Hello All Hope this email update finds you well. THANK YOU all for your continued support. Please take a few minutes to read the following and then PLEASE act upon it. Your actions are important and WILL make a difference. The EFA's recent report and Oldham Council's continued indifference to public opinion in Saddleworth has generated even stronger opposition to the plan to move the school. On the 18th February 2015 and following the presentation of a 3000+ name petition Oldham Council requested public views on the site selection for the new Saddleworth School. A paper will go before Oldham Council's Cabinet on Monday 30th March 2015, to seek a final decision and approval on the site. Read their full press release here: http://www.oldham.gov.uk/press/article/902/final_call_for_public_views_on_site_selection_for_saddleworth_school Make your views known NOW! - Let's make sure democracy has its day. IMPORTANT: Deadline is 5pm on Wednesday 18th March 2015 Below you will find template letters which are for your guidance.Please feel free to use some or all of the content as you see fit. You can submit your consultation feedback either by completing the 'New Saddleworth School Consultation Form' here: https://www.oldham.gov.uk/forms/form/368/en/new_saddleworth_school_consultation_form OR by writing to the following address: Saddleworth School Consultation Directorate of Economy and Skills Oldham Council Level 3 Civic Centre West Street Oldham OL1 1UH TEMPLATE OBJECTION LETTER I/We object to the proposal to build a new Saddleworth school on the proposed site in Diggle for the following reasons: Traffic, Congestion, Safety • The proposed development would present a significant safety risk. Huddersfield Road will be the route taken to the school for children who walk to school and vehicles. This road has a narrow carriageway that cannot be widened without the demolition a row of houses and is served by a narrow pavement. Heavy traffic will be generated by the fact that children from parts of Saddleworth previously within walking distance of the school will now have to use buses or be brought by car to Diggle. With only one way in and out of the village, those same cars will then have to turn around and head back out of Diggle. Those children living within walking distance will have to share the same route as these vehicles and those of residents for a significant stretch of the road, whatever alterations to the highway OMBC attempts, and will therefore be put at risk. There are currently four access points to the current Uppermill school site and it would be better to invest in improving and enhancing these than to expose children to the dangers associated with the Diggle scheme. • Siting the school at Diggle will generate increased road traffic across Saddleworth. Pupils located in villages within walking distance of the current school site (Uppermill, Greenfield, Grasscroft) will need to be brought by car or bus to Diggle. The proposed school site is also more remote from other higher density population centres from which children are drawn (Scouthead, Springhead, Grotton and Austerlands). The serious safety risks associated with Huddersfield Road will mean that fewer parents will by willing to encourage children to walk or cycle to school, this will increase private car and bus traffic into and out of the village. These outcomes are in direct conflict with OMBC’s objective of expanding the use of more sustainable forms of transport and will lead to a deterioration in air quality in Saddleworth as a whole and Diggle in particular. • Traffic congestion in Diggle village generated by the school will also have an impact on country lanes and historic hamlets in the vicinity. Routes such as Sugar Lane, Sandy lane, Spurn Lane and Carr Lane are liable to become ‘rat runs’ for vehicles seeking fast exits from the village when the exit via Huddersfield Road is congested. Dobcross centre and Brownhill will suffer significant increases in traffic with an associated increase in hazard to pedestrians. The distinctive character of the Dobcross conservation area will be seriously compromised by the increase in through traffic. • Parents of children in areas currently within walking distance of the school will be forced to pay the cost of bus travel for their children if they do not use private cars, an expense they would not be subject to if the school remained at its current site. Children in Greenfield and Friezland will incur additional transport costs to their families at around £38.00 per month per child. Landscape, Heritage and Environment • The proposed school would breech OMBC’s commitment to protect the greenbelt. Open pasture land would be transformed by the levelling of the land necessary for the provision of sports fields, the erection of flood-lights and the introduction of fencing, asphalt, astro-turf and concrete. • The impact on the character of the landscape would be devastating. The unbroken view from the village, currently across farmland to the Huddersfield Narrow Canal and then to the ridge-line hamlets and pasture-land up to the dramatic edge of the moors will be scarred by the intrusion of inharmonious and inappropriate features into the landscape. • The scale and appearance of the proposed school buildings will be out of character with the vernacular dwellings on Huddersfield Road (several Grade II listed) and the