PLANNING & TRANSPORTATION REGULATORY PANELPART ISECTION 1: APPLICATIONS FOR PLANNING PERMISSION

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APPLICATION No: 17/69776/OUTAPPLICANT: Network Space Developments LtdLOCATION: Ashtonfields Site Part Of British Coal Yard, Ravenscraig Road, Little Hulton,

Worsley, M38 9PUPROPOSAL: Outline Planning Application for flexible B1(b), B1(c), B2 and B8 Employment

Use with ancillary B1(a) Office Space up to 18,581sqm (200,000sqft) including means of access and earth works (Resubmission of 16/69049/OUT)

WARD: Walkden North

Description of Site and Surrounding Area

The application site (5.8 hectares) is located off Ravenscraig Road in Little Hulton. The site lies within an area which comprises a range of uses. To the north, the site adjoins employment units on Ravenscraig Road. The site also adjoins Brookdale Park which is a site occupied by travelling showpersons comprising residential properties, residential pitches, and storage areas for vehicles. The site adjoins existing residential properties along its western and southern boundaries, including properties at Crescent Drive, Eastham Way, and Trafford Drive. To the east lie further residential properties, whilst to the north east the site adjoins an area of public open space known as Ashtons Field.

The site is currently vacant and comprises previously developed land. The site formed part of the former Ashtons Field Colliery, and was subject to an initial programme of land remediation approximately 10 years ago by the Northwest Development Agency using funding from the Homes and Communities Agency's National

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Coalfields Programme. As part of this programme of remediation, the adjoining land was remediated and made available as a new area of public green space providing a green corridor for walkers and cyclists as well as grass land for play and an area of heathland for wildlife. It was the intention of the Northwest Development Agency in funding the initial remediation works that the application site would be developed for employment purposes, however due to market conditions the application site has not come forward for development despite a previous grant of outline planning consent in January 2004 for 15,000sqm of industrial (Class B2/B8) floorspace with associated parking and access. Following its initial remediation the site has been colonised with self-seeded scrub vegetation. The application site is bounded by a raised bund on all sides, with the exception of its access point via Ravenscraig Road. The bund reaches a height of approximately 4 – 5m above the surrounding ground level and is colonised with trees and vegetation, which taken together afford considerable visual screening of the site from surrounding properties.

The existing vehicular / pedestrian access point to the site is via Ravenscraig Road, which in turn is accessed off Clegg’s Lane (A5082) via a roundabout.

Description of Proposal

Background

This application is a resubmission of 16/69049/OUT, which was previously approved by the Planning and Transportation Regulatory Panel on 2 February 2017. Following the grant of consent and issue of the decision notice, it came to light that there was an error within the description of development in that it did not refer to B2 (General Industry) use, notwithstanding that all supporting application documents referred to B2 use forming part of the flexible consent being sought, and the application having been appraised by technical experts and the case officer on this basis. This resulted from an error on the part of the planning agent acting on behalf of the application when the application was submitted via the Planning Portal.

On the basis of legal advice, the Council has been advised that the only means to address this omission from the description of development would be via a resubmission application. As such, this application is for the same form and quantum of development that was previously approved under 16/69049/OUT, but B2 use is now included within the description of development as follows: Outline Planning Application for flexible B1(b), B1(c), B2 and B8 Employment Use with ancillary B1(a) Office Space up to 18,581sqm (200,000sqft) including means of access and earth works Re-submission of 16/69049/OUT

Description

The application seeks outline planning permission for the development of the site for flexible B1(b), B1(c), B2 and B8 employment use with ancillary B1(a) office space up to a total floorspace of 18,581sqm. The application is in outline only for access and earth works, with all details relating to appearance, scale, layout and landscaping of the site to be determined at a later date via the submission of reserved matters application(s). The applicant has submitted a parameters plan for approval, and the outline permission would establish the following parameters: a flexible permission for B1(b) (Research and Development), B1(c) (Light Industry), B2 (General Industry)

and B8 (Storage and Distribution) employment uses with ancillary office space (B1(a)), up to a maximum of 18,581sqm of floorspace. The proposal seeks flexibility regarding the employment use in order to secure a market facing permission which can react to changes in market demand;

a maximum developable area of 4.45ha (11 acres) across the site; vehicular access in to the site to be taken via the existing access point off Ravenscraig Road; earth works to remove the peat and organic clay from the developable area of the site which in turn will

lower the overall developable site area by a maximum of 400mm to create a development platform. The applicant’s commissioned consultant specialists estimate the peat/clay volume to be removed to be a maximum of 17,000m³;

the retention of the existing landscaping bunds which surround the site and, where possible the retention of the trees and planting which are positioned on the bunds;

the provision of car parking to serve the employment units that is in accordance with the car parking standards defined within the UDP; and

an approach that would limit maximum building heights on the basis of the floorspace of each unit, as follows:

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Unit size (floorspace)

Eaves height Maximum unit height

279 – 1,858sqm 8 – 9m 12m1,858 – 5,574sqm 9 – 13m 16m

16,723sqm 16 – 19m 22m

The Planning Statement which accompanies the application confirms that this represents the maximum quantum of development, and that the actual quantum of development may be lower than what is being sought via this application. The purpose of the application is therefore to establish a maximum quantum of development and provide the applicant with flexibility to respond to market demand in terms of the type and nature of employment units that are to be developed.

Parameters plan

The applicant has also submitted three indicative layout plans which show options for how the site could come forward within the context of the parameters plan. These options are indicative at this stage as the application is in outline only for access and earth works, with all details relating to appearance, scale, layout and landscaping of the site to be submitted at the reserved matters stage. The following three indicative layout options have been presented: Option 1 – a series of employment units ranging between 279sqm and 2,787sqm in floorspace, with a total

cumulative floorspace across all units of approximately 13,000sqm. The units would be arranged in a series of courts off a central access road with surface car parking provided to serve each of the units.

Option 2 – five units ranging between 1,858sqm and 5,574sqm in floorspace, with a total cumulative floorspace across all units of approximately 16,720sqm. The units would be accessed off a central access road and each would be provided with a service yard area and surface car parking.

Option 3 – a development for a single occupier comprising 14,864sqm of warehousing / distribution floorspace, 1,858sqm of ancillary office floorspace, and a separate building comprising 1,858sqm floorspace

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for ancillary / vehicle maintenance purposes associated with the storage / distribution use, with a total cumulative floorspace across all buildings of approximately 18,581sqm.

The application is also accompanied by a means of access plan which identifies that the access to the site via Ravenscraig Road would be via a 7.3m wide carriageway to provide sufficient width for two articulated vehicles to pass, and with a 3.0m wide split footway / cycleway on the south side of the highway access to connect with the existing split footway / cycleway on Ravenscraig Road, and a 1.8m wide footway on the north side of the highway access.

The application seeks permission for unrestricted hours of operation such that any future occupier could operate on a 24 hour basis.

The following documents have been submitted in support of the application: Design and Access Statement Planning Statement Transport Assessment and Travel Plan Phase 1 Geo Environmental Desk Study Air Quality Assessment Noise Assessment, and addendum report Flood Risk Assessment and Conceptual Drainage Strategy Crime Impact Statement Tree Location and Constraints Report, and Arboricultural Constraints Report Ecological Reports including: Preliminary Ecological Appraisal, Bat Report, Breeding Bird Survey Report,

Botanical Survey Report, Reptile Report Sustainability Checklist Statement of Community Involvement

Publicity

Site Notice: Non HH Article 15 Date Displayed: 4 April 2017Reason: Article 13

Press Advert: Manchester Weekly News Salford Edition Date Published: 13 April 2017Reason: Article 13 Standard Press Notice

Neighbour Notification

A total of 131 neighbouring properties were notified of the application. In addition, site notices were displayed within the surrounding area. The following properties were notified: Albany Close (nos. 6 and 8) Brookdale Park (nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 12A, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25,

26 and 27) Crescent Drive (nos. 37 – 99 (odd number only)) Charlton Fold (nos. 1 – 15 (all properties)) Eastham Way (nos. 106 – 132 (even numbers only)) Ravenscraig Road (the following commercial premises were notified: J Rosenthal and Son Ltd, Ross

Roofing, and Web Lighting Ltd) Trafford Drive (nos. 1 – 67 (odd numbers only))

Community engagement

Prior to submission of the previous planning application (16/69049/OUT), the applicant’s agent liaised with ward councillors for both Walkden North and Little Hulton (whilst the site lies within Walkden North ward, Clegg’s Lane forms the boundary with Little Hulton ward and therefore the site lies in close proximity to this adjoining ward) to discuss the scope of pre-application community engagement. Informed by this, a pre-application community drop in event was arranged, which was advertised by means of a flyer distributed to over 348 properties and the display of posters in prominent locations within the surrounding area. A postal address, email address and telephone number were also included within the flyer in order to allow individual who could not attend the event to make comments.

