes an essential element of a modern, outdoor equestrian facility, given that it fulfils an ancillary role in broadening the appeal of the venue by addressing the need for early morning training, bad weather and use during non-daylight hours. The applicant continues that whilst the indoor arena is ‘by no means the core element’ of a modern equestrian facility, it would not be commercially feasible to seek to operate such a centre without an indoor arena and that the structure is no more than reasonably necessary for the enterprise to function. The applicant goes on to state that it would be equally implausible for such a modern facility to seek to survive on the basis of the indoor arena alone, without access to any outdoor facilities. Although the applicant makes this claim this is not supported through the submission of any evidence.  

3.89	Paragraph 3.4 of PPG2 states that the construction of new buildings within the Green Belt is inappropriate, unless it is for purposes including essential facilities for outdoor sport and recreation. It is considered that the nature of the indoor arena is such that it could function on its own, completely independent of there being outside uses such as eventing and cross-country. It is not considered that there is a clear link between the indoor and outdoor equestrian uses. The indoor arena could be used solely as a riding school/indoor facility without the need for outdoor activities. The level of provision within the indoor arena is questioned as the development includes a shop and cafeteria, which are not considered to constitute essential facilities for outdoor sport and recreation.  The proposed stables could be used solely in association with the indoor arena use and the link to essential facilities for outdoor sport and recreation is again tenuous. PPG2, paragraph 3.5 refers to the provision of ‘small stables for outdoor sport and outdoor recreation’. Whilst some level of provision may be appropriate for outdoor horse-riding uses, the scale and level of the proposed provision is questioned. The proposed indoor arena and stables are not considered to provide essential facilities for outdoor sport or recreation.  

3.90	It is considered that the provision of the indoor arena and stables would result in encroachment of the countryside and sprawl and as such, would conflict with the purposes of including land within the Green Belt and therefore represents inappropriate development in the Green Belt. 

3.91	Racecourse – The applicant states that the extensive scale of the racing oval and straight is such that an observer at ground level would be highly unlikely to discern its full extent from any single vantage point. Given the distances involved and given that the course is at the same level as the surrounding terrain, the applicant does not consider that the introduction of the all-weather and grass tracks would result in any alteration to either the openness or general appearance of what the applicant terms an expansive, yet introverted landscape. The applicant suggests that whilst the all-weather track would have a different surface appearance and running rails would be erected, these two elements would not have any marked visual effect and openness would be maintained.    

3.92	It is considered that a racetrack itself could maintain the openness of the Green Belt, although concern is raised that the introduction of floodlighting and floodlighting columns would be intrusive and would impact detrimentally on the openness of the Green Belt. During the day the columns and banks of luminaries would be prominent compared with the adjacent rural surroundings, and would impact on the skyline.

3.93	It is considered that the introduction of the proposed lighting columns and banks of luminaries would conflict with the purposes of including land within the Green Belt.  The presence of lighting columns and luminaries in combination with the proposed level of illumination would result in the area being seen as an extension to the urban area of Boothstown (i.e. sprawl) and would result in encroachment of the countryside, thus conflicting with the purposes of including land within the Green Belt. 

3.94	The racetrack incorporates an all-weather surface, which is 23m in width and an emergency vehicle track over significant area of land. It is considered that the change in surface material and colour would undoubtedly have some impact on visual amenity.  Whilst the use retains openness the change in surface material and colour means that on balance it is considered that the formation of the racecourse is inappropriate development.

3.95	Hotel and associated car park – The applicant considers this element of the development to represent appropriate development in the Green Belt when considered against paragraph 3.8 of PPG2: re-use of buildings inside a Green Belt. However, the applicant acknowledges that the majority of the buildings at Moss Farm would be demolished, as they are unsuitable or need to be rebuilt because of their present condition. The majority of the buildings are not considered to be of a permanent and substantial construction and are not capable of conversion without major or complete reconstruction. As a consequence of this it is considered that the buildings must be considered against paragraph 3.4 of PPG2: New buildings. The construction of a hotel on the site is not considered to represent appropriate development in the Green Belt as the development does not represent a limited extension, alteration or replacement of existing buildings. The 120-space car park associated with the development is significant in size and would generate considerable activity, urban characteristics and clutter into an area that is considered to be open countryside. It is therefore considered that these elements of the proposed development would not maintain the openness of the Green Belt and therefore represent inappropriate development in the Green Belt.   

3.96	Cross Country and Eventing Area – The applicant considers that the cross-country eventing course would have no material visual or physical impact upon the environment and landscape of the area, given that the actual route of any course would only be marked out for the events themselves and given that fences and jumps ‘would not be conspicuous’ and may be constructed on a one-off basis, tailored for a particular event. The applicant suggests that such works would be unlikely to require planning permission. The applicant argues that the use of a significant area of land for cross-country eventing, bearing in mind that this would be in active agricultural/grazing uses at other times, would assist in preserving the openness of the Green Belt and would not conflict with the purposes of including land within it.

3.97	It is considered that the use of the land for cross-country trails, show jumping and eventing would result in a change in character of the landscape from open agricultural land to a more managed landscape.  However, the applicant indicates that outside such events, the land would remain in agricultural / grazing uses. The applicant has indicated that one major regional three-day eventing show would be staged each year. Each event would in practice take place over four days at a weekend (Thursday-Sunday). A range of schooling and competitive activities, attracting between 50 and 200 entrants may also be held at the Equestrian Centre. 

3.98	It is considered that the provision of the car park would result in sprawl and encroachment of the countryside and as such, would conflict with the purposes of including land within the Green Belt. Despite this, it is considered that the Cross Country and Eventing Area does not conflict with the five purposes of including land in the Green Belt and therefore represents an appropriate use of Green Belt land. 

3.99	Eastern Access Road (Shaw Brook to Grandstand) – 300 metres west of the Shaw Brook bridge crossing, the road splits, one spur providing access to the landfill car parks – open on race days only and the other continuing towards the Grandstand/Hotel/Equestrian Centre – providing restricted access to Grandstand and for officials/VIPs/taxis only on race days. The road becomes a 6m wide two-lane carriageway without a grass-reinforced verge. The road lighting strategy indicates that solar activated intelligent road studs would provide illumination on this section of road.  The development would result in the generation of a significant level of activity and would introduce suburban characteristics and clutter, from vehicles, into an area, which is presently considered to be open countryside and therefore represents inappropriate development in the Green Belt.

Restored Landfills

3.100	Main Racecourse Car Park and Overflow Car Parks - The main racecourse car park and overflow car parks are to be located on the former landfills that have been restored and enhanced and have vegetation cover. The applicant states that it is the intention that any visual effect arising from these parking areas should be kept to the absolute minimum and that it is not either visually or commercially appropriate to propose significant areas of tarmac where usage through the year would be so limited. As a result, the applicant argues that the parking facilities present an essentially green appearance at all times, other than when cars are parked there. The applicant therefore argues that the openness of the Green Belt would be maintained. The applicant asserts that there would be no conflict with the five purposes of including land within the Green Belt and that the ability to offer such parking would complement the outdoor sport and recreation initiatives, contributing positively to fulfilling the land use objectives for Green Belt land. 

3.101	It is considered that the provision of temporary car parking would conflict with the purposes of including land within the Green Belt, in that the parking of vehicles on such extensive areas of land would result in sprawl resulting in encroachment onto the countryside. The use would generate considerable activity and would introduce suburban characteristics and clutter into an area that is considered to be open countryside. Although extensive tree planting is proposed to the boundaries of the proposed car parks and the proposed reinforced grass surface would minimise visual impact, it is considered that the development would represent inappropriate development in the Green Belt. 

3.102	Astley / Boothstown Urban Fringe - A western access road from the A580 is proposed in this area, the northern part of this access falls within Wigan MBC jurisdiction. The proposals in this area include a replacement bridge crossing at Vicars Hall Bridge. Structural landscaping is also proposed. 

3.103	Vicars Hall Bridge Crossing - The western access crosses the Bridgewater Canal over an improved bridge comprising two-lanes (6 metre wide carriageway) and a segregated 3 metre wide shared pedestrian/cycle/bridleway path. The bridge would be lit and low-level lighting would be provided across the bridge deck. Bollards would be installed at 3 metre centres for 30 metres either side of the bridges. The bridge would be supported by retaining walls on the southeast and northeast sides, and would be constructed of brick to match the existing structure. The new bridge deck would have a smooth concrete finish, with concrete supporting pillars at the back of the towpath. The embankments would be planted with native woodland species.

3.104	It is considered that the design and dimensions of the proposed bridge crossings and the associated illumination of parts of the road are distinctly urban features. The development would result in the generation of a significant level of activity and would introduce suburban characteristics and clutter, from vehicles, into an area, which is presently considered to be open countryside. The proposed bridge crossings would conflict with the purposes of including land within the Green Belt, in that the development would result in encroachment of the countryside. The proposed bridge crossing would result in the introduction of urban characteristics and clutter leading to sprawl on an area that is considered to be open countryside. It is therefore considered that this represents inappropriate development in the Green Belt.

Conclusion

3.105	When assessing the site on an individual component basis, it is considered that the majority of components represent inappropriate development in the Green Belt. It is recognised that the golf course, golf course maintenance depot, cross country and eventing area, and the racecourse track (not including the grandstand and associated development on the scale outlined in the application) could be said to represent appropriate development in the Green Belt. Despite this a substantial and significant number of elements represent inappropriate development. 

3.106	The applicant as part of their submission indicates that the site should be considered as a single cohesive entity, and as such the SFP scheme is now considered as such. The applicant has indicated that the site would retain its openness once the full scheme is in place. The applicant states that 0.29% of the 684-hectare site would be devoted to built development, a proportion of which would arise through the re-use or redevelopment of existing structures and would not result in entirely new built form.  The applicant indicates that as such there would be no harm to the openness of the Green Belt and the development would not result in urban sprawl.  

3.107	Although it is acknowledged that the development would result in 0.29% of the 684ha site being devoted to built development, this still represents 2ha of new built development in the Green Belt and as such it is considered that this in itself cannot be the determining factor as to whether openness has been lost / impacted upon or whether urban sprawl will arise. Although it is acknowledged that the level of built development when considered against the entire site may appear small, it is considered that the development would have a negative impact on the overall openness of the site and in particular the areas of the site where built development is proposed. The SoS judged in the London City Racecourse application that although the applicant sought to mitigate the harm caused to the Green Belt through the careful siting of the development, the development would still have a negative impact on openness. The SoS attached considerable weight to his concern about the impact of the proposals on the openness of the Green Belt.

3.108	It is clear from the applicant’s visual assessment (as discussed later) that the grandstand and racetrack lighting columns would have the most significant impact on openness. The proposed grandstand would be sited at 19 metres aod, and the building would be 25 metres in height giving it a maximum height of 44 metres aod. Sixty-three lighting columns would be erected in a fixed position and so would also be visible at all times. From the visual assessment of the site it is clear that the grandstand and racetrack lighting columns would be visible from a number of distant viewpoints and would have a detrimental impact on openness.  

3.109	PPG2 paragraphs 1.5 to 1.6 outline the purpose of including land in the Green Belt and the objective of Green Belt land. The purposes of including land in the Green Belt are of paramount importance to their continued protection and should take precedence over land use objectives. This confirms that whilst a development may contribute towards the achievement of Green Belt objectives, it may not be acceptable if it conflicts with the fundamental purposes of including land in the Green Belt. 

3.110	The applicant has assessed the SFP proposal against these purposes and objectives indicating that four of the five purposes of including land in the Green Belt are relevant in the context of the SFP scheme. The purpose of preserving the setting and special character of historic towns was considered by the applicant to be irrelevant in the context of this application. The applicant does not consider any element of the scheme to represent ‘sprawl’ when considered in relation to openness due to the percentage of the site devoted to built development, and that no elements of the development are contiguous with the existing built up area. They indicate that the majority of the site would continue to be devoted to open land uses, despite a change in the ratio between recreation and agriculture.   

3.111	It is considered that the site at present acts as a means of checking the unrestricted sprawl of large built up areas. However, it is considered that the proposal would in an incremental way result in sprawl and urbanisation whether when considered as individual components of the scheme or when seen as a single cohesive entity. When considering the London City Racecourse appeal the Secretary of State (SoS) agreed with the Inspector’s conclusions that the site has for many years checked unrestricted sprawl and prevented neighbouring towns from merging.  However the SoS did not attach much weight to the Inspector’s conclusion that the provision of a racetrack would act as an additional check against any sprawl and coalescence with adjacent built up areas, which is considered to be relevant in this case.

3.112	In terms of preventing neighbouring towns merging into one another the applicant states that there would be no tangible change in the existing spatial relationship between Boothstown and Worsley as although the development incorporates some new development this would not result in the coalescence of Boothstown and Worsley. The applicant states that the scheme would lead to the introduction of open recreational uses and the protection and enhancement of the existing woodland framework that would contribute to retaining and safeguarding the open land between Boothstown and Worsley. 

3.113	In terms of this purpose it is considered that given that the fundamental aim of PPG2 is to preserve openness then it follows that if development has an unacceptable impact on openness, which it is considered it does, and is positioned in those areas which currently prevent Boothstown and Worsley from merging, then it cannot be said to be consistent with that purpose.

3.114	In relation to the third purpose, to assist in safeguarding the countryside from encroachment the applicant acknowledges that the proposal would result in some built development. However, they indicate that this would be offset by a wide range of countryside initiatives that would result in a positive impact for the surrounding population through the delivery of a new recreational resource that would contribute towards the aim of safeguarding the countryside from encroachment.

3.115	In relation to this purpose it is considered that the development proposal involves built development and engineering operations and uses of land including large areas of car parking. Although it is recognised that encroachment may occur from appropriate or inappropriate development when considered in terms of PPG2, it is considered that this development represents encroachment as a result of inappropriate development.  

3.116	In terms of the purpose to assist in urban regeneration by encouraging the recycling of derelict or other urban land the applicant considers that the scheme would have a neutral impact in terms of assisting in urban regeneration, by encouraging the recycling of derelict and other urban land. They state that it is not possible to locate such a significant facility within the urban area as no single derelict or other urban site of some 700 hectares available within the urban area. The applicant does not consider it feasible to try and create a viable and attractive Forest Park on a derelict or other urban site. They have also not provided any substantial evidence as to the need for such a facility.

3.117	It is considered that although the site as a whole cannot be transported to an urban location, individual components of the scheme, such as the hotel, could be. The applicant has carried out an alternative site assessment, which takes in a number of alternative urban sites, however the assessment does not consider individual elements of the application. It is concluded that the development of this site in the Green Belt would not help to further this purpose.  

3.118	In relation to the applicant’s assessment of the scheme against the six objectives of including land in the Green Belt, it is considered that the proposal would open up the site for greater public access and therefore would provide opportunities for access to the open countryside for the urban population. However, it should be noted at this point that the site is within the ownership of the applicant and therefore the site could be opened up to the public without permission being granted for the development. 

3.119	The applicant has considered the extent to which the SFP proposals could help to fulfil the six objectives identified in PPG2 paragraph 1.6 concluding that the scheme would impact positively on four of the six objectives, and have a neutral impact on the other two identified. The applicant states that the development would have a positive effect on providing opportunities for access to the open countryside for the urban population through introducing a wide range of permissive routes, which would afford the public legitimate access to an area of countryside that is currently inaccessible. The applicant considers that the proposals would provide enhanced opportunities for outdoor sport and recreation as a result of the nature of the proposals. 

3.120	The applicant has indicated that in terms of retaining attractive landscapes, and enhancing landscapes, near to where people live this would be achieved through the retention and enhancement of the forestry, moss land and landscape attributes of the overall site, in addition to the planting and management regimes associated with the development. It is considered that certain landscape features would be retained and some would be enhanced due to the impact of the development. However it is considered that the development would have some negative impacts (as discussed later in the report) on other areas of the site.

3.121	The applicant has indicated that the proposals would result in a neutral impact on the objective of improving damaged and derelict land around towns. It is agreed that the proposals would have no impact in improving damaged and derelict land around towns. 

3.122	The applicant indicates that the proposals would result in the provision of a wide range of ecological commitments that focus upon enhancement, mitigation and management. As a result, the applicant feels that this contributes towards the objective of securing nature conservation interests and makes a positive contribution to UK and GM Biodiversity Action Plan targets which results in the nature conservation interests of the site being secured. 

3.123	The applicant indicates that the development would have a neutral impact in relation to retaining land in agricultural, forestry and related uses. The applicant’s assessment in respect of this Green Belt objective is contended, as there would be a significant change in land use terms as large areas of land currently devoted to agriculture would be used for recreational use and would therefore not contribute towards achieving this objective.  

3.124	In conclusion the applicant states that the scheme performs satisfactorily in terms of the five purposes of including land within the Green Belt and would play a positive role in fulfilling the six specific objectives for the use of land within a Green Belt. The applicant acknowledges that the introduction of sporting and recreational facilities would have an impact on the landscape, but they state that the positive contributions made by the individual recreational and sporting elements of the proposal would not harm the fundamental Green Belt aim of keeping land permanently open.

3.125	The conclusions reached by the applicant, are in many respects agreed.  However it should be noted that the fulfilment of these objectives does not mean that the development should therefore be considered as appropriate development in Green Belt terms and does not, by itself, justify inappropriate development in the Green Belt.   

3.126	It is considered that the development, when considered as a single entity, would conflict with the role and purpose of the Green Belt, harm its openness and have an adverse impact on its visual amenity. As a result, it is considered that PPG2 paragraph 3.2 is of relevance and it is therefore the responsibility of the applicant to show why permission should be granted (the applicant’s case for VSC’s is outlined later in this planning appraisal). There is Court of Appeal authority that one should not attempt to split development up into parts which are appropriate and parts which are not in the manner attempted by Peel and that if parts are inappropriate the whole development is inappropriate – the case is Kemnal Manor Memorial Gardens Limited v First Secretary of State [2005] EWCA Civ 835 [2006] 1 P&CR 10.

3.127	Very special circumstances (VSC) to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. The following section of the appraisal will assess these other elements of ‘harm’ that should be taken into consideration as part of the application process.

4.	VERY SPECIAL CIRCUMSTANCES 

4.1	It has been concluded that the proposed development would be harmful to the Green Belt by virtue of its inappropriateness.  With regard to Green Belt policy, inappropriate development is by definition harmful to the Green Belt.  Such development should not be approved except in very special circumstances.  Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness and any other harm is clearly outweighed by other considerations.

4.2	Throughout the application process the applicant has always contended that the proposal is appropriate development within the Green Belt.  However, within the grounds of appeal, the applicant states that whilst ‘the Appellant does not resile from the position that it has maintained throughout these discussions…in the interests of minimising inquiry time and reducing its costs and those of other participants, the Appellant’s case will take as its starting point an assumption that the proposed development is considered to be “inappropriate” within the context of PPG2.’ It has always been the view of the Local Planning Authority that the development is inappropriate, a view the applicant has always been aware of but only recently acknowledged. 

4.3	Notwithstanding the above, the applicant submits that if the proposal is considered to be inappropriate development in the Green Belt, there are very special circumstances why planning permission should be granted.  These can be summarised as follows:

•	The unique nature of the site and the need for enhanced public accessibility on a public scale;
•	The current under-provision for horseracing and related facilities in the north west;
•	The horse racing industry need for further facilities;
•	The enabling effect of the racecourse and related facilities for the delivery of the recreational and educational benefits of the scheme;
•	The fact that no credible alternative site for a racecourse could be found elsewhere around the conurbation;
•	The need for and benefits of the significant recreational, educational and sporting provision proposed in addition to the racecourse;
•	The need for and benefits of increases in woodland cover, protection of the natural environment and the introduction of ecological management across the site;
•	The socio-economic benefits of the proposal;
•	The potential contribution to tourism through the interpretation of the social history of Salford; 
•	The enhancement of the image of Salford and Greater Manchester which supports urban regeneration in the wider area; and
•	Wider policy support for the proposal.

Each point will be addressed in turn:

The unique nature of the site and the need for enhanced public accessibility on a public scale

4.4	The applicant asserts that the scheme will deliver a positive impact in terms of access to open space / countryside for the local population on a day-to-day basis, and for visitors from further afield.  The estate will become accessible in a managed way, with 32 km (19.6 miles) of new permissive footpaths proposed, some available for cycle trails and bridle-routes (13km and 18km respectively).  

4.5	It is argued that the site is one of unique inherent interest, located on Bridgewater Canal with its history associated with coal.  Botany Bay Wood is Greater Manchester’s largest mature woodland and the site is the location of some of the earliest mossland reclamation works undertaken in the Victorian era.  

4.6	The applicants consider that such provision is consistent with the Green Belt objective, ‘to provide opportunities for access to the open countryside for the urban population.’

4.7	To support this argument, drawing number 251A 164A (Accessible Natural Greenspace Analysis) has been submitted.  This identifies greenspace provision within the locality including: Lyme Park (556 ha); Tatton Park (404.7 ha); Quarry Bank Mill (180 ha); and Dunham Park (101 ha).  To the north of Manchester there is: Heaton Park (259 ha); Slackbrook Country Park (>100 ha); and Moses Gate Country Park (303.5 ha).  In Wigan there is: Haigh Country Park (150 ha); and Pennington Flash Country Park (200 ha).  On a smaller scale in Salford there is: Clifton country Park (32 ha) and Blackleach Country Park (50.6 ha).

4.8	Whilst useful, this map is deceiving as it only includes sites that are country parks or National Trust sites over 100 hectares.  A number of further parks / greenspace do exist within the region that provide a valuable source of open space, for example, the Mersey Valley trail covers a significant area of land, and is in close proximity to Salford, but is not considered on the map. It is also considered that many of these sites are based on historic buildings and established estates, and that those that are not do not have the level of development proposed as part of this application. 

4.9	The application site has an area of 684 hectares and the applicants have considered the level of greenspace provision on this basis.  However, the entire site would not be accessible, for example Botany Bay will be inaccessible to the public, and as such using the full size of the application site distorts the actual level of greenspace that would be provided.

The current under-provision for horseracing and related facilities in the north west

4.10	The applicant’s evidence in relation to this point is based on the Racing Review document produced by the British Horseracing Board.  It is asserted that the current under provision for horse racing in the North West can be met by the scheme.  The applicant highlights the following:

•	The North West is not as well served as neighbouring regions (Yorkshire and Humber and West Midlands) in terms of numbers of fixtures or courses;
•	The comparative growth in the number of fixtures in neighbouring regions (other regions have grown whilst the NW has lost fixtures);
•	There are less fixtures per million population within the NW compared to neighbouring regions;
•	The poor accessibility of Carlisle and Cartmel racecourses for the main concentration of population in the Mersey Belt; and
•	The proposed location would mean that the course is the nearest racecourse for residents from all the central and eastern parts of the Greater Manchester conurbation, East Lancashire, parts of Cheshire and Staffordshire and for the more westerly local authorities within Yorkshire and Humberside region.  In conclusion, SFP would be the nearest racecourse for 2.2 million people.

4.11	The arguments formed are largely based on evidence within the Racing Review. The ‘need’ has therefore been identified by the racing industry and has not been rigorously tested. Furthermore, this was published in 2003 and will not therefore take into account any new developments.   

4.12	Figure 4.3 of the Needs Statement 2007 states that within a 60 mile radius of Greater Manchester the options for racing are substantially increased by access to the North Midlands and Yorkshire and the need case demonstrated is not therefore sufficient.

The horseracing industry need for further facilities

4.13	The applicants evidence is based upon the British Horseracing Board Racing Review document which highlight the following:

•	The fundamental call for ‘an urgent expansion of the future list’;
•	The need to modernise the racing product through the introduction of a new all weather track, to develop Britain’s position in a global market;
•	SFP would deliver the aspirations of the Racing Review by introducing the only all-weather track in the country, north of Nottinghamshire;
•	Survey evidence suggests strong support from the public for an additional racecourse as the region is poorly served;
•	There is unlikely to be any significant expansion of the racing offer from other courses in the NW region, therefore SFP represents the only significant opportunity to broaden and modernise the racing product in the NW region;
•	The revenues raised from the racecourse would provide the enabling finance to undertake the development of the facilities within the park, particularly the costs relating to the delivery of additional greenspace; and
•	The Racing Review does not identify a need for development in the NW, and more specifically Salford.

4.14	It is considered that the evidence used i.e. the Racing Review is not robust as it is based on evidence from stakeholders in the form of customers, the betting industry and race horse owners and it is therefore not surprising that the betting industry and race horse owners in particular wish to see an increase in fixtures.

4.15	The expansion of all-weather racing is noted in the Racing Review as a means of sustaining the diversity of British racing.  However, it also notes that, ‘The advent of all-weather racing in the winter has drawn a large number of horses away from jumping, putting pressure on field sizes and competitiveness.  If the Office of Fair Trading succeeds in allowing racecourses to race whenever they wish, the foundations of jumping are likely to be undermined and the finances of jumping transferred to all-weather racing.  An important part of the sport of racing would in all probability, ultimately disappear.’  This does not support the introduction of an all-weather course in the NW.

The enabling effect of the racecourse and related facilities for the delivery of the recreational and educational benefits of the scheme

4.16	It is argued that many of the benefits of the scheme are dependent upon the enabling effect of those components which will earn income, in order to cross-subsidise such elements as the recreational and educational components and greenspace provision.  The racecourse and grandstand are highlighted as the most significant parts of the scheme to achieve this.  Without the racecourse and grandstand the ‘country park’ elements of SFP would not materialise.

4.17	There have been no robust financial arguments presented in terms of enabling development.  The level of subsidy is not identified and no regard is had to the revenue generating elements within the proposed development. There is also no evidence as to the relationship between the various aspects of the development, how they would be managed, how the subsidy would be provided and how long this would be maintained. 

4.18	As detailed earlier within this report, many of the Forest Park elements of the proposal are also considered to be inappropriate development within the Green Belt.  It may therefore be the case that the racecourse and grandstand would be enabling other parts of the scheme that are also inappropriate.  The applicant’s assertion that there is an important need for greenspace regionally could make this element viable in its own right.

The fact that no credible alternative site for a racecourse could be found elsewhere around the conurbation

4.19	The applicants have concluded that no credible sites have been found in the search.  The area of search was derived from a 1 hour drive time catchment for Greater Manchester and beyond, centred upon the application site.  The extended to Preston and Burnley in the north, Huddersfield and Halifax in the east, past Macclesfield and Northwich in the south, towards Congleton, and embraced Warrington, St Helens and Skelmersdale to the west.  Sites capable of accommodating only the land needed for the racecourse and associated parking areas were identified.  Possible sites were evaluated against a range of criteria, including policy designations, topography, landscape features and accessibility.

4.20	The availability of alternative sites is a very important ‘very special circumstance’ if a demand for the product can be successfully demonstrated.  It is accepted that an urban location may be difficult and it is therefore considered that the applicant should investigate alternative Green Belt sites.

The need for and benefits of the significant recreational, educational and sporting provision proposed in addition to the racecourse

4.21	A key aim of the SFP scheme is to provide sporting facilities of the highest possible quality to appeal to both spectator and participant (golf, horse riding, cross-country eventing and horse racing).  In addition it aims to provide a new recreation / leisure / tourism resource, with a strong educational emphasis, comprising a range of individual components which are intended to appeal in equal measure to individuals, couples, families, the young and the old and school parties i.e. the broadest cross section of the population.

