Planning Application 93628/FUL/18


Objection and Comments of Trafford Green Party





General summary

We object to the proposals.

The proposals and the accompanying documentation are poorly presented and significantly incomplete.  There are gross inconsistencies between documents and many vital plans are illustrative only.  A decision cannot be made on this application until satisfactory details on layout, restrictions on public access, end-user, drainage and flood risk, contamination, bio-diversity, lighting, pitch design standards, traffic usage and safety issues, have been provided - with consistency across documents.  Planning permission could not possibly be granted when the relevant plans and documents present such divergent information, and when essential details are missing.  

The whole set of proposals and accompanying documentation bear all the hallmarks of a hastily- and poorly-constructed approach – as is evidenced by the number of indicative or illustrative plans included.  This approach is not compatible with the scale of development proposed and the widespread implications.

The proposals are clearly in contravention of National Policy as contained within the National Planning Policy Framework, and in particular Green Belt Policy. They are also clearly in contravention of a number of planning policies adopted by Trafford Council in its Development Plan Documents.  We do not believe that the proposals could be amended or conditioned in any way to overcome these contraventions.  Similarly we do not believe there is sufficient detailed and accurate information to allow for any meaningful Section 106 agreements to be concluded to overcome the major planning concerns and that therefore there is no way of securing the supposed community benefits outlined within the documentation. 

There are significant and worrying errors within a number of the key documents submitted with this application.  A decision cannot be made until these are rectified.  Other documents are incomplete and the results of further surveys are apparently still awaited.  It is not possible for consultees to make fully informed responses on the basis of incomplete, erroneous or confusing documentation, and we request that the application is withdrawn until full, complete and accurate reports are provided.

Notwithstanding the above, if the application is not withdrawn, given the contravention with adopted national and local planning policy and the existence of a large number of harmful other material considerations, we believe that the local planning authority has no option but to dismiss this application.

Furthermore, given the seriously flawed nature of the consultation process, together with the clear non-compliance of the proposed scheme with established national/local Green Belt Policy and a number of adopted Council policies from the Core Strategy, we believe that to approve this application could lead to a successful Judicial Review of the processes.  

We call upon the Council to make public the terms of the proposed lease with Salford City FC (or with Academy 92 if this is the correct terminology) since without this information, it is impossible to consider the crucial issues of exactly how much land will be lost to free and unrestricted public use; what rights the lessee will have over pitches, buildings, and other adjacent land; and whether the council has got the best financial deal for the community – one which will guarantee the supposed community benefits in perpetuity.

Finally, we contend that the application should be referred to the Secretary of State as a significant non-compliant proposal on the basis that it is a significant inappropriate development in the Green Belt and a Flood Plain; that it would lead to loss of a large amount of an area of playing fields; and that it would be in clear contravention of a number of adopted development plan policies.


Summary of findings

  1. The documentation, including plans is totally inadequate for the purpose of making a reasoned decision on this application.  Errors, omissions and inconsistencies mean that many consultations will have been carried out based upon misleading information, and it is impossible for the planning authority to know what it would actually be giving permission for.      
  2. There are crucial inconsistencies both between and within documents.  In particular:
  • There are inconsistencies in the use of Academy 92, A92, and Salford City FC within documents and between plans – we point to inconsistencies in labelling of buildings and pitches, and also when referring to the potential lessee.
  • There is confusion as to the role of UA92 in the proposals, not least because there has not yet been a planning application relating to UA92 and so its future existence remains in doubt.
  • There is a large irrigation storage tank that has appeared on the revised car park layout masterplan.  This is not described on the application form, nor is it referred to in any other document or shown on any other plan.  This item is not considered in any appraisal document.
  • There is total confusion as to the purpose and extent of the fencing to the west of the playing pitches, along with the degree of free and unrestricted public access to be available across or around the “football training facility” – or indeed to what the term actually refers.
  1. There are a number of inaccuracies, or misleading answers on the application form.
  2. There are inconsistencies between plans, but also, worryingly, many of the plans are illustrative only and are on a scale where it becomes impossible to assess the true impact of the proposals.  In particular the plans of pitches need to be given a larger scale with measurements, in order to assess implications for, amongst other things, trees and, by association, biodiversity and landscape.  Also Appendix E to the Flood Risk Assessment shows the proposed 3G pitch at 90 degrees orientation away from that of every other plan.
  3. The Design and Access Statement has the feel of one that has been hurriedly put together, with insufficient thought over many vital details, and with some evidence of having been amended badly as ideas have changed over time – and maybe still changing?
  4. The Supporting Planning Statement is a very disappointing document – it is full of inaccuracies and generalisations, and it fails to deal adequately with a number of vitally important planning issues, including compliance with adopted national and local planning policies.  In particular:
  • It fails to assess the appropriateness of the proposal to Green Belt in anything other than a superficial way.  The proposal is very clearly inappropriate development in terms of both building and engineering operations; it would be harmful to the openness of the Green Belt; and it would result in the encroachment of urban park facilities into an open countryside environment.
  • It fails to note that “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations”.  There would clearly be other harm in terms of harm to the landscape and biodiversity, and there would be harm by way of adverse effects on highway and pedestrian safety; loss of free and unrestricted public access; noise and lighting issues; loss of on-site storage facilities; a net loss of 8 pitches, and potential flooding risks both across the site and outside of the site boundaries.  Potential benefits are restricted to the provision of a café and play area – the demand and/or need for which is highly debatable and un-evidenced; a 3G pitch which could be sited in any number of appropriate non-Green Belt locations, and which would only benefit a limited number of footballers; and re-designed changing rooms, which would have no additional space than is currently available.
  • It gives totally inadequate consideration to the relationship of the proposals to relevant policies in the Council’s Core Strategy and other Development Plan Documents.  A full consideration of the policies shows that it conflicts significantly with Strategic Objective SO5, Place Objective SO5; and policies L4, L5, L7, R2, R3, R4, and R5 of the Core Strategy.  This should be added to its non-compliance with National Policy on Green Belt (amongst other things), and other harm caused, to make it impossible to recommend the proposal for approval on this basis. 
  • The proposal does not comply with Policy P1 of the Sport England Planning Policy Statement relating to Playing Fields, despite an attempt by the Statement to indicate that it does.  Neither does it comply with the Council’s own Playing Pitches Strategy
  • It relies on support from the “Refreshed” Stretford Masterplan which, in the case of Turn Moss was based upon a seriously flawed consultation process and which should, therefore, be disregarded.
  • References to the Salford City FC community programme should be disregarded.  Any supposed benefits would be minimal and non-specific to the local community.  Furthermore there is no reason to suppose that such benefits (including references to “healthy eating” programmes) could not be provided by local community groups instead, and in a way that is compatible with national and local planning policies.


  1. The Ecology Report is totally inadequate.  It only covers the eastern half of the site; it ignores consideration of ponds on the fringes of the site where amphibians may well be present; it ignores the existence of Sites of Biological Importance adjacent to the site; the survey was carried out on one day only by one person; there is insufficient survey of foraging bats and of birds, resident or migratory, on the site and in the surrounding area; there is no reference to the Greater Manchester Ecological Framework; and there is no consideration of the Impact Risk.  Further surveys are needed at different times of year and covering a full site and full wildlife implications, in line with best practice guidelines. 
  2. In the absence of any detailed scaled plans of pitches etc, the arboricultural survey is incomplete, since it is impossible to assess properly the impact of the proposals on hedges and trees within and around the site.
  3. The Transport Report is fundamentally flawed and incomplete.  The TRICS data used refers only to usage by 5-a-side pitches, ignoring all usage other than that by the 3G pitch and Salford City Football Club.  The traffic survey took place only on one day in winter and then only at a time when it was dark and very little usage would have occurred – this is totally unrepresentative and worthless.  It totally ignores traffic generated by the football training facility at the times when users would be arriving and leaving.  The fact that the proposed access road within the site is only 5.5 metres wide (contrary to what is sown on the plans) is not considered in terms of pedestrian and vehicular safety.  The seriously substandard visibility at the junction Turn Moss Road and Edge Lane is glossed over in an unacceptable way.  The use of Turn Moss Road for access to the Hawthorns is not considered.
  4. The Travel Plan is not fit for purpose and would appear to be generic in that it refers only to use of the site by “Staff”.  It is incomplete.
  5. The Flood Risk Assessment and Drainage Strategy incomplete and inadequate.  It gives insufficient attention to policy guidance given in the NPPF (paragraphs 100 to 103) and fails completely to make any assessment of the risk of flooding from groundwater, despite requirements of the Manchester, Salford and Trafford Strategic Flood Risk Assessment.  There is no assessment of the existing drainage facility other than a vague reference to underlying strata.  There is no attempt to track the route of drainage from the site or to assess the causes of the recent worsening of the flooding on the eastern side of the site.  There is no detailed strategy for any new drainage systems and the map showing the general strategy is inadequate and shows the 3G pitch in the wrong location.  There is not attempt to consider the possibility of potential flooding risk outside of the site due to the proposals.  There is no assessment of the implications of irrigation systems on drainage. 
  6. The lighting report shows internal inconsistencies while Appendix B actually refers to the wrong scheme.  
  7. The Ground Conditions report is incomplete and we still await the results of a Phase 2 site investigation, without which the application could not be considered since there is potential threat to human health that could not be covered by condition or other agreement at this stage. 
  8. There has been no Noise Survey despite noise implications across the range of development proposals.

