ib3 ~7tgl katherine howarth - borough of chorleychorley.gov.uk/documents/planning/examination...

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Ib3 ~7tgl Katherine Howarth From: Sent: 15 July 2014 21:11 To: Planning.Policy Mr D & I O'Malley, Re :Cowling Farm Gypsy And Traveller Preferred Option• Dear Sir /Madam, having resided in the cowling area for over 10 years we are concerned with the lack of consultation and information with regards to the proposed site for the Gypsy and Traveller community. Having moved to the Cowling area for the picturesque views, quiet location and community environment we feel that this is now under threat and therefore we object to the Chorley Planning proposal to use Cowling Farm as their preferred site for the Gypsy /Traveller community for the following reasons: Although several sites have been identified, Chorley planning report appears to be biased towards the Cowling site compared to other sites and we feel that the assessments completed on all sites are not up to date information in relation to bus service, education, traffic and also conflictions in relation to green belt. We strongly recommend that Chorley planning review there processes and procedures and look to sites more suitable for the Gypsy /Travelling community on existing brown field sites and or more accessible sites with nearby facilities that fit the criteria. Yours sincerely D & I O'Malley

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  • Ib3~7tgl

    Katherine Howarth

    From:

    Sent: 15 July 2014 21:11

    To: Planning.Policy

    Mr D & I O'Malley,

    Re :Cowling Farm Gypsy

    And Traveller Preferred

    Option•

    Dear Sir/Madam,

    having resided in the cowling area for over 10 years we are concerned with the

    lack of consultation and information with regards to the proposed site for the Gypsy and Traveller

    community. Having moved to the Cowling area for the picturesque views, quiet location and

    community environment we feel that this is now under threat and therefore we object to the

    Chorley Planning proposal to use Cowling Farm as their preferred site for the Gypsy/Traveller

    community for the following reasons:

    Although several sites have been identified, Chorley planning report appears to be biased

    towards the Cowling site compared to other sites and we feel that the assessments completed on

    all sites are not up to date information in relation to bus service, education, traffic and also

    conflictions in relation to green belt.

    We strongly recommend that Chorley planning review there processes and procedures and look to

    sites more suitable for the Gypsy/Travelling community on existing brown field sites and or more

    accessible sites with nearby facilities that fit the criteria.

    Yours sincerely

    D & I O'Malley

  • ~tT~$~

    Katherine Howarth

    From:

    Sent: 151u1y 2014 22:17

    To: Planning.Policy

    Subject: Gypsy, Traveller &Travelling Show People Preferred Options Documen

    Hello,

    Please see my comments regarding the potential Gypsy, Traveller &Travelling Show People Preferred

    Options Document and the Yarrow Bridge, Bolton Road, Chorley PR7 4AB.

    believe the Bolton Road Site is unsuitable for the following reasons:-

    1. A bus stop is located directly in front of the entrance to the site. This will cause issues regarding traffic if a

    bus is blocking the entrance and a vehicle is turning into the site. Due to the increase in house building in the

    area the traffic has considerably increased during peak hours it is not uncommon for traffic to be backed up

    from Chorley or from Heath Charnock so any additional traffic will have an adverse effect.

    Due to the bus stop also being located near two schools it could increase the possibility of an accident as the

    site access will be in use at all times.

    2. The site is on Green Belt land which should be preserved as per Government guidelines.

    3. There has been three large housing developments off Little Carr Lane, Pilling Lane &off Myles Standish

    Way. This has increased the demand on local services especially the primary schools which are already over

    subscribed.

    4. Due to the sites location to the river further developments could increase the possibility of flooding

    hope you take my comments into consideration.

    Kind Regards

    David Byrne

  • 1~5C~ Tt$3

    Katherine Howarth

    From: Graeme Wright <

    Sent: 15 July 2014 22:52

    To: Planning.Policy

    Subject: Objections to Travellers site @Crosse Hall Lane

    would ask for the following are taken into consideration for the proposed travellers site at Crosse Hall

    Lane.

    1. This land is actually on Howarth Road rather than Crosse Hall Lane.

    2. The land is almost half the size of the stated minimum size required (0.4 hectares), and would

    require a second site in order to meet the minimum 5 households - at additional cost to the council

    tax payer.

    3. The site would not be in-keeping with the Iocal street scene, and would be visible from the road.

    4. Should this site be used, it would not allow any future expansion of St James' Primary School, which

    understand is nearing over capacity - as schools are not allowed to build on their playing fields.

    5. The road is very busy - especially at school time, causing a danger to pedestrians and other road

    users. This additional building will increase traffic volume.

    6. The cost of this site is prohibitively expensive, in comparison to the preferred Cowling Farm site.

    7. The consultation has not taken place in a fair manner to existing residents living in surrounding

    areas to proposed sites. Residents have not been informed directly by letter. One article has

    appeared in local press, and the planning documents have not been placed in a prominent position

    on the council website. This has limited our opportunity to investigate our options and legal

    position, and to respond within the allotted consultation period.

    8. The site is located on an unadopted road - it is therefore not in control of the council, and it being

    maintained at the cost of the local Morris homes development. This additional traffic will cause

    wear and tear (especially given the size and weight of a large caravan. The expense of repairs

    would be borne by local Morris homes residents until such a time as the Council is in a position to

    adopt the road. As residents, we have no control over this travellers' development, and the type of

    vehicles that will be used on the site. In addition, this road is not gritted and therefore is likely to

    be unsafe in winter conditions, for private cars, let alone large caravans and mobile homes.

    9. The existing Rivington View site has only one access road (Howarth Road), leading to circa 200

    homes. Should this be blocked for any reason, this causes a real safety problem, given the size of

    the vehicles which could use the road. We have particular concerns regarding access for emergency

    and refuse vehicles.

    10. The palisade fencing will not screen the proposed travellers' development from view. Given that

    this would be a highly visible site from the road, it would be not in keeping with the local

    surroundings and street scene.

    Many thanks

  • i bb

    G~('1$ ~-

    Katherine Howarth

    From: BURTON MACLEOD

    Sent: 15 July 2014 22:47

    To: Planning.Policy

    Subject: Chorley local plan - Gypsy, traveller Preferred Options

    I would like to oppose the planned consideration of using the Former Depot at Yarrow Bridge,

    Bolton Road, Chorley PR7 4AB on the grounds that the proposed site is within the Greenbelt and is

    in an area of natural beauty and wildlife. The erection or allowance of any habitation would put this a

    risk and would not be in keeping with the local area.

    I would also like to object on the grounds of the increased disruption that this site would cause to one

    of the main arterial routes into Chorley. The new lights at Myles Standish Way have already created

    traffic flow problems particularly at rush hour, and should this site be selected together with the road

    widening and carriageway crossings being suggested by the highways agency it would compound the

    problem and adversely affect the traffic flow. Coupled with this, having a site entrance in close

    proximity to a bus stop, given the size of the vehicles entering the site, would create a hazard to

    anyone alighting the bus at this location.

    I believe that on these grounds this site should be removed from the list of proposed locations.

    Kind regards

  • 1 ~ ̀l

    4'T~gSKatherine Howarth

    From: Heather Laughton

    Sent: 15 July 2014 23:04

    To: Planning.Policy

    Subject: Objection to proposed permanent gypsy and traveller site on Cross Hall

    Lane, chorley.

    Dear sir/ madam,

    am a resident of the rivington view estate chorley. It has recently come to my attention that there are a

    number of proposed gypsy /traveller sites in my local area.

    am therefore emailing you to express my objection to the proposed permeant gypsy and traveller site on

    cross hall lane, chorley for the following reasons:

    the site does not appear to provide the required size to support the gypsy /traveller community as

    requested e.g. Regarding accommodating size of pitches /trailers; the site is attached directly to a school

    preventing expansion requirements considering the increase of potential attendees from the rivington view

    estate; road safety may bean issue considering the access road is currently unadopted, especially at peak

    times when parents drop /pick up children from school.

    believe that the alternative proposed sites provide more satisfactory accommodation than the one on cross

    hall lane e.g. Cabbage hall fields, cowling farm and yarrow bridge depot (if removed from the Green Belt)

    and should therefore be considered for development.

    Kind regards,

    Sent from my iPad

  • Chorley Local Plan 2012-2026~~~~~~~Gypsy and Traveller and Travelling Showpeople

    Preferred Options (June 2014)C o u n c~ 1

    Ref Number:

    Representation Form G TI$(~Official use only

    4 JUNE to 16 JULY 2014

    Chorley Council is seeking comments on the Council's preferred location for the provision of a minimum of 5 permanent Gypsy

    and Traveller pitches (Chorley Local Plan 2012-2026). The Council has also considered and discounted a number of

    alternative sites and welcomes views on these. A Schedule of Proposed Further Modifications which includes a proposed

    policy on Gypsy and Traveller and Travelling Shopwpeople (Policy HS11) to the Local Plan has also been produced.

    This consultation is intended to invite comments on the sites (and whether the document is a) legally compliant and b) sound.

    Further guidance on this is provided at the back of this form).