4.22	The needs statement identifies that the classroom space would enable the scheme to act as a significant educational resource across Greater Manchester and beyond.  The overnight accommodation and camping facilities would be used to facilitate longer educational courses.  It is argued that most other similar educational resources have such facilities.  The presence of on-site management is justified by the fact that other country parks have an on site warden facility.

4.23	The need for workshops and exhibition space is argued on the basis that consultants from the Wildfowl and Wetlands Trust have advised that interpretation space of this nature helps ensure that parks have all year round interest.  The development of these facilities is critical to the scheme achieving its full range of economic, social and educational benefits. Whilst these use are attractive, given the inappropriate nature there still needs to be evidence for demand and that has not been provided.

4.24	The need for the hotel is argued as there is a requirement for good quality accommodation for competitors, visitors and tourists to facilitate their stay at SFP.  This would be important for corporate, hospitality packages offered on race days.  The applicants have identified 28 hotels (3* - 5*) within 10 miles of SFP, in addition, within a 10 mile radius there are 1,500 Travelodge style rooms available, with 60 of these available within a 3 mile radius.  It is argued that this current hotel accommodation is insufficient to meet the anticipated needs.

4.25	In terms of the equestrian centre, a British Equestrian Trade Association (BETA) survey carried out highlights that equestrianism in the UK is a growing and popular activity.  The survey identified a large latent demand of people who would like to, but do not currently participate in equestrian activity.  SFP would provide an opportunity to meet this latent demand in the sub region and region.  The BETA survey indicates that participation and interest in the sport is likely to keep on growing, especially with the coverage of the London Olympics.  There are only a modest number of equestrian facilities in and around Greater Manchester, with the liveries at Moss Bank Stud (on SFP site) being the only listed liveries in Salford.  

4.26	Eventing in the NW region is not as well served by 3 day evening courses as other regions.  However, the NW does have a similar concentration of events as some, the northern regions have far fewer fixtures than other more southerly regions.  There is limited supply of fixtures in the summer months of May and June.  Most events are based in Cheshire.  SFP could fill this void.  Show jumping events in Greater Manchester do not take place in the winter months as there is a need for indoor facilities.  Equestrian standards in Greater Manchester do not conform to standards required by the British Show Jumping Association.

4.27	Many of the arguments for having certain aspects of the development appear to be based on the reasoning that other country parks have these facilities.  It is conceded that a development of this sort would generally require the facilities as indicated but the justification provided by the applicant is not robust.

4.28	The ‘benefits’ of the hotel are unlikely to benefit the people of Salford as this aspect of the development is not aimed at local people.  Other successful racecourses do not have on site hotel facilities (e.g. Aintree) and are not needed for the racecourse to run successfully.  There are two hotels within a 1 mile radius of the site.  Furthermore, the need for the hotel has not been addressed in relation to PPS6 – Planning for Town Centres.  

4.29	PPS6 requires that new development should be focussed in existing centres in order to strengthen them. Paragraphs 3.3-3.27 of this document set out the considerations, which should be taken into account by local planning authorities in determining application for town centre uses.  The application proposes to develop ‘town centre uses’ of a hotel and associated function and leisure facilities outside of a town centre and therefore justification has to be provided to assess the impact of the development.  Consideration is required of the quantitative and qualitative need for the development.

4.30	As with the Racing Review, there is concern about the independent nature of the evidence and it is therefore considered that less weight can be attached to it than if it were independent.

The need for and benefits of increases in woodland cover, protection of the natural environment and the introduction of ecological management across the site

4.31	The applicants state that the development would bring new woodland planting in accordance with the aims of the Red Rose Community Forest.  This would contribute significantly towards achieving the Red Rose Forest target of planting 25 million trees across Greater Manchester over the next 40 years.  It is stated that the NW has the lowest tree coverage across the whole of England.

4.32	The applicant lists the benefits as the creation of 20 new waterbodies and marginal swamp and redbeed habitats, and the planting of 40 hectares of new broadleaved woodland.  Habitat enhancement would benefit at least 12 species of conservation concern and help deliver a number of UK and Greater Manchester BAP targets.

4.33	No indication has been given as to the level of benefits, i.e. whether this is a desired outcome or an identified need, who the benefits would serve, what the alternatives are for the site and whether those alternatives are undesirable and unavoidable.  It has not been demonstrated whether it is possible to provide 40 hectares of woodland in alternative locations and whether there are alternative schemes in place to meet this target.  It has also not been demonstrated whether the woodland element of the scheme could go ahead without the need for this development as a whole.

The socio-economic benefits of the proposal

4.34	The applicants argue that the scheme would result in the creation of between 260 and 270 full time equivalent jobs in a local authority area that has significant socio-economic problems resulting in a number of disadvantaged communities.  Salford’s Economic Development Strategy highlights encouraging investment in the City as one of its three key strategic objectives through pursuing a number of flagship schemes that have the potential to create employment in their own right.  The applicant highlights the potential economic spin offs as a result of the development in terms of attracting new business to the area.

4.35	It is not considered that SFP can be a major generator of jobs when providing 260-270 full time jobs.  In addition, there has been no indication as to level of benefits, whether this is a desired outcome of an identified need and who the benefits would serve.

The potential contribution to tourism through the interpretation of the social history of Salford

4.36	The applicant highlights the current tourism offer associated with Worsley and the scope for the restoration, management and interpretation of the Worsely New Hall Garden and the contribution of the development towards the development of Worsley Village as a ‘heritage’ visitor destination.

4.37	The applicant states that the commercial elements of the scheme would facilitate the development of the important heritage initiatives by cross-subsidising the Garden Project for phases 1 and 2. No evidence has been submitted to support this contention.

4.38	This is not considered to be a very special circumstance to overcome inappropriate development within the Green Belt.

The enhancement of the image of Salford and Greater Manchester which supports urban regeneration in the wider area

4.39	The applicant states that a prestige scheme of this type would raise the profile of Salford and Greater Manchester in a positive way, to a significant degree through national media coverage of racing events etc, plus development of the area as a specific destination for visitors from Salford, Greater Manchester and from further afield.  The applicant states that the green theme of the development would provide a positive base for marketing and promotional material, so enhancing the image of Salford as a 21st Century modern city to residents, visitors and investors.  The development of parkland and open space can act as a catalyst for regeneration and attract people to the area to both live and to work. Again little explicit and quantifiable evidence has been submitted to enable a proper assessment to be made of this general claim. 

4.40	This is not considered to be a very special circumstance to overcome inappropriate development within the Green Belt.

Wider policy support for the proposal

4.41	The applicant considers that the scheme would call into play a broad range of national, regional and local policies, which are supportive of a range of initiatives.

4.42	This report has demonstrated that the proposal would conflict with other development plan policies.  Firstly, concern is raised on ecological grounds. Comments have been received from the Environment Agency and the GMEU.  The EA have removed their objection but the objection of the GMEU still stands.  The application therefore has the potential to conflict with PPS9 and policies EN7, EN8, EN10 and EN12 of the City of Salford Unitary Development Plan.  

4.43	Secondly, objection is raised on transportation grounds.  The modelling undertaken by the applicant is unacceptable and insufficient information has therefore been submitted to demonstrate that the proposal would not have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation.  As such, the proposal is contrary to PPG13, policies A1, A2 and A8 of the UDP and policies RT2 and RT9 of RSS.

4.44	Notwithstanding this, Green Belt policies are not complied with and these are the key determining factor in the consideration of this application.

VSC’s Conclusion

4.45	In conclusion and on the basis of the information that has currently been put forward in support of the application, it is not considered that very special circumstances have been demonstrated that would override the harm arising as a result of the inappropriate nature of the development and to warrant a decision that would not be in accordance with the development plan for the area.

5.	VISUAL IMPACT AND DESIGN QUALITY 

5.1	The applicant carried out a visual assessment, which appraises the construction period; a year after opening; and seven years after opening (to portray establishment of any new planting proposals). The applicant has used thirty-eight viewpoints from around the site taking into account:

•	The sensitivity of the view and/or viewers;
•	The magnitude of change to the view – including the amount of view affected;
•	The quality and nature of the new view; and
•	The permanence or temporary nature of the change

5.2	The assessment has provided us with the information required to assess the positive and negative visual impacts of that which would be seen.  

5.3	The site is characterised by agricultural and woodland land uses, although there are a number of subtle variations across the site. The site is largely undeveloped with only a few farms within the application site. The topography of the site to the south of the Bridgewater Canal is largely flat and low lying, generally between 21-22m aod. North of the canal the natural landform rises, at first steeply and then fairly steeply. The northeast corner of the site at Worsley lies at 60m aod. The landform of the farmland within the site to the west of Botany Bay Wood and the Canal are three areas of former landfill, which lie within the site. The landfills have a slightly domed landform which are level with the canal towpath to the north, and which slope steeply down to the flatter land on their southern sides. East of Botany Bay Wood the agricultural land stretching out to the motorway is flat and relatively open. North of the Canal to the west of Boothstown the land rises gently to the A580 East Lancashire Road.

5.4	The scheme involves a number of facilities dispersed across a large site. The visibility of each of the new facilities would vary depending upon the viewpoint taken and the siting, height and bulk of each new component. Due to their height, the grandstand and racetrack lighting columns have the largest potential zone of visibility in the wider landscape. The hotel and equestrian centre are sited at existing farmsteads and the re-development of these areas would not affect the existing open views, as they are no higher than the existing buildings and therefore their zone of visibility would extend no further than the existing level. The Forest Centre buildings would be located in an enclosed landscape where open views are limited. The buildings have been designed to ensure that the buildings are not visually intrusive and have a countryside character. The applicant states that the scheme would have a neutral or negligible impact overall on the majority of existing views towards the site. 

5.5	Due to their height, the grandstand and racetrack lighting columns have the largest potential zone of visibility in the wider landscape when compared to the other scheme components. The ground floor of the grandstand building would be located at 19m aod, and the building will be 25m high giving it a maximum height of 44 metres aod, and 102 metres long. Surrounding it the saddling stalls and stables will be 4 metres in height, and the stable lads accommodation would be 8 metres to the ridge. The basal parts and sides of the building would be glazed or mirrored, and the curving roof section would be clad in a mixture of translucent sheeting, mill finish, metal profiled sheeting and curved tinted glazing to the viewing galleries. The length of the roof would be subdivided by raised metal clad ribs located on the main structural support grids. 

5.6	The grandstand would be visible from a number of near and distant viewpoints. The viewpoints that would have the most significant visual impact would be from the near viewpoints (footpath W97 west of grandstand site). The grandstand would be visible from a number of distant viewpoints however the most significant of these would be from the residential properties on Leigh Road, the southwest edge of Boothstown (Amberhill Way), and the properties around Boothstown Marina. Although the grandstand would be visible from a number of distant views around the site these would only have a neutral or negligible visual impact.     

5.7	The lighting columns situated around the course have been designed to provide illumination for evening meetings. There would be sixty-three lighting columns, spaced at approximately 40 metre centres. On the north side of the track, alongside the six-furlong straight, the columns would range from a height of 36.5 metres (including head frame) near the grandstand, gradually reducing to the east to 30.5 metres at the eastern bend, and to 21.3 metres at the start of the six-furlong straight. On the south side of the track all columns would be 21.3 metres high. The columns would be a slender circular tapered design with a galvanised finish and would be static in nature. The floodlights would be installed in clusters on a head frame at the top of each column, with each cluster varying from a maximum of twenty fittings on the highest columns near the grandstand, to as few as 5 fittings. The majority of columns would carry between 12 and 16 fittings. 

5.8	The racetrack lighting columns would be visible from a number of viewpoints around the site. The most significant impact would be from footpath W97, west of the grandstand site, Keepers Cottage Kennels and residential properties on the southwest edge of Boothstown (Amberhill Way) and around Boothstown Marina. The applicant’s visual assessment indicates that the racetrack lighting would result in slight adverse impact at the following locations; Leigh Road and the residential properties along it, and the Bridgewater Canal paths at Boothstown. Although the lighting would be visible from a number of further viewpoints around the site the applicant states that the visual impact of the development would be neutral to negligible.  

5.9	The lighting columns would provide illumination during evening racing. The floodlights would be controlled so that the floodlighting would only operate at high settings during races, and would operate at a reduced setting between races. The lighting around the track is designed so that it can be controlled by sector to enable only those lengths of track needed for any particular race to be lit. The applicant indicates that evening racing would be relatively infrequent with last races finishing at 9pm, when the racetrack lighting would be switched off. Light emitted from the lighting columns during the evening races would result in ‘skyglow’. This would lead to an urbanising effect on the area due to the fact the area is currently darker than the urban area. 

5.10	Paragraph 34 of PPS1 states that design which is inappropriate in its context, or which fails to take the opportunities available for improving the character and quality of an area and the way it functions, should not be accepted.

5.11	PPS7 states that the Government’s overall aim is to protect the countryside for the sake of its intrinsic character and beauty, the diversity of its landscapes, heritage and wildlife, the wealth of its natural resources and it must be enjoyed by all.  The statement goes on to say that all development in rural areas should be well designed and inclusive, in keeping and scale with its location, and sensitive to the character of the countryside and local distinctiveness.

5.12	PPG2 paragraph 3.15 indicates that, “the visual amenities of the Green Belt should not be injured by proposals for development within or conspicuous from the Green Belt which, although they would not prejudice the purposes of including land in Green Belts, might be visually detrimental by reason of their siting, materials or design.” Although PPG2 paragraph 3.15 remains the senior policy in consideration of applications in the Green Belt regard should also be made to policy DES1 of the Salford UDP. Policy DES1 requires development to respond to its physical context, respect the positive character of the local area in which it is situated, and contribute towards local identity and distinctiveness. Regard will be had to the impact on, and quality of, views and vistas; and the scale of the proposed development in relation to its surroundings. 

5.13	It is acknowledged that the applicant has made attempts to reduce the visual impact of the development through careful siting of the development (in particular locating the hotel and equestrian centre at existing farmsteads); the reuse of some buildings for the hotel; replanting trees and vegetation to screen new development; and the careful illumination of new access roads (access road from A580). Despite this it is considered that the proposed development, with particular reference to the grandstand and the lighting columns would significantly change the existing open character of the area and appearance of the site. 

5.14	The proposed development of the grandstand and associated enclosure, the hotel, and the equestrian centre would contribute to this change from a site that in its current form is largely agricultural in nature. In addition to the built form that is proposed as part of the development the character of the area would alter due to the intensive use of the land for sport and recreation. As a result the application site would become a centre for intensive activity, particularly on race days, but also on all other days due to the recreational aspects of the facility. It is considered that the changes in intensity and activity, compared to agricultural uses would lead to the surrounding area becoming less rural and more suburban in character as the agricultural character of the site is changed due to the proposals. When considering this in relation to PPG2 paragraph 3.15, it is considered that the development would to some degree impact upon the visual amenities of the Green Belt.  

5.15	In relation to the impact of ‘sky glow’ from the lighting columns, the Council’s lighting consultant has used a document produced by the Institution of Lighting Engineers (ILE) titled ‘Guidance Notes for the Reduction of Obtrusive Light’ to assess the impact of the lighting columns on the surrounding area. The document contains specific guidance that determines the level of sky glow considered acceptable from new developments. The guidance advises that sky glow upward light ratio should be a maximum of 2.5%. An assessment of the lighting columns indicates that the luminaries positioned on the columns and the grandstand structure would emit an upward light ration of 1% which is below the 2.5% maximum threshold set for this land classification and is considered acceptable. Policy EN17 of the adopted UDP states that development proposals that would be likely to cause or contribute towards a significant increase in pollution by reason of artificial light will not be permitted unless they include mitigation measures commensurate with the scale and impact of the development. It is essential that any impact from light pollution should be addressed through sensitive siting and design, keeping any light spillage to a minimum and thereby reducing visual disturbance to the amenity of the Green Belt and also any neighbouring residential properties.   

5.16	In terms of frequency, the applicant’s submission indicates that there would be 30 race days per year. However, of these 30 meetings, evening events would be infrequent and would finish at 9:00pm when the track lighting would be switched off. In addition to this, during the summer months the need for floodlighting would be reduce as a result of longer day light hours, which in turn would reduce the impact of ‘skyglow’ from the floodlights. The applicant would control the floodlights during race meetings; using the high setting during races, and the lower setting between races. The track lighting would be controlled by section so that only those sections of track that are required for the race are.  It is recognised that there would be a disturbance to the amenity of the Green Belt and also a limited affect on nearby residential properties, however it is considered that the proposed floodlight design would not have a objectionable impact in terms of skyglow and as such consider that it be acceptable and in accordance with policy EN17 of the UDP.

6.	IMPACT OF THE DEVELOPMENT ON ECOLOGY 

6.1	The applicant has carried out ecological assessments from April to July 2000, February to July 2001 and December 2002 to July 2003. These surveys included a range of desktop surveys, Phase 1 Habitat Survey, Breeding Bird Survey, Winter Bird Survey, Baseline Bird Evaluation, Amphibian Survey, Water Vole Survey, Badger Survey, and a Bat Survey. The surveys considers the impacts of the proposed development, in terms of the effects on identified Valued Ecosystem Components (VEC) taking into account direct, indirect and cumulative ecological impacts; an evaluation of the importance of an ecosystem feature; an assessment of the magnitude of the impact on the VEC; and Ecological Impact Significance. The ecological assessment also considers a wide range of mitigation measures. Summary of Habitats and Species 

6.2	The ecological surveys identify a number of Valued Ecosystem Components (VEC) both within and outside the application boundary. A heronry has been identified in the central/western section of Botany Bay Wood and is a proposed Site of Special Scientific Interest (SSSI). The heronry is composed of 110 occupied nests and is understood to be the largest in the northwest of England and probably one of the five largest in the UK. 

6.3	There are three sites designated as Sites of Biological Importance (SBI), including Bittern Pits Wood, Botany Bay Wood, and Middlewood. These are designated as Grade C: More than local importance; Grade A: County Importance and Grade B: District Importance respectively. 

6.4	The southwest corner of Botany Bay Woods is a former habitat of wet modified bog, which is now a monoculture of purple moor grass, and is of high value to invertebrates. Degraded raised bog still capable of restoration is a recognised habitat of international importance. The review of Greater Manchester Mossland BAP recognises all types of mossland habitats as important including unmodified, modified and degraded bogs. Salford’s SPD Nature Conservation and Biodiversity (2006) recognises the importance of this resource for the district. This part of the site however, is being used as part of the mitigation for the Astley Moss East sand and gravel excavations and therefore should not be counted in any benefits to SFP. 

6.5	There are 18 ponds within the application boundary, many of which are surrounded by willow and hawthorn scrub, which prevents light from reaching the open water. Some of the ponds suffer from eutrophication due to fertiliser run-off from neighbouring fields. Despite this, the ponds and associated drains provide key wildlife corridors and ‘stepping stones’ within the site which provide habitats for amphibian metapopultaions and also feeding areas for herons, reed buntings, ducks and other birds.

6.6	There are a number of main rivers throughout the site including Whitehead Brook and Stirrup Brook; Moss House Farm Brook; Sniggley Brook; Shaw Brook; Red Box Drain; and the Blue Box Drain. Watercourses in the area have been over-deepened and re-sectioned for flood defence and land drainage reasons. The network of brooks and ditches provide important wildlife corridors for water voles, reed buntings, amphibians and feeding areas for herons.

6.7	There are very few hedgerows on site, however of those most are associated with the Avenue and the roads leading to Moss House Farm and away from Malkins Wood Farm. There are no hedgerows on site that would qualify as “important” under the Hedgerow Regulations 1997. The landscape north of Botany Bay Woods is important for wintering flocks of linnet, red bunting, finches, tits fieldfare/redwing and song thrush.

6.8	The applicant has identified a significant number of breeding and visiting bird species associated with the site as follows: Barn Owl, Bullfinch, Buzzard, Corn Bunting, Curlew, Dunnock, Goldfinch, Green Sandpiper, Grey Heron, Grey partridge, House Sparrow, Kestrel, Lapwing, Lesser Spotted Woodpecker, Linnet, Long-eared Owl, Nightjar, Quail, Reed Bunting, Short-eared Owl, Siskin, Skylark, Song Thrush, Snipe, Starling, Swallow, Teal, Tree Sparrow, Turtle Dove, Willow Tit, Woodcock, Yellow Wagtail and Yellowhammer. A significant number of these, in particular the farmland birds are identified as UK Biodiversity Priority Species and are specifically highlighted as an important Salford biodiversity resource in Salford’s Nature Conservation & Biodiversity SPD. The SPD recognises that Salford holds important County populations of some farmland birds such as corn bunting and yellow wagtail. 
6.9	Outside of the application boundary Astley and Bedford Moss SSSI is located 2km directly west of the proposed development. This SSSI is a candidate Special Area of Conservation (cSAC). Two Grade C SBI’s have been identified:  Alder Forest Marsh lies to the east of the M60 and Fox Hill Glen lies outside the proposed development footprint of Barton Aerodrome. 22 ponds have been identified within 500 metres of the site.

6.10	Amphibian activity has been identified through the survey of ponds and small populations of Great Crested Newts (European Protected Species – Habitats Regulations 1994 as amended) have been found in ponds to the north and to the south of the Bridgewater Canal. 

6.11	Due to the nature of the landform and drainage of the site SFP has the potential to be ideal for water voles. Water voles have been identified in the following watercourses; on the Moss House Farm Brook and also in a small tributary; the Sniggley Brook and tributary ditches; and the Shaw Brook north of the Bridgewater Canal.

6.12	Bats (European Protected Species – Habitats Regulations 1994 as amended) including bat roosts have been identified at Malkins Wood Farmhouse, Malkins Wood Farm and foraging/commuting activity along hedge lines near the farm. 

6.13	Although a disused badger sett was found in 2000, no evidence of badger activity was found in 2003. Brown Hares (UK Biodiversity Priority Species) have been identified on site although no detailed survey was undertaken.   
6.14	The ES submitted by the applicant identifies the ecological impacts resulting from the development, and assesses the magnitude of these impacts. The following section of the appraisal details these impacts, outlines the mitigation proposed, and assesses the appropriateness of the mitigation offered. 

Habitats

6.15	The proposed SSSI would be adopted as a Nature Reserve with public access restricted during the breeding period resulting in the western end of the wood being quiet and undisturbed. The ES indicates that this would have a positive impact upon the heronry. Woodland management would continue to be focused on the retention and favouring of trees with suitable crowns for nesting and retention of an understorey. The woodland within the Heronry Reserve would be managed specifically for the benefit of grey herons on the basis of a rolling programme of 5-year plan of operations to be agreed between the applicant, Natural England (previously English Nature), the Forestry Commission and the Council, taking advice from the Lancashire Wildlife Trust and the Greater Manchester Bird Recording Club. 

6.16	Public access would be restricted within the pSSSI and no new recreational trails would be created. The nearest trail would be a path/cycleway, which runs along the edge of the pSSSI, 350 metres from the core heronry area. The forest play space with tree top walkway would be 1 kilometre from the pSSSI and 1.4 km from the Core Heronry Area. The ES indicates that this would have no impact on the heronry. 

6.17	In relation to the Timber Workshop there would be no effect on the heronry arising from visual intrusion, public access or vehicle movements due to distances from the heronry. The closest position of the timber workshop and associated timber storage areas is 250 metres from the pSSSI and 700 metres from the nesting area. 

6.18	During the construction phase of the Forest Centre, Grandstand and racetrack noise would be generated. However, the ES states that there would be no effect on the heronry as a result of this. Noise during race meetings and other events would be generated from the crowd and the public announcement / tannoy system. Despite this no impact is predicted in the ES from noise disturbance associated with race meetings. The cross-country eventing course would run around 400 metres from the heronry at its closet point, and it is expected that at most would only attract about 50 supporters around each jump. The ES indicates that there would be no noise impact predicted as a result on the heronry.      
6.19	The racecourse lighting would at its closest point be located 700 metres from the pSSSI boundary and 1km from the heron nesting area. The applicant states that the impact from the lighting would be minimised by the bespoke lighting design (further details are of this are outlined earlier in the report). The applicant states that the additional lighting on the herons would be negligible due to the screen of trees provided by Botany Bay Wood. The ES concludes that there would be no disturbance to the heronry from public access, lighting or noise, either during construction or operation. 

6.20	Policy EN7 of the UDP relates to developments affecting the special interest of a Site of Special Scientific Interest (SSSI). Astley and Bedford Moss is identified as a SSSI and is located outside of the application site boundary. The development would have no impact on this designated site and is therefore in accordance with policy EN7.

6.21	GMEU and Lancashire Wildlife Trust have expressed some concerns relating to expected visitor numbers and the impact that this would have on the Heronry. However, Natural England have indicated that the proposed development should not result in a significant impact. The proposed Nature Reserve Management Plan would deal specifically with issues relating to the maintenance of the heronry and the pSSSI. It would include monitoring of visitor activity and effectiveness of visitor management to maintain the isolation and lack of disturbance on this part of the site. Natural England have indicated that the construction and operation of the proposed development would not materially affect the heronry provided that the proposed mitigation measures are implemented to prevent disturbance during the bird-nesting season. The applicant requires licences for protected species and these would be based on the mitigation proposals being of an appropriate level. In light of the consultation responses received and the information in the ES/ESS it is considered that this part of the application is in accordance with policy EN10.  
Sites of Biological Importance (SBI’s)
6.22	The applicant states that Botany Bay Wood SBI would encounter minor negative impacts both during the construction and operational phases of the development in relation to the Forest Visitor Centre, Timber Workshop and play space. The proposals for this part of the site would lead to direct impacts in relation to loss of woodland habitat, altered abiotic/site factors through soil compaction and erosion, and also disturbance to woodland birds.

6.23	A Woodland Management Plan would be produced by the applicant which would determine how the woodland areas would be managed to meet key objectives in terms of mitigating the impact of the development. The management of Botany Bay Wood SBI would be focused on the retention and favouring of trees with suitable crowns for nesting and retention of an understorey. The ES indicates that the proposals would have a minor positive impact in relation to woodland management and this would be secured by the entering of the whole wood into a management plan based on the UK Woodland Assurance Scheme. Lowland Broadleaf Woodland Biodiversity Action Plan targets would be set in order to improve the quality of the balance of the wood and mean that the wildlife holding capacity of the wood is unaffected by the development. The applicant states that the overall increase in ditch and wetland habitats within the Forest Park would favour the continued expansion of the heronry.

6.24	The applicant identifies four main impacts at Hollins Wood SBI relating to the physical loss of woodland cover; the potential impact on bird/bat flyways; the potential impact on rooting of edge trees where the road runs alongside the woodland; and lighting effects from the racetrack start point. The applicant states that the SBI would encounter minor negative impacts at both construction and operational phases in relation to site access and infrastructure. The introduction of new woodland and woodland management would lead to a minor positive impact. When considering the impacts cumulatively the short term minor negative impacts would be mitigated in time by additional new planting to increase wildlife capacity. The applicant indicates that there would not be a long-term impact on Hollin Wood SBI.