In conclusion, the application has clearly been unacceptably rushed such that there are serious inconsistencies within and between documents, the proposal conflicts with national and local policy, and all accompanying assessments are either incomplete, misleading, or inaccurate – or a combination of the three.

On this basis, the application must either be withdrawn pending submission of accurate, consistent and complete documentation (including the application form, the plans, and the supporting documents), or refused on the basis of conflict with policy and lack of credible supporting evidence. 


General Issues

We fundamentally object to the current proposals contained within Planning Application 93628/FUL/18.

There are a number of inconsistencies both within and across documents submitted with this application.  In particular, the role of UA92, Academy 92 (A92) and Salford City FC (SCFC) alongside the Council is totally confused.  Insofar as UA92 appears to be one of the main drivers for the proposal, (as is clear from the report to the executive Committee on 2nd October 2017 and other subsequent public consultation documents) this application is premature in that UA92 as yet has no planning permission to use the proposed site at “Kelloggs” for its base, and the whole project is considered High Risk on the Council’s Strategic Risk Register.  There is no need to proceed with this application at this stage and with such haste other than a perceived desire of SCFC to develop a training facility with undue and relentless speed.  This is insufficient reason to process this application before a number of serious issues concerning weaknesses, inconsistencies, and lack of clarity within the proposal have been cleared up and properly evaluated. 

In particular there must be concern over the position of the Council, as a local planning authority, when the Council is making statements about UA92 as if the necessary planning permission for its existence at “Kelloggs” has already been granted.  Does the Council intend to grant that permission, if and when the application is submitted, regardless of the requirements of established planning application procedures?  If the normal planning procedures as required by the Planning Acts are to be followed, which we assume they are, the Council should be planning now for the potential situation where UA92 does not materialise in the form proposed (if at all), and make it clear what alternatives have been considered for Turn Moss.

In relation to the above, we call upon the council to release into the public domain the proposed lease relating to the use of land and buildings by SCFC and/or related bodies (Academy 92).  If UA92 does not materialise then the relationship between the council and the lessee is crucial to identifying the actual usage of the site and buildings; the actual amount of land that will be lost to free and unrestricted public use; the ability of the financial arrangements to deliver the supposed community benefits; and to ascertain whether the council has secured the best possible deal. 

On the basis of the above, and other serious concerns, we submit the following questions/comments, without prejudice to our right to continue to object to the proposal subsequent to answers being provided, if necessary, and to continue to monitor new information as and when it is made available, with sufficient time to consider that information fully.

Our more specific concerns, comments and questions are listed below in summary form.  The list is not exhaustive and may be added to as further issues come to light.


Application Form – Question numbers supplied

There are a number of queries here regarding possible errors or misleading information.

The description of the site as “Playing Fields” is inaccurate.  Turn Moss has completely free public access and is used for a range of freely available public uses in addition to its use purely for playing team games. (Q14).  Similarly, reference to the site as a “Recreation Ground” – as described on the Refreshed Stretford Masterplan Turn Moss Board (TMB), produced by Trafford Council and Trafford Leisure (images by 5-Plus, Trafford Council and Zerum) – is also misleading.  It is an integral part of the Mersey Valley and an Area of Protected Landscape Character.  

The description of the proposed development refers to a perimeter trim-trail, and this description is borne out by illustrations and description on the original Turn Moss fact sheet, (put out for consultation purposes at the commencement of the “Refreshed” Stretford Masterplan consultation exercise) and on related information boards produced by Trafford Leisure and Trafford Council.  However, the trim-trail shown on the submitted site masterplan shows it as utilising only the western side of the site.  This strengthens the assumption that there will be no public access whatsoever to the eastern side of the site?  This requires urgent clarification?

The description of the proposed development omits mention of a proposed large irrigation tank adjacent to the proposed Academy Gym to serve the First Team Pitch.  This presumably would necessitate installation of under pitch irrigation mechanisms, but this also is not mentioned anywhere in the description – nor does it appear on any plans other than the revised car park masterplan – it was not included on the original car park masterplan.  Further consultations are now necessary since this will have an effect on engineering works affecting the wider site and will of necessity have an impact on the Flood and Drainage assessments (See below).  

There is apparently to be no provision made for storage and collection of waste, including recyclable waste.  Presumably this is an omission? (Q7)

The application states that there is no land known to be contaminated (Q14) when the ground conditions survey indicates that there is evidence of contamination resulting from an above ground storage tank.

Why is there to be additional car parking provided but no increase in disability spaces?   (Q10)

The answer to Q12 states that there will be no increase to flood risk elsewhere.  The submitted Flood Risk assessment appears to offer no coverage or evidence to substantiate that statement.

The answer to Q13 indicates that there is no likelihood of impact on protected species or designated sites.  The site is a wildlife corridor and there is significant evidence of protected species, including Bats, on or near the site.

Why is there no need to dispose of trade waste (Q16) when the proposal includes significant commercial elements including offices and a café?

Q18 describes the proposed uses as A3 and D2.  The proposed admin building will also include office space for a commercial end-user(s) (a professional football club and, potentially, the private UA92).  This should be reflected in the description.

With regard to Q20, it is inconceivable, given the degree of pre-application discussion with potential end-user(s) of the proposed new admin building that the hours of use of the D3 element (+offices?) are not known.  These should be entered.

Again it is inconceivable, given the proposed uses within the buildings (new and refurbished) that there will not be air conditioning and ventilation equipment installed. Q22 needs amending accordingly.



There are many questions relating to the submitted plans.  In particular:

Along with many other plans, the site masterplan is indicative only.  Until precise dimensions and positions of the proposed SCFC pitches and run-off areas - along with the same details for the proposed 3G pitch - are made clear on appropriately scaled diagrams, it is not possible to determine the extent of the impact of those facilities on trees, wildlife or footpaths, or to determine the location and extent of any new drainage provisions.  Furthermore, the drawing refers only to Academy 92 training pitches, whereas the new building ground floor plan makes it clear that there is a First Team changing room and the illustrative car park layout plan shows an irrigation tank for the first team pitch.  If there is to be use of the training pitches by the first team this needs to be made clear on the plans and all other references to Academy 92 expunged in favour of reference to Salford City Football Club, since it would then be clear that the training facility is for the whole of the professional football club and not just the Academy. 

Drawing RFM-XX-00-DR-L-0003 (Rev PL02) indicates a realigned footpath between the southernmost training pitch and the running mounds.  On the TMB, the pitches and running mounds are shown as Football Club Facilities.  Can you confirm that the realigned footpath is intended in that position and that there will therefore be unrestricted public access between the various elements of the football club facilities?  

There are 3 Gaelic Football pitches shown on the site location plan (and in the Design and Access statement).  The Council’s Playing Pitches Strategy notes the existence of only two.  This is confusing.  Could you confirm that there should in fact be 3 Gaelic Football pitches on Turn Moss and where the displaced third pitch will go – since it does not appear to be included on any other plans?

It is unclear from the plans exactly where the fencing to the western and southern sides of the training pitches will end.  It is imperative that it is clarified whether or not there will be any free and unrestricted general public access whatsoever around the eastern perimeter of the site or whether the fence will extend to the site boundary on its western and southern arms.  If the fence will extend all the way to the site boundary, then the full amount of land taken out of full and unrestricted public access must be made public to enable informed comments on this matter.  If the fence is to stop before the boundary, then the purpose of the fence should be made clear, since it would completely lack credibility for the supporting documents to claim that there would not be public access across the training facilities without appropriate fencing to achieve this.   This issue is raised in more detail in our comments relating to the Supporting Planning Statement.