    The Council is not inviting views on whether this proposed allocation is sufficient to meet the permanent and transits needs of

    the Gypsy, Traveller and Travelling Showpeople Community as this issue is being considered in a separate Development Plan

    Document (DPD —taken fornrard December 2014).

    If you have any views on the Preferred Options document, please use this form. Copies of the Preferred Options document

    along with all accompanying information can be viewed at:

    ■ The Council's website www.chorlev.gov.uk/planninq

    ■ Local libraries and Post Offices in villages without a library (paper copies). The documents are available for inspection

    during normal opening hours. The times of opening can be viewed on the Council's website_

    ■ Chorley Council Offices at Union Street, Chorley —open Monday to Friday 8.45am — 5.00pm.

    Please complete this form and email it to planning.poticvCa~chorlev.gov.uk or post to Planning Policy, Civic Offices, Union

    Street, Chortey, PR7 tAL.

    For more information please call: 01257 515151

    Please note the deadline for responses to be received is 16 July 2014, by 5pm at the latest. If responses are

    received after this deadline unfortunately they will not be considered. Please allow for postage delivery times.

    Please note that your comments cannot be treated as confidential (see below).

    Data Protection StatementThe information you provide will be held and used by Chorley Council, in accordance with the Data Protection Act 1998, to help

    in the preparation of the Local Plan. Please note that all responses received will be available for public inspection and wi II be

    placed on the Council's website. This will include your name but the remainder of your personal details will remain

    confidential. Anonymous representations will not be accepted.

    Inappropriate, offensive or racist comments will not be accepted.

    Thank you for taking the time to complete this form

    Please fill in your details below, or if an Agent has been appointed, their details.

    Tick as appropriate (~): Personal Details [~j Agent Details ~

    Title Mr

    First Name Paul

    Last Name Walton

    Organisation(where relevant)

    PWA Planning

    Job Title/Position

    Director

    Address Line 1

    Address Line 2 ~~~

    Town ~■~~ Telephone numberPost Code a~~ Email address

  • This consultation seeks views on the suitability of sites and not the principle of

    allocating sites. Please fill in your comments below. Please use a separate

    form if you wish to make comments on more than one site.

    To which part of the Preferred Options document does this representation re{ate? (please state)

    Site Ref No/ Cowling Farm Paragraph Number

    Location

    FurtherProposedModificationNumber

    1. Do you have any evidence or information about this site which will help the Council to

    demonstrate that this site is available, suitable and achievable for Gypsy provision?

    See attached document.

    2. Do you agree that the Council's preferred site at Cowling Farm should be taken forward as

    a formal allocation?

    Yes ~

    No ~

    3. Do you have any other comments on the Preferred Options document?

    See attached document.

    Please use a separate sheet if required but indicate Site Reference No/Location.

  • 4. Do you consider the Preferred Options document is: (please tick one box only per

    representation)?

    (1) Legally Compliant Yes ~ No 0

    (2) Sound* Yes ~ No ~

    *The considerations in relation to the Local Plan being ̀ Sound' are explained in the

    National Planning Policy Framework in paragraph 782.

    5. Do you consider the Preferred Options document is unsound because it is not: (please

    tick box one box only per representation)? Explanations of these terms can be found in the Guidance

    IVotP_s.

    (1) Positively prepared ~

    (2) Justified 0

    (3) Effective ~

    (4) Consistent with national policy ~

    6. Please give details of why you consider the Preferred Options document is not legal)

    compliant or is unsound. Please be as precise as possible. If you wish to support the lega

    compliance or soundness of the Preferred Options document, please also use this box to se

    out your comments.

    See attached document.

  • 7. Please set out what changes) you consider necessary to make the Preferred Options

    document legally compliant or sound, having regard to the test you have identified above

    where this relates to soundness. You will need to say why this change will make the

    Preferred Options document legally compliant or sound. It will be helpful if you are able to

    put forward your suggested revised wording of any policy or text. Please be as precise as

    possible.

    Please note your representation should cover succinctly all the information, evidence and

    supporting information necessary to support /justify the representation and fhe suggested

    change. After this stage, further submissions will only be at the request of the Inspector, based

    on the matters and issues she identifies for examination.

    See attached document.

    8. If your representation is seeking a change, would you like to participate at the oral part of

    the independent examination due to take place on 23 and 24 September 2Q14? (please tick

    box).

    No, I do not wish to participate at the oral examination 0

    Yes, I do wish to participate at the oral examination ~

    9. If you wish to participate at the oral part of the independent examination, please ou#Fine

    why you consider this to be necessary:

    Please note the Inspector will determine the most appropriate procedure to adopt to hear

    those who have indicated that they wish to participate at the oral part of the examination.

    It is essential that we are able to participate at the examination to :-

    (i) ensure that the views of interested parties are properly represented to the Inspector;

    (ii) ensure that we have adequate opportunity to question the LPA's assumptions in arriving

    at their preferred option site;

    Signature:

    Date: 15/07/2014

    Chrley~oU~~~~

  • Chorley Local Plan 2012 — 2026

    Gypsy and Traveller and Travelling

    Showpeopie Preferred Options -June 2014

    Representations on behalf of

    Moorland Gate Business Park and Cowling Action Group

    July 2014

    P4VA_34_079_06J01

    RTPI

    PacE Viaitan dssxiates and PWA Ftanrin~ are trzGing names of Paut Wal:on Associates Ltd, a company registered in England ;na. 8605106)

    Ribble Saw Mill

    Paley Road

    Preston PR1 8LT

    01772 369 669

    01772 887 022

    [email protected]

    www. pwa pla n n ing.co.0 k

  • Chorley Local Plan 2012 — 2026

    Gypsy and Traveller and Trevelling Showpeople Preferred Options (June 2014)

    1. BACKGROUND

    1.1 PWA Planning is retained to advise the owners of Moorland Gate Business Park and the Cowling

    Action Group and in particular to submit representations to the Chorley local Plan 2012-2026

    'Gypsy and Traveller and Travelling Showpeople Preferred Options' document dated June 2014.

    1.2 Our clients have requested PWA Planning to prepare a summary document to consider the

    manner in which Chorley Borough Council (CBC) has concluded that, of the various sites

    considered within the 'Gypsy and Traveller and Travelling Showpeople Preferred Options' (GTTSP)

    report, the Cowling Farm site is the Preferred Option.

    1.3 The following report identifies why we believe that CBC have incorrectly undertaken the site

    comparison in the GTTSP; have rejected site for inappropriate reasons and consequently have

    made the wrong choice of preferred option. We ask the Inspector to therefore conclude that this

    element of the Chorley Local Plan (CLP) is unsound. .

    NATIONAL PLANNING POLICY FRAMEWORK (NPPF): EXAMINING LOCAL PLANS

    1.4 The following is an extract from the'Communities and Local Government: National Planning Policy

    Framework — Examining Loca! Plans':

    "The Local Plan will be examined by an independent inspector whose role is to assess- whether the

    plan has been prepared in accordance with the Duty to Cooperate, legal and procedural

    requirements, and whether it is sound. A local planning authority should submit a plan for

    examination which it considers is 'sound'— namely that it is:

    • Positively prepared —the plan should be prepared based on a strategy which seeks to

    meet objectively assessed development and infrastructure requirements, including unmet

    requirements from neighbouring authorities where it is reasonable to do so and

    consistent with achieving sustainable development;

    • Justified —the plan should be the most appropriate strategy, when considered against

    the reasonable alternatives, based on proportionate evidence;

    • Effective —the plan should be deliverable over its period and based on effective joint

    working on cross boundary strategic priorities; and

    • Consistent with national policy —the plan should enable the delivery of sustainable

    development in accordance with the policies in the Framework."

    1.5 This report will demonstrate that CBC have not undertaken the GTTSP Preferred Options Plan in a

    manner consistent with the requirements of the NPPF. The assessment therefore does not comply

    with national policy guidelines and hence the plan is considered to be unsound.

    Page ~ 1

  • Chorley Local Plan 2012 — 2026

    Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

    2 FACTORS WHICH CONTRIBUTE TOWARD THE PLAN BEING CONSIDERED UNSOUND

    2.1 The paragraphs below describe how it is considered that the Preferred Options document does

    not comply with the NPPF (as detailed above) leading to the Preferred Options document being

    'unsound';

    Positively Prepared

    2.2 It is considered that there has been a distinct lack of adequate consultation with the settled, and

    indeed the traveller, community and certainly a lack of meaningful public engagement prior to and

    during the selection and recommendation of a Preferred Option. Despite the commentary within

    the Regulation 22 (1)(c) report, it is clear that adequate prior consultation, particularly with the

    settled community, has not occurred. The Statement of Consultation Supplement Paragraphs 1.2 —

    1.5 makes it clear that there has been no previous engagement or informal consultation with the

    settled community on the issue of a specific land use allocation to meet the needs of the gypsy

    and travelling community. All references within the statement of consultation relate to the much

    earlier call for sites, which occurred from 2005 — 2010 and which were simply requests for

    potential site allocations. None of these ̀ consultation' period actually tackled directly the issue of

    allocations to meet the needs of the gypsy and traveller community. Accordingly it is not surprising

    that large sections of the settled community were surprised to learn of a 'preferred' option having

    been determined, given that they were not even aware that there were any options being

    considered.