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The pre-application community drop in event was held on Thursday 15 September 2016 at the Wharton and Cleggs Lane Church and Community Centre. The event was attended by over 34 members of the local community and 9 comments forms were filled in. The key issues raised by attendees included:

Highways Impact of increased traffic along Ravenscraig Road / Cleggs Lane, and impact of this on residents of

Brookdale Park Another vehicular access point to the site is needed Parking on Ravenscraig Road associated with the existing employment units causes problems for residents

of Brookdale Park

Environment Remediation / development of the site may cause the release of dust / toxins which will affect local air

quality The landscape buffer should be retained to afford screening to residential properties

Other Would not want to see 24 hour operation, but standard working hours would be acceptable Employment uses will be good for the local community and create job opportunities

The Statement of Community Involvement submitted alongside this planning application provides more detail on the nature of the pre-application consultation activities.

Representations

No representations have been received to date.

Relevant Site History

16/69049/OUT – Outline planning application for flexible B1(b), B1(c) and B8 employment use with ancillary B1(a) office space up to 18,581sqm (200,000sqft) including means of access and earth works. Approved – 2 February 2017.

07/55797/FUL - Erection of three industrial units comprising a total of ten General Industrial Units (Class B2) together with associated car parking. Refused – 12 March 2008. The sole reason for refusal was the lack of a submitted flood risk assessment and that insufficient information had therefore been submitted to assess the impact of the proposed development in terms of flooding and drainage issues.

03/46311/OUT - Outline planning application for 15,000sq.m of industrial (Class B2/B8) floorspace with associated parking and access together with re-modelling and remediation works to provide an area of public open space & associated foot and cycle paths and landscaping. Approved – 15 January 2004. This consent has been partially implemented in terms of the remediation and the provision of public open space known as Ashtons Field.

01/43116/FUL – Erection of 2.4m high security fencing to part boundary. Approved – 7 February 2002.

Consultations

The following consultee responses were made in relation to the previous application (16/69049/OUT). Consultees have been renotified of this resubmission application, and those consultees who have responded have confirmed that their responses to the previous application continue to apply.

Arboricultural Consultant –

No objections, subject to conditions requiring the implementation of tree protection measures to protect the existing trees to be retained, the implementation of works in accordance with the submitted Arboricultural Constraints Report, and the submission and implementation of a replacement planting scheme for the trees that are to be removed.

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Design For Security –

No objections subject to the development being designed and constructed in accordance with the recommendations set out within the submitted Crime Impact Statement.

Bolton Council - No comments received to date.

Greater Manchester Ecology Unit –

No objection to the application on ecological grounds. The application site is not of substantive nature conservation value, it does not support habitats of significant nature conservation value, and it is considered to have only low potential to support any specially protected or priority species.

The vegetated bund surrounding the site has some local nature conservation value, and the site has some local value for nesting birds. The bund is to be retained as part of the scheme and this is welcomed. Recommend that works to or removal of trees should not take place within the main bird breeding season and that trees and vegetation on the bund be suitably protected during the course of any groundworks and future construction activity. Encourage the provision of SuDS schemes as part of any future development on the basis that this could enhance the site’s value for wildlife.

Greater Manchester Minerals And Waste Planning Unit –

No objection. The application site is identified as an area suitable for waste management uses within Policy 5 of the Greater Manchester Waste Plan. This policy does not preclude the development of the site for non-waste uses, and therefore this raises no issues in terms of the principle of the proposed development in this location.

Highways –

No objection. The submitted Transport Assessment indicates that traffic generated by the proposed development will not have any adverse highway impact. A Travel Plan will need to be established following occupation of any future development. Remedial works to the existing footway on Ravenscraig Road should be undertaken as part of any future highway extension.

Transport for Greater Manchester have also reviewed the submitted documents and raise no objection.

Senior Engineer Flood Risk Management –

A Flood Risk Assessment and Conceptual Drainage Strategy has been submitted which indicates that flow will be restricted to greenfield runoff and that there will be a SuDS treatment train that includes swales, detention basins and permeable paving. It is also identifies that the SuDS features will provide oil separation.

These proposals are acceptable in principle and indicate that the Strategic Flood Risk Assessment requirements will be met.

The detailed approach to drainage will be confirmed at any future reserved matters stage and a condition is recommended requiring future submission of a detailed strategy for surface water drainage that is in accordance with the submitted conceptual drainage strategy.

The Coal Authority –

The application site falls within the defined Development High Risk Area. The Coal Authority records indicate that within the application site and surrounding area there are coal mining features and hazards which need to be considered in relation to the determination of this planning application, specifically historic recorded underground coal mining at shallow depth, likely historic unrecorded underground coal mining at shallow depth and recorded mine entries (shafts).

The Phase 1 Geo Environmental Desk Study Report identifies that shallow coal mine workings and the recorded mine entries pose risks to development at the site. Accordingly, the report recommends the undertaking of

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intrusive site investigations and confirms that appropriate stabilisation works may be required dependent on the results of the investigation.

The Coal Authority would therefore expect any subsequent reserved matters submission relating to the site layout to adhere to this commitment and to avoid the siting of buildings over or within influencing distance of any recorded mine entry on or off site.

The applicant should ensure that the exact form of any intrusive site investigations, including those relating to the recorded mine entries, are agreed with The Coal Authority’s Licensing and Permitting Department as part of their permit application. The findings of these intrusive site investigations should inform any mitigation measures which may be required in order to ensure the safety and stability of the proposed development.

No objection subject to recommended conditions regarding the undertaking of intrusive site investigations for mine entries and shallow coal workings, the submission of a layout plan with any future reserved matters application which identifies appropriate zones of influence for any recorded mine entries and the definition of suitable no build zones, and the submission of a scheme for the treatment of any recorded mine entries and remedial works for any shallow coal workings, and its subsequent implementation.

Urban Vision Environment (Air And Noise) –

In relation to noise, the submitted noise assessment and addendum report indicate that the site can be developed to achieve the Council’s expected noise design target. As such no objection is raised subject to conditions to define the operational noise standard that any future development will be required to meet, and to require submission of a Delivery Yard Management Plan to ensure no unacceptable noise impact arising from the operation of any service / delivery yards associated with future development. The submission of a further noise assessment report will be required at any future reserved matters stage in order to ensure that the form and layout of development will not result in any unacceptable impact on neighbouring residential properties.

In relation to air quality, the submitted air quality assessment report demonstrates that the proposed development will not lead to an unacceptable risk from air pollution and concludes that there are no material reasons in relation to air quality why the proposed scheme should not proceed. The conclusions of the report are accepted and no objections are raised in this regard. In terms of the construction phase of development, the submission of a Construction Method Statement is recommended to ensure no unacceptable impact on neighbouring occupiers.

Urban Vision Environment (Land Contam) –

The Phase 1 Geo Environmental Desk Study concludes that a site investigation will likely be required to investigate the potential pollutant linkages further. In addition, the report states investigation and treatment of shallow abandoned mine workings will also be required before any development is carried out on site. Further liaison with the Coal Authority will be required to investigate and treat the shafts to minimise the risk of collapse and risk to human health in the long term.

No objections subject to recommended conditions requiring a Site Investigation report to address the land contamination on site, and the submission of further reports regarding the identification and subsequent implementation of appropriate remedial works.

Planning Policy

Development Plan Policy

Unitary Development Plan ST3 - Employment SupplyThis policy states 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.

Unitary Development Plan ST5 - Transport NetworksThis policy 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

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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.

Unitary Development Plan ST14 - Global EnvironmentThis policy states that development will be required to minimise its impact on the global environment. Major development proposals will be required to demonstrate how they will minimise greenhouse gas emissions.

Unitary Development Plan MX3 - Sites for Mix of Open Space and Built DevelopmentThis policy states that the following sites are allocated for a mix of open space and built development1. Cleggs Lane, Walkden North2. Whit Lane, Irwell Riverside.

Unitary Development Plan DES1 - Respecting ContextThis policy states that development will be required to respond to its physical context and respect the positive character of the local area in which it is situated and contribute towards a local identity and distinctiveness.

Unitary Development Plan DES2 - Circulation and MovementThis policy states that the design and layout of new development will be required to be fully accessible to all people, maximise the movement of pedestrians and cyclists through and around the site safely, be well related to public transport and local amenities and minimise potential conflicts between pedestrians, cyclists and other road users.

Unitary Development Plan DES4 - Relationship Development to Public SpaceThis policy states that developments that adjoin a public space shall be designed to have a strong and positive relationship with that space by creating clearly defining public and private spaces, promoting natural surveillance and reduce the visual impact of car parking.

Unitary Development Plan DES7 - Amenity of Users and NeighboursThis policy states that all new development, alterations and extensions to existing buildings will be required to provide potential users with a satisfactory level of amenity in terms of space, sunlight, daylight, privacy, aspect and layout. Development will not be permitted where it would have an unacceptable impact on the amenity of occupiers or users of other development.

Unitary Development Plan DES9 - LandscapingThis policy states that hard and soft landscaping should be provided where appropriate that is of a high quality and would enhance the design of the development, not detract from the safety and security of the area and would enhance the attractiveness and character of the built environment.

Unitary Development Plan DES10 - Design and CrimeThis policy states that developments must be designed to discourage crime, antisocial behaviour, and the fear of crime. Development should i) be clearly delineated ii) allow natural surveillance iii) avoid places of concealment iv) encourage activity within public areas.