None of the plans indicate where storage of large equipment (both SCFC and Council) will be available.  It is inconceivable that all equipment will be brought from off-site every time pitches etc are used or maintenance required.  If it is intended that equipment will be brought in from off-site then this should be reflected in the transport statement, which it is not. 


Design and Access Statement (DAS)

There is confusion created throughout this document by its referencing to UA92, A92 (the Academy for Salford City FC) and SCFC itself.  The document was apparently produced on behalf of the Council and A92.  The introduction, in section A03, makes reference to an “Innovation Corridor” which is a meaningless and misleading concept that makes little sense, and then only in the context of UA92.  Yet the same section makes reference to Turn Moss only in the context of A92 and SCFC and not UA92.

Paragraph 02 of Section A states that “non-sporting visitation will also be encouraged through the integration of new family orientated facilities”.  This would indicate that the building/construction of these facilities would be in contravention of national and local Green Belt Policy, and would appear to contradict statements in other documents, which relate to the benefits to outdoor sport of the proposals as a whole.  This is also covered elsewhere in this report.  


The context, in Section B, is given as the Refreshed Stretford Masterplan.  The consultation for this document in regard to Turn Moss was seriously flawed in that no mention was made of SCFC in the initial information sheets or early consultation meetings, such that any supposed evidence of support is totally unreliable.  We would point to the results of the Council’s questionnaire survey which indicate that only 27% of respondents were supportive of the proposals without concerns, while 35% disagreed with the proposals and 27% were supportive only on the proviso that there would be full access to the public.  This issue is dealt with further in the section on the Statement of Community Involvement below.


Section B04 is largely incoherent and meaningless, with totally unsubstantiated comments related to Turn Moss.  In addition, it fails to note that Longford Park, in addition to a café and two childrens’ play areas (see the photographs), also has a trim/fitness trail (though now in a poor state of repair and maintenance), while reference to the many other facilities in the Park, including a range of sports facilities, is only mentioned in an appendix.  We note that the rationale proposed for the proposed café is that it is required in the context of the provision of professional football training facilities, which is not compatible with community usage.  

Section D03 is confusing.  The aspects of Active Design picked out include a perimeter path for walking/cycling etc.  It is unclear how this will relate to the trim trail which presumably would not welcome cyclists.  Furthermore, the private A92 facilities are erroneously included within the heading “co-location of community facilities” 

The Illustrative masterplan in Section E01 notes that training pitches will be managed by SCFC and A92, whereas the admin building and changing rooms are consistently referred to in the context of A92 only.  This is confusing, especially as floor plans for the building show a First Team Changing Room as well as other facilities clearly intended for use by the First Team as well as the Academy. This section also refers to a drainage strategy which is not provided.  The Flood Risk Assessment does not include any detailed drainage strategy.

Section E03 indicates that the training pitches will have 1.5 metre fencing in specific locations to contain football activity.  It also notes that certain organised community uses of the pitches will occur.  It does not indicate any free and unrestricted public access to these areas.  It is also hard to credit that a 1.5 metre fence will contain professional football activities.  We note that at consultation meetings, the local community was told that fencing would be only 1 or 1.2 metres high (depending on who gave the information) and the diagram in Section F05 gives a totally false impression.  This diagram purports to show a 1.5m high fence.  If that is accurate the spectator is over 2.5 metres tall.  It would appear that an original drawing with a low fence has been used un-amended in an attempt to create a lower-impact image.

The proposed alterations to Turn Moss Road access are not credible.  It is not possible to resolve the insertion of retractable bollards to restrict access in out of hours (or “core-functioning hours) times with benefits to the arrival experience of visitors – especially those who come by car “out-of-hours” to walk dogs etc.  Who will decide what is “out-of-hours” or “core-functioning hours”, and on whose behalf? 

Similarly it is not possible to resolve pedestrian safety issues with a proposal to delineate a narrow pedestrian route with no physical separation from vehicles (as shown on Fig 23).  The access road has been measured as around 5.5 metres wide and not 6.3 metres as shown.  On this basis, it is clearly not wide enough to allow for any safe use jointly by pedestrians, mobility scooters, double buggies, cycles and vehicles (including service vehicles and minibuses/coaches).  .

Section F10 shows soft landscaping appropriate to an urban park or garden, but not to an open area of protected landscape.  This will change the whole character of the area. This is compounded by reference to ornamental trees in Section F11.

In general, this document has the feel of one that has been hurriedly put together, with insufficient thought over many vital details, and with some evidence of having been amended badly as ideas have changed over time – and maybe still changing.


Supporting Planning Statement (SPS)

This is a very disappointing document – it is full of inaccuracies and generalisations, and it fails to deal adequately with a number of vitally important planning issues, including compliance with adopted national and local planning policies.

This document begins with the assertion the application relates to a series of alterations.  This seriously underplays the scale of the proposals.

Para 1.4 repeats the false claim that the site is a “recreation ground”, presumably intended to give it the air of an “urban” facility, which it is not.  Recreation in its full accepted sense does not only relate to organised sports, which is what the term “recreation ground” implies.  The site is a recreational area.

Para 1.7 – there is no indication of how much investment is needed for improvement to facilities, or indeed why such investment could not be found in some other way.  Apart from the 3G pitch, which could be provided in any number of other places, none of the other “alterations” proposed will have any direct link to widening activities in sports or leisure activities, and there are no other improvements planned that would appear to involve large sums of money such that this scheme is essential.

Para 1.8 – SCFC is currently in the sixth tier of English Football but it is the well-documented avowed intention of the owners that it should progress through the tiers as quickly as possible – and it has the financial wherewithal to do that.  This site is totally unsuitable for the training facilities of a major professional club with high aspirations.

Para 1.13 – since the proposal appears to conflict with standard Sport England Guidance, and since the Environment Agency has already objected to the proposal, we can only suppose that any advice given was ignored.

Para 2.3 – there are 3 gaelic sports pitches.  Furthermore, the fact the ground is sometimes flooded does not prevent its use for any number of other recreational uses.

Para 2.5 – It does not link in to the Mersey Valley – it is part of the Mersey Valley.

Para 2.18 – reference to two-way traffic movement ignores the fact that the proposals show part of the road being taken up with a pedestrian route that is not physically demarcated from the remainder of the road.  Furthermore, the access road is only 5.5 metres wide which renders it incapable of accommodating the vehicular and pedestrian movements anticipated.  Reference is also made to the junction of Turn Moss Road with Edge Lane as a priority controlled junction.  Turn Moss Road is a private road with no signage at the junction and no opportunity for such signage to be provided.  It was never designed for the use it is getting and cannot accommodate any additional traffic safely (see comments on traffic below).

Para 3.5 – reference to flooding fails to mention that the site used to drain well, but has not been maintained.  Despite this, it is still useable for part of the year for sports and for the whole of the year for a wide range of informal recreational uses, which is the way such a site in such a location should be used.  In addition, there is no indication anywhere in the documentation as to why existing, properly maintained drainage could not be used to improve the state of the land if required, or whether alternative sources of finance, that did not involve development of a Green Belt site, could not be found to upgrade the drainage system.  Furthermore, if the site can satisfactorily accommodate community usage without the land to be used by SCFC, then there would appear to be no need for any drainage improvements in any event.

Para 3.6 – there would appear to be a lack of consistency here with DAS.  A figure of 1.2 metres (or 1 metre depending on the source) was given at certain consultation meetings, but it appears, from other documents, to have been increased to a height of 1.5 metres in the interim – a point not picked up by the consultants. 

Para 3.11 – SCFC’s aspiration is not a relevant planning consideration and should not be used as an excuse for a hurried and poorly thought out scheme.  In any case, it is not possible to undertake any works that could affect nesting birds for most of the spring and summer months and that would rule out any works affecting trees during this period.

Para 3.12 – there is no indication of what is meant by the “football training facility”.  It is vital that this is clarified.  In particular answers are essential to the following questions:

  • What is included within the term “training facility”?  Just the offices/changing rooms and gym?  Or does it include the pitches?
  • If it includes the pitches, does this mean that the area covered by the pitches will not be available for use by the general public – eg for informal recreation/dog-walking?
  • If it includes the pitches, does it include any other land around the pitches?
  • If it includes the pitches and/or any other land, how will the public be kept out, bearing in mind that the proposed fencing only appears to follow, incompletely, the western and southern boundaries of the pitches?
  • How much land, in total, will be removed from full and free public access as a result of the proposed training facilities?