6.25	New planting and woodland management would be undertaken at Hollin Wood SBI to mitigate the impacts outlined above. New planting of native woodland species around the eastern margin of the wood would bring additional habitat for woodland birds. The wood would be managed resulting in the removal of sycamore and replanting of native species, particularly wet woodland species.  
6.26	The applicant indicates that 15 trees would be lost at Bitterns Pits Wood SBI resulting in a break in the canopy of 10 metres. Minor negative and negligible impacts are predicted during the construction and operational phases of the development respectively, in relation to site access and infrastructure. The introduction of new woodland and woodland management would lead to a minor positive impact. When considering the impacts cumulatively the short term, minor negative impacts would be mitigated in time by additional new planting to increase wildlife capacity and through the avoidance of disturbance.

6.27	The trees lost at Bitterns Pits SBI would be compensated by the planting of new native woodland, particularly wet woodland species on the western and southern aspects of Bitterns Pits woodland and by the creation of a “wood pasture” landscape on the eastern side of the wood. There would be no public access into Bittern Pits Wood, recreational activity associated with the Forest Centre would be restricted to the south of the access road, except for multi-user paths to link to the canal towpath. Woodland management would be introduced to the wood, which the applicant states would result in a major positive effect on Bittern Pits Wood and particularly on the way woodland habitats and bird species are supported.
 
6.28	The impact of development on Middlewood SBI would result in the loss of 0.52ha of woodland, which will result in habitat loss, and altered abiotic/site factors. There would also be indirect impacts in relation to the reduction in habitat quality reducing population viability, and through fragmentation due to canopy gaps, lighting effects and potentially the restoration of the Middlewood Gardens. Middlewood SBI would encounter minor negative impacts at both construction and operational phases in relation to site access and infrastructure. The introduction of new woodland and woodland management would lead to a minor positive impact. The golf course would have a minor negative and neutral impact during the construction phase and operational phase respectively. When considering the impacts cumulatively the construction phase would cause minor negative effects, which would be moderate to negligible impacts as new habitats are established nearby.

6.29	Mitigation would be provided for Middlewood SBI through new woodland planting and the introduction of woodland management to favour retention of mature and over mature broadleaves. The applicant intends to plant 7.2 hectares of new woodland copses around Middlewood on the golf course, which would result in a net gain of 6.25 hectares of woodland in and around Middlewood. The impact of new woodland management around the Worsley New Hall Garden Project area would favour the retention of mature and over mature broadleaves. 
6.30	Policy EN8 of the UDP clearly indicates that development that would adversely affect the nature conservation value of an SBI will only be permitted where the benefits of the development clearly outweigh the reduction in the nature conservation interest for which the site is protected; the detrimental impact on the nature conservation interest of the site has been minimised as far as is practicable; and appropriate mitigation is anticipated to ensure that the overall nature conservation interest of the area is not diminished. It is considered that the mitigation measures set out by the applicant in the ES would result in an appropriate level of mitigation to ensure that the overall nature conservation interest of the SBI’s are not diminished, and therefore should be considered to be in accordance with policy EN8. 

6.31	The development would result in the loss of trees at Middlewood, Bittern Pits Wood, Malkins Wood Farm, and Hollin Wood. Policy EN12 Important Landscape Features of the UDP indicates that where any development would result in the loss of, or detrimental impacts of an important landscape feature, a replacement of at least the equivalent size and quality will be required. The applicant has proposed to compensate the loss of woodland in these areas by planting native woodland species. The planting of these replacement trees would enhance the habitat for woodland birds and would result in the planting of 7.2 hectares of new woodland around Middlewood creating a net gain of 6.25 hectares. In total the scheme would deliver 42ha’s of new woodland and it is considered that this is in accordance with main thrust of policy EM1(D) of RSS.

Mature plantation woodland/broad-leaved semi-natural woodland

6.32	The ES identifies that new woodland planting and management on lowland broadleaved and wet woodland resources would result in a major positive effect. The applicant states that 42 hectares of new woodland would be created in the Forest Park, of which the majority would be native species. At least half of the new woodland would be “wet woodland” habitat; a type that is prioritised in the UK Biodiversity Action Plan (BAP) and the Natural Area targets for the Urban Mersey Basin. The balance would be lowland broadleaved woodland, which is another UK BAP/GM BAP priority. This approach leads to a 20% net increase in woodland in the long term as the woodlands mature and a positive magnitude impact on habitats of UK and Greater Manchester priority, resulting in a moderate positive significance. When considering the impacts cumulatively, new woodland planting would result in minor positive biodiversity gains. The management of the existing woodlands would create a feature of value, which can be considered to be a moderate positive impact.    

Swamp

6.33	There are two areas of Common Reed (Phalaris arundinacea) dominated swamp that would be affected by the proposed development. The first is the 0.7ha area of swamp immediately south of Moss House Brook and east of Keepers Cottage Kennels. The second area of swamp is near the Bridgewater Canal south of the Worsley Garden Centre and Middlewood, covering an area of 0.4ha. The loss of swamp during the construction phase would represent a loss of greater than 50% of existing swamp on the whole of the site resulting in a high magnitude impact. 
6.34	To compensate for the loss of swamp habitat, 17 new waterbodies would be created and four existing ditches and swamps would be re-profiled to increase swamp, reedbed and open water habitat, resulting in a net increase of about 16 hectares of various wetland habitat types, some of which may support swamp. The applicant indicates that this is in line with the GMBAP aim of increasing the area of swamp and reedbed within Greater Manchester. The ES indicates that the phasing of the construction programme to allow advance creation of swamp and open water habitats prior to the loss of existing habitats means that at no time would there be less swamp habitat than at present.  

6.35	It is considered that the mitigation provided is sufficient to compensate for the identified losses of swamp during the construction phase and should be considered to be in accordance with policy EN8 of the UDP.  

Ponds

6.36	The proposals would result in the loss of three ponds, two where the racetrack is proposed and one at Booths Bank that would make way for the golf course. The other ponds on site would encounter a minor negative impact during the construction phases of the following; site access and infrastructure, racecourse car parking, racetrack, grandstand and ancillary buildings. When considering the impacts cumulatively there is potential for minor negative impacts during the construction phases which can be mitigated by advance habitat creation. Despite this, long-term major gains are expected resulting in a major positive impact.
6.37	Seven existing ponds would receive management and a further two field ponds would be created adjacent to pond 1 to try to restore newt population viability. Four of the water bodies would be created as “off-line” pools; eleven new ponds would be created on the Southern Golf Course; one restored pool at grandstand; one new pond at Moss House Farm; one at the lake near the centre for sustainable living; and a number of newly created or managed ponds in a farmland setting. 
6.38	It is considered that the mitigation provided is sufficient to compensate for the identified losses outlined above, and therefore should be considered to be in accordance with policy EN12 of the UDP.  
Watercourses

6.39	The line of the Moss House Farm Brook would be retained through the grandstand area but re-profiled and it would be crossed by a number of bridges. There would be culverting of three sections of two non-main river tributary ditches of the Moss House Farm Brook to allow for the positioning of the racetrack. The Whitehead Brook and the Shaw Brook would be crossed by two access roads. An unnamed ditch would be crossed by the eastern access road, using a box culvert with mammal shelf. Fairways 3 and 4 would cross the Shaw Brook in the Southern golf course but it would be retained in open cut apart from two bridge crossings. Sniggley Brook would be culverted to pass under the road, footpath and racetrack. One tributary ditch of the Sniggley Brook would be realigned to allow construction of the racetrack. The length and continuity of the watercourses would be maintained by ensuring that all crossings and culverts incoporate the full existing channel width plus at least a mammal shelf, and that any losses due to culvertings or diversion would be compensated by on-line or off-line watercourses/pond creation to ensure the length of the water and bank are maintained.       

6.40	In the absence of successful mitigation, the ecological impacts identified in the ES are as follows: Shaw Brook: minimal negative; Whitehead Brook: minimal negative; Sniggley Brook: major negative impact; and Moss House Farm Brook: moderate negative impact.
6.41	The applicant has indicated in the ES that the existing degraded watercourses would be de-silted, enhanced and re-stocked with marginal vegetation, and buffer strips would be implemented between all watercourses and areas developed to retain existing river habitat.

Farmland Habitat 

6.42	The proposed development would have an affect on how the whole area is farmed and managed resulting in a number of changes in land use.  Some actively farmed areas would be taken out of agricultural production as a result of the development of the racetrack, grandstand, and woodland for example. Some areas of abandoned farmland would be brought into new uses with different vegetation and would no longer be managed as farmland. Some areas of abandoned farmland would be brought back into active farm management, or would be farmed in a different manner than at present, using best practice methods including the DEFRA Countryside Stewardship scheme. 

6.43	The farmland area is of particular value to birds of open countryside and brown hares. The applicant would submit an Agricultural Habitat Management Plan, which would apply to all farmed areas under control of the Equestrian Centre, the Racetrack, the Forest Park and Manor Farm. Farming practices will support the feeding and breeding requirements of each of the Red list UKBAP species currently breeding on site.
 
6.44	A net reduction of 187-hectares (40%) of farmed land would result due to changes in land use, leaving 279 hectares of land being actively farmed. Of the 187 hectares, 121 hectares is attributable to changes of use to vegetation cover, for example new woodland, golf course roughs, ecological grasslands and wetlands. 55 hectares would be amenity grassland and 11 hectares would be for infrastructure and all weather surfacing.  

6.45	The ES indicates that 223 hectares of farmland would be managed in ways that are, at least in part, favourable to birds of highest nature conservation concern. 135 hectares would be managed as spring-sown arable land and 56 hectare of farmland would be managed primarily for grazing and silage. Chat Moss is of recognised regional value for its farmland habitats. The ES indicates that the impact of this reduction on actively farmed areas on Chat Moss as a whole would be a minor negative. 

6.46	Consultation with GMEU indicates that in line with PPS9: A Guide to Good Practice, not only protection and maintenance of biodiversity features should occur but also enhancement and restoration of the sites biodiversity should be achieved. GMEU acknowledges that features of biodiversity value would occur within the proposal but it may be different from what currently occurs. To achieve this for the Farmland habitats all farm holdings within the site boundary would be required to enter into a Farm Management Plan as part of their tenancy agreement. The applicant has however provided no information as to how this would be implemented. It should be noted that the proposed changes to farm tenancies cannot be required or enforced by planning conditions or planning obligations. Despite this, entering into a Farm Management Plan may result in the beneficial management of non-agricultural features including hedgerows, ditches, headlands and copses.

Management Plans

6.47	In addition to the Agricultural Habitat Management Plan and the Woodland Management Plan, a Golf Course Management Plan and a Wetland Management Plan would be implemented. The Agricultural Habitat Management Plan can only be enforced in areas that would be under the resultant operator licences (e.g. within the Equestrian Centre or race track) where the ground is not within a farmed tenancy. The management plans would include the following information:-

•	Specific plans showing the features to be managed
•	Provide outline key objectives
•	Provide details of tasks to be undertaken to implement key objectives
•	Provide details of implementation responsibility; which section of the ground staff/tenant would undertake the works
•	Include details of schedules and programmes, with facility to amend details of work if necessary
•	Monitoring and report back programme to the Local Authority on an annual basis as a minimum. This should operate up to and including the first revision of the plan
•	Incorporate a programme for revision of the plan within 10 years of the signing of the Agreements, completed on a staggered basis so that all the Plans do not come up for review in the same year. 

6.48	GMEU have recommended that the Golf Course Management Plan should incorporate all the different elements of habitat management from the other Plans (Agricultural Habitat Management Plan, Woodland Management Plan, Golf Course Management Plan, and Wetland Management Plan), but specifically adapt them for the golf course. The management of the golf course would be a separate entity from the other Plans and activities within SFP, although the principles of biodiversity management would be applicable to it.

6.49	GMEU recommend that the Wetland Management Plan identifies the biodiversity features of ponds, ditches and other watercourses. The Plan should have specific management targeted for the maintenance of the amphibian and water vole populations. It should also include the management of the swales, grey water system and the sediment load/contaminants from highways run-off.

Species 

6.50	Policy EN10 of the UDP indicates that development proposals will only be permitted where mitigation measures are put into place for developments likely to have an adverse impact on legally protected species. Mitigation measures will be expected to maintain the population level of the species at a favourable conservation status within its natural range. If the proposed development was to adversely affect a European Protected Species, it will need to be demonstrated that 1) there is no satisfactory alternative, in terms of the form of, or location for the development, that would have a lesser negative impact on the species; and 2) there are imperative reasons for the development of overriding public interest. The two species concerned are Great Crested Newts and bats, which are discussed individually below. Any mitigation for Great Crested Newts, bats and water vole will require licensing from Natural England.

Birds of conservation concern
6.51	The applicant states that there are a number of bird species on site identified in the UK Biodiversity Action Plan (BAP), GM BAP or are “Red list” or “Amber list” species. The applicant states that the scheme could have a number of impacts, positive and negative on birds due to loss of feeding/breeding habitat; habitat change; construction phase disturbance and operational disturbance; road traffic casualty; and changes to flyways and foraging corridors. The applicant assesses the impact of the scheme on each bird species. The applicant concludes that there would be a net benefit for song thrush, linnet, corn bunting, tree sparrow, yellowhammer, grasshopper warbler, house sparrow, and dunnock; while there would be a net dis-benefit to 3 priority species (skylark, grey partridge, and lapwing,); and a neutral impact on 6 priority species (Lesser Redpoll, Cuckoo, Yellow Wagtail, Willow Tit, Starling, Lesser Spotted Woodpecker). Despite the conclusions reached, GMEU have indicated that they disagree with the suite of benefits as identified in the ES. 
6.52	Consultation responses have raised concern in relation to the mitigation associated with farmland birds due to displacement as a result of car park, racecourse and golf course developments. The applicant has identified a number of ecological commitments that would benefit on site birds. A number of the commitments are interconnected with other mitigation proposals and would form the overall mitigation package. The applicant would produce a habitat management plan underpinned by a S106 agreement, which would outline the proposed commitments to birds. The applicant has indicated that further mitigation of birds would be provided in consultation with SCC and the relevant consultees, the detailed measures, which can be taken to further improve the carrying capacity of the site. The applicant has indicated that they are satisfied to produce the details of the plans prior to the commencement of the main earth works on the site, and during the period that ecological protection and conservation measures are being designed and implemented. It is considered that the proposed management plans would provide a number of ecological commitments that would help to mitigate the impact of the development on the bird population, however the development would none the less result in significant displacement. 
Great Crested Newts 

6.53	The applicant states that without successful mitigation, the population of Great Crested Newts would probably become extinct due to impacts of the construction phase on habitat quality in and around Pond 1, which would be lost during construction. The population north of Bridgewater Canal, south west of Boothstown would not be detrimentally affected; however there is a risk that individual newts would be killed due to road construction activity. The population of Great Crested Newts in Ponds 19 to 22 would become isolated from the pond clusters to the west of the proposed new road which would reduce the future prospects of gene flow and meta-population recovery.

6.54	The populations at Booths Bank would benefit from new wetlands and potentially from habitat management associated with the Golf Course. However, the existing newt colony is confined to a swampy area which would be lost during construction – in the absence of mitigation, the newt population might become extinct. The applicant therefore states that in the absence of successful mitigation, the net effect of the Forest Park on Great Crested Newt would have a major negative impact.   
6.55	A number of mitigation measures have been proposed and agreed through consultation for the on site Great Crested Newt population. These include:
•	Construction of new ponds 12 months in advance of the proposed construction programme
•	Making improvements to existing ponds prior to construction to increase amphibian capacity
•	Trapping newts within any ponds affected by developments and moving them to safety 
•	Following best practice trapping procedures
•	Installation of an amphibian tunnel in the new access road from the A580 to allow migration of newts 
•	Management of all water bodies through agricultural and golf course management plans to ensure continued great crested newt and other aquatic life habitat quality

6.56	GMEU have indicated that in addition to these mitigation measures, a resurvey of Great Crested Newts should be carried out at least every 2 seasons prior to the commencement of works on each part of the site. The applicant has agreed to this approach, and this would be incorporated into the mitigation strategy. The applicant indicates that with successful mitigation there would be a major positive impact on Great Crested Newts and other aquatic life habitat.

6.57	It is considered that the mitigation measures proposed by the applicant may maintain the population of on site Great Crested Newts and as such is in accordance with policy EN10 of the UDP.  

Water Voles

6.58	The development would result in an impact on tributary ditch B of Moss House Farm Brook; Sniggley Brook; and Shaw Brook. The applicant states that without any successful mitigation the existing vole population would become isolated into a significantly reduced ditch network south and east of Moss House Farm Brook. This would result in a reduced population and would make it less able to respond to future environmental difficulties such as flooding. In the absence of successful mitigation the impact would be a major negative.   
6.59	A comprehensive Water Vole mitigation strategy is proposed that includes a number of measures as follows;
•	Creation of 2,840m of new watercourse, of which 890 metres is full permanently wet channel and 1,950 metres are swales within the racetrack. 
•	Creation of new water vole friendly profiles on all newly created watercourses
•	Creation of seven off-line pools hydraulically connected to watercourses within existing or potential vole habitat
•	Management and enhancement of all other watercourses in the Forest Park (Moss House Farm Brook, Sniggley Brook, Shaw Brook, Stirrup Brook and Whitehead Brook) by use of buffer strips to prevent cultivation to bank top and by localised intervention to create better profiles and de-silting of choked channels
•	Use of bridges or box culverts with mammal shelf for all road crossings
•	Creation of new habitats in advance of destruction/modification of existing habitats, such that, at all times there will be more open watercourse than at the commencement of development
•	Protective fencing during developments along watercourses
•	Monitoring and reporting arrangements to be agreed with Environment Agency

6.60	In addition to these mitigation proposals, GMEU has indicated that a resurvey of all watercourses should be carried out two seasons prior to commencement of any watercourse works. In addition to this any new habitat created for water voles must reach a level of maturation suitable to support any new water vole habitats, irrespective of how long this takes. The applicant accepts these recommendations and proposes to incorporate them into the mitigation strategy. 

6.61	The applicant has assessed the scheme with successful mitigation as resulting in a moderate positive impact prior to and during construction, and over a ten-year period the impact of the operation of the forest park would result in a net major positive impact on water voles. It is considered that the mitigation measures proposed by the applicant may maintain the population of on site Water Voles and as such is in accordance with policy EN10 of the UDP.  
Bats
6.62	Confirmed and potential bat roosts in several of the existing farm buildings (Malkins Wood Farm and Moss House Farm) would be destroyed and/or disrupted during renovation and redevelopment works. Existing bat flyways would be disrupted near Malkins Wood Farm due to the tree felling required for the racetrack. One line of mature trees from the farmstead would be severed and some garden trees and shrubs within the farmstead would be removed. The impact of the development on bats in relation to site access and infrastructure is considered to be a minor positive impact during the operational phase, with no impact identified during the construction phase. The racetrack lighting would have no impact during either the construction phase or operational phase. The development of the racetrack, grandstand and ancillary buildings would have a minor impact during the construction phase of the development. The equestrian centre buildings would have a minor positive impact once operational, and no impact during the construction phase. The Centre for Sustainable Living and Timber Innovation would have a moderate positive impact during the operational phase of the development. The introduction of new woodland would have a major position effect once it is established. The woodland management practices would have a minor positive impact on the bats. The ES indicates that when considering the cumulative effects of the development, no direct impacts would occur on the roosts during construction phase, but minor negative effects would occur from tree felling. GMEU however dispute the findings relating to the applicants assessment of the direct effects associated with the development and consideration of this has been taken into account. 

6.63	The long-term creation of a bat-friendly landscape and buildings would be a major positive impact although there’s a risk of a local negative impacts occurring.     
6.64	The applicant suggests a number of mitigation measures for the bat population. These include:
•	Planting of linear woodland belts from Malkins Wood Farm to create a new northern corridor along the western racetrack fringe and along the Avenue
•	Planting a line of 3m extra-heavy standard trees along the eastern edge of the Equestrian Centre specifically to increase the potential flyways for bats emerging from the farmhouse to link to existing mature tree belts
•	Wetland and woodland creation throughout the site coupled with improved farmland management to increase invertebrate diversity
•	Provision of several bat roost units in trees around the Equestrian Centre
•	Improvements to existing roost in Malkins Wood Farmhouse, including making provision for emergence onto the darker eastern side of the property.
•	Phasing of the works so that the new roost unit and improvements to Malkins Wood Farm loft roost and tree planting are installed prior to felling of existing trees. 
•	Shielding of the outdoor arena lights to ensure that no light is directed onto Malkins Wood Farmhouse
•	Provision of roost potential facilities in loft spaces at the Moss House Farm Hotel, the Stable Lads Hostel and the Forest Centre which will increase overall loft availability

6.65	In addition to the mitigation measures outlined by the applicant GMEU consider it necessary to resurvey all buildings and structures to be demolished and / or altered and any trees felled and/or subject to tree surgery works for bats. A detailed method statement would be produced for each phase of the scheme to include protection measures, timing programmes and / or mitigation for lost roosts. A generic Method Statement would be produced which would include a watching brief on demolition and alteration works, a demolition protocol, identification of trees with roost potential and a tree felling methodology. New hedgerows and / or tree belts would be planted to facilitate commuting routes from roosts to feeding areas, and would be included within the detailed Landscape Scheme. A monitoring remediation and management programme would be agreed for replacement roosts. The applicant would incorporate these recommendations into their mitigation strategy.  

6.66	It is considered that the mitigation measures proposed by the applicant may maintain the population of bats and potentially enhance foraging habitats and as such is in accordance with policy EN10 of the UDP.  

Badgers 

6.67	The applicant states that there would be no impact on badgers as a result of the proposed development.

Brown Hares

6.68	The development would result in the direct habitat loss of farmland and grassland due to the development of the grandstand, lakes, access roads and new woodland. The amenity grassland of the car parks would retain some value to brown hares, as it would rarely be used intensively or at night. These losses would collectively reduce hare habitat to 415ha. Despite this the provision of new woodlands, hedgerows and scrub would provide cover for hares.  

6.69	The applicant states that many of the farmland initiatives that are to be implemented for the benefit of farmland birds would also benefit hares. The provision of new woodlands, hedgerows and scrub would provide cover. 

6.70	The applicant concludes that the qualitative improvements to open habitats would to some degree balance the qualitative loss of habitat. However, the loss of open farmland and grassland of value to brown hares represents a minor negative significant impact on brown hares.  

Japanese Knotweed

6.71	At least one year prior to any earth moving on the site a resurvey for Japanese knotweed should be conducted. A Method Statement should be produced for the control and eradication of the species.

Conclusion 

6.72	The size of the SFP scheme means that the ecological impacts are many and varied. The key ecological impacts are as follows:

•	Impact on 3 different great crested newt populations (European Protected Species – Habitats Regulations and UK Biodiversity Priority species)
o	pond (P44) lost to golf course and impacts on terrestrial habitat
o	potential temporary loss of pond (P1) to racecourse remodelling and terrestrial impacts
o	bisection of pond cluster by access road from A580 
•	Impact on bat populations (European Proetced Species – Habitats Regulations and UK Biodiversity Priority Species)
o	One confirmed bat roost (Malkins Wood Farm)
o	Potential bat roost (Moss House Farm)
•	Loss of habitat in all three areas of the existing ditch network that support water vole (UK Protected Species and UK Biodiversity Priority species)
•	Loss of agriculturally managed habitats which support farmland birds, ground nesting birds and brown hare (Birds of Nature Conservation Concern and UK Biodiversity Priority Species)
•	Loss of existing successful barn owl nest and interruption to feeding territory (UK Protected Species)
•	Disturbance, visitor pressure and potential habitat loss in 2 of the 3 Sites of Biological Importance (SBI) on the site
 
6.73	The scheme would introduce a large-scale change to the presently undeveloped countryside. GMEU indicate that biodiversity would be maintained within the scheme, but due to the impacts of the proposals there would be substantial changes in the species assemblages and suite of habitats that currently occur. The development would alter the management, substrates, levels of disturbance and connectivity to other landscape and habitat features resulting in ecological impacts that would be apparent on a landscape scale.

6.74	The applicant has outlined a wide variety of ecological commitments as part of the ES and ESS submission that could be implemented via conditions and/or obligations. However, the applicant acknowledges that there is an element of risk associated with the measures proposed and not all the identified impacts are compensated for through the proposals. GMEU state that the scale of the proposals, in combination, would result in a considerable degree of uncertainty about the outcomes of any particular element of the mitigation and the site’s future management for biodiversity. GMEU also indicate that it is difficult to integrate ecological mitigation into major regional developments and produce agreements that continue to be implemented to maintain a high level of enhancement for biodiversity.  GMEU concluded that, “the cumulative ecological impacts are greater in total than the sum of the individual species/habitat impacts. The impacts on wildlife should be considered significant on a district scale.” 

6.75	The EA have withdrawn their objection stating that the revised details submitted by the applicant meet with their requirements.  This is subject to the applicant agreeing to appropriate planning obligations and / or conditions to deal with the long-term management of the ecological features on site.

6.76	The GMEU consider that although the applicant presents a significant level of mitigation, which have been agreed on a species by species basis, when considering the site in its entirety the impact of the development would be significant and the mitigation measures proposed result in a level of future uncertainty. Due to this uncertainty it is considered that the nature conservation and ecological impacts of the development mean that these aspects of the proposed development are finely balanced.  

6.77	In light of the conflicting views from two credible consultees, the City Council are unable to come to a view on ecological grounds at this stage.  Ordinarily, discussions would take place with these consultees to enable a conclusion to be reached.  However, given the submission of the appeal and the tight timescales in place, insufficient time is afforded to facilitate this.

7.	ACCESS, PARKING, TRAFFIC AND TRANSPORTATION 

7.1	At the time of writing, the Highways Agency (HA) have a valid holding direction in place.  This holding direction is valid until 12th December 2008.  The HA indicated in writing on 4th December 2008 that it is not their intention to renew this direction subject to the conditions relating to the following:

•	Full implementation of the site travel plan;
•	Full implementation of the traffic management strategy;
•	Implementation of the agreed highway works, complete with high occupancy vehicle lanes, access control and ramp metering on the M60 slip roads;
•	Agreed thresholds to the scope and frequency of events;
•	Provision of a formal site steering group;
•	Provision of traffic management strategy for major events;
•	Provision of shuttle buses and event ‘race day specials’; and
•	Management of the internal highway network during ‘normal’ (non-event) operation.

7.2	In consideration of the above, it is likely that the Highways Agency holding direction will be lifted before the meeting of the Planning and Transportation Regulatory Panel on 18th December 2008.  Any response received by the HA will be reported through an amendment sheet to this report.

7.3	The Greater Manchester Transportation Unit (GMTU) were appointed by Salford City Council to review the original Transport Assessment (TA) submitted in June 2004.  GMTU’s initial assessment and comments were forwarded to the applicant.  During this period, the HA issued a holding direction and expressed concerns over the proposed layout of Junction 13.  As a result of this concern the proposal for Junction 13 was revised and remodelled by the applicants traffic consultants TTHC.

7.4	TTHC submitted a partially revised TA in May 2007 which was reassessed by both SCC and the HA.  TTHC were informed that both SCC and the HA were concerned about their method of assessment of Junction 13.  This concern was in respect of the dumbbell gyratory being treated as two independent roundabouts rather than one gyratory.