    2.3 It is considered that this lack of adequate engagement with interested parties, renders the

    preferred options document inconsistent with the requirements of the NPPF, and hence unsound.

    2.4 Moreover there are a number of gaps in the information provided in the GTfSP, which appear to

    be because the authors of the report have not had adequate time to compile or simply do not

    have the information; have made assumptions which are not supported by evidence, or the

    evidence is not in the public domain. By failing to substantiate assumptions or facts which have

    influenced the choice of a preferred option, the Council have failed to prepare the plan positively.

    It seems evident that there has been a lack of rigorous assessment of contributory factors that

    would impact the selection of a Preferred Option. For example there is yet to be a full assessment

    of the highway authority and other statutory undertaker's concerns regarding the Cowling Farm

    and other sites, with ̀ comments awaited' on many of the considered sites. This suggests that the

    plan has been prepared in haste, without full knowledge of the impacts and effects of particular

    proposals on particular sites. This lack of up to date information and evidence reinforces the fact

    that the plan has not been ̀ Positively Prepared' and hence is unsound.

    Justified

    2.5 It is considered that the manner in which CBC have assessed the alternative sites is flawed, both in

    terms of the assessment criteria used and more particularly the manner in which the preferred

    option has been chosen.

    2.6 The Council have used a relatively 'standard' Sustainability Appraisal (SA), which of itself is clearly

    better suited to assess potential housing or similar allocations, as opposed to potential sites for

    Gypsy and Travellers. A number of the sustainability criteria are not particularly relevant to an

    objective assessment of a site's suitability to provide a sustainable site for gypsy and traveller

    Page ~ 2

  • Chorley Local Plan 2012-2026

    Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

    communities, who tend to have different needs as outlined in the Planning Policy for Traveller

    Sites (PPTS). The Council seem to acknowledge this fact within the preferred options document,

    but it is not at all clear how the sustainability appraisal has been weighted or scored. It is

    considered that a more appropriate set of assessment criteria would demonstrate more clearly

    that sites other than Cowling Farm are most suited to such an allocation.

    2.7 Even accepting the criteria chosen, and without any clear understanding of how the Council have

    weighted the various criteria and hence arrived at the ranking that flows from this scoring, it

    seems apparent that the Council have arrived at the wrong choice of site. The table reproduced at

    APPENDIX 1 to this statement provides a comparison of the preferred options site against three

    alternative sites, each of which we believe outperform the preferred option by some considerable

    margin, using the Council's own criteria.

    2.8 It can be seen that by reference to the Council's own sustainability matrix that each of the three

    alternative sites indicated outperform the Cowling Farm site by a considerable margin. Indeed the

    Cabbage Hall Fields site scores significantly better than Cowling Farm and it is therefore extremely

    surprising to note that the Council have identified all of these sites within the same "sustainability

    appraisal banding". It seems quite clear that, if the Cowling Farm site is banded "B" then the

    Yarrow Bridge site and certainly the Cabbage Hall Fields site should be banded as "A" if the scoring

    is to have any meaning. Of course such a differential banding would not then support the Council's

    preferred option. Ultimately regardless of the banding, it is clear that the sustainability appraisal

    does not in fact support the Council's choice of preferred option and that the Ackhurst Road,

    Yarrow Bridge and in particular the Cabbage Hall Fields site should be ranked above the current

    preferred option.

    2.9 Turning then to the Council's site ranking assessment, which appears to incorporate the

    sustainability appraisal, reproduced at Pages 10-14 of the report, there continues to be a distinct

    lack of transparency and indeed logic in so far as the criteria which have resulted in the Council's

    choice of preferred option. Again by comparison to the other sites previously referenced (all of

    which are set out a pages 10 & 11 of the report), each of the sites are identified as being of

    sufficient scale to accommodate the intended use and each is said to be potentially a candidate for

    HCA funding. In terms of estimated costs, the Cowling Farm site is marginally the most expensive

    with the Cabbage Hall Fields and in particular the Ackhurst Road sites being markedly less

    expensive to develop.

    2.10 The Yarrow Bridge site is marked down by the Council due to its location within the Green Belt and

    moreover its location outside of the key service centre. It is not entirely clear that being located

    within the key service centre, as opposed to being close to key services, is a key criteria. Indeed

    the Council acknowledge that the relevance of being located in such urban locations is in fact the

    proximity and availability of services. To this end, it is clear that in sustainability terms, the Yarrow

    Bridge site outperforms the Cowling Farm site and is better located in relation to the range of

    services and facilities. Accordingly it seems entirely inappropriate to reject or mark down the site

    due to its location outside of the urban boundary. Moreover the Council appear to have argued

    that the Yarrow Bridge site is unsuited to an allocation due to its location within the Green Belt.

    Again this argument seems to contradict various other indications within the Council's preferred

    option document as well as the national guidance. Such guidance acknowledges that the plan

    making process is the correct time to consider making an exceptional alteration to the Green Belt,

    Page ~ 3

  • Charley Lotal Plan 2012 — 2026

    Gypsy and Traveller and Trevelling Showpeople Preferred Options (June 2014)

    so as to exclude the proposed gypsy site from the Green Belt. Furthermore whilst national

    guidance makes it clear that gypsy sites are inappropriate uses within the Green Belt, the fact that

    the site is acknowledged to be previously developed means that the site ought to be considered

    against Paragraph 89 of NPPF, which permits ...

    "limited infilling or the partial or complete redevelopment of previously developed sites (brownfield

    IandJ, whether redundant or in continuing use (excluding temporary buildings), which would not

    have a greater impact on the openness of the Green Belt and the purpose of including land within it

    than the existing development".

    This exception criteria must apply equally to gypsy sites as it would for housing or other

    commercial uses (all of which are equally inappropriate uses in the Green Belt), provided the

    impact is no greater than the existing. It does therefore appear that the Green Belt argument is

    somewhat erroneous and that, either by way of specific exclusion of the site from the Green Belt

    or through redevelopment in accordance with NPPF Paragraph 89, there should be no reason to

    preclude the consideration of the Yarrow Bridge site due to its Green Belt location.

    2.11 Similarly in the case of the Ackhurst Road site, the Council appear to have marked down the site

    simply on the basis that it provides existing car parking to a number of local businesses. It is not

    considered that this is a substantive reason to reject this site, as the impact of the loss of parking

    will not be significant if alternative parking can be provided. It does however indicate that there

    may be some delivery issues with this site, given that there is a long lease to a third party which

    could preclude its development in the short term. The site does however perform reasonably well

    in all other respects and could provide a very adequate reserve site.

    2.12 Taking into account the above matters it seems that by any logical assessment of the evidence, the

    sites should be ranked differently to that produced by the Council. The table below reproduces the

    Council's table on Page 10 of the preferred options document, but revises and re-orders the

    ranking and hence the preferred option based on an objective assessment of the criteria and

    taking account of the comments raised above.

    SITE Location Area Capacity Conformity with Core Sustainability HCA Funding Ownership Estimated

    RANK (Ha) Strategy Banding Cost

    1 Cabbage 0.6 5+ Policy 1 —In confarmity A Potentia€ly Charley fA84,000

    Hall with poEicy, wifhin Key Council

    Fields Service Centre of

    Charley Town (triterion

    b)

    Policy 8 —all of criteria

    could be satisfied.

    2 Ackhurst 0.49 S+ Policy 1— Inconformity with B Potentially Charley E440,000

    Road policy, within Key Service Council

    Centre of Charley Town

    (criterion b)

    Policy 8 —The site does not

    have very good access to a

    number of services under

    criterion (a~.

    3 Yarrow 0.63 S+ Policy 1— Outside urban B Potentially Charley E550,000

    Bridge boundary but well located Council

    Depot, in relation to Key Service

    Charley Centre of Charley Town.

    Brownfield site within

    Green Belt.

    Policy 8—All of the criteria

    could be satisfied

    Page ~ 4

  • Chorfey Local Plan 2012 — 2026

    Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

    4 Cowling 9.5 5+ Policy 1— Inconformity with BPotentially Charley E560,000

    Farm, policy, within Key ServiceCouncil

    Charley Centre of Charley Town

    (criterion b)

    Polity 8 -All of the criteria

    could be satisfied

    Table showing revised site ranking.

    2.13 Based on the Council's own evidence, without adjustment, it is clear that the preferred option site

    should clearly be Cabbage Hall Fields, followed by Ackhurst Road, with Cowling Farm at least

    fourth ranked or worst. When adjustments are introduced to properly reflect the sustainability

    scoring of Cabbage Hall Fields in particular, as well as using a more reasonable assessment of the

    need for the site to fall within the urban area, the preferred option and the second choice

    (reserve) site become even more apparent.

    2.14 Taking all of the above into account, it is clear that the Council have failed to identify the correct

    site as the preferred option and hence that the plan does not represent the "most appropriate

    stratepY when considered against the reasonable alternatives" and hence that the plan is unsound

    for this reason.