Without answers to these questions it is not possible from the submitted documents to determine whether or not the proposal will result in a very large amount of public land being removed from full and free public access.  It would however appear from the latest Council produced Fact Sheet for Turn Moss that the proposal would result in 10% of the Turn Moss site being lost to pitches alone.  This is unacceptable in its own right but it also means that the whole SCFC training facility would involve the loss of significantly more than 10%, and possibly up to 20%.  It is necessary for the Council to release the terms of the draft lease to enable such relevant planning issues to be considered.


Para 3.15 - the TMB shows the café as a Football Club facility, though it does not specify which club.  Can the Council confirm that it will now not be a Football Club facility and will not form part of the proposed lease of land and facilities to A92.   Reference to the “physical activity referral base” presumably relates to the work of the Council’s Activity Living Managers who we believe to be already in post, so there would not appear to be any need to move the base to a site effectively in the open countryside. 


Para 3.18 – again the consultants are out of date here – the fencing will be 4.5 metres high.  Significantly different.


Para 3.19 – how will users of the trim trail be separated from cyclists and other recreational walkers?


Para 3.20 – This paragraph states that “Although there are no specific proposals to improve the retained community adult football pitches and six junior football pitches at the present time, Trafford Council will continue to work with local sports clubs and governing bodies to deliver improvements to these pitches in the future”.  There is little or no evidence to show that the Council has been working with clubs or governing bodies in the lead up to these proposals, nor is there any timescale to indicate that existing pitches will be improved at any time in the near future for the benefit of local community use.  This is a major flaw iin he approach y the Council to the development of the proposed scheme.  Furthermore, how does the recent demands of the Council that certain structures used by local sports clubs be removed from the site (with little notice) equate with the assertion that the Council will continue to work with local sports clubs and governing bodies to deliver improvements to pitches?    


Para 3.21 – this is extremely vague and includes no specific commitment.


Para 3.23 – what exactly is meant by the local community – presumably Salford?  If SCFC continues its progress through the tiers of English Football it will be looking much more widely.

Para 3.25 – 3.28 are irrelevant since UA92 remains an aspiration that, at present, has no physical presence in Trafford, nor can it be guaranteed to have, for reasons outlined above – not least that no planning applications have yet been received.  If UA92 were to materialise, we do not see that there is any reason why a private, for-profit University should not simply pay directly for use of Council pitches, or even to pay for drainage works that would enable more pitches to cater for community and University needs equally.  This option does not appear to have been considered despite the references to UA92 in the documents

We are particularly disappointed that the sections dealing with vitally important planning issues have been covered so weakly and with so many omissions.  This only serves to give an impression that crucial planning concerns have been underplayed or ignored – possibly because they put the scheme in a bad light by showing that it does not, in fact, comply with national and local planning policy as claimed.  The following examples, relating to policies in the Council’s Core Strategy (CS), are crucial in showing that the proposals do not comply with local adopted development planpolicies, and that the application should therefore be refused.

  • The consideration given to Strategic Objective SO5 ignores the key point entirely.  No consideration whatsoever is given to the requirement to “protect and enhance the landscape character, recreational and biodiversity value of the borough’s natural environment”.  Recreation does not just apply to sports pitches.


  • Place Objective SO5 relates to the aim to improve the appearance and quality of green and open space within Stretford for recreational purposes.  This is chiefly considered in the SPS in relation to buildings only and, in any case, this is not the same as “recreational quality”.  They are two quite different meanings.


  • Policy L4 - The combined trim trail/cycle route and the new pedestrian route on the inadequate existing internal road, which forms the main access to the trail, would, for reasons already stated, completely fail to provide a safe access.  It does not comply with this policy.


  • Policy L5 –Consideration of the scheme completely ignores the issue of flooding and the likely impact of the proposals on flooding on the site and elsewhere.  There is no detailed drainage scheme and this is arguably the most important aspect of the policy, with which it therefore does not comply.


  • Policy L7 – there is no consideration of disabled access, and it would be arguably more dangerous given the inadequate treatment of the pedestrian route to the car park.  Also there would appear to be no increase in disability parking despite the increase in the size of the car park.  In addition, the proposals would not improve the function of the site as wildlife corridor, area of protected landscape value, Community Forest and protected open space.  It fails to comply. 


There is little or no consideration given to the value of the Mersey Valley in landscape and biodiversity terms.  The Council’s own Authority Monitoring Report 2012 - 2013 notes that “The River Mersey runs east to west across the Borough separating the urban areas of Urmston and Stretford from Carrington and Sale. It is dissected by the M60 and A56. The valley either side of the river forms a unique green wedge of land which is predominately meadowland and agricultural land in the floodplain, containing few buildings and protected from development by Green Belt. It is a highly valued area balanced for nature conservation and recreation in close proximity to populated urban areas.”  The focus of the SPS is on organised team sports and recreation that requires formal facilities.  This is a flawed analysis of the recreational value of the site in the context of the landscape and biodiversity of the site.  This can be seen in the coverage of the policies below.


  • Policy R2 – The inadequate content of the Ecology Appraisal is dealt with in detail in the section on Ecology below.  In summary, we contend that the Ecological Assessment submitted is totally inadequate and inappropriate for the significance of the development to such a sensitive site.  It fails to comply with adopted Council planning policy and should be ignored until a satisfactory report is submitted.  The proposed development, in no way covers the requirements of Policy R2 in that it does not protect and enhance the landscape character, biodiversity, geodiversity and conservation value of the Borough’s natural urban and countryside assets having regard not only to the immediate location of the development site but also to its surroundings.


  • Policy R2 - The landscaping scheme fails to acknowledge the countryside nature of the area, in that much of the proposed planting is limited to the central core and is decidedly urban in nature.  There is no existing planting or landscaping on the site that remotely displays this nature and it is inappropriate.  Planting of native trees is restricted to a narrow line alongside the access road and this does not compensate for loss of mature trees around the central hub and elsewhere around the site.  Once again the proposal does not comply with Policy R2.


  • Policy R3 – The SPS has selected and referred only to 3 elements of the policy.  It has failed comprehensively to address the following:


  • Protect and connect existing and potential sites of nature conservation value and historic landscape features, and seek to create new wildlife habitats as recommended in the GM Ecological Framework;
  • Protect and provide appropriate natural space to connect landscapes and allow wildlife to move through them to adapt to climate change;
  • Mitigate the negative effects of climate change and support biodiversity, for example inclusion of green roofs, green walls and tree planting;
  • Maximise the potential climate change benefits of the network and deliver, where appropriate, the opportunities and requirements set out in Policy L5, including enhanced flood risk management through water storage or run-off protection, integrating mitigation measures such as SUDS into the design, controlling temperatures through shade and other cooling effects, and reducing air and water pollution;


In general, the SPS fails completely to address the impact of the proposals on the landscape character of the area.  The Council’s Supplementary Landscape Guidance Document “Landscape Strategy” (SPG) identifies Turn Moss as part of a “River Meadowlands” Landscape Type.  The table on page 13 of the document amplifies the features, pressures and policy guidelines for such an area, and it is clear that formal recreation use is inappropriate.  The existing playing fields have completely open public access and an open visual character.  The use of a substantial amount of land for the training facilities of a professional football club and a 3G pitch, with all of the associated fencing etc, would clearly be inappropriate and therefore in contravention of the SPG.  


Moreover, the application site falls within the Greater Manchester Conurbation National Character Area (NCA), recently produced by Natural England as part of its responsibilities as set out in the Natural Environment White Paper, Biodiversity 2020,and the European Landscape Convention.   The SPS fails to respond in any way to the Statements of Environmental Opportunity in that document, in particular SEO1 and SEO4.  


It also fails to acknowledge that improvements to health and wellbeing are not solely related to organised sports or other activities that require pitches or tracks. The importance of access to greenspaces for experiencing and enjoying nature and wildlife informally is a point consistently made in the NCA, which notes the benefits to health and wellbeing of such access.


For the above reasons, the proposed scheme does not comply with Policy R3.