7.5	GMTU reviewed this updated TA.  The analysis provided in the TA (and unchanged in the updated TA) is based on the following uses proposed for the SFP site:

•	Horse-racing courses (including both turf and all weather tracks)
•	Equestrian facilities:
-	Equestrian Centre
-	Cross country eventing courses
-	Stabling and riding trails.
•	Woodland park:
-	Forest visitor centre
-	Eco village accommodation (20 double rooms)
-	Adventure play facilities
-	Nature reserves and heron protection area
-	New woodland trails and riding trails.
•	80 bedroom ‘country style’ hotel
•	18 hole golf course.

7.6	Based on an examination of attendances at race meetings elsewhere in the country and an assumed profile of events at the proposed racecourse, the TA examines five scenarios:

(i)	Non-race days, but including activity at all other facilities;
(ii)	Standard (10,000 attendance) afternoon race event, plus all other activity;
(iii)	Standard (10,000 attendance) evening event, plus all other activity;
(iv)	Premium (20,000 attendance) afternoon race event, plus all other activity; and
(v)	Premium (20,000 attendance) evening race event, plus all other activity.

7.7	Although we have no independent data, our examination of the data from the British Horseracing Board confirms that the assumed pattern of racing events at the venue is realistic, and that this set of scenarios is a robust examination of the full range of possible traffic impacts of the proposals.

7.8	As race events will potentially generate large volumes of traffic, mostly arriving and leaving together, but on relatively few occasions during the course of a year, it is considered that it is unrealistic to expect the developer to fully ameliorate all of the traffic impacts by providing sufficient capacity to cope with peak race day flows.  This would lead to the construction of junctions with considerably more capacity than necessary for the vast majority of the year.  It is expected that careful traffic management combined with a Police presence would deal with the traffic during the busiest periods for arrivals and departures at race meetings during high attendance race meetings.

7.9	The applicants were unwilling to undertake further modelling of the two roundabouts at Junction 13.  Subsequently, a joint meeting was held with the HA and their traffic consultants JMP in early July of this year at which GMTU suggested the most appropriate method for looking at the operation of the two roundabouts at Junction 13, which involved a joint modelling approach with GMTU, utilising the information from a video survey of traffic movements at the junction done by the GMTU.

7.10	The Highways Agency have confirmed that JMP have provided a final report (Working Note 7) which summarises the work undertaken.  The Highways Agency have summarised the report conclusions:

•	Whilst the Salford Forest Park development covers a large area with a range of uses its primary use, namely that of a racecourse, would only generate significant volumes of traffic on 9 days of the year.  For the remainder of the year, the ancillary uses are of modest size with low levels of traffic generation;
•	It would be unfeasible to provide sufficient highway capacity to accommodation the occasional major events associated with the Salford Forest Park proposals.  In order, therefore, to minimise the potential impact associated with major events, it is proposed that more modest highway improvements be provided but that these improvements be supported by a full programme of measures which accord with Circular 02/2007, including a comprehensive Travel Plan and a Traffic Management Strategy;
•	The Travel Plan now provides sufficient detail as to how sustainable travel will be promoted to staff and visitors to Salford Forest Park;
•	The Traffic Management Strategy identifies in principle how major events would be managed on-site; and
•	As a result of the proposed highway scheme, the Salford Forest Park development would not have a material impact on the operation of the strategic road network and would, on the whole, provide a benefit to the operation of the M60 Junction 13 on both the local and strategic road network.

7.11	It is understood that the working note concludes that, taking account of the overall transport package, the proposed Salford Forest Park development would not have a material impact on the safe and efficient operation of the strategic road network.  It is as a result of these findings that the Highways Agency intend to remove the holding direction.

7.12	This report has not yet been received but is expected before the meeting of the Panel on 18th December 2008.  Given that there has not yet been sight of the report, the application must currently be assessed on the basis of the modelling undertaken by the applicant.  It must therefore be concluded at this stage that insufficient information has been submitted to demonstrate that the proposal would not have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation.  As such, the proposal is contrary to policies A1, A2 and A8 of the UDP and policies RT2 and RT9 of RSS.

7.13	The applicant has submitted an interim travel plan and detailed comments were submitted in January 2008 outlining their obligations and requirements to produce a comprehensive travel plan for this major development.  The applicants are also requested to submit an event management plan for the major events.  

8.	IMPACT OF THE DEVELOPMENT ON RECREATION

8.1	Access within the site is currently limited, consisting of concessionary footpaths in the Middlewood area, some public rights of way to the west of Boothstown, and the Bridgewater Canal corridor (towpath along the south bank, and a concessionary route along north bank). The SFP proposals would significantly improve the accessibility of a site that is currently restricted in terms of access leading to the opening up of a significant area of greenspace for both the local and wider population. Policy EM3 of RSS states that proposals should promote and deliver multi-purpose networks of greenspace which the SFP proposals clearly achieve, and therefore the scheme should be considered to be in accordance with this policy.

8.2	The Spatial Framework for the City is outlined in the Salford UDP, which splits the city into five sub-areas. The SFP development is located within the Urban Fringe and Countryside, and is a major environmental asset of ecological, landscape, recreation and agricultural importance. The policy places a strong emphasis on developing the area’s recreational potential to ensure that the city’s residents have good access to a wide range of recreation opportunities and is therefore in accordance with policy ST10 of the UDP. 

8.3	The location of the site, on the urban fringe would help to meet greenspace standards and provide a range of accessible leisure and sporting activities for the people of Salford and the wider region. Due to the location of the scheme, within the Countryside and Urban Fringe of Salford it is considered that the scheme has the potential to contribute towards the aim of establishing a Regional Park, and is therefore consistent with policy EM4 of RSS. It is considered that the proposals would satisfy many of the purposes of creating a Regional Park.  

8.4	The scheme would provide a mix of formal and informal, indoor and outdoor recreation opportunities through the creation and enhancement of an existing open space and through the creation of a series of new footpaths (32km’s), bridleways (18.4km’s) and cycleways (12.7km’s) and it is considered that this is in accordance with policy DP2 and W7 of RSS 

8.5	It is considered that this is in conformity with policy DP2 and W7 of RSS and policy R3 of the UDP. In addition, it is considered that the proposals are broadly consistent with the thrust of the two main national policy guidance documents, PPS7: Sustainable Development in Rural Areas and PPG17: Planning for Open Space, Sport and Recreation. It is considered that the scheme would contribute towards the aims of these policies and is therefore in accordance with national, regional and local planning policy. It should, however, be reiterated that there is no evidence brought forward by the applicant as to why the site could not be opened up without the proposed development.  

9	IMPACT OF THE DEVELOPMENT ON NOISE

9.1	Policy EN17 of the UDP states that development proposals that would be likely to cause or contribute towards a significant increase in noise pollution will not be permitted unless they include mitigation measures commensurate with the scale and impact of the development. In areas where existing levels of pollution exceed local or national standards, planning permission will be granted for environmentally sensitive developments only where the development incorporates adequate measures to ensure that there is no unacceptable risk or nuisance to occupiers, and that they are provided with an appropriate and satisfactory level of amenity.  

9.2	The noise and vibration assessment undertaken by the applicant assessed the potential noise and vibration impacts associated with 
	
•	Site preparation;
•	Construction of the new development and infrastructure, and associated traffic;
•	Operation of the site, including site noise and the potential noise changes on the local road network that may occur from the addition of development generated traffic. 

9.3	The noise assessment undertaken by the applicant was carried out after full consultation with Salford City Council's Environmental Health Department. The monitoring locations and methodology were agreed to ascertain the Baseline Noise Environment levels, and two monitoring exercises were carried out in May 2001 and August 2003. The noise assessment has been agreed as an appropriate and reflective assessment of noise impact during the construction and operational phases of development. Throughout the construction programme, various construction activities would have to occur across the whole site in a phased and coordinated fashion.

9.4	The grandstand, racetrack and immediate supporting buildings and features would all be located in close proximity to Keepers Cottage, with the Grandstand within about 250m of the site, the temporary Grandstand (170m), the Racecourse itself, the Stablehands Residential Block (175m), Stables and the Equestrian Centre (Malkins Wood Farm). The development of these would involve considerable construction works to prepare and construct the facilities. A concentration of work in this area would occur which would need to be carefully controlled to limit the impact of noise on the nearby residents. Residents of Boothstown may be partially shielded from this noise by the existence of the raised landfill car parking areas, however, noise may still be a factor for Boothstown residents and is likely to be a significant factor for the residents of Keepers Cottage.  

9.5	The applicant has indicated that the construction noise levels at Keepers Cottage are predicted to be 60dB LAeq(T)  which is above the Council's suggested noise level of 55dB LAeq(T)  due to the continuous nature of construction activity. Despite this, consultation advice indicates that the implementation of the proposed mitigation measures prior to construction commencing would result in acceptable noise levels at Keepers Cottage. This could be imposed through the attachment of appropriate planning conditions. 

9.6	During the operational phase of the development the impact of noise on Keepers Cottage would also be significant when race meetings are in progress. The applicant reports that noise from the crowd and public announcement system will have the greatest potential impact on Keepers Cottage. The predicted noise level of 60 dB LAeq is about 21/22dB above the measured daytime background level of about 38/39 LA90,15mins The applicant reports that the predicted level is also 7dB above the measured daytime ambient level of 53dB. 

9.7	To mitigate against this impact it has been agreed between the applicant, Urban Vision Environment and the residents of Keepers Cottage that a planted mound with an acoustic fence on top of it would be the most appropriate means of achieving the required level of mitigation that is also considered appropriate for the residents.  A barrier would be created at a total height of 3 metres, relative to their garden level, located on the east side of the ditch alongside the track, and between the track and the proposed new access road. This relates to diagram 251D.142 and could be secured through the attachment of a condition.  The mound would extend along the complete length of ground, which would lie between the old and new tracks. This design would help contribute to screening of low level activity on the horsebox area and views from the house. The acoustic fence would extend only along the area to the south of Moss House Farm Brook since there is no requirement for it to the north. This would provide a 6dB level of attenuation and would result in garden levels of 53dB LAeq(T). These reductions in noise are considered acceptable. In addition to this it has been agreed with the consent of the Keepers Cottage residents that the windows to habitable rooms to the northern, eastern and southern elevation of the property would be acoustically treated to provide reduced internal noise impacts. The applicant would incorporate ventilation systems into all habitable rooms of the property, which preclude the needs of residents to open windows to achieve cooling and also achieve an acceptable level of noise reduction.   

9.8	Noise from construction activities would affect different areas on and around the site in different ways. Access to the site via Junction 13 of the M60 and the A580/Chaddock Lane gyratory area (considered under Article 10 Direction) would require significant works both to the proposed new road layout and also stretching back into the site itself. Noise from the construction of the M60 junction would have an impact on residential uses located close to the junction. 

9.9	Extending the highways onto the site would reduce amenity for local residents however the further into the site less sensitive receptors are present to be affected by noise. As well as the main entrance/exit routes, there are also significant changes to internal access routes within the site. Some of these, especially adjacent to the proposed car parking areas and circulatory systems for buses are reasonably close to noise sensitive receptors. 

9.10	The Hotel complex would undergo significant works and would be located in closest proximity to Boothstown residents. Despite this some natural shielding may occur due to the topography of the site, although noise would be a consideration.

9.11	The Golf Course is near to residential properties along Leigh Road and also to the south-eastern residential areas of Boothstown. Due to the topography of the site, noise generated can travel reasonable distances without any natural attenuation.

9.12	The other areas of the site including the Timber Initiative Centre, Eco Village, and Woodland Wildlife centres are likely to have less of an impact on residential amenity as they are generally located more centrally on the site and this places both natural and distance attenuation factors in place to limit the impact of noise on sensitive receptors.

9.13	It is considered that the noise mitigation measures, as discussed above in relation to Keepers Cottage and agreed between the applicant and SCC are commensurate with the scale and impact of the development and satisfy the requirements of policy EN17: Pollution Control of the Salford UDP. The mitigation measures proposed would provide an appropriate and satisfactory level of amenity protection for the people identified within the report above. The mitigation measures would be implemented by planning condition.

10.	IMPACT OF THE DEVELOPMENT ON AIR QUALITY/DUST 

10.1	Policy EN17 of the adopted UDP states that development proposals that would be likely to cause or contribute towards a significant increase in pollution to the air will not be permitted unless they include mitigation measures commensurate with the scale and impact of the development. In areas where existing levels of pollution exceed local or national standards, planning permission will be granted for environmentally sensitive developments only where the development incorporates adequate measures to ensure that there is no unacceptable risk or nuisance to occupiers, and that they are provided with an appropriate and satisfactory level of amenity.

10.2	The air quality assessment undertaken by the applicant considers the following:

•	Identification of existing levels of ambient air pollution in the area
•	An assessment of potential air pollution as a result of the proposed development
•	Identification of measures to mitigate these; and
•	An assessment of the residual impacts of the proposed development

10.3	Salford City Council designated an Air Quality Management Area (AQMA) for nitrogen dioxide and particulates (PM10), which covers the majority of the eastern part of Salford from the M60 ring road to Manchester City Centre, Bolton and Bury borders, and westward along the M62 corridor and northward along the M61. The eastern fringe of the proposed site together with the adjacent land to the east and south falls within the declared AQMA. 

10.4	During the construction phase air quality within the SFP site and the surrounding area has the potential to be affected by vehicular emissions. The applicant states that there would be some temporary periods of relatively high construction traffic movements, these will occur after the construction of the main site accesses off the A580 and M60 Junction 13.  The applicant reports that there would be no significant change in local air quality with the magnitude of the impact on residential and commercial properties in the vicinity is considered to be negligible. The impact on properties in the area is estimated to be a negligible to slight significance. 

10.5	The applicant states that dust emissions during the construction phase of the proposal could arise from various sources including; mixing of aggregate on site (cement); mechanical handling operations, including crushing and mixing processes, where in general the more powerful the machinery and the greater the volume of the material handled, the greater the potential for dust; and on-site storage of cement. The applicant assesses the impact of dust on residential and commercial properties in the vicinity of the development as slight. Despite this the applicant identifies a number of options by which to control dust. 

10.6	During the operational phase, the local air quality assessment concludes that the main direct air quality effects would be limited to an area near to the road. Beyond 200 metres, the contribution of vehicle emissions to air quality is considered insignificant.  

10.7	Four different scenarios were modelled as follows 1) development open, non race day; 2) a Premium event with up to 20,000 spectators, occurring once a year; 3) a flagship event with up to 15,000 spectators occurring 3 times a year; and 4) a standard event with 7,000 to 10,000 spectators occurring 30 times a year. The model predicts that the increases in the values of the annual mean NO2 with development scenarios would not alter the number or location of receptors where the objective would be exceeded by the baseline values. The annual mean PM10 ‘with development’ concentrations at all receptors are still below the objective level. This would represent a negligible magnitude of impact on a medium sensitivity residential property in the vicinity. The impact is therefore estimated to be of negligible/slight significance.

10.8	The daily mean objectives show that the 2009 baseline model results predict a lower number of exceedences than for 2004 baseline due to improvements in engine emissions. The model predicts that for all the scenarios, 2004 and 2009 without development and 2009 with development, options would be well below the number of exceedences of the daily mean objective. The 2009 non-race day scenario and the standard race day scenario indicate that the numbers of exceedences are identical, indicating the negligible impact that the site would have on the surrounding environment. There would be a negligible magnitude of impact on the medium sensitivity residential properties in the vicinity; therefore the impact is estimated to be of negligible/slight significance. 

10.9	The hourly mean objectives indicate that the 2009 baseline is identical to the 2004 baseline. The 2004 baseline and 2009 ‘without’ and ‘with-development’ concentrations are all predicted to be below the stated objective of 200ug/m3. Despite this, exceptions exist at Boothshall Way and Highclove Lane where there is an approximate 3% increase. These increases can be attributed to the relatively low existing background levels and any increase in traffic would raise the NOx emissions. Similar situations are demonstrated on race days when the internal link road and the northern car parks are in use; these receptors show increases of between 12% and 20% due to the very low baseline level. Overall there would be a negligible to low magnitude of impact on the medium sensitivity residential properties in the vicinity; therefore the impact is estimated to be of negligible to slight significance. 

10.10	In relation to dust, no significant dust issues are predicted to arise during the operational phase of development. The operational phase of the development would therefore not have any significant impact on the surrounding properties. 

10.11	The applicant states that it is anticipated that there would be no significant change in local air quality during the construction or operational phase. The impact magnitude on residential and commercial properties in the vicinity is considered to be of negligible to slight significance and therefore no specific mitigation measures are required. Despite this the applicant is committed to producing a Green Travel Plan for SFP. In addition to on-site public transport provided on race days, off-site shuttle buses connecting to the local rail services are proposed. The applicant states that these measures would assist in ensuring that the site is served by sustainable transport modes and that accessibility by public transport, walking and cycling is encouraged at the expense of travelling by car. 

10.12	Urban Vision Environment considers these mitigation measures to be appropriate in this instance and a suitable Green Travel Plan has been agreed to deliver the required air quality mitigation required. 

10.13	The applicant would be required to submit a Dust Management Plan to cover the construction phase of the development. The Dust Management Plan would apply to all areas and activities on the site for the duration of the construction phase. The dust management plan could be secured by a suitable planning condition. 
 
10.14	Urban Vision Environment is of the opinion that in recognising the existing air quality regime in the area, the development would not result in any significant increases but that the use of a strong travel plan, as submitted by the applicant would be important in managing and reducing such impacts. With regards to air quality, the proposals are considered to accord with policy EN17 of the adopted UDP, subject to the implementation of conditions relating to the dust management plan and the green travel plan. It is also recommended that a payment towards air quality management be secured through a S106 agreement.

11.	IMPACT OF THE DEVELOPMENT ON FLOODING AND DRAINAGE 

11.1	Policy EN19 of the Salford UDP states that development will not be permitted where it would materially increase the risk of flooding elsewhere. Any application that is considered to increase the risk of flooding will need to be accompanied by a formal flood risk assessment. Any assessment should clearly identify the mitigation or other measures to be incorporated into the development. 

11.2	Two areas of land within the site are shown by the Environment Agency as ‘indicative floodplain’, and are interpreted as flood risk areas based on a 1 in 100 year storm event. The area of land in the vicinity of the confluence of Moss House Farm Brook and Whitehead Brook near Keepers Cottage Kennels and the existing ponds are susceptible to flooding. The other area susceptible to flooding is along a stretch of Shaw Brook adjacent to Botany Bay Wood. The SFP proposals would lead to 14% of the flood plain being developed, comprising of development of the grandstand building, part of the racetrack and the raised area in between. The volume of water displaced due to development is estimated to be 5600m3 and would cause an increase in water level of no more than 30mm with a subsequent increase in the flooded area. 

11.3	Consultation advice from the Environment Agency indicates that where flood storage capacity would be lost through the development of the racecourse grandstand, the applicant must provide within their submission equivalent compensatory flood capacity storage. This means that the flows in the brook should not increase and the existing standard of flood defence would be maintained. The applicant would create flood basins in the green areas around the development, which would result in there being no reduction in flood storage capacity. 

11.4	In relation to the indicative floodplain in the vicinity of Shaw Brook adjacent to Botany Bay Wood, there is no development proposed in this area which would result in their being no changes in flows to the brook and would not increase flood risk.  In relation to onsite drainage the site would be drained on a separate system, with only foul drainage connected into the foul sewer. Surface water should discharge to the watercourse/soakaway/surface water sewer. 

11.5	In conclusion, although the development would result in a reduction of flood storage capacity the applicant has successfully assessed the flood risk and the run off implications of the development and would provide an acceptable amount of replacement flood capacity storage on site. In relation to policy EN19 of the UDP and PPS25, it is considered that the flood risk posed by the development is adequately mitigated for within the details of the proposals submitted by the applicant.  A condition could be attached to any planning consent stating that works should be carried out to reflect drawing 251D.143 (found in a letter from PR dated 28th February 2008).     

12.	IMPACT OF THE DEVELOPMENT ON GROUND CONDITIONS 

12.1	Various sources of potential gas exist across the site, more specifically; the three landfills to the north of the site; the peat mosslands across the majority of the site (in the south); mine gas from both deep and shallow mine workings; and exposed shafts acting as potential pathways and or sources. The scheme has been specifically designed to avoid disturbance of the landfills. Clay would be used to infill and level the subsided surface of the landfill site.  The surface of the landfill would be covered with grass paving. The coach car parking would have the additional protection of a 200mm geo-grid reinforced engineered fill. All of this would be subject to the results of the detailed intrusive investigations to include both gas and ground issues.

12.2	General proposals have been made to deal with leachate and landfill gas issues. These would be subject to intrusive investigations. The suggestions at this stage include; passive venting systems on the Booths Hall 1 and 2 landfill sites, as Boothstown already has a passive venting system in place. The existing passive venting system installed on the Boothstown site would need to be assessed in terms of its current status and the effect the development may or may not have on the adequacy of that system. This would determine the passive venting system to be installed on the Booths Hall 1 and Booths Hall 2 sites.  

12.3	Urban Vision Environment are concerned that very limited proposals have been made to address any potential ground contamination issues and make a number of recommendations in relation to the commissioning of detailed site investigations. Concerns exist relating to the durability of the proposed grass paving on the landfill sites, as this would be subject to both heavy traffic movements and subsidence from the settling landfill. The weight of traffic on top of the landfill has raised some concerns in relation to lateral migration. Urban Vision Environment state that any additional loading on the landfill site could place the site under pressure, therefore forcing gas out at a greater rate. This combined with the proposed cap may force the gas to migrate laterally towards more sensitive properties, this could lead to degradation of the cap and exposure of the landfill beneath. Urban Vision Environment state that any site investigations would need to consider not only the suitability of the depth of the cap but also the durability of this cap over time. 

12.4	It is recommended that each proposed structure on site would need gas monitoring either under or within the footprint of the building to assess the gas protection needed. It is recommended that the long-term management of the gas protection system would need to be implemented as part of a planning condition. Depending upon the gas protection schemes put in place, long-term management of such schemes may be necessary. 

12.5	Urban Vision Environment indicate that ground contamination issues would need to be considered as part of the proposed contamination investigations. They suggest that any contamination investigations are conducted in a phased approach as recommended in current best practice and ease of assessment due to the large area covered and differing previous uses and proposed end uses.

12.6	A number of planning conditions would need to be attached to any planning consent which, if adhered to would ensure that the development complies with policy EN16 of the Salford UDP and PPS23. 

13.	IMPACT OF THE DEVELOPMENT ON MINERAL RESOURCES 

13.1	Policy M1 of the UDP states that known mineral resources that are, or could realistically in the future be, capable of being worked will be protected from sterilisation by other forms of development. Policy ST17 of the UDP states that known mineral resources will be safeguarded and their exploitation will only be permitted where there are no appropriate secondary sources. The Greater Manchester Geological Unit (GMGU) previously raised concerns regarding to the potential risks of sterilisation of mineral resources and additional information was requested regarding the presence of sand and gravel deposits under the peat. With regards to supply, it is a requirement of national minerals planning guidance that a 7-year ‘landbank’ of planning permissions is maintained in order that there is a steady and regular supply of aggregates to the construction industry. The supply for Salford is part of the Greater Manchester and Cheshire sub-regional supply. 

13.2	GMGU states that the proposals would not cause the sterilisation of any financially viable mineral reserve. GMGU indicate that although there is not sufficient evidence to prove the presence, or otherwise, of any viable mineral resource within the application area the application is unlikely to result in the sterilisation of such potential minerals due to the design and siting of the built development. It is considered that this therefore complies with policy ST17 of the UDP. 

14.	IMPACT OF THE DEVELOPMENT ON THE ECONOMY

14.1	The applicant submitted as part of the SFP application an assessment of the range of economic benefits that the scheme would bring for the city and the surrounding area. The applicant estimates that SFP would create between 260 and 270 Full Time Equivalent (FTE) jobs. Using the lower estimate of 260 FTE jobs; this would give rise to 100 full time jobs; 237 part time jobs and 430 casual jobs (mainly in the catering, hospitality, retail and security sectors). In addition to this it has been estimated that 88 FTE construction jobs will also be created from the building, infrastructure and environmental improvement works associated with SFP, and that between 30 and 50 FTE jobs would be created in the off-site catering/hospitality sectors. Economic assessments of the development proposals are supported by the Council’s Economic Development Section (Chief Executives Directorate) and are considered to contribute towards the City of Salford Economic Development Strategy (2004-2007), which highlights encouraging investment in the City as one of its three key strategic objectives.

14.2	Whilst a number of new jobs would be created as a result of the development, a development of this size cannot be considered to be a major generator of jobs when providing 260-270 full time equivalent jobs.

14.3	The applicant would ensure that the economic benefits of the scheme are felt locally, both in terms of making best use of the local labour supply and in the use of local suppliers in the provision of goods and services to SFP operators. The applicant would work with the relevant statutory and voluntary agencies to provide support to local targeted groups to enable them to access the opportunities that evolve from the development. It is recommended that a S106 legal agreement be used to secure this agreement. It is considered that this complies with policy ST3 of the UDP. 

15.	IMPACT OF THE DEVELOPMENT ON TOURISM 

15.1	Planning policy at the national, regional and local level all support the development and growth of tourism provided that it is in accordance with national sustainable development policies and that any adverse impacts are outweighed by the resulting benefits. PPS7 highlights the value in developing tourist facilities but paragraph 34 (iii) states that it must be ensured that “proposals for large-scale tourism and leisure developments have been subject to close assessment to weigh up their advantages and disadvantages to the locality in terms of sustainable development objectives.”

15.2	It is considered that the SFP proposals would develop a major tourist attraction in the city and in doing so has the potential to be a key economic driver within the North West and more specifically within Salford. SFP could help to achieve important employment growth through tourism development and as such is in accordance with policy E6 of the Salford UDP and policy W7 of RSS

15.3	Policy W7 of RSS encourages developments that improve the region’s overall tourism offer, harness the potential of sport and recreation, particularly the role of major sporting events, and promote eco-tourism in areas of high natural value. The SFP proposals would have a positive impact in terms of raising the profile of sustainable development in the area as the proposals include the Forest Park Visitor Centre with three sub-centres; an Eco-Centre, a Timber Initiative and Woodland Wildlife Centre. These resources would provide a useful environmental education resource in Salford, and would bring an added element to the sustainable tourism that is currently on offer within Salford. In addition a significant proportion of the SFP proposals are centred on the provision of sport and recreation. 

15.4	Whilst, in this respect, the proposal can be considered to be in accordance with policy W7 of RSS and policy E6 of the Salford UDP, the applicant has not demonstrated that there is a need for this type of facility in Salford that would override the harm to the openness of the Green Belt.

16	IMPACT OF THE DEVELOPMENT ON AGRICULTURE 

16.1	PPS7: Sustainable Development in Rural Areas sets out the national planning policy in relation to development in rural areas. Paragraph 28 of PPS7 confirms that the presence of Best and Most Versatile (BMV) agricultural land should be taken into account alongside other sustainability considerations when determining planning applications. Policy EN3 of the Salford UDP indicates that where development that would involve the loss of the BMV agricultural land (Grades 1, 2 or 3a) development will only be permitted where it can be demonstrated that there are no appropriate alternative sites available on lower grade agricultural land or on non-agricultural land.