    Effective

    2.15 Delivery is a key issue in terms of the identification of any land use allocation, in particular the

    allocation of a gypsy and traveller site allocation. Where there are known constraints to

    development, these should be identified. In this respect it is understood that there are specific

    issues associated with the Cowling Farm site, whereby the proposed access, which itself is

    proposed to include land within the Green Belt, is subject to restrictive covenants which would

    preclude its use to provide a means of access to the wider site. Furthermore based on the

    response from the highway authority, there is some considerable doubt about the delivery of a

    safe and convenient means of access to the Cowling Farm site. Pages 17 and 18 of the GTTSP

    identifies a possible objection to the proposal to develop Cowling Farm from Lancashire County

    Council (LCC) Highways. It is stated that in respect of Cowling Brow ...

    "there have been no less than 10 recorded slight personal injury traffic accidents in the past 5

    years at different locations of its length. Two of these accidents were recorded as serious.

    "if the accident review cannot be undertaken and the additional safety measures implemented

    then, Highways would seek io object to the proposed site".

    2.16 Evidently there is some considerable doubt as to the delivery of a safe. and convenient access from

    Cowling Brow and the impact any development would have on the local and strategic highway

    network. This itself casts further doubt on the decision to identify Cowling Farm as a preferred

    option, particulary as such constraints to delivery (by way of access) do not affect the Cabbage Hall

    Fields site, where it is stated that "there are no highway objections".

    Z.17 It therefore considered that the decision to identify Cowling Farm as the preferred option will not

    render the plan effective as there is considerable doubt about the delivery of the scheme and such

    doubts do not affect other sites, particularly those which, in our opinion, out-perform the

    Council's preferred option site. For this additional reason, the plan is considered to be unsound.

    Page ~ 5

  • Chorley local Plan 2012 — 2026

    Gypsy and Traveller and Travelling Showpeople Preferred Options (June 2014)

    3 SUMMARY AND SUGGESTED AMENDMENTS

    3.1 In summary and for the reasons identified in the body of this response, it is considered that the

    GTTSP fails the tests of soundness on a number of grounds due to considerable flaws in the

    evidence base and more particularly in the choice of preferred option for the identification of a

    gypsy and traveller site.

    3.2 In particular it has been demonstrated that the plan :-

    (i) not been "positively prepared", as it has not been subject of appropriate community

    engagement and there are significant gaps in the evidence base;

    (ii) is not justified, as it is plainly not the most appropriate strategy when considered against

    the reasonable alternatives;

    (iii) is not effective, in that there are considerable doubts about the delivery of the preferred

    strategy, which do not affect other alternatives.

    3.3 It is therefore considered that the plan is unsound.

    3.4 It is recommended and suggested that the Council review and reconsider the preferred option as

    set out in the GTTSP and identify the most appropriate site, based on a more thorough and

    rigorous evidence based assessment. We consider that there is one site which is clearly the most

    suitable site and which outperforms the others -the Cabbage Hall Fields site. This site should be

    identified as the most suitable option and a further round of consultation should be undertaken

    based on this proposal.

    Page ~ 6

  • Chorley Lo

    cal Plan 2012 — 2026

    Gypsy and Tra

    vell

    er and Travelling Showpeople Preferred Options (Ju

    ne 2014)

    S.A Obj

    Indicator

    Cowl

    ing Farm (CF

    )

    Distance to ra

    ilwa

    y st

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    n1.

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    Distance to near

    est bu

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    op

    Bus se

    rvic

    e frequency

    Dist

    ance

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    0.81 to 1.6km

    Distance to A Road jun

    ctio

    n0.

    81 to 1.6km

    51

    Distance to motorway jun

    ctio

    nOv

    er 3km

    Distance to supermarket

    0.81 to 1.6km

    Distance to convenience store

    0.41

    to 0.

    8km

    Distance to Post Office

    ~ ~~,~~,~~~„~~,~, ~

    0.41

    to 0.8km

    Distance to Primary Sc

    hool

    Distance to Secondary Sc

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    0.81

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    S2

    On a cycle rou

    teNo

    Distance to cycle route

    Distance to GP sur

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    2.1 to

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    Distance to NH5 gen

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    Distance to pu

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    , . ~

    , __

    `l1p

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    Dist

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    1.2~

    . Go~~:.6km

    Desi

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    Area

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    - Ou

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    ~ Ou

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    Grade 3

    APPENDIX 1

    Yarrow Bri

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    0.81 to 1.6km

    0.81 to 1.6km

    R~'~

    V`~ $

    4~KY

    L1;

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    0.81 to 1.6km

    0.81 to 1.6km

    ? 1 to 5km

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    .~.~

    Qut>

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    Cabbage Hal

    l Fi

    elds

    (CHF)

    0.81 to 1.6km

    2-5/hour /direction

    0.81 to 1.6km

    0.41

    to O.8km

    0.41 to 0.8km

    0.41 to 0.8km

    0.41 to 0.8km

    ,~~'~~,

    ~{~

  • Chor

    ley Lo

    cal Plan 2012 — 2026

    Gyps

    y and Traveller and Travelling Sh

    owpe

    ople

    Pre

    ferr

    ed Opt

    ions

    (June 20:14)

    APPENDIX 1

    High

    est sc

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    SA Obj

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    Cowling Farm (CF)

    Yarrow Bri

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    Cabbage Hal

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    CHF

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    15

    YB

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    9

    AR

    Ackhurst Roa

    d8

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    g Farm

    4

  • i f~qG ► 1 ~~

    Moorland Gate

    Cowling Brow

    Chorley

    PR6 9EATel: 01257 226635

    Fax: 01257 469309

    11/07/2014

    Chorley Local Plan 2012-2026

    GYpsv and Traveller and Travelling Show people Site — Preferred Options June 2014

    Cowling Farm

    Dear Sirs

    write on behalf of FDC Holdings Ltd to express my concerns from a Local Business perspective to

    the proposed Gypsy, Traveller and Travelling Show People site in the Cowling area of Chorley.

    FDC Holdings owns Moorland Gate Business Park immediately adjacent to the proposed site. The

    feedback I am receiving from our Tenants on site is that if the proposed site does go ahead they will

    o;±hoc o~f.,r~P rhP hrPak clause in their leases when they fall due or they will not renew the lease at

    the end of the term, whichever comes first.

    Whether this could be viewed as discriminatory I do not know, I have nothing against the travelling

    community, I only know that this is what the Businesses on site are telling me — it is fact. It goes

    without saying that this outcome would seriously damage our business resulting in some job losses

    or worst-case scenario the business would cease trading altogether.

    We have owned the Moorland Gate site for 10 years and have worked extremely hard to build a

    successful business and attract other businesses to the area. The site currently has a very high

    occupancy and the site employs in the region of Z00+ people. We have plans to expand the site in

    the near future however this would now appear to be extremely unlikely as we feel we would not be

    able to attract other businesses to our site.

    All goods carried subject to RHA terms and conditions, and all goods stored subject to RHA storage conditions...— - .. .... .~.n inn D..,.;,. «...-...I :.. C..,.I.....J O.\A/.I.... /"'....____..

    D__ n1_ ]'~'1~n1]i

  • Clearly the mixing of Gypsy and Travellers in a mixed residential and business area will also have a

    severe impact on both the Councils revenue for the sale of the prime land and the value of the

    Moorland Gate site. This would severely affect FDC Holdings' future borrowings and ability to

    expand the business. I fear that if the proposed site does go ahead it will be the beginning of the end

    for Businesses in the Cowling area.

    also attach letters from two independent Commercial Property Agents which confirm their fears

    that Moorland Gate Business Park will no longer be able to attract new Tenants should the proposed

    sit go ahead.

    Yours Sincerely

    _~

    Stephen Allen

    Director

  • 1)urlL.~i`. C'U13.(~11 ~hartcrad SurvercxsC'ert~mereial Pi~}x:ity Consultants

    Yuur Kef

    .•St~~~r Allen LaqFi~C' (Hulclin~st I_imiicd ~.-.__..._ __ __... ,..~4ati~i M2rtin (Lanes} Limited.

    h1c~~rlancl

  • eck~rs eC01'~'~r"i('rf~2.: )?'Opc•r$./ S~iEaYici'15F

    Our Ref MAC/CF

    Date 14 July 2014`~'>>~k~f ~: ,:j~~~ r ; _ . _ ;

  • ~~a~ T~$S

    A. R. Yarwood, DipTP, MRTPI,Planning Officer

    ~~~Nauona1FPa~aho~° National Federation of Gypsy Liaison Groups

    of GypsyLiaeon Groups Unit 3, Molyneux Business Park

    .~ - Whitworth RoadMatlock,DE4 3HJ

    01629732744

    Planning Policy,Civic Offices,Union Street,Chorley,PR7 1 AL.

    16 July 2014

    Dear sirs,Gypsy and Traveller and Travelling Showpeople Preferred Options

    comment on the above document on behalf of the National Federation of Gypsy

    Liaison Groups. Whilst the plan may be legally compliant it is not sound and, in

    our view, has not been positively prepared.