Unitary Development Plan A2 - Cyclists, Pedestrians and the DisabledThis policy states that development proposals, road improvement schemes and traffic management measures will be required to make adequate provision for safe and convenient access by the disabled, other people with limited or impaired mobility, pedestrians and cyclists.

Unitary Development Plan A8 - Impact of Development on Highway NetworkThis policy states that development will not be permitted where it would i) have an unacceptable impact upon highway safety ii) cause an unacceptable restriction to the movement of heavy goods vehicles along Abnormal Load Routes.

Unitary Development Plan A10 - Provision of Car, Cycle and Motorcycle Parking in New DevelopmentsThis policy states that there should be adequate provision for disabled drivers, cyclists and motorcyclists, in accordance with the Council’s minimum standards; maximum car parking standards should not be exceeded;

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and parking facilities should be provided consistent with the provision and maintenance of adequate standards of safety and security.

Unitary Development Plan EN12 - Important Landscape FeaturesThis policy 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. 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.

Unitary Development Plan EN17 - Pollution ControlThis policy states that in areas where existing levels of pollution exceed local or national standards, planning permission will only be granted 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.

Unitary Development Plan EN18 - Protection of Water ResourcesThis policy states that development will not be permitted where it would have an unacceptable impact on surface or ground water.

Unitary Development Plan EN19 - Flood Risk and Surface WaterThis policy states that any application for development that it is considered likely to be at risk of flooding or increase the risk of flooding elsewhere will need to be accompanied by a formal flood risk assessment. It should identify mitigation or other measures to be incorporated into the development or undertaking on other land, which are designed to reduce that risk of flooding to an acceptable level.

Unitary Development Plan EN22 - Resource ConservationThis policy states that development proposals for more than 5,000 square metres of floorspace will only be permitted where it can be demonstrated that the impact on the conservation of non-renewable resources and on the local and global environments, has been minimised as far as practicable; and full consideration has been given to the use of realistic renewable energy options, and such measures have been incorporated into the development where practicable.

Unitary Development Plan R5 - Countryside Access NetworkThis 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.

Unitary Development Plan DEV5 - Planning Conditions and ObligationsThis policy 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 be granted planning permission subject to planning conditions or planning obligations that would ensure adequate mitigation measures are put in place.

Unitary Development Plan DEV5 - Planning Conditions and ObligationsThis policy 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 be granted planning permission subject to planning conditions or planning obligations that would ensure adequate mitigation measures are put in place.

Other Material Planning Considerations

National Planning Policy

National Planning Policy Framework

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Local Planning Policy

Supplementary Planning Document - Sustainable Design and ConstructionThis policy document expands on policies in Salford’s Unitary Development Plan to provide additional guidance for planners and developers on the integration of sustainable design and construction measures in new and existing developments.

Supplementary Planning Document - DesignThis document reflects the need to design in a way that allows the city to support its population socially and economically, working with and inviting those affected into an inclusive decision making process. Equally, development must contribute to the creation of an environmentally sustainable city supporting the natural environment minimising the effects of, and being more adaptable to, the potential impact of climate change.

Supplementary Planning Document - Design and CrimeThis policy document contains a number policies used to assess and determine planning applications and is intended as a guide in designing out crime.

Supplementary Planning Document - Trees and DevelopmentThe policy document has been prepared to give information to all those involved in the development process about the standard that the Local Planning Authority requires for new development proposals with specific reference to the retention and protection of trees.

Supplementary Planning Document - Planning ObligationsThis policy document expands on the policies in Salford’s Unitary Development Plan to provide additional guidance on the use of planning obligations within the city. It explains the city council’s overall approach to the use of planning obligations, and sets out detailed advice on the use of obligations in ensuring that developments make an appropriate contribution to: the provision of open space; improvements to the city’s public realm, heritage and infrastructure; the training of local residents in construction skills; and the offsetting of greenhouse gas emissions.

Planning Guidance - Flood Risk and DevelopmentThe overarching aim of the planning guidance is to ensure that new development in areas at risk of flooding in the city, is adequately protected from flooding and that the risks of flooding are not increased elsewhere as a result of new development.

It is not considered that there are any local finance considerations that are material to the application.

Appraisal

The key issues for consideration in the determination of this application are: Principle of the development Design Highways, accessibility and parking Amenity Land contamination and land stabillity Flood risk and drainage Biodiversity Sustainability Planning obligations

Principle of the development

The NPPF sets out the Government’s commitment to building a strong and competitive economy and that the planning system does everything it can to support sustainable economic growth, “Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system” (NPPF, paragraph 19). The document sets out that to help achieve economic growth, “local planning authorities should plan proactively to meet the development needs of business and support an economy fit for the 21st century.

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The application seeks outline permission for the development of up to 18,581sqm of floorspace for B1(b), B1(c), B2 and B8 employment use with ancillary B1(a) office space. Whilst the precise mix of employment floorspace will be confirmed at any future reserved matters stage in response to market demand, the description of development makes clear that any B1(a) office space would be ancillary to the main employment uses on the site and as such there would be no conflict with the NPPF requirements in terms of the sequential approach to office development as a main town centre use.

The application site forms part of a mixed-use allocation within the Unitary Development Plan. UDP Policy MX3/1 allocates a 15.4ha site at Clegg’s Lane, Walkden North, for open space and employment. The reasoned justification confirms that a comprehensive reclamation scheme is required to bring this site back in to beneficial use and that such a scheme should set aside approximately half of the site for provision of an open space area incorporating a strategic recreation route for pedestrians and cyclists, with the remaining land (approximately 7ha) being developed for employment purposes. The reasoned justification identifies that adequate environmental safeguards will be required to ensure that the amenity of neighbouring residential properties is protected.

As part of the planning permission granted in January 2004, the entire site was subject to remediation by the Northwest Development Agency using funding from the National Coalfields Programme and the area of public open space was established on the eastern half of the UDP site allocation and transferred to the Land Trust in 2007 for its ongoing management. The application proposal relates to the western part of the site allocation (approximately 5.8ha of the total 15.4ha allocation) which is surrounded by a landscaped bund and has an existing vehicular access point via Ravenscraig Road. The proposed development of this part of the site for employment purposes is therefore in accordance with the UDP allocation.

The application site is also identified as an area allocation suitable for waste management facilities within the Greater Manchester Joint Waste Development Plan Document (the Waste Plan). The site is identified as SL12 – Ashtons Field in Table 9 under Policy 5 of the Waste Plan. The site is identified as potentially suitable for: Anaerobic Digestion and In-Vessel Composting, Material Recovery Facility, Mechanical Heat Treatment or Mechanical Biological Treatment. Within the Waste Plan, ‘areas’ are identified locations where the principle of a waste use would be broadly acceptable. However, the allocation of an ‘area’ in the Waste Plan does not prevent other non-waste related uses coming forward in these locations. The proposed development would not therefore conflict with the Waste Plan ‘area’ allocation. The Greater Manchester Minerals and Waste Planning Unit have reviewed the submitted application documents and raise no objection in this regard.

The principle of employment development on this site has also been established via the previous grant of outline consent in January 2004 for 15,000sqm of industrial floorspace (Class B2/B8), and via the grant of consent in February 2017 for which this is a resubmission application.

In this context, the principle of the proposed development is considered to be acceptable, in accordance with UDP Policy MX3/1 and Policy 5 of the Waste Plan.

Design

UDP Policy DES1 states that development will be required to respond to its physical context, respect the positive character of the local area in which it is situated, and contribute towards local identify and distinctiveness. It also states that when assessing new development, regard should be had to the scale of the proposed development in relationship to its surroundings and the relationship to existing buildings and other features that contribute to townscape quality.

The application seeks approval for the principle of the development only with all other matters reserved for laterapproval. Therefore, the site layout, appearance and materials of buildings would be determined at any future reserved matters stage.

The submitted parameters plan for which approval is sought does however set out the parameters in terms of proposed building heights. This defines the eaves height and maximum unit height on the basis of the floorspace of any proposed units as follows:

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Unit size (floorspace)

Eaves height Maximum unit height

279 – 1,858sqm 8 – 9m 12m1,858 – 5,574sqm 9 – 13m 16m

16,723sqm 16 – 19m 22m

The impact of this in terms of the amenity of surrounding properties is assessed below under ‘Amenity’. In terms of design however, it is important to assess the appropriateness of this proposed scale as the outline permission would provide the basis for any future reserved matters application to come forward in line with these parameters.

The proposed development site is afforded a considerable degree of screening due to it being surrounded by a raised bund. The bund reaches a height of approximately 4 – 5m above the surrounding ground level and is colonised with mature trees and vegetation which provides further screening, particularly when the trees are in leaf given that the majority of the vegetation is deciduous. The majority of the bund lies within the application site ownership, with the only exception being the bund which lies to the north east of the site which lies outside of the site ownership, but forms part of the adjacent Ashtons Field open space ownership. The only break in the bund is for the access point to Ravenscraig Road on the site’s northern boundary.