16.2	The proposal would result in elements of reversible and irreversible development to land currently in use as agricultural land. An analysis of the agricultural land within the site boundary indicates that 2% of the land is classified as Grade 2; 75% of the land is Grade 3a and 23% of the land is categorised as Grade 4. The Grade 2 land covers a small area of land immediately to the north of The Grange. Subgrade 3a land covers land to the north and south of The Avenue; to the west and south of Bitterns Pit Wood; to the north of The Grange and to the south of Moss House Farm. The Grade 4 land covers an extensive area of land to the west of Malkins Wood Farm; along the proposed access road route and in the east to the north of The Grange; and also the small area of land to the north east of Moss House Farm.  

16.3	The main racecourse car parks would be located on previously land filled sites, the equestrian centre, grandstand enclosure and stabling, along with the western end of the race track are located on lower quality than BMV land. The eco centre developments, lake, associated car parking, roads, golf course and remaining section of the racetrack are located on land considered to be BMV. 

16.4	The development would result in a number of reversible and irreversible development features. The irreversible development features include the access roads; the racecourse; grandstand and ancillary buildings; the equestrian centre; reinforced grass car parks; the special running surface on the racetrack; water bodies; the Eco Village Centre and the whole of the area containing the Woodland Wildlife Centre; the western half of the centre of the racetrack and the extension to the golf course. The total area of land surveyed which is assessed, as irreversible development is 108.6ha of which 72.3ha is subgrade 3a and 36.3ha is grade 4. 

16.5	The elements of the development considered to be reversible include the new woodland planting; most of the cross-country event course inside the racetrack; the green corridor to the south of the racetrack surrounding the land remaining in arable use; and the eastern half of the area containing the Eco Village excluding the access roads. Of the land surveyed, 51ha would be affected by reversible development. The remaining 219.8ha of the development site would be left as undisturbed agricultural land. 

16.6	DEFRA do not object to the development in terms of its impact on BMV land although they recognise that consideration should be given to the identified permanent loss of Grade 3a land. It is considered that the loss of 72.3ha of land classified as subgrade 3a represents a negative impact on BMV land, however a significant element of the development would not impact on land classified as BMV and the majority would remain as undisturbed agricultural land.

16.7	The applicant has identified a number of mitigation measures associated with the proposed development. The applicant has proposed to mitigate the impact on soil and land through the appropriate re-use of topsoil from areas of hard development. The mitigation of adverse impacts on soil, relating to compaction and smearing and soil loss would be achieved by the appropriate soil handling measures followed by post-placement aftercare.  

16.8	The applicant proposes that an Agricultural Management Plan would be created through negotiation with owners and tenants and Salford City Council. A planning condition to ensure the implementation of this proposal could be attached to any planning consent.

17.	IMPACT OF THE DEVELOPMENT ON ARCHAEOLOGY AND CULTURAL HERITAGE

17.1	The applicant has carried out a study to describe the impact of the proposed development on the cultural heritage and the likely impact on palaeoecological deposits. The applicant suggests a variety of mitigation measures including evaluation, survey, monitoring, investigation and recording that are intended to avoid, reduce or remedy any negative effects of the proposal. Alongside this the applicant would include a watching brief for a number of important elements. 

17.2	GMAU raise no objection to the proposals, subject to an appropriate condition requiring archaeological mitigation through a programme of evaluation and following on from this, further more detailed excavation, palaeo-environmental analysis, watching briefs, post excavation analysis, reporting/publication and archive deposition as appropriate. 

17.3	A planning condition could be attached to ensure compliance with policy CH5 of the UDP. 

18.	IMPACT OF THE DEVELOPMENT ON DESIGN AND CRIME

18.1	Greater Manchester Police Architectural Liaison Unit have raised no formal objection to the proposals, although state that all new and refurbished buildings should be completed to ‘Secured by Design’ standards. Complying with this request would not result in an increase in crime and as such it is considered that the proposals would comply with policy DES11 of the Salford UDP and the Design and Crime SPD. 

19.	CONCLUSION

19.1	It is concluded that the development is inappropriate development within the Green Belt. The applicant has, until recently, refused to accept that the development is inappropriate and has therefore not advanced any very special circumstances of substance. The failure of the applicant first of all to accept that the application is inappropriate development in the Green Belt, and then to justify the proposal adequately in terms of very special circumstances, means that there is no alternative but to recommend refusal of the application at this moment in time.

19.2	The Highways Agency has indicated that it is likely to lift its Holding Direction preventing the Local Planning Authority from making a decision. It is understood that the applicant's consultants have undertaken more modeling work to justify the scheme, but until that has been submitted and assessed there is no alternative but to recommend refusal on highway grounds.

19.3	In terms of the appraisal on ecology, the position is more finely balanced, with Natural England and the Environment Agency not objecting to the application, but the GM Ecology Unit still having significant concerns. The view of officers as set out above is that it is difficult in the time available and the fact that this matter is to be tested at appeal to come to a firm conclusion on ecological matters and therefore it would be difficult to justify objecting on ecological grounds.

20.	RECOMMENDATION

That the Planning Inspectorate be advised that on the basis of the information that is currently before the City Council in the consideration of this application, the Council would resolve to refuse planning permission for the following reasons. 

1.	Green Belt

The proposal represents inappropriate development within the Green Belt and as such is contrary to PPG2: Green Belts and policy EN1 of the Salford City Council Unitary Development Plan. 

To date, very special circumstances have not been demonstrated that would override the harm arising as a result of the inappropriate nature of the development and the harm to Green Belt policy.  

2.	Highways

The modelling undertaken by the applicant is unacceptable and insufficient information has therefore been submitted to demonstrate that the proposal would not have an unacceptable impact on highway safety or the ability of the Strategic Route Network to accommodate appropriate traffic flows by virtue of traffic generation.  As such, the proposal is contrary to PPG13, policies A1, A2 and A8 of the UDP and policies RT2 and RT9 of RSS. 

APPENDIX A – CONSULTATION RESPONSES

Barton Aerodrome Operation Ltd

Response dated 18th October 2004:- The Barton Aerodrome has a 13km radius safeguarding circle surrounding the development and any existing or future developments that might attract birds requires consultation. Over 80% of birdstrikes occur on or close to aerodromes and therefore necessary steps must be taken to ensure that birdstrike rate is reduced to the lowest practical level. The application proposes significant landscaping and creation of new water features, which may have the potential to create a wide range of exploitable habitats for birds. For the objection to be lifted the following will be required;

•	Production of a Bird Hazard Assessment for the development
•	Evidence to demonstrate that the Bird Hazard to aircraft flying to/from Barton Aerodrome will not be increased
•	Detailed information in the form of a Bird Hazard Management Plan detailing the measures that will be put in place to monitor the existing Bird Hazard Level and prevent any future risk occurring. 

Response dated 10th February 2005:- Remove the objection relating to bird hazards as this issue can be adequately investigated and addressed directly through continued discussions with the applicant

Response dated 9th June 2006:- After extensive consultation between the Licensee of Barton Aerodrome and TEP Ltd, on behalf of Peel, initial objections raised are now satisfied. The Hazard Assessment plan, prepared as additional information to the application submission identified the potential hazards arising from the development and the mitigation required during the design stages and the continuous management of the development site.

Boothstown Residents Association

Response dated 10th January 2005:- A number of comments are made relating to PPG2 (Green Belts), traffic and congestion issues, access, traffic modelling, travel plans, noise, and wildlife issues.

The submission highlights the significant visual impact of the development from the construction of the grandstand, lighting columns, two storey accommodation block for stable lads, stables, saddling enclosure, hotel, and ticket office as these reduce the openness of the site. The intended access points to the site (via Junction 13 of the M60 and the A580 East Lancashire Road) are expansive in nature and the infrastructure required for the development is in conflict with the aspirations of PPG2 in relation to checking the unrestricted sprawl of large built-up areas and safeguarding of the countryside from encroachment.  
 
The application does not assist urban regeneration, by encouraging the recycling of derelict and other urban land. The proposal will provide opportunities for access to the open countryside for the urban population. This can be achieved without the development of the scheme. PPG2 encourages the provision of outdoor sport and outdoor recreation near to urban areas, however the attendance at a race meeting does not involve any form of organised activity. Attendance at a meeting only allows the spectator to participate in ‘on course’ betting. The use of green belt land for this purpose does not appear to be adequate reason to sacrifice Green Belt land.  

Comments are made on the revised UDP: Policy ST4 – Key Tourism Areas - Areas are identified and protected from inappropriate development that could undermine their success as tourist areas reduce their attractiveness or otherwise adversely affect their ability to function optimally. Traffic impacts, unsuitable uses and poor design of the development could undermine this policy. Similarly it is contended that the development would not comply with policy E6 Tourism development due mainly to traffic/highway impacts and impacts on residential amenity. Policy ST6 Major Trip Generating Development - the location of the scheme precludes against a choice of means of transport - uncertainties over the Leigh Guided Busway and the future funding of Metrolink are real concerns. Policy ST13 Natural Environmental Assets - the development will have an adverse impact on an area with significant wildlife assets. Policy EN1 - Green Belts - The scheme will have a major impact on openness of the green belt. The requirements of a spectator recreation (racecourse element) do not justify the loss of this green belt asset i.e. does not have any health benefits. No overriding case has been made that warrants special circumstances being given. Policy EN7 Farm Diversification - the scheme will not protect the open character and amenity of the area. Policy EN7B Nature Conservation Sites of National Importance- Botany Bay Woods is under consideration as a Site of Special Scientific Interest.  The application proposals do not protect this proposed SSSI. Policy EN7C-The scheme is unlikely to have a beneficial effect on 3 sites-SBIs- due to the large volumes of traffic, loudspeaker noise, crowd noise, noise during construction, light pollution together with the large loss of trees from Middlewood. Overall it will have a negative impact. Policy R2 Provision of Recreational Land and Facilities-there are a number of areas within the policy where the applicant is at variance with the aims of R2 Policy. EN7 Protection of Species- there is concern that these proposals could affect the heronry result in driving them away. In conclusion the application should be refused as it is contrary to a number of planning policies that have been outlined. 

There is a significant volume of traffic on the roads in the Boothstown/Worsley and immediate surrounding areas. The proposal will generate more traffic on both race meeting days and through other events to be held at the venue. The congested nature of the roads will encourage ‘fly-parking’ of cars in Boothstown and Worsley as people become annoyed at waiting in their cars to gain access into the site.  

Access routes to the site are already operating beyond design capacity for long periods of the day. The access/egress at ‘Queens Island’ located on the A580 East Lancashire Road is understood to be for agricultural purposes only however reference is made within the application, as this road is access/egress for the proposed development.  

To alleviate congestion issues the applicant suggested rail transport as the primary source of travel, using local stations (Patricroft or Walkden) and then shuttle buses. However the already congested roads would appear to make this unfeasible.  

The document makes reference to a number of unrealistic travel assumptions including the Leigh Guided Bus Route and the future expansion of Metrolink, which are considered contrary to policy ST4. Optimistic assumptions are made relating to the number of visitors arriving at the site by bicycle. The A580 is the only road with appropriate combined pedestrian footpath/cycle track. This indicates that access to the site via a range of public transport choices is reduced.  The Highways models used to predict traffic flows at Junction 13 require manual adjustment to cater for actual traffic conditions. The Highways models should be taking into account the emerging Port Salford and Salford Reds proposals, both of which will generate additional traffic onto the road system that will serve the proposed application site.

Policy A1 indicates the requirement for a Travel Plan. No Travel Plan has been prepared as yet, although it is anticipated that this will be prepared in conjunction with the Highways Authority. A viable travel plan is required as part of the planning application process.    

Noise predictions at Boothstown should be treated with great caution as they are only predictions – not facts. Noise to the human receptor is subjective; an annoyance level cannot be quantified by units of sound alone.

British Horseracing Board (BHB)

Response dated 30th September 2004:- Outlines when an application must be received by the BHB to participate in the fixture allocation process for 2006. Peel Investments have yet to submit a formal application and until such an application is received BHB are not in a position to comment. The Jockey Club has been informed of the proposal since they have to approve the track layout and infrastructure. 

Response dated 15th February 2005:- Indicate that the comments made previously are a typical response from the BHB’s New Racecourse Committee to information from an interested party. The BHB consider the proposal to be an opportunity to expand the sport of British thoroughbred horseracing to a market of untapped potential considering the affluence and population of the Greater Manchester area. A capital investment is required of the magnitude envisaged by Peel Holdings in developing Manchester Racecourse as the most recent addition was at Taunton Racecourse in 1927. A sound business plan and endorsement of the City of Salford can only result in a racecourse facility comparable with the best in Britain. In June 2004 BHB published “ The Modernisation of British Racing” (MBR) which represented a blueprint for the future financial, administrative, governance, and commercial structure of the sport. The MBR document will guarantee Manchester Racecourse a minimum of 16 BHB national fixtures and opportunity for additional fixtures in recognition of its participation in British racing’s fixture allocation process. An ability to participate in the fixture allocation process is contingent on Peel Holding’s project conforming to “The British Horseracing Board’s Guidelines for the Development of New Racetracks” issuance of a licence by the Horserace Betting Levy Board and ultimately endorsement by the BHB Board.      

Council for Protection of Rural England – Lancashire Branch

Response dated 3rd December 2004:- Support the idea of a development that opens up Botany Bay Wood and the surrounding area for public access although they do have concerns. An aim of the Branch is to promote positive solutions for the long-term future of the countryside. Concerned about possible future development implications if the planned proposal goes ahead. The biggest area of concern is the Eco Village complex. They can only encourage a learning resource centre focussing on the education and promotion of the concept of sustainable development and are pleased that the site has been designed to minimise its impact on the woodland environment. However they are concerned about the possibility of this site being further developed or redeveloped if the proposal a) proved not to be economically viable and b) was to expand. The Branch want to see statutory measures put in place to protect this ancient woodland and surrounding area from potentially more damaging development. Legal constraints should be applied as part of the planning approval to control the way the site is developed in the future. 

Response dated 11th March 2005:- More consideration required to public transport arrangements for accessing the site. A shuttle bus service, running from the Walkden and Patricroft rail stations should be provided to access the site on race and non-race days. The Leigh Guided Busway park and ride scheme at junction 14 of the M60 should be used to access the application site. The park and ride scheme should provide 500 spaces rather than the 250 proposed. Race meetings should finish at a time that doesn’t contribute to traffic congestion during the evening rush hour. As an alternative to this, a traffic management scheme should be introduced to ensure that traffic movements leaving the racecourse do not coincide. In relation to the necessary removal of trees to facilitate the construction of a golf course at Middlewood, CPRE would like to see the replacement of trees at a ratio of 2:1. CPRE reiterate their concerns regarding the Eco-Village and future development. If no legal constraints are included as part of the planning approval then CPRE will formally object. 

Countryside Agency

Response dated 24th November 2004:- The Countryside Agency consider that the proposal does not meet the restricted criteria for detailed comments as outlined in the Countryside Agency’s publication ‘Planning Tomorrow’s Countryside’. 

Economic Development Chief Executive Salford City Council

Response dated 6th June 2005:- Comments relate to ‘The Environmental Statement (Part 5) Environmental Assessment Chapter 13: Socio Economic Effects’. ED broadly welcomes the application. ED feels that the ES should make reference to current employment strategies/initiatives within Salford. In some circumstances, further detail is required relating to the analysis of statistics relating to potential job creation. Comments made by Economic Development indicate that the applicant should make links to current Salford employment strategies. ED have indicated that they wish to ensure that the economic benefits of the scheme are felt locally, both in terms of making best use of the local labour supply and in the use of local suppliers in the provision of goods and services to SFP operators.  

Response dated 3rd March 2008:- Economic Development remain supportive of this application but would ask that consideration be given to:

Local Economic Benefit - Economic Development would be seeking to work with the developer to ensure maximum local economic benefit is gained, particularly through the provision of tailored training initiatives to enable residents to access employment opportunities generated at both pre and post construction phases of the development.

Implementation of section 106 - Section 106 Developer Contributions for Local Employment Supply: Construction Industry as outlined in Supplementary Planning Document, applicable to developments with a cost greater than £1 million, the Salford Construction Partnership would be seeking contributions to support the training and development of Salford residents.

English Heritage

Response dated 18th October 2004:- No detailed comments provided although a number of observations are made. Mitigation proposals appear sensible for most of the works. Concerns regarding the impact of the proposed racecourse on the peat, which may contain buried palaeoenvironmental and cultural remains. The proposed programme of survey and analysis is acceptable subject to the detailed agreement in advance of determination. On site historic features should be incorporated into the design of the golf course. The Worsley New Hall Garden Project/Middlewood Garden Project are encouraged and should be integrated into the design of the golf course through condition or planning agreement. Providing that the identified issues are addressed they recommend that this case be determined in accordance with government guidance, development plan policies and with the benefit of any conservation advice locally. 

Response dated 2nd July 2007:- No objections to the proposed developments, however regard should still be taken in relation to previous comments relating to archaeological mitigation. Particular concern should be given to potential buried palaeoenvironmental and cultural remains. Recommend a mitigation programme taking place in advance of determination in order to inform and direct development. 

Environment Agency (EA) 

Response dated 11 January 2005:- The EA objects to the proposal as the Environmental Statement does not fully investigate the flooding issues or provide adequate mitigation to compensate for the loss of flood storage volume upstream of Vicars Hall Lane. The grandstand and associated structures are within an area liable to flooding and their construction will cause the loss of flood storage and an increase in the risk of flooding elsewhere, particularly in the vicinity of Keepers Cottage. 

EA feel that the applicant needs to provide further information relating to the provision of additional flood storage in terms of;

•	Calculations, which demonstrate the amount of, flood storage volume lost
•	A plan showing the proposed flood storage ponds and demonstrate how they will remain empty until required
•	Proposals to defend Keepers Cottage from flooding 

A number of conditions are suggested to reduce/alleviate the risk of flooding; that a scheme for the provision and implementation of a surface water regulation system is approved by the LPA; that the provision and implementation of compensatory flood storage works has been approved by the LPA; and that details of the existing and proposed floor levels have been submitted and approved by the LPA. 

The EA require unrestricted access to Moss House Farm Brook, Shaw Brook, and Sniggley Brook to carry out maintenance and improvement works. Any temporary or permanent works within 8 metres of the top of the bank require prior written consent in accordance with the provisions of the Water Resources Act, Land Drainage Act and Land Drainage Byelaws.    

In relation to ecology, EA object that the proposed culverting of 270m of watercourse, particularly the 95m of Sniggley Brook as this would lead to an unacceptable loss of water based habitat and of its continuity. The mitigation proposed on 2550m of new watercourses will not compensate for the loss of 365m of watercourse to culverts, much of which is Water Vole habitat, and the infilling of a further 360m. Swales are not normally considered suitable watercourses for consideration as mitigation. Applicant should consider more adequate mitigation through alternative site layouts that minimise the loss of watercourses to infilling or culverting. 

The development is within the Mossland Heartland area and aspects of this development will have a detrimental impact on the remnant mossland area, conflicting with policies EN7, EN8 and EN9. An ecological survey should be carried out on any watercourse that may be infilled, modified or is likely to be significantly impacted by culverting. New ponds or watercourses should be created 12 months in advance of any losses to allow colonisation by aquatic plants and for and the development of these areas as suitable receptor sites for animals. 

Development should include an undeveloped buffer strip of at least 5 metres adjacent to the watercourses, increasing to 8 metres where the watercourse is considered to be a main river. This should apply along any watercourse within the proposed Golf Course, where the undeveloped strip should be considered as additional to any rough. 

The golf course should incorporate nature conservation into its design including ponds, planting of woodland, management of riparian buffers and mowing regimes in areas of rough. The proposal should maximise the existing and potential wildlife value of the site, including ecologically friendly features and management practices. The development should take into consideration best practice documents, “On Course Conservation”, and “Committed to Green”. 
   
Response dated 12th August 2005:- The EA maintain its objection to the proposed development. Further comments will be provided once the supplementary paper on Water Vole mitigation is provided.   

Response dated 24th February 2006:- Comments made relating to the Watercourse, Water Vole and Amphibian Mitigation plan. Figures relating to habitat changes and provision of additional open watercourses are unclear and further clarification is required. Further clarity is required regarding Sniggley Brook, and feasibility of the options. Agreement has been reached regarding isolation of Water Vole population through the provision of a channel around the edge of the racecourse. EA recommend a condition relating to the realignment of the ditch at Sniggley Brook and the provision of a 8m buffer strip between the realigned channel, that should incorporate natural features and the racecourse boundary. Also request in this condition that any work to this section of watercourse seeks to enhance the channel by incorporation of natural features, such as meanders. The EA support the proposal that any ditches within the development will be subject to management as detailed in the Habitat Management Plan. The habitats provided for the displaced Water Voles should be checked to ensure that it meets prearranged standards. EA object to the proposed methodology detailed in the mitigation scheme.    

Response dated 31st July 2006:- In relation to ecology the updated plans and information mean that we are unable to remove the objection as the development will result in the loss of a large area of habitat used by a number of species, and despite mitigation proposals for a number of species the total losses to biodiversity cannot be mitigated for and is contrary to PPS9. If the development proceeds then the level of disturbance created will increase irrespective of the mitigation schemes outlined. The mitigation proposed by the developer will only be sufficient when considered on an individual/single habitat scale but when considered against the scheme as a whole the mitigation proposals will be insufficient and will result in further fragmentation of the mossland landscape and habitat. 

The additional information submitted by Jacobs Babtie relating to flood risk is considered to be acceptable.   

Response dated 19th March 2007:- The racecourse grandstand is to be built on the flood plain of Moss House Farm Brook, which will result in the loss of flood storage capacity. A previous objection to the proposal was satisfied when the developer provided equivalent compensatory storage, which meant the flows in the brook should not increase, and the existing standard of flood defence maintained.   

Response dated 26th June 2007:- EA will be maintaining objection to the proposals as the overall impacts on biodiversity of the scheme have not been adequately mitigated and are in conflict with the provisions contained within the Natural Environment and Rural Communities Act and the Countryside and Rights of Way Act relating to biodiversity. The scheme proposes little enhancement other than for Water Voles. Application should be refused on grounds of PPS9, Policy EN1, EN3 EN9, and EN12 of the UDP.  

The culvert beneath the racetrack is contained within a straight channel. The EA has previously stated that it would wish to see this section redesigned to create a meandering watercourse similar to other watercourses in the area. 

Section 6 (Construction phase) of the Water Vole report refers to a twelve-month period between the creation of habitats and destruction of existing Water Vole habitat. This conflicts with the mitigation strategy later in the report. Any new habitat must have reached a level of maturation suitable to support any new population of water voles before habitat is destroyed, irrespective of how long this may take. 

There appears to be a loss of 180m of watercourse (with no Water Vole interest) that has not been mitigated for. The applicant should submit further information as to how this loss is to be mitigated and also details of how the applicant would deal with any problems arising from difficulties with or failure of the mitigation scheme. 

Clarification required as to where the permanently wet swales would be located. If they are to be located on the peat (within the racecourse), we would like clarification as to how the applicant proposes to create permanently wet swales on areas of peat whilst maintaining a functional swale and without raising water levels in the surrounding areas, i.e. on the racecourse. Further consideration should be that groundwater in the area is rising which may further impede the ability of swales or soakaway/drainage facilities. 

Any wetlands formed as part of a SUDS scheme must conform with the SUDS code of practice, and any grey water ponds/swales must not allow percolation into groundwater. 

A net loss of biodiversity would occur as a result of the development, impacting on birds and other species associated with the loss of agricultural farmland. Salford’s SPD on Nature Conservation and Biodiversity identifies a number of species likely to be affected by the proposals that have no associated mitigation. The SPD indicates that there are targets for reversing the long-term decline in the number of farmland birds by 2020. 

The SPD states that indirect as well as direct development impacts should be considered in relation to biodiversity. This is an issue that hasn’t been addressed in the submission documents.   

Response dated 13th March 2008:- EA are satisfied that there are sufficient measures in place to protect the property of Keepers Cottage from floodwaters, and as such lift their objections on flood risk grounds. 

EA maintain their objection on ecological grounds as the proposals fail to provide sufficient mitigation and enhancement and therefore fail to meet the requirements of PPS9. EA agree that some of the proposed mitigation may be suitable for individual species; the overall package is insufficient to mitigate the wider landscape loss. EA consider that there should be no detrimental impact on any species listed as a priority species in the UK BAP, or as listed on the Section 74 list. The impact on species is a result of loss of area of habitat. In order to mitigate for this development the developer must provide an area of habitat of similar area to support the numbers of species and individuals present on the site, or a smaller area of much higher quality with the same or higher carrying capacity, to support species affected. EA accepts that it may not be possible to provide all of the mitigation within the application site although the applicant should consider off site mitigation. 

EA consider the applicants commitment to enter all farm holdings affected by the scheme (and all other open land in the application boundary) into a long term habitat management scheme to be inappropriate if the applicant is referring to the Entry Level DEFRA scheme as this is not a targeted scheme and is of limited timescale (five years). EA state that there is no guarantee that the scheme will be available again once the five year timescale has elapsed, which may result in a stop to mitigation measures and should therefore be considered to be unsuitable.  

EA are satisfied that in relation to policy EN9 (Wildlife Corridors) the loss of individual corridors has been mitigated for in most instances. 

EA have previously requested that Sniggley Brook be restored as a meandering channel however if this request would affect mitigation for farmland birds then EA would not want to pursue this request. However EA state that the creation of a meandering watercourse along Sniggley Brook has always been thought of as part of the overall mitigation/enhancement of the scheme and if this is not possible then further mitigation/enhancement needs to be provided. 

EA still raise issues relating to the loss of watercourses and the creation of swales based on previous correspondence, and as a result have issues relating to the proposed mitigation package. 

EA state that if the application is minded for approval then it is essential that they are re-consulted so that they can make further representations and suggest appropriate conditions. 

Response dated 11thNovember 2008:- The EA are satisfied that the details submitted meet with their requirements and are now able to withdraw their objection subject to the applicant agreeing to appropriate planning obligations or conditions to deal with the long term management of the ecological features on site.
 
Forestry Commission

Response dated September 2004:- The proposals carry merit both in terms of existing woodlands, proposed woodlands and those who may use them. The woodland proposals and the interpretative developments would offer substantial added value to the Red Rose Forest and the overall initiative in Salford, west Manchester and the wider sub-region of the Mersey Belt. The Forestry Commission supports the use of a UK Woodland Assurance Standard (UKWAS) compliant management plan. Further clearance of the remaining rhododendron in the woodland should form part of the work for future woodland management plans. 42 hectares of new woodland is welcomed and supported. Further investigation is required so that all woodland sites within the application boundary are utilised. Concerns that opportunities may have been overlooked to deliver further new woodland establishment that would not only mitigate the potential built development but also add to the overall integrity of the existing woodlands and enhance landscape and biodiversity. Such areas would be all the avenues fringing the existing roads and tracks and the difficult/awkward field corners that modern farm machinery cannot effectively cultivate. These areas would deserve further investigation into their potential as expanded/new woodland sites. The use of national vegetation classification woodland type, native broadleaves and Scots Pine are supported. The woodland proposals are of merit both for the existing woodlands, proposed woodlands and those that may use them. As a national partner in the Community Forest Programme, the woodland proposals and associated interpretative developments would also offer substantial added value to the Red Rose Forest and the overall initiative in Salford, west Manchester and the wider sub-region of the Mersey Belt. It would be good if the developers would work closely with Red Rose Community Forest to maximise the value of the proposals in terms of delivering the Community Forest Plans.   