    The consideration given to the sites listed in appendix 2, suggested by the

    Traveller Community at Hut Lane is superficial and in stark contrast to those

    selected for consideration. All the sites listed in appendix 2 which are in the

    Green Belt are dismissed solely on the grounds of their location in the Green

    Belt, yet several sites suggested by the Council within the Green Belt have been

    given detailed consideration.

    The dismissal of a site suggested by the Traveller Community at Hut Lane simply

    because the Council could not be bothered to locate it also suggests a

    discriminatory approach.

    Site 9, with temporary permission at Hut Lane, should be allocated. It has too

    easily been dismissed. The fact that it cannot easily accommodate 5 pitches

    does not meet it cannot contribute to Traveller provision.

    Yours faithfully,

    A, n, yarwv6d

    A. R. Yarwood,

    The National Federation is a Company Limited by Guarantee registered in England and Wales. ~p

    Company No: 6983027. Registered Charity No: 1136730 lC~~.SU i

    Also funded by The Esmee Fairbairn Foundation ~"""T" " "̀R"

    :~~~,.~.,~3v.,..~ ~ss,~.«,

  • r~►G ~~$9

    Katherine Howarth

    From: Cllr Paul Walmsley

    Sent: 16 July 2014 10:07

    To: Planning.Policy

    Cc: Cllr Beverley Murray; Cllr Alistair Bradley

    Subject: Fwd: Former Depot at Yarrow Bridge

    please not the comments from Mr Haslam

    Cllr Paul Walmsley

    Chorley South East Ward

    Begin forwarded message:

    From: Derek Haslam

    Date: 15 July 2014 22:18:35 BST

    To:

    Subject: Former Depot at Yarrow Bridge

    Hello Paul, could you please forward my comments on the above as the allocated

    form on Chorley BC website is ridiculously complicated. ie — in PDF format which

    needs converting before its usable.

    think the above site for a permanent Gypsy travellers home is unsuitable for the

    following reasons:

    1 It would be accessed by lorries etc to and from a very busy main road.

    2 It is very close to two School playgrounds, one of which is used by small children

    and on full view from the footpath.

    3 It backs on to the River Yarrow which has been the subject of a major clean up in

    recent years and inevitably there would be pollution from the site.

    4 It would be next to one of our bigger residential Premier inns and would have an

    adverse effect on economic growth and could in fact cause its demise.

    Many thanks Paul, Derek Haslam,

  • 112GTIgO

    Katherine Howarth

    From: Jayne Gouldthorpe

    Sent: 16 July 2014 10:31

    To: Planning.Policy

    Subject: Gypsy and Traveller Preferred Options Consultation

    am writing with my concerns regarding the proposed permanent site fora 'traveller' site for travellers who

    are going to be permanently resident.

    As an aside comment: The format of your consultation is not accessible to all as you are expecting a pdf form

    to be printed out, then completed and scanned in to email back to you. The pdf cannot be typed into and

    not only do people not have these facilities the form is not easy to understand. I am therefore emailing my

    comments.

    My first point is that if people want to live permanently in an area then there is accommodation available to

    rent or to buy. There seems to be a lot of money going to be used to create a gypsy and traveller site which

    could be spent elsewhere.

    Secondly, I do not think that greenfield sites should be used for this purpose. It is destroying the natural

    beauty of places within Chorley and having an impact on the natural habitat and ecology of the area.

    am writing with particular opposition to Site 2 Yarrow Bridge Depot. It is not a good location for a

    permanent site for the following reasons:

    It will have an adverse impact on the natural environment, there is a lot of wildlife in this area with deer,

    foxes, badgers, herons, squirrels being seen there.

    It is out of keeping for the area which consists of woods, Duxbury park, the canalside, the river etc, low

    density housing, semi-rural.

    The nearest primary school is a Church of England school which requires regular church attendance and is

    always oversubscribed. Other primary schools are some distance away.

    There has recently been a housing development (Arley Homes) which has put increased pressure on services

    in the area including the school.

    There are no shops nearby.

    There is no GP surgery nearby.

    There is no chemist nearby.

    The entrance to the site is where there is an existing bus stop —this is an issue for safety.

    The stretch of road here is particularly busy and the traffic lights created by the Myles Standish Road have

    created bottlenecks at rush hour. Having large vehicles coming and going is going to be hazardous. It is a

    known stretch for accidents and fatalities.

    In the past the school (St Georges) has requested the services of a lollypop person to help people across the

    road and this was refused. So why can money now be spent on crossings for 5 potential families?

    The area has issues for flooding and creating a site could aggravate the drainage issues.

    am not as familiar with the proposed site at Cowling Farm. However, some of the reasons (eg greenfield

    site) I have used above are likely to apply to this proposed site and I do feel that there are probably more

    suitable brownfield site which could be used if explored further.

    hope that my comments can be taken into account even though I have not used your form.

    Mrs Jayne Gouldthorpe

  • 1~3

    CT19 !

    Mr &Mrs Eckersley

    Thursday 16th July 2014

    Planning PolicyCivic OfficesUnion StreetChorleyLancashirePR7 1 AL

    Re: Gypsy and Traveller and Travelling Showpeople Preferred Options June 2014

    CC: Chorley Borough Council

    Dear Sir or Madam,

    I am writing this letter in respect of the Gypsy and Traveller and Travelling show people

    preferred options (June 2013) document. The majority of the households oppose the proposed

    "Crosse Hall Lane" site described in the Gypsy and Traveller and Travelling Showpeople

    Preferred Options June 2014 report. The following arguments opposing this site have been

    developed giving a strong and coherent reason for the site not being suitable.

    Reasons for not adopting Crosse Hall Lane as a Gypsy and Traveller site

    Design and Location of Gypsy and Traveller sites

    The following information is taken from Central Lancashire's Joint LDF Officer Team

    Report, dated 26 March 2014, sections 26, 27 and 28:

    In addition to the provision of hot and cold water and electricity, there should be space on the

    site for the provision of a separate community building and community open space and

    grazing. The average Trailer size is 15 metres but some are as long as 25 metres.

    The study is based on Leighton Street, Preston. The site covers an area of 0.3 ha (3000 sqm)

    where five pitches have been installed each measuring 15 metres by 11 metres.

    Using the above information the total area for five pitches would equate to 825 sqm; All other

    amenities, therefore, are housed on 2175 sqm.

    If provision had been made for the larger trailers, which are approximately 25 metres by 11

    metres, and area of 1375 sqm this leaves only 1625 sqm to house all other amenities; This

    would not be enough space.

  • The Crosse Hall Lane Site4

    - ~

    Applying fie Preston cri,~eria to the Crosse Hall Lane site which is 0.23 hectares (2300 sqm),

    then fivaptehes at 15 riietres by 11 metres, 825 sqm, would only leave 1475 sqm, ~9% less

    than the Creston site, wi~h'not enough room for the recommended other requirements.

    In a worst case scenario, providing room for the larger trailers, only 1245 sqm is available for

    communal activity. This is a smaller area than the total of the pitch bases. In conclusion the

    Crosse Hall Lane site is unsuitable as a permanent Gypsy/Traveller site.

    Other Considerations

    A case could be made for a site with fewer than five trailers. However, the relative costs of

    providing two or more sites far outweighs that of a single site, especially as the local

    taxpayers would possibly be asked to help foot the bill. Additionally, it would be

    advantageous to the Gypsy/Traveller families to have a single site this is especially important

    where children are concerned.

    The use of palisade fencing against the backdrop of the Rivington View estate is not in

    keeping with the general aesthetic of the surrounding area, and therefore does not meet

    criterion d of Central Lancashire Publication Core Strategy Local Development Framework

    Policy 8.

    Finally, when preparing the site initially, some provision could be made to accommodate the

    larger trailer. The Chorley Local Plan 2012- 2026 published in February 2012 states that the

    total 14 year requirement for pitches is five. Taking a longer timeline there is the possibility

    that more pitches may be required. This helps the case for looking at a larger site where the

    infrastructure can easily be extended.

    I await your response regarding our objections.

    Yours faithfully,

    Mrs Stacey & Mr Alex Eckersley

  • i~~C1I92

    i

    Email:

    Direct line: 01695 554917

    Date: 16th July 2014

    Dear Peter McAnespie,

    Chorley Local Plan 2012-2026: Gypsy and Travellers and Travelling Showpeople

    Preferred Options Document Consultation

    The NFU is a professional body which represents the interests of approximately 75% of all

    farmers and growers and has 2000 members in the county of Lancashire. We have

    compiled the following comments in response to your consultation on your Gypsy and

    Travellers and Travelling Showpeople Local Plan Consultation. Our views are on behalf of

    the farming and land management sector in general. We do make our comments in the

    knowledge that the Council is under a duty to assess the need for Gypsy and Traveller sites

    in its area and is under pressure to plan for sites over a reasonable timescale.

    Our primary concern is that the consultation document does not include enough information

    on how these sites would affect local infrastructure and the nearest settled community.