The raised bund and the nature of the site’s access via Ravenscraig Road means that its design context is predominantly defined by the character of this approach from Ravenscraig Road. There are existing large employment / warehouse units on the north side of Ravenscraig Road which lie behind paladin fencing. On the south side lies the Brookdale Park travelling showpersons site which is also bounded by paladin fencing and the residential element of the site is afforded significant screening by a mature conifer hedge, with that part of the Brookdale Park site which lies closest to the application site being used for the storage of vehicles and fairground rides by the travelling showperson community. Ravenscraig Road is therefore largely industrial in character and appearance, notwithstanding that there are residential units on Brookdale Park.

The position of the application site at the head of the cul-de-sac of Ravenscraig Road, coupled with it being surrounded by the raised bund means that there is limited visibility of the site from the surrounding area. Whilst the scale of the proposed buildings means that they would be visible from the residential roads which lie to the south of the application site (such as Crescent Drive, Eastham Way, and Trafford Drive), the landscaped bund would afford considerable screening and mean that the proposed employment units would not be read in the context of the streetscape of these established residential roads, but would instead be seen in the background of vistas, lying beyond the landscaped bund.

In this context, the scale of the proposed development is considered to be appropriate in design terms having regard to its setting and the character of Ravenscraig Road as its means of access. The detailed arrangements in terms of the layout and siting of buildings within the site would be determined at any future reserved matters stage. As such, the application proposal is considered to be in accordance with UDP Policy DES1.

Design and crime

UDP Policy DES10 states that development will not be permitted unless it is designed to discourage crime, anti-social behaviour and the fear of crime. This approach is fully in accordance with NPPF paragraphs 58 and 69 which indicate that planning decisions should aim to ensure that developments “create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion.” Further policy guidance is outlined in the council’s Design and Crime Supplementary Planning Document.

A Crime Impact Statement (CIS) has been submitted as part of the planning application, prepared by Design for Security which is part of Greater Manchester Police. The Crime Impact Statement recommends that the site should be secured by a properly installed and robust fencing system to enclose the whole of the site, and that this should be particularly resistant to damage, scaling and penetration where adjacent to publicly accessible space. It also recommends that a robust access control strategy be adopted at the entrance to the site in order to prevent unauthorised access, particularly outside of normal working hours.

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The application is in outline for access only with all other matters reserved, and therefore the detailed approach to designing out crime would be confirmed at any future reserved matters stage where the proposed site layout and boundary treatment would be defined. The CIS contains a number of recommendations to inform any future reserved matters submission in this regard, and a further CIS would be required to be submitted at this future stage. In this context, it is considered that there are means of reducing the potential for crime through the detailed design of the site and that this application in terms of establishing the principle of development and the means of access would not conflict with the objectives of UDP Policy DES10 and the Design and Crime SPD.

Highways, accessibility and parking

Accessibility

The submitted Transport Assessment describes the accessibility of the application site by sustainable travel modes including pedestrians, cyclists and by public transport. In terms of bus, the site is served by bus stops located on the A5082 Cleggs Lane with the eastbound stop being 260m walking distance from the site, and the westbound stop being 345m walking distance. These stops are served by four bus services and are served by a high frequency of buses with 23 buses during the weekday AM peak (8:00 – 9:00) and 25 buses during the weekday PM peak (17:00 – 18:00), running between a wide range of destinations including Farnworth, Pendleton, Bolton, Manchester City Centre, and the Trafford Centre.

In terms of accessibility by pedestrians and cyclists, the site is accessible from residential areas across Little Hulton, Walkden and Farnworth. To the west of the site lies Linnyshaw Loopline which connects to National Cycle Route 55, and which has recently been upgraded by the Council and partners to connect to Roe Green Loopline and other strategic recreation routes. The Linnyshaw Loopline can be accessed from Clegg’s Lane at a point lying approximately 150mm north of its junction with Ravenscraig Road. There is also a split footway / cycleway along the length of Ravenscraig Road providing a defined cycle route to the site.

Highway impact

As set out above, the application seeks outline permission for the development of up to 18,581sqm of floorspace for B1(b), B1(c), B2 and B8 employment use with ancillary B1(a) office space, with the precise mix of employment floorspace to be confirmed at any future reserved matters stage. In terms of assessing the highway impact of this outline application, the Transport Assessment has therefore undertaken an assessment of the impact of the most onerous mix of development in terms of the three indicative layout options. Option 1 would generate the highest number of vehicle trips as it comprises the largest proportion of B2 (General Industry) land use, which typically generates significantly more vehicle trips per square metre of development when compared against B8 (Storage and Distribution).

The Transport Assessment identifies that Option 1 can be anticipated to generate 81 vehicle trips in the weekday AM peak hour, and 65 vehicle trips in the weekday PM peak hour. The impact of this has been modelled on the surrounding highway network, assessing the impact on three junctions; the Ravenscraig Road / A5082 Cleggs Lane roundabout junction, the A5082 Cleggs Lane / A6 Manchester Road traffic light controlled junction, and the A6 Manchester Road / A575 Bolton Road traffic light controlled junction. In addition, the impact on two stretches of highway in Farnworth which provide access to J2 of the M61 on the Kearsley Spur (the A5082 Long Causeway, and the A6053 Bolton Road) have also been assessed. The assessment demonstrates that with the exception of the Ravenscraig Road / A5082 Cleggs Lane roundabout junction, the proposed development would not result in material increases in traffic along and through the study area links and junctions (with impacts of 1.6% or below). In light of this, only the Cleggs Lane / Ravenscraig Road roundabout junction has been assessed in terms of development traffic impact on theoretical operational capacity. This roundabout was assessed using modelling software and the results demonstrate that the junction would operate with significant reserve theoretical capacity in all scenarios and the cumulative residual impact of the proposed development traffic would be immaterial with no additional queuing projected on approaches.

A Framework Travel Plan has been submitted alongside the planning application. The objective of the Travel Plan is to minimise the impact of the development on the surrounding highway network, and this would be achieved by encouraging future employees at the site to use sustainable modes of travel through the promotion of sustainable travel modes and the provision of sustainable travel infrastructure from the outset. Over a five year period the Travel Plan seeks to achieve a 16% reduction in the number of employees travelling to the site

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by car as single occupancy drivers (to a total proportion of 51% by Year 5), and to achieve a 12% increase in the number of employees travelling to the site by sustainable modes (to a total proportion of 30% by Year 5).

The Transport Assessment and Framework Travel Plan have been reviewed by the Council’s Highways Engineer. The Highways Engineer considers that the Transport Assessment provides a robust basis to indicate that traffic generated by the proposed development will not have any adverse highway impact. The assessment of Option 1 as a worst case scenario is considered to be a robust basis for the Transport Assessment, given the trip generation levels of the three indicative development options.

In terms of the Framework Travel Plan, the Highways Engineer notes that the identified measures and recommendations are generic at this stage, but this reflects the outline nature of the application where details of the proposed form of development and potential occupiers are not known at this stage. On this basis, the Highways Engineer recommends that an updated Travel Plan be prepared within three months of first occupation of any future development, and a condition is recommended in this regard.

In terms of detailed highway works, the Highways Engineer notes that the existing footway on the northern side of Ravenscraig Road is not continuous and this will require works to ensure safe pedestrian access to the application site. Works may also be required to maintain appropriate visibility splays to the easternmost highway access to the existing employment premises on Ravenscraig Road. These works lie outside the applicant’s site boundary and therefore the applicant will be required to enter into an agreement with the Council under S278 of the Highways Act 1980 to secure the required highway works. A condition is recommended in this regard.

On this basis, the Highways Engineer raises no objection to the proposed development in highway terms. Transport for Greater Manchester have also reviewed the submitted Transport Assessment and Framework Travel Plan and raise no objection.

Parking

As the application is in outline for access only, the precise mix of employment floorspace and the associated level of parking provision will be confirmed at any future reserved matters stage. The Transport Assessment confirms that any future parking provision (including car parking, disabled parking, motorcycle parking, and cycle parking) will be in accordance with the UDP parking standards, and compliance with these requirements would be assessed at the reserved matters stage.

In this context, it is considered that the application proposal would accord with UDP Policies A2, A8 and A10, and the requirements of the National Planning Policy Framework in this regard.

Amenity

UDP Policy DES7 states that development will not be permitted where it would have an unacceptable impact on the amenity of the occupiers or users of other developments. In addition, UDP Policy EN17 seeks to ensure that development does not have a detrimental impact on environmentally sensitive uses such as housing by way of an increase in pollution to the air (including dust pollution), water or soil, or by reason of noise, odour, artificial light or vibration.

The application site adjoins the rear gardens of residential properties along its southern and western boundaries, with the raised landscaped bund serving to separate the site from these residential properties. The majority of these properties are two storey terraced properties, but there is also a row of four bungalows on Crescent Drive which adjoin the site. Along the site’s western boundary the residential properties on Crescent Drive which back on to the site lie approximately 32m from the developable area of the site, taking into account the separation afforded by their rear gardens taken together with the raised landscaped bund. Along the site’s south western boundary the residential properties on Eastham Way which back on to the site lie between approximately 46m and 71m from the developable area of the site, taking into account the separation afforded by their rear gardens taken together with the raised landscaped bund. Along the site’s southern boundary the residential properties on Trafford Drive which back on to the site lie approximately 37m from the developable area of the site, again taking into account the separation afforded by their rear gardens taken together with the raised landscaped bund.