  • Policy R4 – It is clear and obvious that the proposals represent inappropriate development in the Green Belt.  Frankly we are amazed that the SPS can limit its considerations only to the proposed two main new buildings and ignore the other building and engineering operations, and then conclude that the range of developments is not inappropriate.  Our detailed comments on this inadequate analysis are covered in the sub-section on Green Belt below. The proposed development is contrary to National Planning Policy on Green Belt as given in the NPPF, and does not comply with Policy R4 of the CS.


  • Policy R5 – The SPS notes that this policy states that development which results in an unacceptable loss of quantity of open space, or does not preserve the quality of such facilities, should not be permitted.  It also accepts that “the development proposed at Turn Moss Playing Fields would lead to a quantitative loss of public open space, on the basis that the land in the eastern part of the site, where the football training facility is proposed, would no longer be available for use by the general public”.  We would note that the proposed 3G pitch would also be a bookable facility and therefore unavailable for free and unrestricted use by the public.  There are no figures given for the amount of the loss of freely accessible loss of public open space, but it would appear from information contained within the documentation that the land lost could be in the range of 8 – 9 hectares, which represents over 20% of the application site.  This is unacceptable, and cannot be compensated for by a childrens’ play area and trim trail as suggested in the SPS.


Green Belt (GB)


With regard to the Green Belt issue, the National Planning Policy Framework (NPPF) states that “The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”  It goes on to state that “Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.”

In this case, the proposals would be harmful to openness; would reduce access to public open land that is currently free and unrestricted; would reduce the amount of land and number of pitches available for the outdoor sport and recreation of the local community; and would be detrimental to the landscape, visual amenity and biodiversity of the site and the wider area.  Since the land is not damaged or derelict, this issue is not relevant.  Whilst we accept that drainage of part of Turn Moss is currently poor, this does not mean it is damaged, but merely emphasises that it is part of a designated Flood Plain and gives an indication of the nature of the Groundwater situation in the area.  Furthermore, there is no evidence provided that the drainage issues could not be solved in an alternative way that does not require inappropriate development in the Green Belt.

With regard to Green Belt protection, the NPPF indicates that a local planning authority should regard the construction of new buildings as inappropriate in Green Belt, and therefore by definition harmful to it.  In this case, the proposals would involve the construction of a new two-storey building for use by a professional football team and the construction of a new café.  The total floorspace of these buildings would be 600 sq metres and they would have a significant bulk.  There is also apparently a proposal to construct a large irrigation storage tank, that could be up to 2.8 metres high.

It is highly questionable whether the provision of what is essentially the training headquarters of a professional football club on this scale is an appropriate facility.  Also the provision of a commercial café enterprise is not appropriate or necessary for use by the staff and players of the SCFC building, who have “breakout facilities” within the building itself.  Moreover, as mentioned above, the DAS clearly states, in Section A, paragraph 02 that “non-sporting visitation will also be encouraged through the integration of new family orientated facilities” (our emphasis), which we take to mean the café and play area.  In any case, the construction of buildings is only appropriate if it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it.  The buildings, by virtue of their floorspace and bulk would clearly fail to preserve the openness of the Green Belt. Moreover, the construction and use of the main SCFC building would appear to necessitate the removal of a number of trees, which would increase its visibility and further harm the openness of the Green Belt.  Finally, the proposed buildings, by virtue of their nature and use would represent encroachment into the countryside of what are essentially urban type uses.


On this same matter we would point to a recent retrospective planning application (75809/FULL/2010) relating to a number of new buildings for use by a professional football club within an existing established complex at Carrington Training Ground.  Here the applicants themselves acknowledged that the proposals represented inappropriate development in the Green Belt and that certain “key elements” would not directly constitute essential facilities for outdoor sport. 

In addition to the buildings, there would be a number of other building operations that would be harmful to the openness of the Green Belt.  Most significantly, the creation of a full-sized 3G pitch with 4.5 metre high fencing surrounding it would have a significantly harmful impact on the openness as well as completely destroying a key view across Turn Moss from the entrance to the site at Turn Moss Road.  It would therefore be harmful to openness (by virtue of its bulk and sense of enclosure), and also by virtue of its detrimental impact on the visual amenities of the area.

Similarly, the construction of a 1.5 metre fence along the whole of the western side of the area proposed for training pitches would have a harmful effect on the visual amenities of the Green Belt and would create a sense of enclosure incompatible with the current openness of the site.  If, as suspected the fence would meet the existing boundary of the site on the northern and eastern side, not only would here be a sense of enclosure, but there would be actual enclosure.  Either way, this element of the proposal would be harmful to the openness of the Green Belt and the visual amenities of the area.

There would also be a number of engineering operations resulting from the proposals including the extension to the car park, new drainage works and excavations associated with the creation of new training pitches, the erection of floodlights, and the construction of a trim-trail/cycleway.  In particular the trim-trail, encircling around half of the site, would be some 1.5 km long with a width of 1.8 metres and with equipment areas at intervals.  This, in itself would represent around 0.3 hectares of land that would surround the whole of the western side of the site thus creating an effectively urban feel that would be harmful to the openness of the Green Belt and would represent encroachment of an urban-type facility into the Green Belt.

The totality of the proposals would be significantly harmful to the Green Belt, conflicting with national policy guidance in the NPPF and with Policy R4 of the CS.    

By way of further support to our contention we would point to the report of an Inspector determining a recent planning appeal (Ref APP/C3620/W/17/3171075) relating to the erection of a 1.2 metre high fence around a site, who noted clearly that “for the purposes of the (Town Planning) Act the term “building” includes any structure or erection and therefore includes fences.  Fences and gates are not listed as exceptions for the purposes of paragraph 89 (of the NPPF)” …. and concludes that “the installation of the fencing and gate would be inappropriate development for the purposes of paragraphs 87 and 89 of the Framework. The development because of its inappropriateness would, by definition, be harmful to the Green Belt and I therefore find that great weight should be given to that harm”. 

There are exceptions, where development may not be inappropriate, including appropriate facilities for outdoor sport and recreation, but only if it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it.  In this case, the proposals are not appropriate; would not preserve the openness of the Green Belt; and would, in addition, conflict with the purpose of safeguarding the countryside from encroachment.”

Furthermore, in a recent legal judgement (Turner [2016] EWCA Civ 466, Arden, Floyd and Sales LJJ), it was determined that:

“Greenness is a visual quality: part of the idea of the Green Belt is that the eye and the spirit should be relieved from the prospect of unrelenting urban sprawl. Openness of aspect is a characteristic quality of the countryside, and “safeguarding the countryside from encroachment” includes preservation of that quality of openness. …… Again, the reference in para. 81 to planning positively “to retain and enhance landscapes, visual amenity and biodiversity” in the Green Belt makes it clear that the visual dimension of the Green Belt is an important part of the point of designating land as Green Belt.

The openness of the Green Belt has a spatial aspect as well as a visual aspect, and the absence of visual intrusion does not in itself mean that there is no impact on the openness of the Green Belt as a result of the location of a new or materially larger building there. But, as observed above, it does not follow that openness of the Green Belt has no visual dimension.” 

In one further case, regarding a judicial review relating to a planning permission erroneously granted by a local planning authority (R (Boot) v Elmbridge Borough Council [2017] EWHC 12 (Admin)), the High Court concluded that “a development cannot “preserve” the openness of the Green Belt when it causes harm to openness. Therefore, if a new sports facility causes harm to the openness of the Green Belt, it is inappropriate development, regardless of the extent of the harm”.

In the light of the above, the following are relevant considerations in support of our conclusions:

  • The proposed buildings are inappropriate development in the Green Belt 
  • The creation of new training pitches and mounds, including a training mound, and the laying of an artificial pitch (or pitches) are engineering operations which, by virtue of the end result and the means of enclosure proposed for these, would be harmful to openness, both visually and in the volumetric sense.
  • The provision of a childrens’ play area, while superficially appearing innocuous, would not be directly related to the use of public and private playing pitches, and would also be inappropriate development.
  • It would be reasonable to assume that the additional use of the area around the existing car park and changing rooms would potentially require works to the access road. In addition there will be the construction of increased parking facilities.  These again would be engineering operations harmful to openness.
  • There are a number of examples of planning appeal decisions as well as case law regarding inappropriate uses/operations in Green Belt that indicate fences as being harmful to openness.
  • The introduction of an artificial pitch in this location, together with fenced off training pitches, a commercial café, a trim-trail and a childrens’ play area would represent the encroachment of what is effectively urban park development into what is currently open countryside.
  • There is already a café and childrens’ play areas, as well as a trim-trail (admittedly poorly maintained) in Longford Park, only some 200 metres away, and the proposals at Turn Moss, as well as representing urban encroachment, also represent undesirable competition to those facilities in the primary urban park in Trafford.  There is no evidence that Green Belt land is needed for additional similar facilities – or indeed, in the case of the café, even sustain such facilities.  Moreover, there is already a recently adopted management plan in place for the Park, as part of its conservation area status, which indicates improvements to the facilities there.
  • Similarly, there is no evidence that this particular area of Green Belt land is essential for the provision of a 3G pitch when there would appear to be no reasons why other non-Green Belt sites could not be used instead..
  • No provision is shown for the storage of large equipment for use either by SCFC in association with its training pitches, or by Trafford Leisure, in association with its management and maintenance of the 3G pitch, or for the use of local football clubs.  This would presumably require an additional building.  Even if stored in the open, which we consider unlikely, this would still be harmful to the openness of the Green Belt.