    The local farming community must be fully consulted on sites and given access to

    information on site selection. It must be remembered that farmers are running businesses

    on their land and that they also have long term plans for the future. Sites must be selected

    so that they take consideration of the practical aspects of running a farm business for

    example by avoiding sites with close proximity to livestock units, or opposite busy farm

    entrances. They should avoid using quality agricultural land.

    hope that you find our contribution to the consultation useful. If you require further

    information or clarification of any of the points raised in the response please do not hesitate

    to contact me.

    Yours sincerely

    Alice UnsworthEnvironment 8~ Land Use Adviser

    NFU, Agriculture House, 1 Moss Lane View, Skelmersdale, Lancashire WN8 9TL

    Tel: 01695 554 900 Fax: 01695 554 901 Web: www.nfuonline.com

  • Katherine Howarth

    From: Andrew Barton

    Sent: 16 July 2014 11:10

    To: Planning.Policy

    Subject: Objection - Crosse Hall Lane Gypsy/Travellers planned site

    Good morning,

    1~5C~T19~.

    Please accept this email as a notified OBJECTION to the planned Gypsy/Travellers site location at

    Crosse Hall Lane in Chorley.

    must draw your attention to the following concerns:

    Land Use: this planned development is on one of the last few open spaces in this local area. By

    building on this greenbelt location will only be a detriment to the surroundings. Developing this

    small greenbelt location for the plans indicated will be unsightly, and be out of keeping with the

    rest of the local area, given the more suitable locations elsewhere.

    Land size (space): the space for this development is much too small to meet the criteria set out in

    the Council planning document, and does not fit the needs of the development.

    Congestion: There is a school next to this plot, and at school peak times in the morning and

    afternoon, the area is already heavily congested. To consider manoeuvring caravans and larger

    vehicles into or out of such a small space next to the school is potentially dangerous.

    Local Services: The plan does not meet the most important of criteria, which is the proximity to

    local GP services. Nor is it close to motorway junctions. The increase in larger vehicles not only

    impacts the area around Crosse Hall Lane, but also the roads between the motorway junctions and

    the planned development.

    It must also be drawn to your attention that the residents of Rivington View have committed (legal

    covenants and financially) to maintain the high standard of the local area as developed by Morris

    Homes. This site plan will be highly visible at the top of the Rivington View development, be

    unsightly -and potentially goes against the agreements of the hundreds of surrounding residential

    properties. (It is worth highlighting that all of the residents of Rivington View have signed an

    agreement NOT to park/display any caravans/mobile homes etc that they may own on their

    properties so as to detract from the local environment)

    By your own planning document statements, this location is simply not fit for purpose. It is highly

    unsuitable for the requirements indicated, and ultimately will provide no benefits to either

    travellers wishing to base here, or to the existing residents in the surrounding area.

    do hope that the planning department will see the inappropriateness of this location's size, and

    reject Crosse Hall Lane from the siting list.

    Kind Regards,

    Andrew Barton

  • i~ ~~T194-

    Mrs K Brophy

    Jennifer MooreHead of planningPlanning Policy,

    Civic Offices,

    Union Street,

    Chorley,

    PR7 1AL.

    15th July 2014

    Dear Sir/ Madam

    RESPONSE to - Chorley Local Plan 2012-2026 Gypsy and Traveller and

    Travelling Showpeople Preferred Options June 2014

    wish to object to Chorley Council's decision to name Cowling Farm as the preferred site for

    allocation as Gypsy and Travelling and strongly abject to this site being taken forward as a formal

    allocation.

    There are a number of reasons why 1 believe there are serious flaws in the performance site

    indicator, that other sites listed are better options and why Cowling Farm is clearly not the best

    choice on a number of criteria as detailed below:-

    The document "Chorley Local Plan 2012-2026 Gypsy and Travelling Show People Preferred

    Options Sustainability Appraisal Supplement" (referred to as the document herein after)

    states there are no identified negative economic effects in developing this site.

    However this site is the most expensive site proposed. Utilising the site in this way will limit

    the use for housing and extension of the industrial estate already agreed, impacting on

    employment opportunities for the area. Also the mixing of Gipsy and Travellers with

    residential and business use will have a severe impact on the Council's revenue from sale of

    prime Council owned land, and it is extremely unlikely that best market prices will be

    achieved where the mix is as defined in the plan.

    Other sites could be developed at lower cost and without loss of opportunity for other use.

    The area identified is too big and this could easily encourage large numbers of the travelling

    community to settle illegally, developing a Dale Farm nightmare scenario for Chorley Council

    to contend with. The environmental damage caused by unauthorised encampment has been

    witnessed on many Traveller invaded sites across the country. The Council should look to

    the recommendation of limiting site size and quite clearly ability to do this at such a large

    site is severely restricted. This would also place undue pressure on local infrastructure and

    services, if large numbers are able to settle in this area.

    Other sites are more appropriate in size, limiting the risk that unauthorised expansion

    could occur, placing additional demands on Chorley BC and local infrastructure.

  • Cowling Brow is already a traffic blackspot with the roundabout and area close to the Prince

    ,,of Wales pub frequently congested by parked cars with lorries unable to pass. Once past the

    speed bump "chicane", the road becomes a race track and there have been a number of

    accidents, including one fatality in recent years. Approaching from Adlington along Long

    ,+.~~ Lane is equally precarious, with a very narrow road, no pavements and a single track bridge

    and hairpin bend at Limbrick. In winter the icy roads are treacherous and prone to severe

    conditions. Snow is not cleared and in recent winters the road has been impassable. Other

    sites are located closer to main routes and do not carry the traffic risks and problems.

    • The proposed access across Green Belt land should not be allowed as this is inappropriate

    use of the Green Belt. We need to preserve the beautiful green belt countryside around

    Chorley and promote the gateway to the Pennines, and not allow these areas to be snatched

    in any way. If the Site at Hut Lane is to be rejected on these grounds then this should equally

    apply to the Cowling Site. The Local Plan refers to "Protecting the Green Belt from

    inappropriate development and strictly limiting new Traveller sites in the open

    countryside, away from existing settlements or outside areas allocated in the local plan".

    Other sites are outside greenbelt and do not impact greenbelt areas in any way. Yarrow

    whilst identified as a greenbelt is already in use by the council as a depot, and has

    already been tarmacked and therefore has surely already been effectively reallocated as

    Brownfield.

    • The document states that "Cowling Brow is a bus route and there is a bus stop within the

    recommended 400m walking distance of the site and located about

    60m south east of the junction of Cowling Brow and Moorland Gate". This is a very

    misleading statement as the bus service is extremely limited, is not regular or efficient

    with just two buses a WEEK, one in each direction. This can hardly be classed as a

    sustainable service. Othersites lie on main bus routes with direct routes to further/higher

    education.

    • The document refers to "Higher Education located within 1.6 — 3.2km." If this is the case

    and I am not sure it can be, then this must be similar for both the Yarrow and Crosse Hall

    Sites — Yarrow is certainly closer to Runshaw and lies on one of the many bus routes to this

    college, whilst Cowling Farm does not. See above.

    • This is a heavily undulating site with very poorly drained land, and not suitable for caravans.

    Again other sites have better landscapes suitable for travelling communities.

    • Cowling Farmhouse is Grade II listed. Any development in the vicinity of a grade II listed

    building should have respect to the building and its surroundings. A gypsy site is likely to

    detract from this, and not respect the heritage of this building. Not a factor for other sites.

    • The Central Lancashire Core Strategy Policy 1: Locating Growth sets out where

    development should be located in the Borough. It favours well located Brownfield sites. This

    site at Cowling is greenfield, in open countryside and if located in the southern area as

    appears to be intended, will be in full view from the roadside .Again not a factor for other

    sites.

  • Finally The Localism Act 2011 requires Councils to both notify and consult local communities

    in respect of this type of development before publishing proposals. I have not been able to

    see how CBC has satisfied this requirement. Applicable for the whole process.

    believe there are at least two other sites in the performance schedule which are more appropriate

    for this use than Cowling — eg Yarrow and Cabbage Fields, which will have less effect on the

    surrounding locality whilst meeting the criteria required better than the Cowling Site, as shown by

    the sustainability measure and I urge Chorley Council to take my comments into full consideration

    when reviewing the allocation further, and drop Cowling Farm from the site option list completely.

    Yours faithfully

    Kathy Brophy

  • Ili

    ~~T1q~

    Katherine Howarth

    From: S. Robinson < >

    Sent: 16 July 2014 12:49

    To: Planhing.Policy

    Subject: Chorley Local Plan - Gypsy, Traveller and Travelling Show people Preferred

    Options Document

    Dear Sirs,

    am writing to you about the proposed provision for a permanent Gypsy and Traveller Site within the

    borough of Chorley.

    reside on the Duxbury estate and am writing to ask you to note my comments in respect of the former

    depot at Yarrow Bridge, Bolton Rd., Chorley, PR7 4AB as a resident in the area, I am not writing in a

    professional capacity.

    have no objection at all to a permanent site being found in Chorley and don't object, out of hand, to the

    proposal to the use of the site at Yarrow Bridge.