Government Office North West

Response dated 23rd August 2004:- Acknowledged receipt of planning application.

Response dated 24th October 2007:- Acknowledged receipt of further information.

Greater Manchester Archaeological Unit (GMAU)    

Response dated 6th September 2004:- Recommend that a condition is attached based on PPG16, “No development shall take place within the proposed area until the applicant has secured the implementation of a programme of archaeological work in accordance with a written scheme of investigation which has been submitted by the applicant and approved by Salford Planning Authority.” The Unit generally agrees with the mitigation strategy in the ES. They note however that there is no provision for archaeological evaluation through trial trenching (which was in the original application statement) and would wish to remain as an option for examining potential remains, which might be hidden under shallow peat deposits. This could lead to further more extensive excavation if significant remains are discovered. In addition the Unit would wish to see a substantial contingency fund attached to the watching brief element of the archaeological mitigation so that should significant chance finds come to light appropriate archaeological excavation and conservation works could be undertaken. The Unit also believes that the scheme presents an opportunity to present the archaeological and history of the proposal site and its immediate surroundings to the general public in the form of information boards and so on.

Greater Manchester Bird Recording Group   

Response dated September 30th 2004:- Object to the proposals based on the following reasons. The application should be considered alongside developments on Barton Moss, Port Salford and construction of leisure and retail outlets on the north side of the ship canal. Concerns relate to urbanisation of the area from the racecourse stadium, associated car parks, hotel, equestrian centre and golf course. The area is well catered for in respect of golf courses and racecourses. Red-listed and Amber-listed bird species are likely to be lost during development, including Lapwing, Curlew, Barn Owls, Grey Partridge, Yellowhammer, Hen Harrier and Skylark. Physical barriers (water filled ditches, hedges, fences) should be constructed to prevent unauthorised access into Botany Bay Wood. Footpaths should be closed or restricted from January to June to protect the Heronry. Continuous management of fields 19 and 20 required to maintain ecological interest. Better mitigation for wildlife should be provided with alternative replacement provision provided at Astley Moss East. 

Response dated July 12th 2007:- Extensive resurveys will be required if the proposals are implemented as current survey results will be at least 5 years out of date. An ecological protection document should be agreed prior to any works commencing. The Management Plan should include details on clearance of vegetation outside the bird breeding season, effective annual monitoring assessing established territories and nesting, a protocol for dealing with nesting birds on cleared ground, identify all Ecologically Valuable Features, a flexible protection programme, and provision of a full time ecological clerk. 

Barn owl mitigation should include a resurvey of all structures 1 year in advance of demolition/conversion works. Replacement sites should be built one year prior to destruction of existing breeding or other roost sites. Monitoring, remediation and management programmes for new and retained roost features will be required. Barn Owl roost platforms should be incorporated into Equestrian centre, stables and forest centre.

Greater Manchester Ecology Unit (GMEU)

Response dated 14th October 2004:- Various elements of the proposal have been reduced including the continued commitment to terminate the leases for the shooting activities and the reduction in the scale of the Eco Village. Ecologically this is to be welcomed. Concerns continue about the following elements of the scheme;-

•	The Eco Village supplies 20-bed accommodation, but there appears to be no mechanism to prevent future applications to expand this or any other facility. 

•	The Forest Car Park now accommodates over 800 cars whereas previously it was 450. 

•	The Middlewood Garden Restoration is a new proposal, which has ecological implications. There is limited recognition in the proposals for this part of the site to assess whether there will be a major impact on the interest of the SBI. For example, limited tree/scrub clearance on the terraces of the old garden would be welcomed, as they previously supported a suite of acid/neutral grassland species. However, any reseeding and/or ornamentalisation of this area would not be ecologically beneficial.

•	The removal of proposals for bog restoration to the west of the Nature Reserve is an opportunity missed. However, the reasons for the removal of this element of the project may be due to the hydrological impact of proposals for sand and gravel extraction at the adjacent Astley Moss East site.

Ecological Impacts and Assessment

Due to the large size of the SFP scheme the ecological impacts are many and varied. The impacts of these proposals on habitats that support protected species and local biodiversity is of particular concern. The impact assessment considers cumulative impacts within each group/habitat by the different elements of the proposals. The ES does not consider the impacts across the suite of ecological features that will be impacted. The key ecological impacts are as follows:-

•	Impact on 3 different great crested newt populations (European Protected Species – Habitats Regulations and UK Biodiversity Priority species)
o	pond (P44) lost to golf course and impacts on terrestrial habitat
o	potential temporary loss of pond (P1) to racecourse remodelling and terrestrial impacts
o	bisection of pond cluster by access road from A580 

•	Loss of habitat in all three areas of the existing ditch network that support water vole (UK Protected Species and UK Biodiversity Priority species)

•	Loss of agriculturally managed habitats which support farmland birds, ground nesting birds and brown hare (Birds of Nature Conservation Concern and UK Biodiversity priority species)

•	Loss of existing successful barn owl nest and interruption to feeding territory (UK Protected Species)

•	Disturbance, visitor pressure and potential habitat loss in 2 of the 3 Sites of Biological Importance (SBI) and the potential Sites of Special Scientific Interest (pSSSI) on the site

The ES indicates that any individual impact is not of more than minor negative significance. Mitigation has been proposed for these impacts, although it is acknowledged that there is some element of risk associated with them and that not all the impacts are compensated for. The level of impacts should be considered as a moderate negative impact in at least the district context. No attempt has been made to consider the SFP impacts in the strategic sense, although it is known that there are large proposals for other developments in close proximity that will result in the loss of habitat that will impact on a similar suite of birds including barn owl.

Ecological Mitigation 

The production of the Ecological Protection and Enabling Works Plan During Construction (Appendix SD8) is welcomed. This document will indicate the extent of works that will be required at each phase for various ecological receptors. The enabling works to create the great crested newt ponds and new ditches 12 months in advance of their destruction and/or diversion are welcomed. 

Welcome the incorporation of wildlife friendly design features in the drainage network, such as; ditch profiles with shelving for mammal movements, mammal shelves in culverts, inoculation of ditches with native plant species, and the treatment and reuse of grey water. Concerns that the system is designed for the management of surface water run-off and the maintenance of floodwater storage capacity. Specific concerns include;

•	Many of the new drains will not have the ability to support wildlife features. The current impact assessment overplays the extent to which the new drainage system can support key wildlife receptors.

•	The system is designed to hold water to be released through control mechanisms into the major brooks to maintain the existing rates. The new drainage features are likely to be subjected to very flashy flows, which are not ideal conditions for water voles and inappropriate for great crested newt ponds.

•	Concerned that edge of road run-off will be directed into existing watercourses without any apparent mediation measures. This may introduce contaminants, such as hydrocarbons and/or de-icing compounds. This will increase the sediment load of the water (particularly Moss House Farm Brook and the brook which connects to Sniggley Brook, south of the Hotel complex). 

•	Great crested newt mitigation ponds should be designed and created as independent from any of the attenuation ponds. They should not be connected to the grey water recycling system and should not be used to irrigate any of the grassland features. Additional ponds should be incorporated into the design of the golf course specifically with the intention to support great crested newt. 

•	Retained exiting ditches that support water vole and/or are assessed as having good habitats should not be reprofiled as this will be an additional disturbance impact. These ditches should be brought into rotational management as outlined in the objectives of the Wetland Management Plan.

Great crested newts and amphibians – The ponds bisected by the access road from the A580 do not present major issues, providing that an appropriate trapping out and exclusion regime is implemented. The incorporation of the amphibian tunnel design under this road is welcomed. Concerns exist regarding the other two populations.

•	Great crested newt translocations should be considered as a last resort. Consideration should be given to retaining the area at Booth’s Bank on the golf course, where great crested newt ponds currently occur.

•	Great crested newt replacement ponds should not be dual purpose and should be separate from the flood attenuation, irrigation and/or grey water recycling systems.

•	In relation to newt mitigation, concerns exist that replacement ponds to be constructed on the golf course will be impacted by the re-contouring works needed to create fairways etc. This work will need to be programmed for a specific time of year. Recommend that additional detail is sought on the methodology of this aspect of the scheme. 

•	It is unclear whether the great crested newt pond adjacent to the racecourse (P1) will be temporarily lost due to the re-profiling work to create the track profile. Recommend that additional detail is sought on this issue. 

Water voles – The proposals will have a significant effect on the existing populations of water vole on the site. Suggestions made regarding modifications to the drainage scheme as detailed above. Recommend that additional detail is sought on the water vole mitigation prior to the determination of the application. Additional detail should include;-

•	The mitigation proposed includes the displacement of water voles from areas impacted by the works. It will be necessary to trap the animals out of areas to be destroyed.

•	Before displacement is adopted as a mitigation technique the drainage system needs to be categorised to identify areas where displacement into suitable habitat can occur. The Ecological Report indicates that the upstream section of Moss House Farm Brook does not support suitable water vole habitat. If appropriate habitat is not available alternative solutions will need to be sought or additional enabling works proposed. 

•	There is some confusion about Shaw Brook and whether it is to be diverted by the golf course works (cf Appendix SD8). If this is the case then the water vole mitigation will need to consider this area in more detail, as there is little scope for displacement north of the Bridgewater Canal.

Bats – Unclear whether the bat roost in Malkins Wood Farm would be directly affected by renovation works, as alterations to the bats’ roof access points are discussed. Clarification of this point should be sought. Discussions will be needed with English Nature regarding the licensing of this part of the proposal.

Heronry Nature Reserve (pSSSI) – Concerns that a proportion of the visitors to the Woodland Park will disturb the nature reserve area. The prediction of visitor numbers is high (from extrapolation of the car parking places) and therefore the number who will venture more widely will be greater. It is felt that it is not sufficient to limit access to the Nature Reserve just by signage and request that a more effective mechanism be sought to restrict unauthorised access to this part of the site. 

Generally satisfied that approach for replanting and/or restocking of wildlife features is the correct one but suggest that the grassland conservation mix should be reconsidered, and the tree species used should be locally native.

Operational Ecological Management 

The proposed ecological management may produce some biodiversity gains but it is still in broad outline with limited detail. The production of the following plans should be welcomed;-

•	Agricultural Habitat Management Plan - to include hedgerow management
•	Woodland Management Plan
•	Golf Course Management Plan
•	Wetland Management Plan

Recommend that the production and implementation of a specific Nature Reserve Plan. It may be considered unreasonable to expect the production of detailed management plans at this stage, for such a large area. However, the production and implementation of such plans should be conditioned and/or subject to a Planning Agreement which are both legally binding (in the case of the Agricultural Habitat Management Plan) and enforceable, if this proposal were to be granted permission. Without the implementation of sympathetic management for wildlife, the impacts of the development would be totally unacceptable.

The scale and impact of the proposals are very large and consequently the cumulative ecological impacts are greater in total than the sum of the individual species/habitat impacts. The impacts on wildlife should be considered to be significant on a District scale and it is recommended that it is this evaluation is taken forward in the Council’s deliberations over the application. Additional information is required on the drainage system design, the Middle Wood Garden restoration and the great crested newt & water vole mitigation schemes. 

If the Council are minded to recommend approval for this application, the opportunity would greatly be appreciated to discuss the details of conditions that would be needed to protect the wildlife interest of the site.

Response dated 23rd February 2006:- In relation to the Watercourse, Water Vole and Amphibian Mitigation Report a number of comments were made. Welcome modifications to drainage design to maintain a continuous corridor of habitat for water vole. More detailed comments are then made in relation to the provision of additional open water course; summary of habitat changes; water course and water vole construction phase; Sniggley Brook mitigation; amphibian construction phase. Consultee now satisfied with the level of detail provided on the issues of drainage, water vole and great crested newt mitigation 

Response dated 12th July 2007:- Due to the size of the proposals there is a considerable degree of uncertainty about the outcomes of any particular element of the mitigation schemes and the sites future management for biodiversity. There are known difficulties of integrating ecological mitigation into major regional developments and to produce agreements to implement and maintain a high level of enhancement for biodiversity. 

Approach to amphibian mitigation, and drainage ditches have been addressed as adequately as possible at this stage, and implementation should be ensured by appropriate condition. However, there has been no further information relating to the Middlewood Garden Restoration. The amended proposals provide no wider biodiversity enhancements, particularly for critical features such as the farmland birds and other species of open countryside. Also the area of bog restoration at Botany Bay Wood has now been incorporated into Astley Moss East sand and gravel quarry and no additional areas/schemes have been tabled.  

Response dated 2nd November 2007:- Green Belt issues are outside the remit of the Ecology Unit.  

Conclusion – Impacts of the scheme will be apparent on a landscape scale. The development will affect the ecological permeability of the site across the habitats in that landscape by introducing large-scale changes to the presently undeveloped countryside and altering its management, substrate, levels of disturbance and connectivity to other landscape/habitat features. 

Agreement has been reached on each individual element of the mitigation schemes proposed except for the extent to which the farmland birds can be accommodated within the new landscape and be sustained by future management schemes. 

The scale and number of schemes that will have to be implemented satisfactorily and to a high standard to adequately address the identified impacts remains a concern. Recognise that there will be habitats suitable for a suite of species following the construction of the proposals, however there is a significant degree of uncertainty associated with what species assemblages will result and be sustained by future management agreements.

Response dated 6th November 2008:- Changes and clarification received should be welcomed but these are not substantive or significantly different to alter the views expressed in GMEU’s previous correspondence.  GMEU still hold the view that the cumulative impacts of the proposal are greater in total than the sum of any individual species or habitat impacts.  In addition, the impacts should be considered significant on a District scale.  The view is maintained that given the sheer scale of the development proposals and the consequent mitigation schemes that there is a significant degree of uncertainty regarding their achievability and the consequent carrying capacity of any retained / recreated habitats either immediately post development or in the long term under any management plans.

Greater Manchester Passenger Transport Executive (GMPTE)  

Response dated 27th September 2004:- Whilst regular and frequent bus services to a number of destinations run to the north of the site along Leigh Road these are located beyond walking distance. This also applies to the proposed Leigh-Salford-Manchester Quality Bus Route, which would run along A580 and Newearth Road. Rail based transport in the area is also too remote from the site to offer an alternative to the car. The GMPTE are encouraged by the proposed measures to improve public transport accessibility, which will lead to a reduction in the number of trips to and from the site. The Transport Assessment includes a commitment to develop a Travel Plan and proposes a number of measures aimed at improving public transport on race days. The Transport Assessment raises the potential for bus services to be diverted to the site on race days and through it on non-race days. Bus operators may wish to do this as the additional mileage can be justified commercially in terms of patronage but would otherwise require a subsidy to do so. GMPTE would not wish any diversion to be at the expense of services to the residential areas of Boothstown. A Travel Plan is needed to cover trips to and from the site all year round and not just race days. In particular jobs at the various facilities need to be accessible to those without a car. For leisure trips some visitors will be prepared to walk from existing services but the benefits of the facility will not be widely available unless the site is accessible by bus throughout the year. Measures could include a staff minibus and a weekend shuttle for visitors. GMPTE considers it appropriate to ask for a developer contribution to provide for public transport access on non-race days since operators are unlikely to provide this on a commercial basis.      

Response dated 20th June 2007:- The Travel Plan should include information on employment travel and other leisure travel to the on-site facilities or recreational travel to the Country Park as well as on race days. The Travel Plan should have firm measures promoting a choice of transport modes in order to achieve the required modal shift. A developer contribution should be included to extend existing commercial services that currently terminate at Boothstown or Worsley, a staff minibus and a weekend shuttle bus for leisure visitors. Some targets for mode share for race and non-race days and for employee travel should be shown. The Travel Plan should detail a monitoring regime with agreed targets and penalties for not meeting the modal split. 

Proposed cycle route development on Bridgewater Canal towpath will improve access to east and west, however there is a distinct lack of a viable north/south routes crossing the M62 motorway and the Liverpool – Manchester railway. Applicant should investigate pedestrian and cycle crossings to aid north – south movement. Pedestrian routes should be upgraded to shared cycle use to facilitate north south links. 

Development, submission, implementation and monitoring of the Travel Plan should be attached as conditions of any planning consent.   

Greater Manchester Police (GMP) Architectural Liaison Officer

Response dated 14th October 2004:- The unit have not commented on the details of each component part but offer general comments. All new and refurbished buildings should be built to Secured by Design standards and controlled via planning condition. It is essential that areas for vehicles should be clearly defined and measures taken to prevent vehicles from accessing areas where they should not be. Motorcycles and off road driving could be a particular problem. The layout and planting along paths should be done so that hiding places and blind spots are not created and those people using the paths are safe. The woodland centre may attract vandals and as such needs to be carefully detailed and secured. Money handling at the racecourse, ticket office etc. needs to considered and advice about raid control should be sought from the local Crime Reduction Advisors.
 
Response dated 31st May 2007:- No objection to the proposals but any buildings constructed should be built to Secured by Design standards, and should be conditioned to any planning permission granted.

Health and Safety Executive 

Response dated 12 April 2006:- Insufficient information has been provided for the HSE to assess the suitability of the proposal. Further information is required relating to a number of outstanding issues. Requested that Salford City Council get copies of plans of the site that detail all the major hazard installations/complexes, pipelines and sites from National Grid.

Response dated 5th June 2007:- Letter sent to inform SCC that the HSE no longer provides Land Use Planning advice.

Highways Agency

Response dated 23rd August 2004:- The Agency recognise that this is a major and complex application that will take time to assimilate and review. The Agency recognise that impact and influence of the proposals on the operation of both the strategic and local highway networks will be significant. Issue TR110 Holding Direction under Article 14 of the Town and Country Planning (General Development Procedure) Order 1995 as insufficient time and information is presently available to the Secretary of State to determine whether the proposed development would generate traffic on the trunk road to an extent that would be incompatible with the use of the trunk road as part of the national system of routes for through traffic in accordance with Section 10(2) of the Highways Act 1980. The direction shall remain valid until 26th November 2004

Response dated 19th October 2004:- The access layout proposed at the M60 Junction 13 clockwise off-slip indicates a free flow lane into the development, directly from the slip road. The slip road access is in contravention of Government policy relating to the provision of new accesses to developments from the core trunk road and motorway network and needs to be resolved. The applicant should investigate other local road access options and then submit these for review. 

The Agency will need to satisfy themselves that the access is one that is permissible in light of Government policy. It is clear that the proposed access route is unacceptable in policy terms, and a suitable alternative is required that would avoid a breach of this important Government requirement. The Agency advises that the applicant investigates other local road access options and submit them for consideration. 

Response dated 25th November 2004:- Renewal of TR110 Holding Direction. The direction shall remain valid until 26th May 2005.

Response dated 25th May 2005:- Renewal of TR110 Holding Direction. The direction shall remain valid until 25th November 2005

Response dated 25th November 2005:- Renewal of TR110 Holding Direction. The direction shall remain valid until 25th May 2006

Response dated 25th May 2006:- Renewal of TR110 Holding Direction.  The direction shall remain valid until 25th November 2006.

Response dated 24th November 2006:- Renewal of TR110 Holding Direction. The direction shall remain valid until 24th May 2007

Response dated 21st May 2007:- Renewal of TR110 Holding Direction. The direction shall remain valid until 27th November 2007. 

Response dated 20th August 2007:- The HA have reviewed the information submitted by the applicant as part of the May 2007 ESS. An assessment of the acceptability of the assumptions made and work undertaken by the applicant in terms of highways and transportation considerations are made. The HA seek clarification on a number of issues before they are able to draw together final conclusions regarding the materiality of the impact of the proposed development on the trunk road network. Once the HA receive the required information and amendments to the scheme have been made they will be in a position to take a more informed view of the impact of the development on the trunk road network. HA recommend that Lthe Council request the applicant to submit the required details/clarification. A review of the Updated Transport Assessment indicates that some progress has been made relating to a number of concerns raised previously. Despite this concerns exist that there are still outstanding issues that require further discussion with the applicant before progress can be made. Some further work may be required of the applicant.  

Response dated 21st November 2007:- Renewal of TR110 Holding Direction. The direction shall remain valid until 21st January 2008.   

Response dated 18th January 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 18th March 2008. 

Response dated 18th March 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 18th May 2008. 

Response dated 16th May 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 16th July 2008. 

Response dated 15th July 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 15th September 2008. 

Response dated 12th September 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 12th November 2008. 

Response dated 12th November 2008:- Renewal of TR110 Holding Direction. The direction shall remain valid until 12th December 2008. 

Response dated 4th December 2008:- JMP were commissioned to produce a VISSIM model of the M60 junction 13 to determine the impact of the proposed development and its associated highway works on the networks operation in this area.  JMP have provided a final report (Working note 7) which summarises the work undertaken.  This report concludes that:

•	Whilst the Salford Forest Park development covers a large area with a range of uses its primary use, namely that of a racecourse, would only generate significant volumes of traffic on 9 days of the year. For the remainder of the year, the ancillary uses are of modest size with low levels of traffic generation;
•	It would be unfeasible to provide sufficient highway capacity to accommodate the occasional major events associated with the Salford Forest Park proposals. In order, therefore, to minimise the potential impact associated with major events, it is proposed that more modest highway improvements be provided but that these improvements be supported by a full programme of measures which accord with Circular 02/2007, including a comprehensive Travel Plan and a Traffic Management Strategy;  
•	The Travel Plan now provides sufficient detail as to how sustainable travel will be promoted to staff and visitors to Salford Forest Park;
•	The Traffic Management Strategy identifies in principle how major events would be managed on-site; 
•	As a result of the proposed highway scheme, the Salford Forest Park development will not have a material impact on the operation of the strategic road network and would, on the whole, provide a benefit to the operation of the M60 Junction 13 on both the local and strategic road network;
In light of the above, the working note concludes that, taking account of the overall transport package, the proposed Salford Park development would not have a material impact on the safe and efficient operation of the strategic Road Network.

As a result of these findings, it is the intention of the Highways Agency to remove the holding direction relating to this application subject to conditions along the lines of those outlined below: 

•	Full Implementation of the Site Travel Plan;
•	Full Implementation of the Traffic Management Strategy;
•	Implementation of the agreed Highway works, complete with High Occupancy Vehicle Lanes, access control and ramp metering on the M60 slip roads; 
•	Agreed Thresholds to the Scope & Frequency of Events;
•	Provision of a Formal Site Steering Group;
•	Provision of Traffic Management Strategy for Major Events; 
•	Provision of Shuttle Buses & Event `Race Day Specials’; and
•	Management of the Internal highway network during `normal’ (non-event) operation.

Lancashire Aero Club

Response dated 19th October 2004:- The Lancashire Aero Club does not want to be held responsible for noise disturbances to future users of the development, by the continuation of current established operations in the vicinity of the aerodrome. 

Manchester Ship Canal Company

Response dated 22nd April 2005:- No objection to the application and register full support for the proposed development. 

National Farmers Union North West

Response dated 20th August 2004:- The farmers within and adjacent to the application site have requested that the NFU write to the Council noting their objection to the development as proposed on the following grounds:

•	The application site includes land within the designated Green Belt:- Policy EN1 of the November 1995 UDP (now superseded by 2006 UDP) prohibits inappropriate development within the Green Belt unless it falls within any of three exceptions to the strict control, none of which would seem to be supportive of the current application. The proposals whilst incorporating an amount of additional screening would constitute a substantial visual intrusion into the open character of the Green Belt, which is currently principally used for arable and vegetable farming. The scale of the racecourse grandstand and hotel would be particularly prominent when viewed from the surrounding areas. Due the intensification of the use, the rural nature of the land would be adversely affected. 
•	The agricultural productivity of the farmland included in the application:- The land comprising the application site is predominately Grade 1 and 2 as denoted by the Agricultural Land Classification Map of 1984. Policy EN4 of the November 1995 UDP (now superseded by 2006 UDP) prohibits development, which would result in the loss of these categories of land, which are deemed to be the Best and Most Versatile (BMV). The application intends to develop a substantial amount of land in these categories, which are currently in productive agricultural operation. 
•	The application potentially fragments viable agricultural holdings: The farmland within the site forms a productive part of a number of viable and ongoing agricultural businesses. The size of the development would mean the loss of a substantial part of the land accompanying each holding with resultant loss of productivity and income. This would seriously compromise the long-term viability of the farming business and ultimately may lead to the surrender of the farms to the landlord. 
•	The granting of planning permission may jeopardise the long term security of the tenants: The farms are occupied principally by tenant farmers whose tenure is governed by the provisions of the Agricultural Holdings Act 1986 which bestows upon them security of tenure. However, under these same provisions the landlords may apply to resume possession if they are able to obtain planning permission for uses other than agriculture. This eventuality is of great concern to the tenant farmers.
•	The enhanced access may compromise farm security and the requirements of quality assurance schemes: The development proposals include an intention to create a network of interlocking pathways, bridleways and access tracks across land that are currently tracts of productive farmland. This would vastly enhance the potential for unauthorised trespass and also unauthorised use by motorised vehicles, particularly motorcycles. In the current review of EC Agricultural support regime the farmers who receive aid are to be required to adhere to an environmental quality assurance programme known as cross compliance.  As an integral part of the regulation commodity based assurance schemes require that a range of food production standards be adhered to. One such standard is the limiting of unauthorised access to farm yards i.e. essentially food production areas and therefore potentially subject to malicious acts. The farmers access to various areas of land usually with heavy machinery use current tracks and ways and as such a potential conflict with other users would arise.

The submission does not make any intention to protect the current farming interests and the applicant has had no meaningful exchanges with their tenant farmers to ally concerns regarding the long-term intentions for the protection of the current farming interests. It is requested for the reasons given above that the areas of farmland are taken out of the application site. Furthermore it is requested that the Council undertake an independent survey to quantify the implications of the proposals upon the tenant farmers businesses.

Response dated 14th April 2008:- There objections still stand as relevant, but they have now been made aware of the newly advertised intention to create a championship Golf Course facility of a size which would be able to host the Ryder Cup.  Our members, who currently farm within the defined boundaries of the application, regard the speculation about the hosting of the Ryder Cup as a strategy to apply pressure upon Salford City Council when determining the application before them.  The applicants merely give a vague intention to bid for the opportunity to host the Ryder Cup at some indeterminate time in the future and, as such, scant regard should be given to this speculation when considering the application.

National Grid Company / PLC British Gas Transco

Response dated 7th September 2004:- Detailed comments made in relation to the 8” Astley Green to Worsley pipeline and the 36” Blackrod to Warburton high pressure pipeline. Consultation response considers these two pipelines in relation to building proximity distances, access, landscaping and site profiling, water features, drainage, services, planting schemes, and construction. The majority of these points cannot be resolved until detailed design information has been assessed.   

Response dated 10th May 2006:- Provision of a plan detailing gas pipes that cross the site and that are owned by National Grid. The plan shows that there is High Pressure apparatus in the vicinity and that it is essential that no works or crossings of this High Pressure pipeline be carried out until detailed consultation has taken place. 