listed structure incorporating the landmark clock-tower. • The Canal River Trust has noted that ‘the canal infrastructure in the vicinity of the [school] site has significant historic value’ notably the Grade II listed bridge and subway, locks and tow-path bridges and is concerned about the impact of the development on both this and the ‘visual amenity’ for canal users and pedestrians. • The proposed school development is only one kilometre from the boundary of the Peak District National Park and would have a significant negative impact on views into and out from the National Park, compromising the integrity of a landscape asset of national and international significance. • The increased amount of traffic congestion within the village will cause a significant increase in vehicle emissions and a consequent deterioration in air quality. Ecology • There is clear and substantial survey evidence that the fields within the greenbelt on which the sports facilities for the proposed school at Diggle will be located are a significant nesting site and feeding ground for Lapwings, a critically endangered species on the ‘red list’, a Priority Species in the UK Biodiversity Action Plan and Species of Principal Importance within the Natural Environment and Rural Communities Act. The conversion of the fields from floodplain grazing marsh and pasture to sports pitches and associated disturbance once the school is in operation would destroy this breeding site. • Survey evidence also indicates that both Grey Wagtails and Dippers use the site. Dippers have been recorded as breeding on the site of the proposed school buildings for seven years. Both species feed in the Diggle Brook which runs through the site. Development of the site and subsequent disturbance would in all likelihood render it unusable as both a breeding and feeding site for Dipper and Grey Wagtail. • The proposed school site also currently provides a commuting route and feeding location for at least six species of bats and is likely to provide hibernating and maternity roosts; there are further known bat roosts in the vicinity. Flood-lighting and disturbance will have a serious negative impact on bat populations commuting through the site along the Diggle Brook and roosting and feeding within the site and demolition and development will threaten bat roosts. • The Diggle Brook itself provides a significant habitat for riverine species including nationally and internationally important species such as Otter (a European Protected Species), Brown Trout and the now endangered While-clawed Crayfish. Flood relief works, including the use of gabions, will have serious negative impact on the riverine environment, ecology and surrounding habitat. • The Huddersfield Narrow Canal is designated as a Site of Biological Importance and a Site of Special Scientific Importance and runs within meters of the site. Demolition and construction works are likely to degrade this environment through wind-blown debris accumulating on the canal surface and the silting-up of the canal through dust and run-off from the development works (as noted in the EFA’s feasibility study). • The development of the floodplain grazing marsh will destroy an important element of the mosaic of habitats which are integral to the conservation of bird species associated with the South Pennine Moors Special Protection Area, the boundary of which is less than two kilometres from the site. Wet pasture land on the moorland fringe, like that to be found on this site, is crucial to the nationally and internationally significant species associated with the SPA and its loss would have an adverse impact on increasingly vulnerable species like curlew, snipe, skylark and redshank. • Surveys undertaken as part of the EFA feasibility study for the site with respect to bats and breeding birds have been superficial, limited in scope and failed to consider relevant survey data held by the Greater Manchester Ecology Unit. GMEU is currently assessing the site with a view to designating it as a Site of Biological Interest. Flood Risk • There is a serious risk associated with both the threat of overtopping or breech of the canal banks to the rear of the site. • There is also a risk associated with the possible failure of the dam to Diggle Reservoir which would result in the inundation of the Diggle Brook and consequent serious flooding of the site. • A culvert carries a watercourse into the proposed school site where it joins another culvert within the site causing restricted flow and this has caused flooding of the site in the past. • The implementation of drainage works and gabions to prevent flooding of the proposed sports pitches involves the loss of significant and important stretch of the floodplain for the Diggle Brook. Loss of floodplain at this point will generate an increased risk of flooding down-stream at the confluence of the Diggle Brook and River Tame and thence within already high-risk areas of Uppermill. No measures to mitigate these impacts have been contemplated or costed and the view of the Environment Agency has not been sought. For these reasons I/we feel that the proposal to site the school at Diggle is wholly inappropriate and would be disastrous for Diggle and for Saddleworth. We urge you to reverse the decision to build the school in Diggle and instead build it on the more suitable site of the current school in