    My only observation would be traffic safety in light of the fact that the A6 is a very busy road already in that

    area especially since the building of Myles Standish Way. Within a short distance you would have traffic

    joining the A6 from a number of junctions starting with Carr Lane, then Hogs Lane, the proposed site, the

    public house, Taylor's Garage, Springwood Drive, Myles Standish Way, Duxbury Park (people often park

    outside the park entrance}, Worcester Place and then Wigan Lane. There are also a number of properties on

    the A6, which access onto the A6 directly.

    am not sure if it would be safe to introduce another form of access to the A6 at that site and given that the

    land is surrounded by existing properties and the canal it's hard to see how safe access and egress could be

    achieved in light of the existing traffic issues in that area. My observations are made with everybody's

    interests in mind and strictly from a road safety point of view, I have no objection in principle to a

    permanent site being found for travellers in Chorley.

    Regards,

    Simon Robinson.

    Kevills Solicitors5 Park Road

    ChorleyPR7 1 QS

    Tel: 01257 265711Fax: 01257 266925

    www.kevills.co.ukwww.lawyersontheweb.co.ukVAT number 155 3473 63

    Follow me on Twitter: @SiChorley

  • X- - --

    Skype Address SiChorleyq

    Partners: SA. Robinson LL.B (Dip PI Lit}, Vicky K. Nicholson LL.B.

    Regulated by the Solicitors Regulation Authority#00060398

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    this e-mail is intended to create binding legal obligations between us and opinions expressed are

    these of the individual author.

    Regulated and authorised by the Solicitors Regulation Authority #00060398

    Partners: SA. Robinson LL.B (Dip PI Lit), Vicky K. Nicholson L1.6.

    www.kevills.co.uk

    www.lawyersontheweb.co.ukVAT number 155 3473 63

  • Chortey Local Plan 212-2026Gypsy and Traveller and Travelling ShowpeopiePreferred Options (June 2014]

    Representation Form

    4 JUNE ts~ '16 JULY 2014

    ~~-~ r1e~Co~.~ncil

    Ref Number:GTi9

    offlaiat use only

    Chortey Courcii is seeking comments on the Gouncil's preferred iacation fcr the provision aF a minimum of 5 permanent Gypsyand Traveller pitches (Cttodey local Plan 2(112-2026}. The Council has also considered and discnunteci a number ofaftemativa sRes and welcomes views an these. A Schedule of Proposed Fu[ther Modifications which includes a proposedpolicy an Gypsy ar~d Traveller ar~d Trave111ng Shopwpeop[e (Policy HS11} to the Lora! Ptan has also been produced.

    This consu#tation is intendsr3 #o invite commen#s on the sif~s (and whether the ciacumant is a j [egaCiy campfiant and bj sound.Further guidance an this is provided at the back of #his form}.

    The Council is not inviting views fln whether this proposed atfrrcation is suffici~en# to mee# the perrnanent and transits needs offire Gypsy, Traveller an~i Travelling Shawpeopie Carnmunity as this issue is being considered in a separate (3evelopment PtanDocument (t3PD —taken fo~xard L~ecemR~er 2014).

    Ef you have any views on the Preferred Options document, please use this #o~rn. Copies of the Preferred Options documentalong with ati accompanying inforrtaation can be viewed a#:

    The Council's website va~v°v~r_chor~ey_g~av_ukl~ta*~nfLocal libraries and Posk Qffices in villages v+fiihaut a library {paper cap'ses). The documents are availabfe [or inspectionduring normal apenirtg hours. The limas of opening can be viewed on the Council's webs te.Charley Council {Jffices at Union Street, Ghorley —open Noonday to Friday 8.4~am — S.aQpm.

    Please complete this form and email ~t to g~nniczc3-~1icy~a?~hc;rl~~r.gov.~:k ar past to Planning Policy, Civia £Nfiaes, UnienStrset~ Chorley, PR7 1A#_.

    For rr~or~ irrfotma#ion please call: ~i12'~7' S1Si5t

    Pfease note the deadiir~e for responses to E>e reeetved is 96 July ZOid, by 5pm at tine Lafasf. Ef responses arereceived after this deadline unfortunately they will not be considered. Please ai{ow far postage delivery times.P4ease note that your cammunfs cannot be treated as confidential {see below}.

    Data Protection S#aternentThe information you provide vriR be held end us~ti by Choriey Council, ir. accordance v~~ith the Data Prat~ction Rci '! 998, tc, helpin the preparation of the l.acaS Pfian. Please note that all responses received wit! be available #or public ins~ecfion and +rtitl tieplaced on the Council's ivehsite. This vrill include your name but the ~rrEainder ofi your ~ersanai cfaiaiis will remainconfidential. Anonymous representations will not be accepted.

    lnapprcpriate. of#ensive or racist comments ;+~+ li not be accepted.

    Thank you for taking the time fo com~#ete this form

    Please fill in yc~ut details below, or if an Agent has #peen agpoir~ted, their details-

    3'~ck as ~~ rc~priat~ ~~ . P~r~c~r~a~ t#~e#ails ~" Agent aet~~~s ~

    Title

  • This consultatson~ seeks views on the sui#abiEity of sites and no# the principle of

    all+~~ating sites. P~e~se fill 1n your c+amments b~lc~w. Phase use a separate

    form if you wish to make comments nn more than one si#e.

    Ta which part of the Preferred i~ptions document foes this representation relate? (please state}

    Site Fief Nol 31~n~;,,,~~~r~ ~,~~.;~ ParagrapF► NumberLacatian ~ ~►-~~,~^, ~.~ 4~

    FurtherProposedMoc3~ficatiaNumber

    1, 0o you gave any evidence crr information abou# #hts site which w 31 I~eip tt~e Council to

    demeans#ra#e that this site is available, suitable and achievable for Gypsy provision?

    °-

    ~. Dc~ you agr~€~ that the ~Coun~i#°s pre~erret! si#e at C~wting Earrn shQUld be taken frrrward as

    a #orma! attt~cation?

    Yes ~

    Na

    3, Do you have any other cornrr~ents on the Preferreri dptions document?

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  • 4. t}o you consider the Preferred Op#ions document is: (please tick one box only perrepresentation)?

    ~1} legally C~mp~i~nt Yes ,;V ~ C~t~ ~ }~.> e ~,: }-~,4~ ~~~,~~,

    (2) Svun~i~ Yes ~~ Na

    *Tire c~tnsi+dera~ons i,~ r~Ia~ivn to the Luca! P/are 6efn~ ̀Sound' arcs ~e~plalrred ~n theNational P#arming Pcadlcy ~tarrrsrnr~tirk in para~ra~ir 'i82.

    ~. Do you consider the Pre#erred Options document is unsound because it is not: (pleasetick box one box only peC r~pre~en#atiott}? Explanations of these terms can be #ouncl in the GuidanceN»tec

    ('3? Pc~s~tiv~ly prepared ~..~

    (2} Justified

    (3} E~~ctiv~

    ~4) ~~nsi~ter~t with national policy

    6. Ptease give details of why you consider the Preferred Ctp#ions document is not legaltcompliant or is unsound. Please be its precise as possibl$. tfi you wish to support the tsgacomptianGS or sa~r~dness cif the Pref~~ed Uptiflns document, please also use #his boy to seo~# dour common#$,z _

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  • 7, Please set out what changes} you cansicier necessary to make the Preferred Options

    dacumen# iegaily compliant or sound, having regard to the test you have identi#ied above

    where this reia#es t4 soundness. You will need tc~ say why this change will make the

    Preferred Options documen# t~gally compliant ~r sound, It wilE be helpful if you are able to

    put forvvard your suggesfed revised urording of any policy 4r tex#. Please be as precise as

    possible.

    Please nofe yt~ur rep~esentatfon should cover sctcc ncfly a!! the information, evidence end

    supporting information necessary to support / jusfify fhe representation and the suggested

    change. After this stage, furfher submissions wit! only be at the request of the Inspecfor, based

    on the matters and issues she td~ntifies for exat»ination.

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    8, If your cepresentation is seeking a chan~e~ wcsuld you 1ik~ to ~aartici~ate at the oral part of

    th+~ independent examination due to talcs place on 23 and 24 Sepdember 241 ? (please tick

    bax~.

    No, i dti not wish to participate at the rxral examination (~~'

    Yes, I do wish to participate of the ara! exarr~inaticrn

    ~. If you wish to participate at the Arai part of the ndepe~dertt examina#ian, prase outline

    why you consis~er #his to be necessary:Please note the Inspector vuill determine the most appropriate procedure to adap# to hear

    these w~a ha~re indicated that they wish to participate ~t the oral part of tine exam~nat~on,

    r ~" /'t ~°

    Signature;

    ~~~~`~Gc~unCil

  • i~~

    Choriey Loca{ Plan 2012-202#1Gypsy and Traveller and Travelling Shawpeople ~ ~ ~ ~ f ~~~

    Preferred Options (June 2f1'14) C o u r~ c i

    Ref Number:

    RepresentatEOn Form G TIg7O~c3al use isnly

    4 JUNE to ~6 .JULY 21114

    Choriey Council is seeking comments on the Cauncii's preferrarf location far ttYe provision o(a minimum of 5 pemranent GYPSY

    and Traveller pitches {Chorley Local Flan 2 12-2028}. The Council has also considered and discounted a number of

    aite~`riative sites and welcomes views on #here. A Schedule of Proposed Further Modifications which includes a prc~ossd

    policy on Gypsy and Traveller and Travelling Shopwpeople (Policy HS1 T} to the Coca! Plan has also been produced.