Response dated 7th November 2007:- Assessed the application with respect to the operational electricity transmission network and operational gas transmission network. Concluded that proposals pose a moderate risk. Network plans and general guidance are provided. 

Response dated 29th February 2008:- Provision of a plan detailing gas pipes that cross the site and that are owned by National Grid. The plan shows that there is High Pressure apparatus in the vicinity and that it is essential that no works or crossings of this High Pressure pipeline be carried out until detailed consultation has taken place. 

Response dated 25th March 2008:- National Grid does have Major Accident Hazard Pipelines in the vicinity, Astley Green – Worsley and Blackrod – Warburton Tunnel North. The pipelines are laid in legally negotiated easements to which certain conditions apply. It is essential that access to the pipelines is not restricted, particularly in the event of an emergency. There must be no obstructions within the pipeline’s maintenance easement strips, which would limit or inhibit essential maintenance works on the pipelines. It is not acceptable to increase/decrease the amount of cover over the pipeline without written consent form National Grid’s Engineers.  

The building Proximity Distance for the pipelines is 15.5 metres for the Astley Green –Worsley and 3 metres for the Blackrod – Warburton Tunnel North. This is the minimum distance recommended by National Grid between the pipelines and any ‘normally occupied’ building. 

Natural England

Natural England was established by the Natural Environment and Rural Communities Act 2006. Natural England was formed by the amalgamation of three founder bodies:

•	Countryside Agency, the landscape, access and recreation elements
•	English Nature
•	Rural Development Service, the environmental land management functions of The Department of Environment Flood and Rural Affairs (DEFRA)

As a result of this, all previous consultations will be covered under the Natural England heading.

Response dated 24th November 2004:- The organisation is a national and largely strategic organisation and has limited involvement in site based planning. The Agency does not wish to comment formally on the application, as it does not meet the restricted criteria for their detailed involvement set out in the publication, “Planning Tomorrow’s Countryside”.

Response dated 21st April 2005:- There are no statutory sites of nature conservation importance within or adjacent to the proposed development. Botany Bay Wood is of potential SSSI quality because of the large heronry, but is unlikely to be designated as such in the medium term. The proposed development should not have a significant impact on the heronry provided that adequate long-term mitigation measures are implemented to prevent disturbance during the bird-nesting season. Licences will be required for protected species and these will be based on the mitigation proposals being of an appropriate level. Biodiversity gain can be achieved on site through the long-term management and implemented through planning conditions.  

Response dated 3rd April 2006:- Comments are based on material found in Chapter 9 of the Salford Forest Park: Environmental Statement Part 5: Environmental Assessments. The approach taken to grade the peat land as Grade 3a is the common approach used. Grade 3a is considered as being the best and most versatile (BMV) agricultural land category. DEFRA will not object to the development but consideration should be given to the permanent loss of this national asset of BMV agricultural land. It will be up to the planning authority to weigh the loss of this land against the benefits of the proposed development in light of all the issues raised.

Response dated 25th June 2007:- There are no nationally designated landscapes or any statutory designated areas of nature conservation importance that would be significantly affected by the proposed planning application. The proposal will not have any significant impacts upon Natural England’s other interests, including National Trails, Access Land, or the areas of search for new national landscape designations. The proposal lies close to Botany Bay Wood pSSSI but the development will not materially or significantly affect it, providing that the scheme is implemented as described and the proposed mitigation is secured. The detailed mitigation strategy identified for water voles in respect of Sniggley Brook should ensure no detriment to the maintenance of the populations at a favourable conservation status. Defra licenses will be required for all protected species mitigation works. Enforceable planning conditions need to be attached to any permission given relating to the maintenance of any biodiversity and landscape features created as part of the site mitigation is secured for a minimum of 25 years following completion of the development, through a S106 or similar agreement.  

Conclusion – No objection - Natural England are not aware of any statutory designated sites, which will be significantly affected by the proposals. Botany Bay Wood, has been identified for some time a pSSSI, and this designation is unlikely to change in the foreseeable future. Strongly recommend mitigation for any proposals likely to cause disturbance to the heronry, but would also be pleased to see opportunities for general habitat enhancement included. Satisfied in respect of protected species mitigation, and would encourage maximising opportunities for habitat creation and enhancement.

Strongly recommend that implementation of mitigation proposals be achieved through the use of appropriate and enforceable planning conditions, and long-term management be secured through a Section 106 or similar agreement.

Network Rail

Response dated 5th May 2005:- Issued a holding objection based on the illustrative plan it appears that the operational railway is being used as part of the woodland scheme. Network Rail require a copy of the boundary plan that identifies the applicant’s ownership. 

Response dated 12th May 2005:- Objection withdrawn. 

Response dated 30th May 2007:- The developer must provide a suitable trespass-proof fence of at least 1.8m in height where the application site borders the rail boundary. 

North West Development Agency

Response dated 20th August 2004:- No comments with regard to the application.

Response dated 5th June 2007:- No comments on the additional information and amended plans which have been submitted. 

Response dated 16th November 2007:- No comments on the additional information submitted relating to Very Special Circumstances.

4NW – The Regional Leaders Forum (formally known as North West Regional Assembly)

Response dated 6th October 2004:- SCC should be satisfied that the sequential approach set out in Policy DP1 of RPG has been properly addressed in terms of site selection. The Council should take into account the impact of all developments at the Barton Regional Investment Site and the proposed land uses in the wider (Barton/Carrington) area to assess the capacity of the transport network to accommodate development in accordance with policies DP4 and T3 of RPG. 

Policy EC9 of RPG indicates that LA’s must be satisfied that the infrastructure and environment of a site are able to accommodate visitor impacts proposed by the new development. 

The proposal does not accord with Policy UR12 of RPG as it states that, ‘Regional Parks should be focused on informal outdoors recreational provision with limited all weather facilities’. Emerging policy in draft revised RPG (2004) expands Policy UR12 to include a reference that, ‘Regional Park projects should be focused on informal recreation and leisure and sporting provision….’ This policy will be considered as part of the Examination in Public to be held in November 2004 and as such it is premature to suggest that this is emerging policy. 

Response dated 11th June 2007:- NWRA will support the comments and recommendations made by the Highways Agency in relation to the amendment to the configuration of M60/Junction 13 western roundabout and new access road. Welcome the proposal for new planting in the area, due to the loss of trees, which will occur within the revised arrangement at Junction 13, M60. 

The NWRA welcomes the overall environmental balance that remains within the amended plan. Consideration should be taken into account in relation to biodiversity, i.e. Sniggley Brook. Policy EM1 indicates that plans, strategies and proposals should protect areas of wildlife and encourage their protection. Proposals should identify and protect natural or manmade features within this environment. NWRA supports the protection of water vole habitats within the brook and the proposed planting. 

Policy EM3 of draft RSS indicates that proposals should promote and deliver multi purpose networks of green space and integrate green infrastructure within new development, which will promote the provision of socio economic, and public health benefits. Policy EM4 of draft RSS emphasises the use of natural landscape for recreation.  

RAGE - partnership between Worsley Village Community Association, Boothstown Residents Association and Worsley Civic Trust and Amenity Society

Response dated 21st May 2005:- Formal Objection. The application is contrary to RSS policy EC8 Town Centres – Retail, Leisure and Office Development; as the applicant has failed to take in to account that “no need has been demonstrated to create new or extend existing out-of-centre regional or sub regional shopping and leisure facilities.” The application is contrary to policy EC9 – Tourism and Recreation as the policy encourages the provision of new facilities provided that: the location represents economy in the use of land; the infrastructure and environment is able to accommodate the visitor impact; the existing amenities for local residents and business are protected; and the location is, especially in respect of large scale visitor attractions, conveniently accessible by public transport.”

It is considered that the grandstand, other racecourse facilities, equestrian centre, hotel, golf clubhouse, forest park centre and timber workshop represent inappropriate development in the green belt due to reasons of: 

•	scale, 
•	non essential facilities for outdoor sport or recreation, 
•	parts of the development that fail to accord with the guidance contained in PPG2 in respect of the re-use of existing buildings,

In relation to Very Special Circumstances, it is considered that the apparent need is not so significant that the harm that will be caused to the green belt is justified. The applicant provides no detail that if the development does not proceed that any harm will be caused. The arguments put forward by the applicant to demonstrate a need for a racecourse are not considered to express an overriding need that can be considered as VSC, which override the inherent harm that this development would have upon the green belt. The applicant does not demonstrate that the racecourse industry has identified a shortage of facilities within the North West or Greater Manchester, and therefore the argument based upon the racecourse industry’s desire to expand does not provide any specific justification for the need for a new racecourse at SFP. The applicants own survey data does not clearly demonstrate that there is no all-embracing public demand for a new racecourse in Manchester and that a new course at Salford is not the most appropriate location to serve the needs of the conurbation. The applicant does not identify the northwest region or the Greater Manchester area in particular as being in need of a new all weather facility. The applicant has not demonstrated that there is an unmet demand within Greater Manchester for a new racecourse with no evidence of over attendance at Haydock Park or any other North West course. 

There is a sufficient supply of hotel rooms within the local area therefore no new hotel accommodation is required. Due to the infrequency of the race events, the proposed hotel would simply add to a general surplus within the local area and possibly harm the viability of existing hotels, which are located in more sustainable locations. 

The need for additional economic activity can be applied to any conurbation. However, all economic activity should be concentrated upon existing built up areas and Investment sites identified in the planning process as otherwise this would draw activity away from built up areas and regeneration areas contrary to sustainable development and PPG2 principles. 
     
The need for additional greenspace has not been demonstrated in a form that justifies the inappropriate development of the scheme as a whole. The provision of public access is not a sufficient planning benefit to justify the scale of development required for the grandstand and other facilities, the hotel or the indoor arena in the equestrian centre. 

The Environmental Statement does not include details on a range of issues that should have been considered further at this stage. Issues not considered include the consideration of alternative sites in the green belt; no detailed site investigations relating to the on site landfills; consideration within the Transport Assessment of peak trip periods on the existing highway network; and the failure to follow best practice that undermines confidence in the ES. 

The development raises concerns with residents over the impact on residential amenity, in respect of traffic congestion, fly parking, noise from traffic, light pollution, air pollution and general disturbance. Any development, which will increase the quantity of traffic using the local roads, would only exacerbate these existing problems leading to more disruption for local residents.  

In relation to Nature Conservation issues it is considered that the overall impact upon issues of nature conservation importance have not been sufficiently recognised. The impact of the development is considered to be of concern in relation to the Botany Bay Heronry pSSSI, Hollin Wood SBI, Bittern Pits Wood SBI, Middlewood SBI, water vole, great crested newt and bats. The cumulative impact of upon the ecology of the area as a whole would be substantial. Works should not be carried out that would have a negative impact upon protected species or designated sites without an assurance that such impacts would be short term only, the proposal therefore conflicts with policies EN5, EN6 and EN24 of the UDP. 

In relation to openness and visual amenity of the green belt, the grandstand would be considered a considerable urban feature in an area of countryside, but when considered alongside the substantial circulation, parking and other racecourse facilities and the access arrangements, the extent of urbanisation of the application site is colossal. The nature of the proposed new buildings means that they will look incongruous in views of the site. The grandstand, hotel, and indoor arena in particular do not have a rural character nor does it appear that any attempt has been made to integrate them within the rural landscape. Consequently they will harm both the openness and the visual amenity of the green belt. The impact of this is that far from protecting the countryside from encroachment, there will be a perceived expansion of the urban area of Boothstown. 

The visual assessment by the applicant is far too positive and does not take into account the fact that large built structures do not benefit the views of a rural area. The grandstand and indoor equestrian centre are very substantial structures, which will be detrimental to views into the site from the urban area, and they will not be sufficiently mitigated by the proposed planting, which particularly from Boothstown will serve to no more than screen the base of the Grandstand in summer, and be more prominent in winter. 

Access to the site will be prominently by private car, which is highlighted by the fact that a Green Travel Plan has not been submitted as part of the application. The railway stations are located a substantial distance from the facilities proposed within the site, and distances are double those stated within the ES. The suggested shuttle bus service would only be operational if a race was being held. The location of the development means that there are few options to significantly improve public transport links. The proposed guided bus link from Leigh has had its funding withdrawn and transferred to the Metro although there are no extensions proposed near the course, and there would be little advantage in providing a new railway halt to the south. Walking is not an option except for the limited number of residents of Boothstown who are close enough to the site. 

The proposed socio-economic advantages of the development have not been considered in sufficient depth. The assessment is very vague and the assumption that occasional part time work equates to full time equivalent job creation is misleading. 

Response dated 4th July 2007:- Holding objection. Request for further time to assess the revised ESS. Despite this the proposed changes concerns still exist relating to the greatly increased traffic congestion affecting Worsley, Boothstown and immediate surrounding areas; noise will be heard at least a mile form the application site; inappropriate development in the green belt; light pollution; and severe disruption experienced during the construction phase. The conclusions reached in the previous response remain valid. The alterations to the traffic island at junction 13 includes the provision of traffic light control. Whilst this feature does offer a means of controlling traffic it does nothing to improve the capacity of this junction and the associated road network to handle both the present traffic flow, the year on increase through this area coupled with the additional traffic flows into and out of the application site. This response should be logged as an initial objection that will be followed by a more detailed submission. 

Response dated 21st January 2008:- Objection. Reiterates planning policy considerations from 21st May 2005comments an also considers recent policy developments at the local (UDP) and national level (PPS7: Sustainable Development in Rural Areas). Consider the grandstand, other racecourse facilities, equestrian centre, hotel, golf clubhouse, forest park centre and timber workshop to represent inappropriate development in the Green Belt. The same concerns are reiterated in this response. Only the equestrian centre, golf clubhouse, and other racecourse facilities have been subject to amendments in the May 2007 ESS, however these developments still represent inappropriate development. Consider that no additional very special circumstances have been submitted since the original application and therefore it is still maintained that the need for each element of the development is not sufficient to be classed as a very special circumstance. The applicant provides no evidence of a need for a development to take place and there is no evidence that there would be any harm caused if the development does not proceed. A detailed analysis of the applicant’s very special circumstances case is presented which considers all of the arguments put forward and challenges all of the arguments. Concluded that the applicant confuses ‘need’ with ‘desire’, and therefore do not demonstrate very special circumstances to justify inappropriate development within the green belt. Concerns relating to impact on traffic and residential amenity, nature conservation, openness and visual amenity of the green belt, sustainability and public transport and socio-economic effects. Consideration of the recent amendments to the scheme does not overcome these important issues, and it is considered that there is no justification for the proposals and planning permission and should be refused.  

Ramblers Association Manchester and High Peaks Area

Response dated 1st September 2004:- In principle this is an interesting scheme which they do not wish to oppose. Despite this, there is little information in terms of Rights of Way, existing footpaths or the creation of new footpaths/bridleways/cycle routes. 

Response dated 29th October 2004:- Support the proposal, however, the scheme could incorporate an additional pedestrian link to connect the northern end of Eccles FP 31 (E31) to the new concessionary network within the site, which will provide a function for E31 and also provide public access to the site. 

Response dated 5th November 2007:- In terms of rights of way/access more could be done; but as long as regulations and UDP policies are compiled with, the Association consider the proposal favourably. Very Special Circumstances do not apply in relation to green belt issues and as such the proposals will have to be amended or rejected. 

Red Rose Forest

Response dated 23rd August 2004:- The Forest Park Centre is an essential part of the development proposals and the concept of sustainability is supported. However, some of the finer details will need to be considered should permission be granted. In relation to landscape the greatest impact will be the M60 and M62 motorways and the railway as users will gain glimpses of the site at speed. They recommend a condition that the details of landscaping along these routes should be subject to detailed reworking as a condition. The improved access to the site is supported, and there are opportunities to dedicate new public rights of way and areas of access. The whole 16ha area of Manor Farm near Boothstown and the land adjacent to the application area near Boothstown and to the north of the Bridgewater Canal should be dedicated rights of way. New access routes should be dedicated Public Rights of Way and should form strategic linkages to existing routes alongside the Bridgewater Canal, and across the M60 by “The Grange” connecting to the community woodland across the M62. The Grange Farm farmland could be transferred to an established not-for-profit organisation such as a charitable trust, which will safeguard and improve the environmental quality of the land for the enjoyment of the public. It is recognised that the long-term viability of the overall application is dependant on built development specifically the hotel and racecourse. While the buildings of the Forest Park Centre would incorporate the highest environmental design standards some of these should be incorporated into the other remaining buildings. Attention is drawn to policy EN17A (pre inquiry change).

Royal Society for Protection of Birds

Response dated 7th October 2004:- The development contains incompatible elements in relation to Green Belt policy, including the car park developments, racecourse, grandstand, hotel, holiday chalets and the associated infrastructure. Cumulative effects from neighbouring developments should be considered strategically as they will affect undeveloped areas, and the Borough’s biodiversity assets. Compensation and mitigation should be considered strategically. 

Some of the proposals will improve habitats for some species of birds and mammals however; the development of car parks, hotel, chalets, golf course and racecourse will result in displacement of grey partridge, curlew, lapwing, skylark, yellowhammer, water vole, brown hare and great crested newt. The proposal provides no mitigation for the loss of these species except for wildlife friendly farming measures, which will be difficult to enforce in the long term.

Botany Bay Wood is a Grade A SBI, and as such part of the site should be fenced off year-round to prevent public access and disturbance to these species. Rhododendron should also be retained for nesting herons. Astley Moss East should be used as a suitable strategic compensation site through the restoration of lowland raised mire which will benefit biodiversity that visitors to SFP could enjoy.   

Response dated 10th July 2007:- Welcome the removal of paint-ball games, clay pigeon shooting and the rifle club from the Botany Bay Wood. Grey Herons nest among planted conifers with a Rhododendron under storey. The removal of these alien species should not be encouraged as a part of any management plan. Mitigation should be provided for the loss of farmland breeding birds and their habitats. It is considered that the area would only qualify for the very basic Countryside Stewardship scheme, which would not mitigate for the damage to farmland bird populations. All land management mitigation should be being made the subject of Section 106 agreements with provision of funds to enable all works to be carried out. Astley Moss East should be used as a suitable strategic compensation site through the restoration of lowland raised mire which will benefit biodiversity that visitors to SFP could enjoy.     

United Utilities

Response dated 6th September 2004:- No objection to the proposal in principle. Applicant should have regard to underground and overhead electricity assets and ensure that maintenance and/or access rights are maintained. The applicant should consider the potential difficulties caused by trees and consider this when carrying out planting near to overhead line/underground cables. Consideration should be given to the following HSE documents; HS (G) 47 avoiding danger from underground services, and GS 6 avoidance of danger from overhead electric lines. The Thirlmere Aqueduct crosses the site, and access for operation and maintenance of it is required. United Utilities will not permit any development in close proximity to the mains. Ground levels over and adjacent to the pipelines must not be altered without discussion. Water mains will need extending to serve any development on the site, a capital contribution may be required and an Agreement under Sections 41, 42 and 43 of the Water Industry Act 1991 will need to be signed. Site must be drained on a separate system, only foul drainage connected into the foul sewer. 

Response dated 6th October 2004:- United Utilities (UU) have considerable wastewater infrastructure within the boundaries of the site. Any proposals resulting in an increase in river levels, or trade effluent discharge to a public sewer will need to be discussed with UU. 

Response dated 13th June 2007:- A considerable amount of wastewater infrastructure exists within the boundaries of the site, including foul and surface and combined gravity sewer, pumping stations with associated rising mains and a number of Combined Sewer Overflow (CSO) chambers. Deep rooted shrubs and trees should not be planted in the vicinity of the public sewer and overflow systems. The site must be drained on a separate system, with only foul drainage connected into the foul sewer. Surface water should discharge to the watercourse/soakaway/surface water sewer and may require the consent of the EA. Land drainage or subsoil drainage water must not be connected into the public sewer system directly or by way of private drainage pipes. It is the developer’s responsibility to provide adequate land drainage without the racecourse using the use of the public sewer system. The Thirlmere Aqueduct is laid across/adjacent to the site of the proposed development.  

Urban Vision Environment 

From July 2007 the Council’s Environmental Protection Service, who were consulted on issues relating to air quality, noise and contaminated land was transferred from Environmental Services to Urban Vision Environment (formerly known as Greater Manchester Geological Unit). 

Noise – Construction phase

Response dated 27th April 2005:- Noise from construction activities will affect different areas on and around the site in different ways. The first significant areas of construction will be the highways construction round Junction 13 of the M60 and also around the A580 / Chaddock Lane gyratory area. These areas will require significant works both to the proposed new road layout and within the site. Both areas are close to noise sensitive residential uses, the latter area more so than the M60 junction. The first few properties extending south from the A580 junction are extremely close to the junction. This will increase the chances and likelihood of complaints both during the construction phase as well as the operational phase due to the close proximity. It would be advisable to consider the use of some additional acoustic screening in these areas whilst construction works are concentrated there and possibly consider additional screening during the operational phase. 

The construction of the grandstand, racetrack and immediate supporting buildings and features are within close proximity to Keepers Cottage. All of these will involve considerable construction works to prepare and construct the facilities. A concentration of work in this area will occur which will need to be carefully controlled to limit the impact of noise on the nearby residents. Residents of Boothstown may be partially shielded from this noise by the existence of the raised landfill car parking areas, however, noise may still be a factor for Boothstown residents and is likely to be a significant factor for the dwelling indicated above.

The hotel complex will undergo significant construction works and is located closest to Boothstown residents. Noise will be a consideration although some natural shielding may occur due to topography. 

The Golf Course is near to residential properties along Leigh Road and also to the south-eastern residential areas of Boothstown. Due to the topography of the site, noise generated can travel reasonable distances without any natural attenuation. It is recognised that in these locations the predominant existing background noise is that of the local transport interchanges, however, noise from construction activities is likely to be much more distinct from the ambient background noise. 

The other areas of the site including the Timber Initiative Centre, Eco Village, Woodland Wildlife centres etc are likely to be less of a problem as they are generally located more centrally on the site – which places natural and distance attenuation factors to limit the impact of noise on sensitive receptors.   

Specific details within the applicants submission indicate that the phasing of the works and the method of works used by contractors will have a significant impact on overall noise levels. The applicant makes reference to the Construction Management Plan that indicates amongst others the control of noise and dust. It will be necessary to review this information to establish how such measures will be controlled and be able to comment should we feel that measures are inadequate. It is likely that this will be done through a specific condition.  

Response dated 22nd November 2007:- Additional information provided by the applicant is considered to provide an accurate picture of the extent of the noise likely to effect Keepers Cottage. Predicted construction noise levels are above the level considered appropriate for Keepers Cottage. Should the application be approved the noise mitigation measures proposed by the applicant for Keepers Cottage must be erected prior to the construction work commencing. A level of 55dB is considered appropriate for Keepers Cottage due to the length of time that the construction activity is likely to take place.  
  
Conclusion - No objection - Although noise issues are identified as being a problem during the construction phase of the development for residents of Keepers Cottage, mitigation measures are proposed that are considered to acceptably reduce the level of this impact. The Construction Noise Management Plan will ensure that all identified areas of the site and site operations where noise may be generated and also identify control methods to ensure that noise does not create a nuisance. All identified measures will be implemented and maintained at all times.

Dust – Construction Phase

Response dated 27th April 2005:- The intensive earth works and movement of materials during the construction phase is likely to result in the generation of dust and dust migration. It is considered that this will be significant although sensitive properties are few and far between. The application has details on matters such as wheel washes for vehicles entering and leaving the site and indicates that such matters are easy to control. The report suggests that during the construction phase efforts should be made to prevent the dust from becoming airborne, if then any dust does escape such measures, containment procedures should be implemented.

Suggest that as part of any permission for the site that the applicant/developer should submit for approval a dust management plan which will apply to all areas and activities on the site for the duration of the construction phase. Specific details should be included on areas where dust is likely to be problematic along with specific measures to prevent the material becoming airborne. Other measures should be indicated on how airborne dusts will be controlled both on the site and off the site should this occur.

Response dated 28th September 2007:- No objection. Potential exists for dust issues, although appropriate measures to control dust will be contained within a dust management plan. 

Contaminated Land and Landfill Gas Issues

Response dated 27th April 2005:- The ES does not include any intrusive investigations relating to contaminated land and landfill gas issues. However, it is stated that intrusive investigations will be carried out in relation to the 3 landfills to the north of the site. The suggestions at this stage include; passive venting systems on the Boothshall 1 and 2 landfill sites. It is stated that if gas generation and migration are found to be of concern there are number of options available for mitigation. This essentially amounts to gas protection on any proposed buildings. It is also proposed to assess the risk to any buildings already on site and that will form part of the scheme. No/very limited proposals have been made to address any potential ground contamination issues. Reference is made to intrusive investigations that will be carried out to address this issue. Limited desk study information has been obtained from the above reports that highlights potential sources of contamination of the soils across the site including; spreading of material on the moss from the construction of the canal, disposal of mine arisings from botany mine, general agricultural contamination and landfill issues.

Issues to be addressed through any future detailed investigations should include:- 

•	the durability of the proposed grass paving on the landfill sites. This will be subject to both heavy traffic movements and subsidence from the settling landfill. This could lead to degradation of the cap and exposure of the landfill beneath. Any investigations will need to consider not only the suitability of the depth of the cap but also the durability of this cap over time.

•	details relating to  the weight of the traffic on top of the landfill in relation to lateral migration. In theory any additional loading on the landfill site could place the site under pressure, thus, forcing gas out at a greater rate. This combined with the proposed cap may force the gas to migrate laterally towards more sensitive properties. Any investigations will need to consider this issue and it may be an issue to be considered during mitigation of the risk.

•	An investigation into the existing passive venting system will need to be assessed in terms of its current status and the effect the development may or may not have on the adequacy of that system

•	The significance (relevance) of the following will need to be assessed; spreading of material on the moss from the construction of the canal, disposal of mine arisings from botany mine, general agricultural contamination including diesel spillages, pesticides, fertilisers, burial of farm wastes etc…and of course the landfill issues.

•	Gas monitoring of each proposed structure on site under or within the footprint of the building to assess the gas protection needed. This is due to the wide range of potential gas sources across the site. Any proposals for monitoring must be agreed with the Local Authority prior to commencement. 

•	The production of a long term gas protection management system. This should be implemented via planning condition or S106. Depending upon the gas protection schemes put in place, long term management of such schemes may be necessary. 

•	Carrying out any contamination investigations in a phased approach as recommended in current best practice and ease of assessment due to the large area covered and differing previous uses and proposed end uses. 

N.B. The applicant has indicated that they are prepared to enter into an appropriately worded planning condition. 

Odour Construction Phase

Response dated 27th April 2005:- No objection - Odour from the construction works is likely to be minimal however certain works on the landfill sites to the south of the Bridgewater Canal, which are proposed as car parking areas, may cause some odours to be liberated should earthworks break into the decaying fill matter. Odours may also result from the use of heavy plant equipment being on site due to machine oils, diesel fuel etc, however, this is considered to be a low risk and is not expected to have anything but a minimal impact on nearby sensitive premises.