In terms of the supposed benefits of the scheme, to weigh against the significant harm to the Green Belt caused by the proposals, we have the following comments to make relating to the summary provided in section 4.20.  More detailed comments on specific issues will be provided later in this report.


  • The proposals would result in the loss of 9 existing pitches (as taken from the site location plan) – 7 to the SCFC training facility and 2 for the 3G pitch.  Out of the totality of the proposals, only the 3G pitch would be provided for general public use (and then only by booking, in competition with many other bodies or organisations – presumably including SCFC).  This leaves a net loss of 8 pitches, and makes a mockery of the claim that the proposals would increase “the capacity for more usage and significantly enhancing the existing community facilities for the benefit of local residents”.  As mentioned previously, Turn Moss is not just sports pitches, and the community facilities also include free and unrestricted access to the general public for any number of informal activities that can only take place in the open countryside.  Around 20% of the application site could be lost to free and unrestricted access.  This is unacceptable.
  • There is a false implication that health and well-being can only be improved through developments relating to organised sports – and then only a limited range of such sports.  There are no guarantees anywhere in the documents that any investment will be specifically targeted at the local community, or to improvements to remaining pitches, or to those people who already actively use the site and who would, in the future, be excluded from a large part of it.  There are no benefits contained within these proposals that could in any way make up for the harm to the Green Belt and loss of open greenspace.
  • There is no evidence that this Green Belt site is the only possible site for a 3G pitch.  All the benefits mentioned could be equally well provided with a 3g pitch in an alternative, and preferably brownfield site, location.  No evidence has been provided that more appropriate sites have been considered.  In particular, there has been no consideration given to the siting of the pitch within the grounds of the adjacent Stretford Grammar School, enabling joint use – as has been done at Stretford High School.
  • There is a trim-trail within Longford Park and cycle routes through it.  It would be preferable and cheaper to develop and maintain these existing facilities that are within 200 metres of the application site.  In addition, Longford Park also offers a range of other facilities including tennis courts, disc golf, bowling greens, community allotment, park-runs, play areas, café, pets corner, football pitch, café, community centre, open air stage, Trafford Athletics Club, etc, which makes it more of a recreational hub than Turn Moss could ever be – or indeed, given its location, should be!
  • Improvements to the existing changing rooms involve only internal alterations.  Whilst welcomed, this is not a benefit that outweighs the significant harm to the Green Belt.   In any case, there is no evidence that these very limited improvements would be adequate to meet the needs of the varied clubs using the site or that they could not be carried out anyway using alternative small-scale funding methods.
  • The terms of the lease have not been released by the council and it is not possible to comment further, other than to say that there can be no guarantees that the council will in fact use any of the monies for the purposes of the very limited improvements proposed and contained within these application documents, or indeed that any monies obtained will cover the costs of the proposals, which will be carried out in advance at the Council’s expense.   


The SPS goes on to attempt to indicate that the proposals comply with adopted Council development plan policy.  This has been refuted above, but in terms of further specific points made in sections 4.30 and following, we would make these comments.


In paragraphs 4.30 and 4.31, the SPS sets out part of policy R5 of the CS and accepts that there would be a quantitative loss of sports facilities.  As mentioned above, this would equate to 8 pitches overall.  It then attempts to justify this loss with selective evidence from the Council’s Playing Pitches Strategy (PPS).  The following points require further detail and we will comment as relevant.


We are not sure where the information in paragraph 4.33 is to be found in the published documents, but in any case, it is not clear where these 4 pitches are sited.  If they are on the eastern side of the site, they will be lost to public use.  If on the western side there is no indication that the pitches could not be upgraded with minimum cost to the Council and routine maintenance.  In any event, this relates only to 4 pitches, whereas the scheme would result in the loss of 8 pitches.


Form Paragraphs 4.35 and 4.36, it is unclear how segregated changing areas, whilst desirable, would, on their own, help to increase womens’/girls’ participation in football if there are to be 8 fewer pitches available overall.


With regard to the proposed 3G pitch, the PPS Strategy and Action Plan indicates on page 9 that demand for affiliated team training is already met in the north of the Borough.  Therefore, the 3G pitch could only be needed in the context of competitive matches.  There is no evidence that this Green Belt site is the only option for an FA certified pitch, should the Council deem such a specialised facility necessary.  Moreover, to achieve FA certification, the pitch would need to be larger than shown on the Illustrative Site Masterplan, by virtue of the need for deep run off areas, spectator fencing, and on-site storage of posts/nets etc.  Moreover, a fenced off access path to prevent dirt etc being walked onto the pitch, presumably from the changing rooms, would be required (see the FA Guide to 3G Turf Pitch Design Principles and Layouts).  All of these will increase its impact on the openness of the Green Belt, increase its visual impact across Turn Moss, and potentially require a dedicated fenced path across the car park from the changing rooms, with implications for the proposed car parking provision.    Furthermore, there is no evidence whatsoever, that the 3G pitch at Stretford Sports Village cannot provide the necessary facilities for walking and all ability football.


The PPS also notes the existence of a number of lapsed sites (P10 of the Assessment Report).  It notes that these sites must still “be assessed using the criteria in paragraph 74 of the National Planning Policy Framework, and Sport England would nonetheless challenge a proposed loss of playing pitches/playing field which fails to meet such criteria. It should be emphasised that the lawful planning use of a lapsed site is still that of a playing field”.  One such site is “Manor Farm”, described in the report as the “Former training base of Stockport County FC. Previously had in excess of five football pitches onsite. Held on long term lease from the Council by a private leaseholder previously associated with the Club. The Council reports that the leaseholder is exploring opportunities to transfer the lease to another party, with the new party to retain the site for sporting use”.  This site is a Flood Risk zone 1; is not a wildlife corridor; would appear to have a virtually identical previous use to that of the proposal at Turn Moss; is owned by the Council; has a lawful planning use as a playing field; can accommodate 5 pitches; and is adjacent to a Rugby Club site with similar facilities, therefore we contend that the Council must show that it has considered this alternative fully before making any decision on the Turn Moss proposals.  Lease money obtained from SCFC at Manor Farm could still be used to improve Turn Moss since there would be no displacement at Timperley.


Paragraph 4.44 makes reference to a “football hub site”.  Turn Moss playing fields is a Green Belt area and part of a wildlife corridor, area of protected landscape character, flood plain and community forest.  The concept of a “football hub” of the type proposed is totally alien to the nature and existing benefits of the site, and cannot be seen as a community benefit, especially where it would result in other legitimate recreational uses of the site being curtailed by the football developments.


Policy P1 of the Sport England Planning Policy Statement relating to Playing Fields (SEP) states that “Sport England will oppose the granting of planning permission for any development which would lead to the loss of, or would prejudice the use of, all 

or any part of a playing field, or land last used as a playing field in an adopted or draft deposit local plan, unless, in the judgement of Sport England, one of the specific circumstances applies”.  There are exemptions to this policy.  The SPS mentions 2 of these.