To the north west, the application site adjoins the Brookdale Park travelling showpersons site. Within the Brookdale Park site, the residential properties and pitches occupy the northern part of the site, with that part of

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the site which adjoins the application site being used for the storage of vehicles and fairground rides. The nearest residential pitches on the Brookdale Park site therefore lie approximately 41m from the developable area of the site.

The applicant has submitted section plans as part of the outline application in order to demonstrate the relationship between the proposed scale of units that is defined via the parameters plan and the nearest residential properties. These section plans are based on the three indicative layout options which have been submitted for illustrative purposes and are outlined above. These section plans demonstrate that the raised bunds are typically 4 – 5m above the surrounding ground level, and the trees on the raised bunds currently rise to a height of around 9m, representing a cumulative height of approximately 13 – 14m. In this context, the existing landscaped bunds would serve to provide significant screening to the proposed employment units. Whilst the largest scale of units would exceed this height (with the parameters plan allowing for a building with a maximum eaves height of 19m and a maximum overall height of 22m), in the context of the submitted section plans it is not considered that this scale of development would result in an unacceptable impact on the amenity of the adjoining residential properties. In terms of sunlight, the residential properties predominantly lie to the south and west of the application site and there would therefore be limited potential for impact in terms of shadowing. The detailed treatment of the site in terms of the layout and positioning of buildings would be confirmed at any future reserved matters stage, and on this basis it is considered that the requirements of UDP Policy DES7 could be addressed in terms of ensuring no unacceptable impact on amenity in terms of outlook and light for surrounding residential properties.

Noise pollution

NPPF paragraph 123 states that Local Planning Authorities should avoid granting consent for development which would give rise to significant adverse impacts on health and quality of life, and should mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions.

A noise assessment has been submitted alongside the planning application. In response to a request for further information by the Council’s Air and Noise Consultant, an addendum report was submitted. This was requested in order to demonstrate that noise from on-site operations (loading and unloading activities, movement of heavy goods vehicles etc) will not result in adverse impact to neighbouring residential properties. This is of particular significance given that the outline application seeks an unrestricted permission in terms of hours of operation.

The addendum report utilises computer modelling techniques to demonstrate likely future noise impacts and it broadly confirms that the Council’s expected design noise target is likely to be satisfied when a worst case scenario is adopted (i.e. the Option 3 indicative layout of a large storage and distribution centre). The report makes a number of assumptions (such as the number of HGV movements, site layout, positioning of buildings, use of screen fencing) recognising that the application is in outline and the form and nature of development is not known at this stage. However, working on a worst case scenario it concludes that modelling of the site has shown that predicted noise levels are below the measured background noise level, and with careful consideration given to the site layout, operations and mitigation measures, it is possible for noise levels from any future development at the site to meet the Council’s requirements in this regard. The report also states that further development of the proposed layout and mitigation measures at the reserved matters stage, would allow for development of the mitigation and a lower predicted noise levels at sensitive receptors.

The Council’s Air and Noise Consultant has reviewed the submitted information, and has confirmed that he is satisfied with the evidence provided which indicates that the site can be developed to achieve the Council’s expected noise design target. As such no objection is raised subject to conditions to define the operational noise standard that any future development will be required to meet, and to require submission of a Delivery Yard Management Plan to ensure no unacceptable noise impact arising from the operation of any service / delivery yards associated with future development. The Air and Noise Consultant also requires the submission of a further noise assessment report at any future reserved matters stage in order to ensure that the form and layout of development will not result in any unacceptable impact on neighbouring residential properties. Conditions are recommended in this regard.

Air quality

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NPPF paragraph 120 states that to prevent unacceptable risks from pollution, planning decisions should ensure that new development is appropriate for its location and that the effects of pollution on health, the natural environment or general amenity, should be taken into account.

An air quality assessment report has been submitted alongside the planning application. The application site lies outside of the Air Quality Management Area (AQMA), however, the site is located within close proximity to four existing AQMA areas. The submitted report details the results of an air quality assessment to determine the impact of air quality for existing sensitive receptors in the vicinity of the site. The assessment also considers the impact of dust and particulate matter during the construction phase of the development.

A number of assumptions have been made within the air quality assessment report recognising that the application is in outline for access only, and that the form and nature of future employment development is not known at this stage.

The assessment considers the potential impact of development-generated vehicles on air quality at eleven existing sensitive receptor locations. It predicts that there will be a negligible and not significant impact on concentrations of nitrogen dioxide and particulates at all eleven existing sensitive receptors considered in the 2017 opening year and 2027 future year scenarios, with the development in place. In addition, all predicted pollutant concentrations are below relevant air quality standards for both the ‘without development’ and ‘with development’ scenarios.

The assessment has demonstrated that the proposed development will not lead to an unacceptable risk from air pollution and it concludes that there are no material reasons in relation to air quality why the proposed scheme should not proceed, subject to appropriate planning conditions.

The Council’s Air and Noise Consultant has reviewed the submitted information, and has confirmed that he is satisfied with the conclusions of the assessment report and as such raises no objections. In terms of the construction phase of development, he recommends the submission of a Construction Method Statement to ensure no unacceptable impact on neighbouring occupiers. A condition is recommended in this regard.

As such it is considered that the application proposal would be in accordance with UDP Policies DES7 and EN17.

Land contamination and land stability

NPPF paragraph 121 states that planning decisions should ensure that the proposed site is suitable for its new use taking account of ground conditions and land instability, including from natural hazards or former activities such as mining, pollution arising from previous uses and any proposals for mitigation including land remediation or impacts on the natural environment arising from that remediation.

A Phase 1 Geo Environmental Desk Study has been has been submitted alongside the planning application. The report concludes that the site is considered to present an overall low to moderate risk from past land uses, surrounding land uses, ground instability (from its mining legacy) and contamination. The report recommends an investigation of the geological conditions will be required prior to redevelopment. Made ground is expected to be present including a significant thickness of colliery spoil. Further to this, remedial measures may be necessary depending on the nature and extent of the made ground. The report identifies that a Phase 2 intrusive investigation is likely to be required, to include a geotechnical assessment of the site. The report also concludes that investigation and treatment of past shallow abandoned mine workings will be required before any development is carried out on the site.

The submitted information has been reviewed by the Council’s Land Contamination Officer, who raises no objections to the application proposal subject to recommended conditions requiring a site investigation report to address the land contamination on site, and the submission of further reports regarding the identification and subsequent implementation of appropriate remedial works.

The Coal Authority has also reviewed the submitted information and provided comments on the planning application. The Coal Authority records indicate that within the application site and surrounding area there are coal mining features and hazards, specifically historic recorded underground coal mining at shallow depth, likely historic unrecorded underground coal mining at shallow depth and recorded mine entries (shafts). The Coal Authority identifies that it would therefore expect any future reserved matters application relating to the site

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layout to be informed by intrusive site investigations as recommended within the Phase 1 report, to avoid the siting of buildings over or within influencing distance of any recorded mine entry, and that appropriate stabilisation works may be required dependent on the results of the intrusive investigation.

On this basis, the Coal Authority raises no objection to the application proposal subject to recommended conditions regarding the undertaking of intrusive site investigations for mine entries and shallow coal workings, the submission of a layout plan with any future reserved matters application which identifies appropriate zones of influence for any recorded mine entries and the definition of suitable no build zones, and the submission of a scheme for the treatment of any recorded mine entries and remedial works for any shallow coal workings, and its subsequent implementation.

Flood risk and drainage

NPPF paragraph 103 indicates that local planning authorities, when determining planning applications, should ensure flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where it can be demonstrated that the most vulnerable development is located in areas of lowest flood risk, and where development is appropriately flood resilient and resistant.

A Flood Risk Assessment and Conceptual Drainage Strategy has been submitted alongside the planning application. This confirms that the site is located within Flood Zone 1 (Low Probability) and that the risk of fluvial flooding, sewer flooding, and ground water flooding to the site is considered to be low. The document identifies that flood risk management measures will be put in place to ensure that the risk of flooding to areas downstream of the site is not increased as a result of the development, to include a surface water drainage strategy that will mimic greenfield performance for a range of storm events. It confirms that surface water will be discharged at a restricted rate to the United Utilities public surface water sewer in Ravenscraig Road, and on-site attenuation will be provided to accommodate flows up to and including the 1 in 100 year storm event, including an appropriate allowance for climate change and will be regulated by a system of flow controls and Sustainable Drainage Systems (SuDS) including swales, detention basins and permeable paving.

The submitted information has been reviewed by the Council’s Drainage Engineer. They consider that the proposals are acceptable in terms of this outline planning application in terms of principle and indicate that the Strategic Flood Risk Assessment requirements will be met. Calculations for green field runoff and storage required to restrict runoff to the required rate have been provided. Hydraulic calculations for the final drainage scheme are not yet available but will be developed during the detailed design phase.