    This consultation is intended to invite comments on the si#es {and whether fhe document is a) legally compliant and b} sound.

    further guidance on this is provided at the back of #his form}.

    The Gouncl is not inviting views on wrhether #iis proposed altocatiort is sufficient to meet the permanen# and transits needs of

    ~~ ~Yp~Y~ T~ve1ler and Travelling Showpeo~le Commu~ifi} as fhs issue 'ss b$ing cans~ered in a separate [}eve!opmenf Plan

    Qo~umeni (DPB -~ taken forward December 2014}.

    !f you have any views ors the Preferred Op#ions doctttr~ent. pease use lhis (orm. Copies of the i'referred Opiigns doGUtnent

    along with alt accorriparrying inforrnafion can be viewed at:

    ■ Ths Counc~`s watrsite www,ci~o~iev.gov.~k_glae~ni~:a

    • Local 4 braries and Pali ~ffic~s in villages without a library (paper copies)_ The documents are available #or inspection

    during nrnmaE opening hours. The times of opening can 4e vsewed on fha CounciYs websife.

    • Ghorley Council C3it'~s at Union Street, Chorley —open Monday to Friday $.45artt — S.flOprtt.

    Please camptefe Skis form and email if to ptanni~so.ct~licvac~crE~3.~ay.uk or Rost to Planning Policy, Civic Offices, Union

    Street, Chortey, F'i27 iAL.

    For mare informat{art pease c~aif: 01257 515151

    Please note Fhe deadline for responses to be received is 46 3uly 2414, by 5pm at the latest. If responses are

    received after this deadline unfortunateEy they will not be consitier~d. Please aEiow for postage delivery times.

    Pisese note chat your comments canr~o# be treated as confidentia{ (see below},

    Dafa Protacti~n StatementThe information you provide w#II be held and used by Choriey Coureif, in accordance with the Data Prot

    ection Act 1998, to help ~

    in the preparafion of the Lacai Piaa. Please Hale that atI responses received will be available for public inspection and uriii be ~

    placed on the Council's websi#e. This will include your name twt the remainder of your personal deiaiis will remain i

    confidential Anonymous representations will not be accepted_

    Inappr~pria!e, offensive or racEst comments will Hat be accepted.

    Thank you for taking the time to complete this form

    Pteas~ fill ia~ your details below, or i# an Agent has teen ap~flin#eel, their details.

    ~`ic~c as at~prQpriate (~}: Personal Details (~1 At~~nt Cletaits C

    T(t!e ~ t\ ~ "~ ~~'~ ~ c;

    First Name r~'l~(~'t-r ~~~U.~ '~.-ZE~~~~~~'t~'

    Last Name ~;; ~c.~

    Organisation _ __where relevant

    ~ Job Titlel ~ ._~.,~.PositionAddress Line 1

    Address Line 2

    E TOWt1 BIB ~1QC1E CIUR'13}~(

    Post Code i Email adt~ress~~.,,,~-

  • This consultation seeks views an the sui#ability of sites and not the princip3e ofa![ocating ~i#es. Please fi11 ire yrsur ~ommen#s below. P[~~se use a separateform i# yQU wish to make comments on mare than ane site.

    'To which part of the Preferred Options dr~cum~nt doss this representation relate? (please state)

    S(te Ref No/ -~"~~~~s~~.. ~ ~~ ~~ Paragraph NumberLocation ~1~~ G`€-{~~z.~,~~

    FurtherProposedMadificatioNumber

    9. Do you have any evidence or inforn~tatio~ abouf this site which wi![ help the Ct~uncil to

    deman~tra~Ee t3~at this si#e is available, sui#able and achievable for GYp~Y Provision?

    2. Do you agree that the Council's preferred site at Ct~wling Farm should be #aken forward asa forma! allocation?

    Yes

    No

    3. Do you E~ave any other comments on the Preferred ~ptiQns document?

    !_.-E' `

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  • 4. Do you consider the Preferred Options document is: {please #ick one box only p+~r

    representation)?

    (1} ~.egally Compliant Yes ~~"'] No (~ t'`e ~`a ~ ~

    t2} Sounr~* Yes ~ No

    The conside~ratlons fn relatfvn to the Luca/ 'Ian being °Sound' are exp/atn~d fn the

    Nationaf Plar~ning Policy Framework In paragraph 182.

    5, Dc~ you ec►nsider the Preferred Qptinns documen# is unsuunc~ k~ecau~e it is nnt: (pleastick box one box onty pet represetltatlon)? Fxpfanations of these terms can be found in the Gui~fance

    lVnt~c

    (1 } Posit veiy prepared

    ~2} Jusiifed ~y

    (3} Ef#e~ve

    ~4) Gc~nsistent with natiorta( poficy [~

    6. Rlease give tfe#alts of why you consider the Preferred Options document is not legalf

    c+~mp[iant or is unsr~und, Ptease be as precise as possible. If you wish to support the iega

    compliance or soundness of the Preferred t~ptians document, ~alease alsfl use this hQx to se

    +~u# your comments.

    ~, Wit,.

    ,~ -

  • 7, Please set out what changes} you consider necessary try make the Preferred Options

    document legally compliant or sound, having regard t4 the test you have identified above

    where this relates to soundness. You wi![ need to say why this change will make fhe

    Preferred Options document legally compliant or sound. It wil! be helpful if you are able to

    pu# forward your suggested revised wording of any policy or #~xt. Please be as precise as

    possible.

    Please note your representation should cover succinctly all the information, evidence and

    supporting information necessary to support / jusfify fhe representafion ar~d the suggested

    change. After tf~is stage, further submissions will only be a# the request of the Inspector, based

    on the maffers and issues she idenfr~es for examination.

    ~~ ~1~-

    $. 1# your representation is seeking a change, would you like tc~ participate at the oral part of

    the independent examinatian due to take place on 23 and 24 September 2014? (please tick

    box}.

    Riv, f dc~ not wish #a parkicipate at the oral examination ~~

    Yes, 1 da wish to participate at the oral examination

    9. !f you wish to participate at the oral part of the independent axart~ina#icon, please outline

    why you consider this to be necessary;Please note the Inspector wilt determine the most appropriate procedure to adopt #o hear

    those who have indicated that they wish to participate at tt~e oral part of the examination.

    t',rffjS

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    1

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    date: i 5~~~~~ c ~ t~..,~

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  • About yvu

    Cl~otiey ~Q~nci1 is com~it#ed t~ m~ic ng sure that it takes into acct~unt the views of everyone in the. t~oro~agh,Pieass answer the fr~~lowi~tg questions. You des r~o~ hive to ~t~swer these c~e~~stions bu#~ if you ~o, your~nsur~r~ will be used to rna(ce sure tit tiur service are be ~tg accessed equally. ~veeything you felt ~s ispr~~ate and confidential and wi~E nofi be stared,

    Q'~ Gan yt~u please cr~n rr your ful# Post Code?(l'~. A~~ WRITE FULL f~~~~(3DE !t~ BC}X e.g. PR71CiP}

    t~~ Are yvu, {F'I.ER~E T#CK ,~ C3~2E BMX C3~L'Y}

    Male .,....... ,~"~J Fema#e ............. ❑ 7ransgender .,...~,...... ~ Pr~f~r not #o ansvHSr ...,......... CJ

    Q3 What r~ras pour age on y~~r last bi~fhday?4~.~~s v~~~~r~ ~t~ st~x} :~ ~ dears

    Q4 Are you an $mployee or Counc~llctr crf C~~r~ey Council? {~€,EAS~ T1~ ✓ ~~1E BOX ~3 ~.Y)

    Employee..._.__.... ~ GounciCtor ............. ~ Neither cif these; .......,.,....~

    Q~ ~3~ you have any tong-standing it~n~ess, di~agt`ti~r ur infi~nity~ ~ ~ng•stanclang ►Weans~nr~hing that has tr~ubl~d yr~u aver a ~srioci ~f t rr~~ ter ~ha# is i~kety to affect you over apetic~d of time) {PLEASE TICK ~' ~3NE BtiX C}tVLY}

    Yes .................... ❑ hFa..........................~Prefe~ rso# t~ answer......,..,,,.,....

  • Bibb s Farm Scout CamY p,,; ~`~„~`,,,,,~r~'- ' and Activity Centre

    f~~ p~r~,~c~rr~~t

    Date 16th July 2014

    Planning Policy Civic Offices

    Chorley Local Plan 2012 —2026 Gypsy and Travellers and Travelling Show People

    Pref