  • Exception E4 states that “The playing field or playing fields, which would be lost as a result of the proposed development, would be replaced by a playing field or playing fields of an equivalent or better quality and of equivalent or greater quantity, in a suitable location and subject to equivalent or better management arrangements, prior to the commencement of development “.  It should be noted that the lost playing fields would not be replaced by an equivalent or greater quantity as is required.  Moreover, the playing fields of equivalent or better quality would be only 3 pitches which would not available for use by the general public but only for groups selected by SCFC, and presumably when such use would not conflict with the training needs of the club.
  • Exception E5 states that The proposed development is for an indoor or outdoor sports facility, the provision of which would be of sufficient benefit to the development of sport as to outweigh the detriment caused by the loss of the playing field or playing fields’.  The policy exception goes on to list a long series of questions required by Sport England when assessing an application against this policy.  There is an additional list when artificial grass pitches are involved.  The proposed benefits listed in the SPS are minimalist and speculative.  Moreover, the SPS completely fails to provide adequate answers to the vast majority of the questions put forward by Sport England as a requirement for a justification of the adequacy of compensation for lost playing fields.


With regard to the use of the Refreshed Stretford Masterplan for support for this proposal, we believe this to be totally inappropriate and meaningless.  Justification for our contention is given in the sub-section relating to the Statement of Community Involvement below.



Statement of Community Involvement (SCI)  


Frankly, and we are sad to have to say this, this element of the SPS is disingenuous, unreliable, and unacceptably selective.  We would respectfully point out the following.


Para 5.1states that “As part of the wider consultation exercise undertaken in respect of the Refreshed Stretford Masterplan between October and December 2017, a comprehensive programme of consultation was undertaken on the proposals to provide enhanced outdoor sport facilities at Turn Moss Playing Fields, including potential training facilities alongside delivery of a range of improvements to facilities that are accessible to the local community “.  No reference to leasing land to Salford City Football Club, or indeed to any other body, was made until November 6th, well into the consultation period


Paras 5.3 and 5.4.  None of the letters, leaflets or information boards produced for the consultation indicated in any way whatsoever that a significant proportion of Turn Moss would be leased out to a professional football club, and that it would thereby be taken out of free and unrestricted public access.  Any reasonable person would have taken the consultation materials to show new facilities, including training facilities, for the use of the local community.  Any results based upon the period between the start of the consultation process and November 6th are therefore null and void.  It is most significant that subsequent to November 6th, as information slowly began to filter into the public domain by largely non-Council means, almost all comments about the Turn Moss proposals were negative.  


Para 5.4 – The questionnaire was based upon the information supplied at the start of the consultation and the results must therefore be treated with utmost caution (see below).  The questionnaire devised for Year 11 pupils had no question relating to Turn Moss and so reference to consultation with young people should be disregarded.


Para 5.7 – The themed event on 28th November was the first general event where the Council formally acknowledged the links between the Turn Moss proposals and Salford City FC, and even then information was patchy, inconsistent and lacked plenary discussion.


Para 5.8 – Comments relating to the issues covered in Table 3 are covered in other parts of this report.


Para 5.9 – The figure of 59% support is totally misleading – see below.

The following are fundamental flaws clearly evident from the shallow and incomplete coverage of the community involvement made by the SPS:


  • Questionnaire results based on a seriously flawed consultation process should be ignored completely.  Many of the questionnaires filled in early in the process would have been filled in based on incomplete and inaccurate information supplied by the Council.  Moreover, it is clear that, even based on that flawed survey, only 27% indicated full support, whilst 27% offered support only on the basis of full access to the public – which there will not be.  The highest percentage of respondents indicated disagreement with the proposals.
  • It is clear from the responses submitted to the Council regarding the Turn Moss proposals within the context of the “Refreshed” Masterplan, and listed in the Council’s Consultation Results document (Secions 2-9), that subsequent to November 6th – the date when the SCFC connection slid gently into the public domain – almost every single response was one of disagreement and/or notice of serious concerns.  This shows up the seriously flawed nature of the Council’s consultation process.


From these fundamental concerns it is clear that any reference to the consultation relating to the Masterplan should be expunged from this document.  We believe the element of the Masterplan relating to Turn Moss should be dismissed completely and its use in support of these proposals ignored.  We do not believe there has been proper consultation with the community on this application and we believe that a specific consultation  process, targeted solely at the proposals as submitted and involving the whole community using Turn Moss, should be instigated and that the application should not be determined until this is done.  Without this, we do not believe that basic rules of natural justice will have been served on this application.


Issues relating to the considerations in Section 6 are dealt with under the respective sections below.


Appendix 3


With regard to Appendix 3, we have made comments elsewhere regarding the failure of the proposals to comply with the Council’s PPS, and also regarding the inappropriate use of the “Refreshed” Stretford Masterplan, to support the application. 


References to the community programme of SCFC are not relevant, since the club is a professional club with its basis in the community of Salford.  There can be no guarantees that any of the supposed benefits of linking with this programme will have any significant benefits for Stretford in particular, or even Trafford in general.  Any community use of the new SCFC training facilities will be restricted to groups selected by SCFC on their terms and again will not necessarily be of significant benefit to the local community.  


Furthermore, there is no reason to suppose that similar benefits could not be obtained through partnership with UA92, should it materialise as an entity in Trafford, since the University would presumably be using existing public facilities at Turn Moss and might be expected to utilise its own outreach programme in conjunction with the Council.  It would not appear that this has been considered an alternative scenario, one which would not require the effective annexation of a large amount of public land that is currently available for free public use.   Since UA92 would not be a sports university but merely a university purportedly specialising in sports business- related courses, it would not require the professional standard facilities included within this scheme.


For the above reasons, we cannot accept that the supposed benefits of the proposed scheme would in any way remotely compensate for the harm to the Green Belt caused; to the loss of free public access to around 20% of the application site; or to the harm relating to its impact on landscape character, wildlife, highway and pedestrian safety, drainage, and noise/light pollution.




The Ecology Appraisal (EA) is completely unacceptable and effectively worthless.  It covers only half of the development site, whereas the proposed trim-trail and cycleway, with the inevitable additional use involved, surrounds the western half of the site but is not included.  Furthermore, the stated intention of the development is to encourage greater use of existing pitches, which are also within the western half of the site.

The EA would appear to have carried out on one day only, and by only one person.  A second partial survey (covering evidence of bat roosts only) took place over two hours on a separate day.  This is totally inadequate and renders the results of the survey unreliable.

The EA fails to acknowledge the existence of a number of nearby ponds, including an overflow pond adjacent to Hawthorn Lane, within 5 metres of the site boundary at its south-western corner.  For that reason also, the Appraisal should be repeated, acknowledging this omission, and including a full survey of the relevant features.  Furthermore, the EA arbitrarily limits its appraisal to water features within 0.25 km of the site.  This is a major development proposal, seriously affecting a wildlife corridor and a major natural landscape area within the sub-region.  The Appraisal should be repeated using a 0.5 km radius of the full site, and thus including those elements measured at between 0.25 and 0.5 km (including those measured at 0.26 and 0.27 km distant, which is so extremely precise as to be liable to minor measurement errors and therefore to require survey in any event).

The also completely fails to assess and survey the effects of the proposed development on both Broad Ees Dole and Chorlton Ees and Ivy Green Local Nature Reserves, which are adjacent to the site, and which are also Sites of Biological Interest (SBI) – Broad Ees Dole being a Grade A SBI and Chorlton Ees being a Grade B SBI.

There is insufficient survey of foraging bats and of birds, resident or migratory, on the site and in the surrounding area.  A one day survey cannot hope to cover these issues, and relying on a historic data search alone is unacceptable. 

Analysis of the ecological benefits of hedgerows and trees, (or the impact of the trim-trail/cycleway) - does not extend beyond the eastern half of the site and is therefore incomplete.  Furthermore, the analysis of the eastern part of the site cannot be adequately carried out, particularly with regard to trees and wildlife, whilst the masterplan for the site remains illustrative only, and the precise scale and location of the pitches, including the 3G pitch, cannot be determined.  The development proposals acknowledge the need to lop certain trees near pitches, but in the absence of clear and measured detailed siting and extent of pitches (together with any proposed fences to keep off dogs etc), it is unclear whether certain of the trees/hedges may need to be removed altogether or would likely be severely damaged. Finally, the proposed line of trees adjacent to the access road would in no way compensate for loss of mature trees elsewhere in the site, since their position adjacent to the main access would render them incompatible with nesting activity of birds, and possibly even roosting or foraging.