Uppermill. Building the new school on the Uppermill site: • Would not entail any loss or infringement of the greenbelt; • Would mean the school is in a location that has the appropriate infrastructure to support a school; • Means that the school would retain several safe access points; • Would mean that existing sports facilities could be retained; • Means that the existing bus turnaround could be retained; • Would not have any impact on landscape, the environment, heritage nor any ecological implications; • Would not increase and could help contribute to a reduction in traffic, congestion and vehicle emissions; • Would not involve multiple flood risks; • Would not necessitate costly works on access, highways, flood prevention and environmental and ecological mitigation; • Would preserve the vitality and vibrancy of Uppermill as the commercial and retail centre of Saddleworth. ENVIRONMENTAL TEMPLATE OBJECTION LETTER I would like to object to the principle of locating the Saddleworth School in Diggle (the ‘control’ option) on the following grounds: Harm to Green Belt • Due to the environmentally sensitive nature of the site an EIA should be carried out • The proposals conflict with government planning policy guidance (NPPF, 2012) on protecting Green Belt land. • The proposals conflict with Oldham Local Development Framework policies (policies 1 & 22). The Green Belt boundary is established within the adopted Local Plan & can only be altered through review of the Local Plan. • This proposal will set precedence for development in Green Belt, contrary to government policy. The proposals are likely to have a significant impact on the Green Belt for the following reasons: A significant proportion of the proposed development incorporates designated Green Belt land (proposed for construction of sports facilities + land to be allocated for car parking). The plans include the provision of a full sized grass and three-quarter sized all weather pitch, with associated floodlighting and fencing on a 6ha area of Green Belt pasture land adjacent to Diggle Brook. The feasibility study outlines that the provision of these facilities will necessitate land-re-grading, works to raise the banks adjacent to the river and construction of gabions adjacent to the river for flood protection. As such it would conflict with the fundamental aim of Green Belt policy to keep land permanently open and to safeguard the countryside from encroachment. This constitutes ‘inappropriate development’ that would be ‘harmful’ to the Green Belt for the following reasons: introducing unnatural features; spoiling natural or existing contours; loss of visual amenity & landscape value (especially views from the Huddersfield Canal SBI). In addition, the proposed use of the Green Belt for sports recreation conflicts with its current value for biodiversity & further ‘harm’ would occur due to: Loss of important wildlife habitats (bat foraging habitat and commuting routes, lapwing nesting habitat) and highly significant impacts on European Protected Species (bats) due to changed lighting regime. Impact on wildlife and the natural environment • Due to the environmentally sensitive nature of the site an EIA should be carried out • The proposals conflict with government planning policy guidance (NPPF, 2012) on conserving and enhancing the natural environment. • The proposals conflict with Oldham Local Development Framework policies (policies 6,9,21,22,24) The proposals are likely to have a significant impact on the environment for the following reasons: Bats A data search contained within the bat survey identified a large number of confirmed bat roosts (of several species) in the wider area. There are also potential hibernation roosts close by. All species of bats and their roosts are protected under the Conservation of Habitats and Species Regulations (2010). The proposals include the development floodlighting in a previously unlit area of pasture land as well as a change in the lighting regime on the adjoining Pallet works site. Bats are known to react adversely to artificial light. Diggle Brook and Huddersfield Canal run parallel, either side of the development and function as commuting routes & foraging habitat for bats. In addition, the 6ha proposed sports pitch is located on traditional pasture, which will also function as foraging habitat for bats. Floodlighting as required for sports facilities is likely to have a significant adverse impact on the local bat population. It is likely to result in severance of commuting routes along the two waterways and around the site as well as preventing access to foraging areas. This necessitates a full impact assessment. Birds A number of local bird recorders and residents have noted the presence of breeding Lapwings (a Priority Species under the NERC Act 2006) within the site. They nest within the Green Belt field proposed for sports facilities and have also been recorded within the two Greenfield sites towards the front of the Pallet works site. They have been present for at least 28 years according to some residents. They were last recorded nesting in 2013; records are available from the Greater Manchester Bird Recording Group Database. The grazing regime was stopped in 2014 making the habitat unsuitable for nesting. Lapwing did however nest in adjoining fields & it was observed that at least one pair tried to walk chicks into