Air Quality – Operational Phase

Response dated 4th May 2005:- The site is located on the perimeter of an air quality management area (AQMA) declared by the City of Salford in June 2001. The Air Quality Regulations 2000 sets out air quality standards (AQS) for 7 pollutants. The Council must achieve these targets where possible and implement policies where these targets are not being met. The two most important pollutants that are at risk of being exceeded, nationally and in Salford, are nitrogen dioxide and particulate matter. The levels of pollution in the immediate area are some of the highest in the country; the effect of the development on nitrogen dioxide and particulate matter must be determined.

There are concerns about the robustness of the air quality assessment.  It relies on data produced from a model that under estimates levels of pollution in the worst affected area. Currently several air quality objectives are exceeded which is not reflected in the base line condition. Particulate matter is dismissed, as predictions nationally will be reduced. This ignores the current monitoring and modelling data and the national guidance on particles. The most relevant air quality monitoring station is not reported at the M60 showing poor air quality, while Eccles is given which has significantly lower pollution and no exceedances. There is lack of clarity in some aspects of the report coupled with confusing statements. The report should provide a clear audit trail of all the data used.  

The assessment concludes incorrectly that no air quality problems exist and that there is no impact arising from the traffic. No mitigation measures referred to in the plan, although there is strong evidence that the air quality is poor and is likely to be made worst by the events. Achieving sustainable development is a key policy objective for land use planning and has an important role in protecting and minimising the effects of new developments. Air quality is a key component of sustainable development and mitigation should be included to protect the existing residential population from increased pollution levels.

There is concern of the developments impact and the following mitigation should be considered:-

-	Implement a green travel plan for all activities to minimise traffic trips to / from the site. 
-	Informing race goers to forthcoming events of poor air quality to change their travelling arrangements. 
-	Use of electric vehicles or hybrid vehicles to service the car parks (internal external) and for services to / from the site during race days. This will include services to / from the bus or rail stations. 
-	Explore the use of other satellite car parks in Greater Manchester further from the site to reduce trips at Junctions13, for example Trafford Centre, or Manchester United.  
-	Fund air quality monitoring at Junction 13 and junction 11 (M60).

In order to follow up the problems of air quality and the potential health of local residents it is recommended that a Section 106 agreement is entered into to fund air quality monitoring levels in this area. The air quality monitoring would be for PM10 and NOx.

There is insufficient information in the report to inform the public, or the Council about the likely impact of the development on the Worsley and M60 area. It is therefore not possible to determine this assessment. More detailed work is required to determine the impact of the development, determining the spatial extent of air quality in order to quantify the likely exposure.   

This scheme and the others are likely to increase pollution on the M60 making achievement of the Governments air quality standards more difficult for the Council.  It will also reduce the impact of the air quality action plan. 

Recommend that prior to this application being determined further details be provided on air quality assessments. 

Response dated 28th September 2007:- Satisfied that air quality assessment in Updated Environmental Assessment has been carried out in accordance with previous recommendations. The assessment concludes that there is the potential for slight significant impacts on the surrounding area for air quality. Given that the air quality in this area is already poor in some locations, particularly around the motorway junctions, a condition is requested in relation to the Green Travel Plan. The Green Travel Plan is an imperative to resolve any potential air quality problems particularly during major events.

Response dated 23rd September 2008:- Indicate that if funding is secured through a S106 agreement for Salford City Council to fulfill it’s obligations for Air Quality Management then the development would be acceptable in air quality terms. A method to guide the level of S106 contribution is identified, although it is acknowledged that this figure will alter depending upon the air quality scenario modeled i.e. flagship event, regional event etc. A contribution of £52,500 is identified as a guide for the appropriate level of contribution.     

Noise - Operational Phase

Response dated 27th April 2005:- 

Racecourse, Grandstand, Stabling and facilities to North West of the Grandstand

Noise impacts from the PA system will be considerable and little opportunity exists to absorb it, therefore the system will need to be installed in a sympathetic manner. Noise from the crowd will be considerable and is difficult to control. The main site affected by the crowd noise, and significant reduction in amenity will be Keepers Cottage. The proposed hotel at Moss House Farm will have little noise impact on residential amenity. The proposed hotel is located on an existing stables/farm development to the north of the site. In operation, it is not considered to be likely to have a significant impact on the amenity of local residents due to the activities and movements therein.

Noise from crowds will be significant and it is extremely difficult to control. The noise from the crowds will not be continuous in volume and it will vary in line with the excitement of the crowd and the stage of the race. As such it will be intermittently loud and quiet at irregular intervals. Keepers Cottage is approximately 250 metres from the grandstand and noise levels of 60dB LAeq are predicted which is approximately 21-22dB above the existing ambient background noise level and is 7dB above the average ambient noise level. Maximum predicted noise levels will result in LAmax readings of 69dB. The report indicates that it will be this site which will be impacted upon significantly by the development. Recommend that the application should be refused unless stringent mitigation measures are proposed to protect the site from the impact of noise. Due to the size and scale of this development as well as the number of events planned, special consideration must be given to these issues. It is certain that without any mitigation measures there will be a significant reduction in amenity for residents at Keepers Cottage when events are held.

Site Access and Car Parking

The noise calculations made by the applicant relating to vehicles accessing the site are not considered appropriate in this instance; this alongside the mentioned noise bund alongside Southdown Drive (adjacent to A580/Chaddock Lane gyratory) suggests that there may be a noise issue at this location, which has not been identified in the applicants report. 

Equestrian Centre, Forest Park Centre and Golf Course

The proposed Equestrian Centre is located on the Malkins Wood Farm site. This is in itself reasonably remote from most noise sensitive receptors although Keepers Cottage to the north of the site and Rawsons I’th Nook Farm and the Rindle Road properties are located in a westerly direction from the site are within earshot of significant noise sources. The proposals indicate the use of the site for restaurant/café facilities, fitness suite, function room and a conference room. These have been considered and have been determined as unlikely to cause a significant impact although there will be ancillary plant, equipment and other issues which will require addressing through specific conditions.

The proposed Forest Park Centre is located at the northeast edge to Botany Bay Wood. The description of activities proposed for this location tends to indicate that there will be a minimal impact on nearby sensitive receptors including Keepers Cottage (East) and Grange Farm.

The Golf Course is located mainly to the north of the Bridgewater Canal bounded by Leigh Road to the north and the canal to the south. The southeastern side of the course crosses the proposed main access route from the M60 and is bounded by the M60 and the reed beds along the eastern edge. Noise from this proposed use will be insignificant due to the proximity to major highways in the area. No other impacts are foreseen for this proposed use and as such, no further comments are deemed necessary.

Building Plant and Equipment

All plant and other equipment associated with the various buildings proposed for the site will be potential noise sources. This will include boiler plant, air handling plant, air conditioning and refrigeration units amongst others. Any such plant will potentially be noisy when operated. As such, protection will be required to prevent noise sensitive receptors from being affected by the equipment. In this case, it is unlikely that a boundary noise limit would be applicable due to the distance to the boundary of the site (or specific noise sensitive properties on site) however it will be in the interests of the applicant to ensure that any such noise from such plant is not capable of causing a nuisance to receptors both on and off the site. 

Catering Facilities – All buildings

The number of catering facilities spread throughout different areas of the application will be subject to regular inspection by the Commercial Services Team. 
 
Response dated 28th September 2007:- Agree that the proposed changes at Junction 13 M60 and A580 will not result in a change to the previous noise impacts stated. The assessment looked at noise mitigation measures for Keepers Cottage following on from the request from Environmental Services. The report recommends mitigation measures for Keepers Cottage in terms of thermal double-glazing or secondary glazing; additional mechanical ventilation; Venetian blinds to prevent heat build up; and an acoustic barrier 3m high along the garden boundary. 

There has been no background noise monitoring undertaken at Keepers Cottage to fully be able to assess the impact of the noise at this particular location. The noise monitoring dates back to May 2001 and August 2003. The closest monitoring point for both of these locations was at the Vicars Hall Bridge (some 450m away) from the property. Keepers Cottage is approximately 2000m away from both East Lancashire Road and the M62 and the only potential noise source is Whitehead Landfill, which is well bunded and strictly controlled. No specific noise assessment has been carried out to show how effective the proposed mitigation measures for Keepers Cottage would be and whether they would resolve all potential noise issues. The mitigation proposals will be implemented only with the agreement of the owners of the property. However if the owners do not accept the proposed mitigation measures then the level of noise that they will be exposed to during the construction and operational phase would not be acceptable. 
  
Concerns exist relating to the impact of noise on properties that are closest to the new access road coming from the A580, namely Southdown Drive and Linkfield Drive. Concerned that no mitigation measures have been proposed to protect these residents from the new access road, although the first assessment stated that bunds would be sited in this area. As raised previously (27th April 2005) there has been no assessment made of the noise impact from the new access travelling along the new access from A580 down to Vicars Hall Lane. A condition is recommended to address this. 

Noise conditions are suggested relating to a noise and vibration management and monitoring plan relating to the control of noise and vibration from construction; a noise management and monitoring plan relating to the control of noise and vibration from the operation of SFP; permitted times for construction works and deliveries; a dust management plan; extraction equipment; and the production of a Green Travel Plan.  

Response dated 22nd November 2007:- Agreement reached that the methodology and measurement positions used to gather the baseline noise environment information are appropriate for the development as a whole and for Keepers Cottage in particular. 

Mitigation proposed by the applicant for Keepers Cottage is the addition of a 3m high barrier, i.e. close boarded fence along the eastern façade of the property, approximately 30m long. This would provide a direct barrier to the Grandstand noise and give approximately 10dB reduction, resulting in a level of 49dB LAeq(T)  in the garden.  This level is some 9dB over the existing background level, however is lower than the 55dB LAeq(T) recommended by the WHO. The applicant has indicated that as an alternative they could provide a noise barrier on the east side Vicars Hall Lane, on land owned by Peel. This would provide a 6dB level of attenuation and would result in garden levels of 53dB LAeq(T). The proposed 3-metre high mitigation barrier for Keepers Cottage would require the prior consent of the property owner. The applicant has not provided any firm proposals for additional sound reductions by windows or additional ventilation. This would be required as part of a planning condition should the application be approved. 

Applicant recognises that a noise barrier/mound is required along the length of the access road on the western elevation during the construction phase. From the operational noise assessment data, it is considered necessary that a noise barrier/mound be erected along the length of the access road on the western elevation between the A580 and Vicars Hall Bridge, in order to protect residents from the noise of vehicles accessing and egressing the site.   

Conclusion - No objection – Issues relating to locations for noise monitoring resolved. Without the implementation of appropriate noise mitigation measures for Keepers Cottage the noise impact during the operational phase of the development is considered to be unacceptable. However, the applicant has agreed with the Council suitable noise mitigation measures that are considered acceptable to the resident and the Council.  

Minerals 

Response dated 26th February 2005:- Although the application includes geological assessments covering baseline conditions and potential impacts caused by construction they do not address the potential sterilisation of mineral resources. It is unclear whether there are potential mineral resources that could realistically be worked, the extent and nature of these resources, the impact caused by the proposals and the relevance of National Regional and Local Plan Policy. Further clarification is required on these matters.  

Response dated 5th May 2005:- A number of fundamental omissions/errors have been made in the application. Additional data is required to substantiate what the extent, depth and quality of sand and gravel resources below the peat are. 

Response dated 17th May 2006:- The reserves of sand and gravel continue across the site from the Astley Moss boundary. The borehole information supplied by the applicants only covers depth of 5-10m, which is not deep enough to reveal the presence of viable sand and gravel reserves as found on the Astley Moss site. As a result further borehole information is required. The buildings are mainly limited to the north west of the site and are underlain by glacial till which is unlikely to contain economically viable minerals. However, the Salford Forest Park Centre and the Eco Village are to be built in the centre of the site where a continuation of peat deposits from Astley Moss East is likely to occur. As a result of this it would be advisable to consider potential sterilisation of economically viable mineral reserves.     
 
Response dated 3rd July 2007:- The revised statement does not address previous concerns raised regarding the sterilisation of potential mineral resources associated with the original proposals. Request made for additional data with regards to the extent, depth and quality of sand and gravel resources below the peat in the application area is substantiated.   

Response dated 13th December 2007:- The information provided by the applicant includes a re-statement of existing borehole data and accompanying rationalisation. GMGU support the applicant’s statement that the proposals would not cause the sterilisation of any financially viable mineral reserve. The application is unlikely to result in the sterilisation of such potential minerals due to the design and siting of the built development within the red line boundary. 

Conclusion - No objection - GMGU are satisfied that the supplementary assessment of geology in the ESS indicate that the development will not result in sterilisation of mineral resources. 

Wildlife Trust – Lancashire, Manchester and Merseyside

Response dated 4th October 2004:- Botany Bay Wood is a Grade ‘A’ Site of Biological Importance (SBI), including a heronry, and is a proposed Site of Special Scientific Interest (SSSI), and part of the SBI is included in the Invertebrate Site Register No.96/37. Public access at all times of the year should be restricted in the heronry area to avoid disturbance. Support the proposal to remove paintball games, clay pigeon shooting and the gun club from Botany Bay Woods. Any reserve management plan should include the retention of rhododendron and the rest of the under-storey within the area of the heronry. The participants involved in the management of the area needs to be clarified, which will include finance, accountability and resource issues. Further details are required relating to the clearance of woodland at the northern end of Botany Bay Woods as the area encroaches into the SBI boundary. The Wildlife Trust welcomes proposals to enhance hedgerow habitats and the use of native tree species and shrubs in plans for planting/replanting. Support proposals that will result in improved habitats for some species of birds, water voles and great created newts, however the development of the car parks and the racecourse will result in the displacement of a number of Red Listed and Amber Listed bird species. Particular species to be displaced include grey partridge, curlew, lapwing, skylark and yellowhammer. There are no mitigation measures in place for the displacement of Red and Amber Listed bird species from fields ear marked for the golf course development. There will be a reduction in the available habitat for brown hares. 

Support the proposed management plan relating to wildlife friendly farm management, however more clarity is required as to how this will be monitored, how and by whom and how the five year review will be carried out. 

Consider overall that the development will enhance the wildlife and nature conservation value of the site and contribute towards Biodiversity Action Plan (BAP) targets and priority species habitats. The management of the park needs to be underpinned by legal agreements. All management plans should be made subject to Section 106 Agreements.

In terms of conservation the application should be considered in relation to the proposed developments of the sports stadium, the inter modal freight interchange and Astley Moss East, which in particular will have significant impact upon the ecology of the region. It is essential that there should be adequate mitigation for the loss of habitat for important species, especially birds, and for the loss of Green Belt. Unless appropriate mitigation is provided for the loss of wildlife habitat in the area, the Trust will lodge a formal objection to the proposed development.      

Response dated 25th June 2007:- The amended proposals are unlikely to make much difference to the impact on wildlife from that of the original proposals. Welcome the fact that leases on paintball, airgun and clay pigeon shooting have not been renewed. This needs to be a permanent arrangement in order to protect the heronry and the pSSSI. Welcome proposals to enhance Great Crested Newt and Water Vole habitats. Concerns exist that the development of car parks, racecourse and golf course will result in the displacement of Red and Amber listed bird species, and that no mitigation is proposed. Recognise that on-site mitigation for bird species will be difficult but it is recommended that the Forest Park site should be seen in the context of other proposed developments in the wider area. Any mitigation for the disturbance of bird species is problematic. A detailed monitoring and habitat management plan should be required before permission is granted and should include best practice for wildlife friendly farm management and Countryside Stewardship, which will be monitored as part of an agricultural management plan. This could provide some mitigation for the disturbance of some bird species. The Management Plan should be subject to a S106 Agreement    

Worsley Civic Trust and Amenity Society

Response dated 16th November 2004:- Issued a holding response in relation to the application as a ballot is being carried out to ascertain support for, or objection to the proposals. Concerns exist relating to additional traffic in and around Worsley exacerbating the existing severe congestion during race days but also through other additional events. Concerns relating to overt use of Green Belt land for commercial purposes. 

Response dated 18th December 2004:- Wish to lodge a formal objection to the scheme in light of the result from the ballot result; 85% against and 15% for. Principle concerns relating to the development are the additional traffic in and around Worsley, exacerbating existing severe congestion, and the overt use of Green Belt land for commercial purposes. Concerns also exist relating to additional problems of light pollution from the floodlights and the nuisance of off-site parking. 

Response dated 14th January 2005:- The development will be located on green belt land, and whilst access to the area for leisure pursuits should be encouraged it is felt that commercial interests will dominate the site. It is considered that for the site to be viable the facility will need to be used more than the 30 days racing per year that is expected. It is anticipated that the racecourse operators will attempt to attract bookings such as truck rallies, monster truck racing, steam fairs, conferences, weddings, exhibitions and concerts which are incompatible with green belt policy. The hotel is a purely commercial venture to support the other revenue earning elements of the proposals. The equestrian facilities for show jumping and cross-country events can be classified as elitist pursuits; no indication of is given to allow local horse owners and riders the opportunity for to use the park on a continuous basis. A substantial fence, which will detract from the concept of open green belt will need to be constructed around at least 20 per cent of the site area to ensure that all spectators have paid entrance fees.   

Issues relating to traffic and transportation issues and problems are not answered or satisfactorily resolved in the supporting documentation. Congestion on roads in Boothstown and Worsley and on the M60/M602/M62 network is well known. The proposals exacerbate the problems of junction 13 as well as the wider network. The proposals are not compatible with proposals being worked on by Government for a complete re-structuring of the motorway network. The re-alignment of two Worsley roundabouts will not help to absorb additional traffic generated by the scheme all year round. The computer traffic modelling does not take into account the re-structuring of the motorway network, the cumulative impact of several other schemes in the area, the impact of non-racing events and the assumption that traffic will flow smoothly in and out of the site at the Worsley Church entrance, which is considered unlikely, and will quickly result in standing traffic on the roundabout creating gridlock. 

The application makes little reference to public transport other than shuttle services from Walkden and Patricroft rail stations. The scheme is contrary to government transport policy as it encourages car use. Many race goers will seek to park off-site in the streets and roads of Worsley and Boothtown to the detriment of local residents. 

Consideration needs to be given to pollution issues from traffic fumes, noise levels (large crowd noise, the public address system, and helicopters and light aircraft used by jockeys and officials), and light pollution (from floodlit race track, the grandstand area and the illuminated car parks). A 25 metre high grandstand will dominate the open view from Boothstown across the site and into the distance. 

Access to the site for emergency services is difficult due to the proximity of the site to the proposed entrances and also difficulties associated with travelling to and from the site during peak traffic flows. Increased traffic at junction 13 will increase congestion and increase the risk of accidents should traffic back up on the motorway. A fence should be provided to protect people on Leigh Road and the Garden Centre access road from any stray golf balls. The height of the fencing required will be very obtrusive.  

No objections made in relation to the introduction of footpaths and bridle paths for use by the general public, initiatives to improve wildlife habitats, the regeneration of the New Hall formal gardens, facilities for ecological study, adventure play facilities for children, limited free car parking encouraging the use of the area for personal rural pursuits. 

For the scheme to be acceptable, a greatly modified scheme will be required. Amendments should include the following; the only access to the site should be from the western side leaving Worsley unaffected; no events other than racing attracting more than 1000 visitors are allowed to take place and all open air activities other than racing and outside equestrian events should be free to the public and funded by the operators from their commercial revenues.     
 
Worsley Village Community Association

Response dated 21st December 2004:- Strong objection to the scheme. All 600 members balloted and 95% consider that this scheme will be a disaster for Worsley and Boothstown and surrounding districts. The development represents inappropriate use of green belt land. A significant amount of Green Belt will be lost to roads, car parks, grandstand and other structures. In relation to traffic: J13 is one of busiest on the M60 motorway network with 180,000 vehicles passing daily. To put anymore traffic on this junction will result in standing traffic for a radius of 10 miles adding to existing congestion. The area has an existing pollution problem caused by standing traffic; race day traffic will only add to this. Safety issues exist for children crossing the slip road in Worsley Village to reach school. The main entrance and exit is on the off slip at J13. This will cause serious problems to the already dangerous situation with 2 other motorways merging within a few hundred yards of each other. Application makes no provision for public transport i.e. no railway station, no metro link, no bus service other than rudimentary existing one. Concern that the eco village appears to be residential and is inappropriate development in the Green belt. The hotel will have a large amount of new build and the design is not in keeping neither will the equestrian centre. Opposition to the grandstand, as this will dominate the skyline both from Worsley Village and Boothstown. It will have corporate facilities and used for other non-racing activities. The lighting will cause light pollution. It will have detrimental effect on the green belt and the wildlife. Any evening racing will have a huge impact on the residents. The site will be used for other events e.g. exhibitions, pop concerts, and likely every weekend with its associated traffic generation. Part of the golf course runs along Leigh Road and it would necessitate the erection of high barrier netting to protect residents and any passing traffic.

Response dated 28th November 2007:- Having given due consideration to the information contained within the Environmental Statement Supplement members do not agree sufficient or major amendments have been made to satisfy their earlier objections to the original planning application. The proposals for dealing with traffic will not prevent major disruption and pollution in the immediate and surrounding areas. The ESS does not demonstrate that the development is compatible with the national planning policy on Green Belt. Reaffirm previous position and formally object to the planning application. 

RECOMMENDATION:

Refuse 

APPLICATION No:	08/55887/ART10

APPLICANT:	Peel Investments (North) Ltd

LOCATION:	Land West Of Worsely, Bounded By M60, East Of Astley Green And Landfill Site, South Of Boothstown Bounded Partly By Bridgewater Canal And Leigh Road Worsley (Article 10Consultation)    

PROPOSAL:	Article 10 Consultation received from Wigan Council in respect of Development of a Forest Park

WARD:	 

DESCRIPTION OF PROPOSAL

This is an Article 10 consultation from Wigan Metropolitan Borough Council in respect of a hybrid planning application at land west of Worsley bounded by M60, east of Astley Green and landfill site, south of Boothstown bounded partly by Bridgewater Canal and Leigh Road.  The Wigan application seeks consent for alterations to the East Lancashire Road / Chaddock Lane roundabout and a partially embanked access road leading, on a southerly alignment, from the roundabout.

The ‘western access road’ would consist of a nine metres wide, tarmac-surfaced carriageway for approximately 100 metres.  This section of the road would be split into 3 metre wide lanes which would be operated on a tidal flow basis, on race-days.  This section of the road would also be lit.  After the first 100 metres, the 9 metre ‘corridor’ would be continued but with a 6 metre wide tarmac carriageway and 3 metre wide, reinforced verge capable of being used by traffic as the need arose.

Pedestrian and cycle access into the site from the A580 would take a separate route generally parallel to the access road.

Public footpath crossings of the road would be maintained.

A limited amount of existing hedgerow would have to be removed to accommodate the access road.

A screen mound would be constructed between the proposed access road and houses at and off Southdown Drive, near the East Lancashire Road / access road junction.

The access road would be landscaped with 4 hectares of native-species woodland and hedgerow planting.

DESCRIPTION OF SITE

The 11 hectare Wigan portion of the site is flat although there is an appreciable change in levels at its northern extremity where it joins, at a higher level, part of the East Lancashire Road and its complex, gyratory junction with Chaddock Lane.  The site includes a tract, described as an ‘agricultural’ access, leading from the roundabout.  There is an electricity substation, within the application site, adjacent to the East Lancashire Road (A580).  The agricultural access is also the vehicular access to the substation.

The Wigan land is mainly in arable use.  It is separated into fields by partial hedgerows, some of which are tree lined.

The Whitehead Brook is the southern boundary of the Wigan part of the overall site.

RELEVANT SITE HISTORY

Wigan reference A/93/41047 – Planning permission was granted, on appeal, by the Secretary of State, on 2nd July 1994, for the construction of a new vehicular access and private way from the East Lancashire Road (A580), Chaddock Lane (A572) junction.  This is the junction affected by the current proposal.

Wigan reference A/07/68351 – Permission was granted, on 2nd April 2007, for an electricity substation to deal with electricity generated by the landfill gas utilisation plant at the Whitehead landfill site.  The permission identifies the access permitted by permission A/93/41407 as the means of access to the substation.

CONSULTATIONS

There was no requirement for Salford City Council to consult on the application as Wigan Council are the determining Authority.

PUBLICITY

There was no requirement for Salford City Council to give publicity to the application as Wigan Council are the determining Authority.

NATIONAL PLANNING POLICY

Planning Policy Statement 1 (PPS1): Delivering Sustainable Development (2005)
Planning Policy Guidance 2 (PPG2): Green Belt
Planning Policy Guidance 13 (PPG13): Transport (2001)

REGIONAL SPATIAL STRATEGY

DP1 – Spatial Principles
RDF4 – Green Belts
RT2 – Managing Travel Demand
RT9 – Walking and Cycling

UNITARY DEVELOPMENT PLAN POLICY

Site specific policies: 	EN1: Development Affecting the Green Belt
Other policies:		DES1:  Respecting Context
			DES2: Circulation and Movement
			A2:  Cyclists, Pedestrians and the Disabled
			A8: Impact of Development on the Highway Network
	A10:  Provision of Car, Cycle and Motorcycle Parking in New Developments	
 	
PLANNING APPRAISAL

The main issue associated with this development is whether it would have any significant and unacceptable impact upon Salford or its residents in terms of:

•	Whether the proposal would conflict with the role and purpose of the Green Belt, harm its openness or have an adverse impact on its visual amenity; and
•	Whether the proposal would be detrimental in terms of highway safety or traffic congestion.

Impact of the development on Green Belt

The site is situated within the Green Belt and as such PPG2: Green Belts, and policy EN1 of the Salford UDP provide the planning policy framework against which the development must be assessed. PPG2 indicates that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; and further more the most important attribute of Green Belts is its openness. ‘Openness’ should be considered as, essentially, the absence of built or operational development and not the visibility of the development or its visual openness.

The Inspector who determined the agricultural access road (Wigan ref: A/93/41047) took the view that the current road is ancillary to and part of the agricultural use of the land and, therefore, is appropriate in the Green Belt.

Nevertheless, the section of the proposed access road that would be in Wigan and the associated screen mound would compromise the openness of the Green Belt and, as such, would be inappropriate development that should only be permitted under very special circumstances.

It would be difficult to argue, that this part of the overall proposed Salford Forest Park development, considered in isolation, would have such a negative impact on the openness of the Green Belt so as to warrant what would, in effect, be tantamount to an overall rejection of the proposed development.  

Therefore, the principal Green Belt issues that need to be addressed is whether or not there are very special circumstances for allowing the overall Salford Forest Park proposal.  This has been discussed within the planning appraisal for Salford’s portion of the site (04/48900/HYBEIA) and it has been concluded that to date, very special circumstances have not been demonstrated that would override the harm arising as a result of the inappropriate development.  On the basis of the above, objection must be raised to this application.

Traffic congestion and road safety

A detailed assessment of this junction has been carried out and it is considered that subject to the event management plan for the major events and agreeing with Wigan MBC suitable pedestrian and Cycle facilities, there would be no materially detrimental effect on Salford’s highway network.

Conclusion

The proposed access would represent inappropriate development in the Green Belt and very special circumstances must therefore be demonstrated.  The access would serve the proposed Salford Forest Park development and very special circumstances must therefore be demonstrated for this wider, overall development.  To date, very special circumstances have not been demonstrated that would override the harm arising as a result of the inappropriate development.  For this reason, it is recommended that Salford objects to the application.

RECOMMENDATION:

Objection