Draft Objection letter template
Draft letter of objection
To the Planning Department at Blackburn with Darwen,
Re: Outline Planning Application No: 10/23/1075
Location: Land East of M65 and North of Haslingden Road, Blackburn
We are writing to formally object to the outline planning permission that has been submitted by Monte Blackburn to develop 7 units on the moorland fringe at Guide/Belthorn.
As a community, we have set out our very real concerns at local plan stage as to how the supporting infrastructure is not suitable to support an employment site of this magnitude. We have set out concerns regarding the extremely negative impact that the development would have both on the surrounding landscape and residential amenity. We have set out our concerns in relation to the impact the site will have on local ecology and wildlife. Such concerns still remain and our reasons for objection are highlighted once again below.
Continued Highway Concerns:
The level of analysis of the B6232 is inadequate and there remains to be a complete lack of foresight as to how this development will impact this stretch of road in particular. The B6232 is at a standstill at peak times with traffic queueing regularly in both directions – both when approaching and leaving junction 5. This as a result, has a direct impact upon the village of Belthorn as cars regularly cut through the village to try to avoid long delays when approaching Junction 5 from Haslingden. Recently, this has been exacerbated even further as commuters are seeking to avoid queuing on the B6232 heading East towards Haslingden and are now cutting through the village in the opposite direction. It is accepted that at peak times the village should expect to see an increase in traffic but this is already unsustainable, with some residents reporting being stuck outside their properties for extremely long periods of time.
There are also serious health and safety concerns regarding the school as the congestion leads to people parking their vehicles dangerously. The bus is unable to pass through the village, often having to drive on pavements in order to get through which is extremely dangerous for those children accessing the school by foot. Councillors are aware of this as residents have made a number of complaints, sent in letters and video footage, yet nothing seems to be done. It is undeniable that the development of the site will only exacerbate this further.
To date there has been no mitigation or solution proposed for the traffic that regularly queues heading East towards Haslingden – the traffic often queues from Junction 5 and we feel that this is being totally ignored. Whilst it is accepted that junction improvements are needed to improve traffic flow, we still maintain the position that amendment would be needed to the B6232 in the future to alleviate these problems and that it will ultimately lead to the destruction of peat and SSSi land. Traffic data collected by the council shows an increase of roughly 10,000 extra vehicles using the road every ten years (currently 21,500 predicted to be roughly around 25000 by 2026). Given that it is a single B track road, in the long term, it would not sustain any more traffic without the need to amend. We have asked agencies involved on numerous occasions for assurances that developing this site would not lead to the destruction of peat but we are still yet to receive this assurance.
Looking at the above holistically, it is undeniable that there is a direct correlation between the number of drivers utilising the B6232 and the level of congestion within the village. As vehicle numbers increase in order to access to the site for employment, so will the levels of congestion within the village and the current level of traffic is not manageable as it is. The junction improvements will somewhat improve traffic flow but the plans to install traffic lights just a few hundred yards East of Junction 5 will simply re-create the problems we face now but further up, stifling traffic flow on the B6232.
We have serious concerns on how these units will impact on the amenity of nearby residents. Monte Blackburn issued a pre-consultation document to residents asking for their comments and concerns. Many responded to the consultation requesting a buffer zone, yet within the landscape assessment presented, the first set of units are to be positioned only 50m away from near-by properties demonstrating that as predicted, the developer is paying lip-service to consultation and has failed to engage and work with the community. We ask that the council seriously consider how detrimental approving these plans would be on those who are most closely situated to the site. If such plans are approved, will compensation be payable to those who bought their properties surrounded by greenbelt, who are now expected to live only 50m from B-sheds?
We also have serious concerns with regards to the developer submitting retrospective planning applications. This is a substantiated concern given that the developer has a previous track record of breaching conditions that have been previously agreed. Can the council confirm that action will be taken against the developer should they attempt to do the same again? Such breaches have an extremely detrimental impact upon residents and their day to day lives. As if living next to industrial units is not difficult enough, without the constant worry that they will be larger and even more intrusive on people’s homes and the surrounding environment. We need concrete assurances that this will not happen on this site, like it has done so many times before in the past.
The land is located 1.5km away from the West Pennine moor SSSI and as such is within an impact risk zone. Any development on this site will negatively affect this protected area and will need full assessment and consultation with Natural England to consider and mitigate against potential ecological impacts on west Pennine moors SSSI.
This site contains sensitive ecology as it is foraging habitat for barn owls, peregrine small eared owl and kestrel. Part of the site meets biological heritage site criteria although it does not have BHS status.
The fact that it meets this criterion needs to be taken into consideration. The negative impact from this development will displace red listed breeding waders within a minimum radius of 0.5km. There is evidence that part of the southeast of this site is habitat and breeding ground for rare and vulnerable species such as ground nesting lapwing, red listed skylark, linnets, meadow pipits, curlew and grey partridge which nest on and around this site especially around the South-Eastern corner. Removal of the grassland will result in loss of habitat and permanent displacement due to the creation of a predatory environment.
Dust, fuels, chemicals and light pollution will affect the long-term development of plants and hedgerows on site, contrary to Protecting Hedgerows Regulations 1997.
Bats are roosting in the main farmhouse at Blackhill farm and the outbuildings. The land has also been identified as a foraging and commuting ground for them. Removal of buildings and bat trees will result in the death of bats which are protected by law under Wildlife and Countryside Act 1981 and Conservation of Habitats and Species Regulations 2017.
Brown hare and hedgehogs are also breeding on site and protected under The Wild Mammals Protection Act 1996.
Footpaths are surrounding this area and some of these footpaths are being destroyed by the placement of industrial units as identified in the plan. Footpaths are protected under countryside and rights of Way Act 2000.
Without prejudice to our position of objection, should the site proceed we request footpaths are preserved and protected from the view of the industrial units by extending the hedgerows. No development takes place within 0.5km of the habitat of red listed ground nesting birds. Buildings containing bat roosts are left undisturbed Consultation and further surveys are carried out by Naturel England and Lancashire Wildlife Trust. Small mammal friendly features are added to the plan to maintain connectivity with the small mammal habitat. No works take place within the breeding season. Steps are taken to reduce light, dust and chemical pollution on the site.