The detailed approach to drainage will be confirmed at any future reserved matters stage and a condition is recommended requiring future submission of a detailed strategy for surface water drainage that is in accordance with the submitted conceptual drainage strategy. The Drainage Engineer has advised that this should incorporate an acceptable final drainage layout drawing with accompanying hydraulic calculations to demonstrate the sizing of pipes, discharge rates, no flooding in a 1 in 30 year event and no internal flooding in a 1 in 100 year plus climate change event.

As such, it is considered that the application proposal is acceptable in accordance with the requirements of UDP Policies EN18 and EN19 and the requirements of the NPPF in this regard.

Biodiversity

The NPPF states that the planning system should contribute to and enhance the natural and local environment by recognising the wider benefits of ecosystem services, minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity.

A series of reports have been submitted alongside the planning application, including a Preliminary Ecological Appraisal, a Reptile Survey Report, a Breeding Bird Survey Report, a Botanical Survey, and a Bat Survey Report. The Preliminary Ecological Appraisal identified that the application site has the potential to support a number of protected species which will require more detailed consideration, and this informed the commissioning of the various species reports.

The Bat Survey Report confirms that although the habitats on site were assessed to be of medium quality for foraging bats and the site is well ecologically connected for bats, there is a disproportionately low number of

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bats recorded using the site. It is considered that the proposed removal of marshy grassland / rush pasture habitats on the site will not adversely impact on the nature conservation value for bats within the local area. The report recommends that the integrity of the trees and vegetation on the raised bunds should be maintained in order to ensure that the community habitat on site is not compromised, so that the site may continue to act as a valuable corridor for bats to utilise to disperse into the wider landscape.

The Botanical Survey concludes that the proposed development will not lead to the loss of any nationally or county notable habitats, but that the site does contribute to the local biodiversity resource. The proposed development of the site has the potential to secure the ongoing presence and management of the more diverse wetland plant communities on the site and recommends that such habitats can be successfully incorporated into the proposed development as part of SuDS and/or landscaping proposals.

The Breeding Bird Survey identifies that the site currently supports a range of breeding wetland and woodland birds, including 18 Birds of Conservation Concern species and 8 UK Biodiversity Action Plan listed species. The site is defined as being less than local significance in relation to breeding birds. In terms of important habitats within the site the most significant for breeding birds are the areas of marshy grassland and scrub. Mitigation measures are recommended to incorporate these habitat types into the proposals if development takes place, and should outline proposals for habitat incorporation into the scheme, with an emphasis on providing areas of marshy grassland and scrub habitats on site. Areas for potential habitat retention or re-creation are wetland SuDS features and other incidental landscaping buffer zones around the development. The report also advises that any works that require vegetation clearance should be timed to avoid the bird nesting season and that if this is not possible then areas of vegetation clearance should be checked by a suitably qualified ecologist 24 hours in advance of works for the presence of occupied nests.

The Reptile Survey Report identifies that reptiles are likely absent from the study area, and therefore no further survey work is recommended. It does however identify that should reptiles be found during site clearance activities, work should stop and a suitability qualified and experience ecologist contacted to provide guidance on the way forward.

The submitted documents have been reviewed by Greater Manchester Ecology Unit (GMEU). They raise no objection to the application on ecological grounds as the developable area is not considered to be of substantive nature conservation value, it does not support habitats of significant nature conservation value, and it is considered to have only low potential to support any specially protected or priority species. GMEU recognise that the vegetated bund surrounding the site has some local nature conservation value, and the site has some local value for nesting birds. They recommend that works to or the removal of trees should not take place within the main bird breeding season and that trees and vegetation on the bund be suitably protected during the course of any groundworks and future construction activity. They also encourage the provision of SuDS schemes as part of any future development on the basis that this could enhance the site’s value for wildlife. In terms of the recommendation regarding works to trees / vegetation taking place outside the bird breeding season, an informative has been attached in this regard. In terms of tree protection measures during groundworks and any future construction, this is addressed in the section below and a condition is recommended in this regard. In terms of the recommendations regarding areas for potential habitat retention or re-creation such as wetland SuDS features and other incidental landscaping buffer zones, this would be addressed at any future reserved matters stage where the site layout and landscaping arrangements are to be defined and the applicant is strongly encouraged to have regard to this advice in developing any future reserved matters application.

Trees

An Arboricultural Survey has been submitted alongside the planning application. The survey has identified a group of category B trees which are entirely located on the landscape bunds around the perimeter of the site. Individually the trees would be classed as Category C trees (Low amenity value). However, collectively they have a Category B grading (Moderate amenity value). Two individual trees on the site (T1 and T2) have been identified as Category C grading (Low Amenity Value). Given the location of tree T2 on the access point it is likely that this tree will have to be removed to facilitate redevelopment of the site. This would be confirmed at any future reserved matters stage where the site layout is to be defined. It is the applicant’s intention that the majority of trees located on the bunding would be retained as part of the proposed development with the thinning of species to take place over a 10 – 15 year period as required. The remainder of the site which comprises the developable area of the site contains self-seeded scrub / saplings which are below the threshold

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for categorising and this part of the site would be cleared to allow for the removal of peat / clay as part of the groundworks.

The Council’s Aboricultural Consultant has reviewed the submitted documents and considers that the Arboricultural Survey and Tree Location and Constraints Plan provides sufficient information to determine this outline application, with a detailed Arboricultural Impact Assessment or Tree Protection Plan to be submitted at the reserved matters stage. Conditions are recommended requiring the implementation of tree protection measures to protect the existing trees to be retained, the implementation of works in accordance with the submitted Arboricultural Constraints Report, and the submission and implementation of a replacement planting scheme for the trees that are to be removed.

Sustainability

The Sustainable Design & Construction SPD seeks to encourage new development to improve its impact on the environment and to build into proposals a design that maximizes the sites potential, utilizes green technologies and ensures the users employ a sustainable pattern of travel.

As the application is in outline for access only with all other matters reserved, the detailed approach to sustainability measures will be confirmed at any future reserved matters stage. In relation to the submitted documents, the applicant has confirmed through the conceptual drainage strategy that on-site attenuation will be provided to accommodate surface water flows and will be regulated by a system of flow controls and Sustainable Drainage Systems (SuDS) including swales, detention basins and permeable paving. These sustainable drainage solutions will present the opportunity for biodiversity related benefits through potential habitat retention or re-creation, in line with the recommendations of Greater Manchester Ecology Unit in this regard. The applicant has also confirmed that the raised bunds which surround the site and provide a range of biodiversity benefits through the mature trees and vegetation which line them would be retained.

Planning obligations

UDP Policy DEV5 identifies that development that would result in a material increase in the need or demand for infrastructure, services, facilities and/or maintenance will only be granted planning permission subject to planning conditions or planning obligations that would ensure adequate mitigation measures are put in place.

The Planning Obligations SPD identifies that for development comprising 1,000 square metres or more of non-residential floorspace, the city council will seek a transport contribution (Policy OB5) and a public realm contribution (Policy OB6) having regard to site specific circumstances.

In relation to the proposed development, a contribution of £224,000 towards walking / cycling improvements in the surrounding area is considered necessary to mitigate the impact of the development in accordance with the tests for planning obligations set out in Regulation 122 of the Community Infrastructure Levy Regulations 2010 (as amended). This financial contribution would be directed towards the delivery of two projects designed to support sustainable travel and access to employment opportunities across the Little Hulton area, and would specifically fund provision of a toucan crossing on the A6 and improvements to the former mineral loopline between the A6 and Roe Green Loopline (NCN 55).

In relation to commercial development, paragraph 4.27 of the Planning Obligations SPD makes clear that where an applicant considers that a scheme would not be able to support the scale of contributions that the city council considers is necessary to make the development acceptable in planning terms, the developer will be required to submit viability evidence to demonstrate why this scale of contributions could not be supported.

The applicant has submitted viability evidence as they consider that the proposed development is unviable and would be reliant on public subsidy / grant funding, and as such would be unable to support any planning obligation contribution. The submitted viability evidence is on the basis of the indicative Option 1 scheme, which is considered to offer the highest development values. The viability evidence has been independently assessed by Urban Vision’s Property team. They have confirmed that the scheme generates a substantial cost deficit, which would require some form of public subsidy to make the development viable.

In the context of the position on scheme viability, it is not considered appropriate to secure a planning obligation contribution having regard to the Planning Obligations SPD and the National Planning Policy Framework in this regard.

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Conclusion and planning balance

The application site is effectively allocated for employment purposes within the development plan under the provisions of UDP Policy MX3/1 – Sites for a Mix of Open Space and Built Development, given that the remainder of the site has been delivered as public open space. In addition, the principle of employment development on the site has been established by previous consents. The Council’s technical advisers have confirmed that subject to appropriate conditions, the proposal would result in no unacceptable impact in terms of highways, air and noise, land contamination, flood risk and drainage, or biodiversity. The proposal has the potential to deliver significant economic benefits in terms of the creation of local employment opportunities and associated spin off economic benefits. In relation to planning obligations, the independent assessment of the submitted viability evidence confirms that the scheme generates a substantial cost deficit and would require some form of public subsidy, and as such is not able to support a planning obligation contribution. As such, the application is considered to accord with the relevant provisions of the development plan and represents sustainable development in accordance with the provisions of the National Planning Policy Framework.