their previous habitat to feed. OMBC should see this site as a valuable asset to the boroughs conservation and biodiversity and an opportunity to increase numbers of a nationally declining species, not as an opportunity to develop over it. The South Manchester Ringing Group have monitored breeding dippers along the Diggle Brook for seven years and have data on nesting sites within & in close proximity to the development. Several adults are colour ringed and monitored. Kingfisher has also been recorded in the locality (Schedule 1 species) and other bird species e.g. grey wagtail, known to nest along the brook. Again, these records are available through GMBRG. There is a concern about the disturbance that will be caused to these and other riverine wildlife species as a result of the presence of adjoining football pitch, floodlighting and the proposed flood relief works. [NOTE: it has been confirmed that the ecological consultancy that carried out the Breeding Bird report did not request bird records from the GMBRG database manager as advised by GMEU (GMEU do not hold bird records) and as such the report fails to include recent records of birds of conservation concern & suggest appropriate mitigation for them] Further reasons why an EIA should be carried out: Diggle Brook Is home to species of national & international importance e.g. Brown Trout (UKBAP), Otter (European Protected Species): Otter have been recorded on both Diggle Brook and Huddersfield Narrow Canal. White-clawed crayfish (on the decline nationally). Huddersfield Narrow Canal SBI & SSSI Also a Greater Manchester Biodiversity Habitat. The citation for Huddersfield Narrow Canal identifies populations of the European Protected Species floating water-plantain within the water body. The canal has one of only 18 records of this species in England, whose distribution is confined to the north and west of England. The species is particularly sensitive to nutrient enrichment. The Phase 1 Ecology report included in the feasibility study states: “Given the proximity of the canal to the site, there is a high risk of wind-blown debris entering the water course in addition to siltation of the canal as a result of the accumulation of dust or run off created from site works”. Flood Risk • Due to the environmentally sensitive nature of the site an EIA should be carried out: flood prevention works (construction of Gabions) have been proposed. The impact of the proposed flood relief works on the rest on riverine environment, ecology and surrounding habitat needs to be fully assessed, as well as impacts downstream. • The proposals conflict with government planning policy guidance (NPPF, 2012) on Meeting the challenge of climate change and flooding. • The proposals conflict with Oldham Local Development Framework policies (policies 1 &19). Reasons: Significant portions of both the Green Belt field and Pallet Works site fall an area identified within Environment Agency Flood Hazard Maps as having a high risk of flooding from surface water. Smaller portions of the site, adjacent to the river within the Green Belt section of the development footprint & to the north of the Pallet Works site are within Environment Agency Flood Risk 3 for Planning and Flood Risk 2 for Planning. Portions of the watercourse in the neighbouring vicinity are also within the Environment Agency Flood Risk 3 for Planning and Flood Risk 2 for Planning. Impact on the Historic Environment • The proposals conflict with government planning policy guidance (NPPF, 2012) on protecting the historic environment • The proposals conflict with Oldham Local Development Framework policies (policy 24) The feasibility study did not give due consideration to the Schedule 2 clock tower present within the proposed development area, viewing it rather as a problem than an heritage asset that is valued by the local community. The development of modern school buildings, overshadowing the tower will clearly impact on its setting. The school design is not sympathetic. A more appropriate development for this site is exemplified by other former mill sites in the Saddleworth Area. Due consideration was not given to the historical setting of the Huddersfield Narrow Canal. Again, there was no consideration of the impact on the proposed development on the setting of the canal and its users. OMBC failing in its duty to ‘plan positively’ and promote ‘sustainable development’ In any opinion, the proposed plans are ‘inappropriate’ due to the locality, environmental issues and adverse impact on the historical value of the area and local community. OMBC now has an opportunity to consult the public and listen to their views on how we would like to see this site developed. Personally, I would like to see development proposals for use of the Pallet Works site that are more sympathetic to the local surroundings & promote the historical, recreational and biodiversity value of the area. I would like to see the Green Belt field leased out for low-level grazing management that is appropriate to enhance its value for nesting lapwings and for foraging and commuting bats. There are grants available from Natural England for the management of wader (lapwing) breeding habitat through the Higher Level Stewardship scheme & for other management to benefit wildlife. Please consult with the community and allow our input on the management & development of this area.