Time period for submission of reserved matters

Under section 92 of the Town and Country Planning Act 1990, outline planning permission should be made subject to conditions imposing two types of time limit, one within which applications must be made for the approval of reserved matters and a second within which the development itself must be started. The national planning practice guidance states that a local planning authority may use longer or shorter periods where they consider it appropriate on planning grounds, but must clearly give their justification for doing so. The applicant has submitted a development programme and additional information in order to justify a longer period for the submission of reserved matters than the standard three year time limit. The applicant intends to bring the site forward in a number of phases. They anticipate that a reserved matters application would come forward for upfront enabling works to create a development ready platform, and following this and in response to market demand, they anticipate the submission of a reserved matters application for a first phase of development. Reserved matters applications for further phases would be developed following the completion and occupation of the first phase. On the basis of this programme and the history of the site in terms of previous development schemes not having been forthcoming, the applicant makes a robust case for an extended period for the submission of reserved matters. Having regard to this, together with the site’s allocation within the UDP for employment purposes, and the fact that the site has not been brought forward for development to date despite its longstanding allocation for employment development within the adopted development plan, it is considered that allowing a period of five years from the date of any outline consent for the submission of reserved matters would be appropriate in relation to this particular application, having regard to the national planning practice guidance.

Recommendation

Planning permission be granted subject to the following planning conditions:

1 Application for approval of reserved matters shall be made not later than the expiration of five yearsbeginning with the date of this permission and the development must be begun not later than the expiration of two years from the final approval of the reserved matters, or, in the case of approval on different dates, the final approval of the last such matter to be approved.

Reason: Required to be imposed pursuant to Section 92 of the Town and Country Planning Act 1990.

2 Details of the following reserved matters shall be submitted to and approved in writing by the Local Planning Authority before any phase of the development is implemented. The development shall be carried out in accordance with the approved details:a) Layoutb) Scalec) Appearanced) Landscaping

Reason: To accord with the provisions of the Town and Country Planning Act (General DevelopmentProcedure Order) 1995 as amended and to enable the Local Planning Authority to retain adequate control over the proposed development.

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3 The development hereby permitted shall be carried out in accordance with the following approved plans:Parameters Plan – Drawing No 2015-061/102 Rev FMeans of Access Plan – Drawing Number NEA1451-001 Rev A

Reason: For the avoidance of doubt and in the interests of proper planning.

4 Any application for approval of reserved matters for any plot(s) or building(s) shall be in general conformity with the Parameters Plan (Drawing No 2015-061/102 Rev F) approved as part of this permission.

Reason: To safeguard the visual appearance and character of the area and ensure no unacceptable impact on the amenity of neighbouring properties in accordance with Policies DES1 and DES7 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

5 No development shall take place, including any works of excavation or demolition, until a Construction Method Statement has been submitted to, and approved in writing by, the local planning authority. The approved Statement shall be adhered to throughout the construction period. The Statement shall include: i) the times of construction activities on site which, unless agreed otherwise as part of the

approved Statement, shall be limited to between 8am-6pm Monday to Friday and 9am-2pm Saturday only (no working on Sundays or Bank Holidays). Quieter activities which are carried out inside buildings such as electrical works, plumbing and plastering may take place outside of agreed working times so long as they do not result in significant disturbance to neighbouring occupiers;

ii) the spaces for and management of the parking of site operatives and visitors vehicles;iii) the storage and management of plant and materials (including loading and unloading

activities); iv) the erection and maintenance of security hoardings including decorative displays and facilities

for public viewing, where appropriate; v) measures to prevent the deposition of dirt on the public highway;vi) measures to control the emission of dust and dirt during demolition/construction; vii) a scheme for recycling/disposing of waste resulting from demolition/construction works; viii) measures to minimise disturbance to any neighbouring occupiers from noise and vibration,

including from any piling activity;ix) measures to prevent the pollution of watercourses; andx) a community engagement strategy which explains how local neighbours will be kept updated

on the construction process, key milestones, and how they can report to the site manager or other appropriate representative of the developer, instances of unneighbourly behaviour from construction operatives. The statement shall also detail the steps that will be taken when unneighbourly behaviour has been reported. A log of all reported instances shall be kept on record and made available for inspection by the local a planning authority upon request.

Reason: In the interests of the amenity of neighbours in accordance with Policies DES7 and EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

6 Prior to the submission of any reserved matters application, a scheme of intrusive site investigations for mine entries and shallow coal workings shall be submitted to and approved in writing by the Local Planning Authority. The works shall be implemented in accordance with the details approved in writing by the Local Planning Authority.

Reason: In the interests of land stability in accordance with the requirements of the National Planning Policy Framework.

7 Any application for the approval of reserved matters for any plot(s) or building(s) shall be accompanied by:

i. The submission of a report of findings arising from both of the intrusive site investigations, including the results of any gas monitoring undertaken;

ii. The submission of a layout plan which identifies appropriate zones of influences for the recorded

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mine entries on site, and the definition of suitable ‘no-build’ zones;iii. The submission of a scheme of treatment for the recorded mine entries for approval; andiv. The submission of a scheme of remedial works for the shallow coal workings for approval.

Reason: In the interests of land stability in accordance with the requirements of the National Planning Policy Framework.

8 Prior to the commencement of the development of any plot(s) or building(s), a Verification Report shall be submitted to, and approved in writing by, the Local Planning Authority. The Verification Report shall validate that all remedial works undertaken on site with regard to land stability were completed in accordance with those agreed by the Local Planning Authority.

Reason: In the interests of land stability in accordance with the requirements of the National Planning Policy Framework.

9 Notwithstanding any information submitted with the application, no development shall take place until an investigation and risk assessment has been submitted to and approved in writing by the Local Planning Authority. The assessment shall investigate the nature and extent of any contamination on the site (whether or not it originates on the site). The assessment shall be undertaken by competent persons and a written report of the findings submitted to and approved in writing by the Local Planning Authority before any development takes place. The submitted report shall include:

i) a survey of the extent, scale and nature of contamination

ii) an assessment of the potential risks to:

* human health, * property (existing or proposed) including buildings, crops, livestock, pets, woodland, and service lines and pipes,* adjoining land,* groundwaters and surface waters,* ecological systems, * archaeological sites and ancient monuments;

iii) where unacceptable risks are identified, an appraisal of remedial options and proposal of the preferred option(s) to form a remediation strategy for the site.

The development shall thereafter be carried out in full accordance with the duly approved remediation strategy.

Reason: To prevent pollution of the water environment and to ensure the safe development of the site in the interests of the amenity of future occupiers in accordance with Policy EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

10 Persuant to condition 9; and prior to first use or occupation a verification report, which validates that all remedial works undertaken on site were completed in accordance with those agreed with the Local Planning Authority, shall be submitted to and approved in writing by the Local Planning Authority.

Reason: To prevent pollution of the water environment and to ensure the safe development of the site in the interests of the amenity of future occupiers in accordance with Policy EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

11 Prior to the commencement of the development of any plot(s) or building(s), the full design and construction details for the highway works listed below shall be submitted to and approved in writing by the Local Planning Authority. Prior to the commencement of the development of any plot(s) or building(s), the applicant will enter into an agreement with Salford City Council under S278 of the Highways Act 1980 to secure the required highway works. The works shall be implemented prior to the first occupation of any plot(s) or building(s). The highway works are:i) Provision of a new footway / cycleway along Ravenscraig Road to provide a continuous link from

the site access to the existing footway / cycleway on Ravenscraig Road.

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ii) Installation of dropped kerb crossings where appropriate.iii) Works required to maintain suitable visibility splays for the easternmost highway access point off

Ravenscraig to the existing employment premises.

Reason: To ensure the safe operation of the highway network in accordance with Policies ST5, A2 and A8 of the City of Salford Unitary Development Plan.

12 Any application for approval of reserved matters for any plot(s) or building(s) shall be accompanied by an assessment of noise likely to affect surrounding sensitive uses. The assessment shall cover both the construction phase and the operational phase of the development and shall assess and recommend appropriate noise mitigation measures. The development shall be implemented in accordance with the details approved in writing by the Local Planning Authority.

Reason: To safeguard the amenity of surrounding residential properties in accordance with Policy EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

13 Any application for the approval of reserved matters for any phase within the development hereby approved shall be accompanied by a 'Crime Prevention Plan' [CPP] for that phase which shall examine all aspects of site security including, site car parking, pedestrian footways, entrances, internal layout and external security measures for that plot and which shall be capable of meeting 'Secured by Design' requirements. Development of that phase shall be carried out in accordance with the approved CPP and any approved site security measures shall be retained thereafter.

Reason: To ensure that the development is appropriately secured from crime in accordance with policy DES 10 of the City of Salford Unitary Development Plan.

14 No development of any plot(s) or building(s) shall take place until a detailed strategy for surface water drainage of the site that is in accordance with the Flood Risk Assessment and Conceptual Drainage Strategy (Wardell Armstrong, September 2016, Document ST14558), has been submitted to and approved in writing by the Local Planning Authority. The approved strategy shall be implemented prior to the first occupation of any plot(s) or building(s) unless alternative timescales have been agreed in writing as part of the strategy.

Reason: To ensure a satisfactory method of surface water disposal to reduce the risk of flooding elsewhere in accordance with Policy EN19 of the City of Salford Unitary Development Plan and seeks to provide betterment in terms of water quality and surface water discharge rates and meets requirements set out in the following documents; NPPF, Water Framework Directive and the NW River Basin Management Plan The national Planning Practice Guidance and the Non-Statutory Technical Standards for

Sustainable Drainage Systems (March 2015) Manchester, Salford, Trafford Strategic Flood Risk Assessment (SFRA) (2011) and associated

technical guidance Environment Agency Pollution Prevention Guidelines (now withdrawn) Flood Risk Assessment/SuDS Requirements for new developments (Salford's SuDS Checklist)

15 Prior to the commencement of the development of any plot(s) or building(s), a Delivery Yard Management Plan shall be submitted for the written approval of the Local Planning Authority. The Plan shall identify the delivery operations and activities which generate noise and further identify the control measures to mitigate that noise. Once in place, all identified measures shall be implemented and maintained thereafter unless otherwise agreed by the Local Planning Authority.

Reason: To safeguard the amenity of surrounding residential properties in accordance with Policy EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

16 The development of any plot(s) or building(s) shall be implemented to ensure that drainage from areas accessed by vehicles shall pass through an oil separator or equivalent SuDS process.

Reason: To ensure a satisfactory method of surface water disposal and reduce the risk of

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environmental pollution in accordance with Policies EN17, EN18 and EN19 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

17 No above ground construction works shall take place until samples or full details of materials to be used externally on the building(s) have been submitted to and approved in writing by the Local Planning Authority. Such details shall include the type, colour and texture of the materials. The development of the plot(s) or building(s) shall be constructed using the approved materials.

Reason: In order to ensure a satisfactory appearance in the interests of visual amenity in accordance with Policy DES1 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

18 No development shall be started until all the retained trees within (or overhanging) the site (as shown on Tree Constraints Plan No: ST14558-003 Rev. B dated 27-05-2016), have been surrounded by substantial fences. Such fences shall be erected in accordance with the fence specification submitted in the report (Arboricultural Constraints Report (June 2016) ref: ST14558-001) in the positions as shown on Tree Constraints Plan No: ST14558-003 Rev. B dated 27-05-2016 and shall remain until all development is completed and no work, including any form of drainage or storage of materials, earth or topsoil shall take place within the perimeter of such fencing.

Reason: To safeguard trees within the site and to ensure adequate protection is in place in accordance with Policies EN12 of the City of Salford Unitary Development Plan.

19 No development shall commence unless and until an Arboricultural Method Statement has been submitted and agreed in writing by the Local Planning Authority (AMS). The development shall be carried out in accordance with the approved AMS.

Reason: To safeguard trees within the site and to ensure adequate protection is in place in accordance with Policies EN12 of the City of Salford Unitary Development Plan.

20 The felled trees shall be replaced in accordance with a tree replacement scheme which shall be submitted to and approved in writing by the Local Planning Authority. The scheme shall be submitted prior to the first occupation of any plot(s) or building(s), and shall include details of: tree species; tree sizes (including the minimum height and circumference of stem at 1m from the ground level); plan indicating the location of the replacement trees, a timetable for tree planting and details of aftercare.

Reason: To protect the visual amenity value of the landscape in accordance with Policy EN12 of the City of Salford Unitary Development Plan.

21 a) Notwithstanding the details shown on the approved plans, the development hereby permitted shall not be occupied until full details of both hard and soft landscaping works have been submitted to and approved in writing by the Local Planning Authority. The details shall include the formation of any banks, terraces or other earthworks, hard surfaced areas and materials, boundary treatments, external lighting, planting plans, specifications and schedules (including planting size, species and numbers/densities), existing plants / trees to be retained and a scheme for the timing / phasing of implementation works.

(b) The landscaping works shall be carried out in accordance with the approved scheme for timing / phasing of implementation or within 18 months of first occupation of the development hereby permitted, whichever is the later.

(c) Any trees or shrubs planted or retained in accordance with this condition which are removed, uprooted, destroyed, die or become severely damaged or become seriously diseased within 5 years of planting shall be replaced within the next planting season by trees or shrubs of similar size and species to those originally required to be planted, unless the Local Planning Authority gives its consent in writing to any variation.

Reason: To ensure that the site is satisfactorily landscaped having regard to its location and the nature of the proposed development and in accordance with Policies DES1 and DES9 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

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22 Within three months of first occupation of any plot(s) or building(s), an updated Travel Plan shall be submitted to and approved in writing by the Local Planning Authority. The Travel Plan should be designed to raise awareness of opportunities for reducing staff travel by car and should feature a range of measures and initiatives promoting a choice of transport mode, and a clear monitoring regime with agreed targets. The agreed Travel Plan shall be implemented and reviewed in accordance with the timetable set out within the Travel Plan.

Reason: To ensure that the travel arrangements to the development are appropriate and to limit the effects of the increase in travel movements in accordance with Policy A8 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

23 The rating level (LAeq,T) from all activities, including plant and machinery, associated with the development, when operating simultaneously, shall not exceed the background noise level (LA90,T) by more than -5 dB at any time when measured at the boundary of the nearest noise sensitive premises. Noise measurements and assessments shall be carried out according to BS 4142:2014 "Methods for rating and assessing industrial and commercial sound". ‘T’ refers to any 1 hour period between 07.00hrs and 23.00hrs and any 15 minute period between 23.00hrs and 07.00hrs.

Reason: To safeguard the amenity of surrounding residential properties in accordance with Policy EN17 of the City of Salford Unitary Development Plan and the National Planning Policy Framework.

Notes to Applicant

1. STANDING ADVICE - DEVELOPMENT LOW RISK AREA

The proposed development lies within a coal mining area which may contain unrecorded coal mining related hazards. If any coal mining feature is encountered during development, this should be reported immediately to the Coal Authority on 0345 762 6848.

Further information is also available on the Coal Authority website at: www.gov.uk/government/organisations/the-coal-authority

This Standing Advice is valid from 1st January 2017 until 31st December 2018

2. Under the Coal Industry Act 1994 any intrusive activities, including initial site investigation boreholes, and/or any subsequent treatment of coal mine workings/coal mine entries for ground stability purposes require the prior written permission of The Coal Authority, since such activities can have serious public health and safety implications. Failure to obtain permission will result in trespass, with the potential for court action. In the event that you are proposing to undertake such work in the Forest of Dean local authority area our permission may not be required; it is recommended that you check with us prior to commencing any works. Application forms for Coal Authority permission and further guidance can be obtained from The Coal Authority’s website at: www.gov.uk/get-a-permit-to-deal-with-a-coal-mine-on-your-property

Building over or within the influencing distance of a mine entry (shaft or adit) can be dangerous and has the potential for significant risks to both the development and the occupiers if not undertaken appropriately. The Coal Authority would draw your attention to our adopted policy regarding new development and mine entries: www.gov.uk/government/publications/building-on-or-within-the-influencing-distance-of-mine-entries

3. If, during any works on site, contamination is suspected or found, or contamination is caused, the LPA shall be notified immediately. Where required, a suitable risk assessment shall be carried out and/or any remedial action shall be carried out in accordance to an agreed process and within agreed timescales in agreement with the LPA.

4. The existing trees and vegetation on the site have potential to support nesting birds. Please note that if there are nesting birds it will be important that any works to, or removal of, trees and shrubs is not

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carried out between March and July inclusive in order to avoid any potential offence under the Wildlife and Countryside Act 1981.

5. All requests for information regarding the adopted highway network shall be directed to the Local Highway Authority via John Horrocks T: 0161 603 4046 / E: john.horrocks@urbanvision.org.uk No boundary fencing shall be erected or positioned on any part of the adopted highway without first seeking the relevant permits/licenses from the Local Highway Authority.

6. Any internal highways which are proposed to be offered for adoption via a S38 agreement should include the following: Minimum carriageway width of 7.3m Minimum footway width of 2.0m The current adopted Ravenscraig Road consists of a joint cycle/footway of 3.0m wide – discussion

will be required with the Local Highway Authority in terms of the requirement to continue this arrangement within the site or increase the width of the joint cycle/footway.

Construction specification of carriageway to be agreed dependent upon existing ground conditions and proposed traffic loadings.

Layout of proposed adopted carriageway to be agreed, including the requirement for turning heads suitable for industrial vehicles.

Highway drainage to be discharged into a United Utilities adopted sewer. Carriageway to be lit to adoptable standards. Any gated access into proposed units to ensure vehicles can be accommodated off the proposed

adopted highway whilst waiting for access into the units. Traffic Regulation Orders required to ensure all proposed adopted highways are kept clear of

parked vehicles. Road Safety Audits required for any proposed adopted highways.

7. Any future reserved matters application should incorporate marshy grassland and scrub habitats on site as part of wetland SuDS features and other incidental landscaping buffer zones within the site in order to provide mitigation for the loss of these existing habitats as part of any future development.