We would respectfully point out that the Ecological Framework for Greater Manchester (EFGM) notes that most of Greater Manchester is included within the ‘Urban Mersey Basin’ Natural Area as defined by Natural England.  This document also notes that wildlife corridorsas currently identified in land-use plans will have value as existing habitats and as connections between habitats.  The current application site is a Wildlife Corridor, but this is not acknowledged in the EA.  Moreover, the Mersey Valley is identified as a “Most Natural Area” in the EFGM, which goes on to state that these “can be regarded as the ‘core areas’ for wildlife or the ‘critical ecological infrastructure’ of Greater Manchester” (our emphasis).  Figure 3 of the document shows that the part of the Mersey Valley which includes Turn Moss is part of a “link and buffer” strategy.  The EA, along with the rest of the documentation does not address this issue in any way whatsoever. 


In addition, the EA considers that the development does not require an Impact Risk consideration, although the Natural England guidelines indicate that all rural, non-residential developments of over 30m2 floorspace should be considered.  The site lies within the Upper Mersey Basin Natural Area, and should be considered outside of an urban area.  An Impact Risk consideration should be provided.


Policy R2.2 of the Council’s Core Strategy states that “Where the council considers it necessary, in order to protect the natural environment, developers will be required to provide an appropriate ecological assessment report to enable the Council to properly assess and determine the merits or otherwise of the development proposal. All planning applications submitted for development within, or in close proximity to, any of the Borough’s assets, must be supported by such a report”.  The EA provided is totally inappropriate for all of the above reasons.  The Boroughs assets include wildlife corridors and open countryside landscape character areas which are not even considered.


We contend that the Ecological Assessment submitted is totally inadequate and inappropriate for the significance of the development on such a sensitive site.  It fails to comply with adopted Council planning policy and should be ignored until a satisfactory report is submitted.



Arboricultural Report


This was carried out all on one day in January.  It is impossible to assess habitat considerations adequately from such a cursory inspection.  Furthermore, the report is not able to give a clear indication of the true impact of the proposals on trees on and around the site, since the proposals are illustrative only and details are not shown on an appropriate scaled plan.  A plan showing the exact dimensions of the buildings and pitches, along with precise details of the trim-trail etc are necessary since it is clear that many elements are sited extremely close to trees, and that lopping or other even more severe actions may take place.  This would result in much more damaging impacts on the trees and the overall landscape of the site.


It is necessary that this appraisal be carried out again, in the light of accurate scaled up plans, and with more comprehensive assessment. 



Transport report and Travel Plan

Both of these documents, produced on behalf of Zerum Ltd and Trafford Council, are so flawed and incomplete as to be a totally unacceptable and unsuccessful attempt to provide appropriate information on the impact of the proposals, or on the proposals for mitigation of those impacts.

Reference is also made to the junction of Turn Moss Road with Edge Lane as a “priority controlled junction”, where there would normally be appropriate signage.  Highways Agency document TD42/95 notes that where there are severe visibility restrictions, (and para 6.7 of the report accepts the existence of visibility restrictions), a Stop sign should be provided.  However, Turn Moss Road is a private road with no current signage at the junction and no opportunity for such signage to be provided.  It was never designed for the use it is getting and cannot accommodate any additional traffic safely.  The analysis of likely traffic flows using this junction is severely flawed (see below) and the proposal cannot be supported on highway safety grounds. 

Policy L4.13 of the CS states that the Council will require Travel Plans for all qualifying developments.  The travel plan submitted with this application is worthless.  It appears to be based on a template that does not relate to this particular proposal.  Other than references to the existing context and the proposed development, the Plan is generic.  References to Trafford Council and SCFC are insufficient to hide the fact that the all of the measures in sections 3 – 6 are geared towards a standard commercial enterprise where only “Staff” are involved.   The submitted Travel Plan totally ignores any other visitors or users of the proposed facilities – private and public  - including players, spectators, volunteers, trim-trail users, cyclists and walkers – especially those new to Turn Moss and the facilities that it would supposedly offer.  The Travel Plan needs to be re-issued for consultation following proper surveys and analysis.  It is vital that car usage is kept to a minimum and use of sustainable transport maximised.  The Travel Plan as submitted will do next to nothing to achieve this.

The Traffic Impact Assessment is seriously flawed for the following reasons:

  • With regard to the TRICS analysis, we note that it has been based solely on data relating to 5-a side 3G pitch usage.  This ignores all other types of usage of the site.  It also ignores the fact that the stated intention is for the 3G pitch to be constructed to FA recognition standards and that it would, therefore, also be used for competitive 11-a side matches that could attract spectators. 
  • The data for 5-a side usage has been used to assess trips generated by the use of the site by SCFC, which is completely different.
  • It is inconceivable that only 2 inward trips would occur between 09.00 and 10.00 (Fig 1) when the use by SCFC would begin at around 09.30.  It is likely to the point of certainty that all or almost all of the SCFC players and staff, along with visitors and any spectators, will travel from outside Trafford by car, and they will be arriving at around the same time for training sessions and/or matches.  The figures produced by the TRICS analysis cannot be accepted as realistic in any shape or form.  Furthermore, there is no indication whatsoever of trips exiting the site between 13.00 and 17.00 when the SCFC training sessions will be finishing.  These are serious omissions and must be addressed with a new, appropriate transport assessment.  The current assessment, as contained within section 6.3, which is the most important section of all, is not fit for purpose.
  • It would appear that only one survey was done, and that at 17.00 on a January evening when it was dark.  This is totally inadequate and unrepresentative.  We would request that a visit by councillors be made in the morning rush hour and also on a weekend at a time when footballers are arriving or leaving, in order to experience the true situation experienced by users and local residents alike.  
  • The expectation outlined in section 6.4 is pure speculation and has no evidence base to support it.
  • Section 5 is an abrogation of responsibility.  A claim that Council Parking Standards do not explicitly mention the type and range of usage proposed at the site, does not excuse the lack of any attempt to assess existing parking pressures or analyse likely changes to parking pressures resulting from the proposals.  Neither does this fact justify a conclusion that the provision will be expected to cater for demand, when there has been no attempt to predict this demand.
  • Section 6.7 accepts that visibility to the left for exiting vehicles from Turn Moss Road onto Edge Lane is limited.  Although no details of sight lines have been provided, we fully accept that sight lines clearly do not meet required standards.  The supposed justification made in the report for the wholly unacceptable conclusion that this will “enable the junction to continue to operate in a safe manner” is not credible. The presence of a small pedestrian island has no beneficial impact on vehicles using the junction – and in fact reduces the effective width of the road for turning vehicles, whilst providing an inadequate refuge for pedestrians.  Similarly an assumption is made that increased usage will be minimal, but this is, in any event, based on flawed analysis (see above).  
  • No attempt has been made to assess safety along the access road where it would appear that a sub-standard access road width (only 5.5 metres – see below) is expected to cater for pedestrians, cyclists, disabled path/road users, and two lanes of vehicles (potentially including minibuses and coaches – as pointed out in the document itself (see section 6.3.1)). This is a serious omission.
  • It would appear that the use of Turn Moss Road itself for access to and from car park serving The Hawthorns has been omitted from any survey and analysis. 
  • As noted above, measurements taken on site indicate the width of the on-site access road to be around 5.5 metres, and not 6.3 metres as shown on Figure 23 of the DAS.  The access arrangements for pedestrians and vehicles are therefore totally impractical and based on erroneous measurements.  It is inherently unsafe
  • Whilst the Transport Assessment notes the theoretical sustainability of the site with regard to non-car travel, there has been no attempt to measure existing usage of the site by a mix of users involving both sustainable and non-sustainable means of transport, and the Travel Plan is inadequate in terms of trying to maximise the potential sustainability of the site in terms of access.       


Flood Risk Assessment and Drainage Strategy (FRA)

The FRA is incomplete and inadequate.  It gives insufficient attention to policy guidance given in the NPPF (paragraphs 100 and 101) and fails completely to make any assessment of the risk of flooding from groundwater, despite requirements of the Manchester, Salford and Trafford Strategic Flood Risk Assessment (SFRA).  

It is clear that the flooding currently experienced within the eastern portion of the application site is of relatively recent origin, since the playing fields were apparently still in use until 2016.  This would indicate an issue with groundwater flooding and drainage facilities.  This, however, is treated only cursorily by the assessment, and there is no coherent drainage strategy provided associated with the current proposals.  Moreover, it is stated in the section on Drainage Strategy that further investigations to confirm route and points of outfall are on-going.  No decision can be taken until full details of these investigations are provided and further consideration given to the results, since the results could, and probably, would indicate that the proposals would be likely to worsen flooding potential in the vicinity of the site.

More specifically, the application site is in Flood Zone 3a.  Guidance in the NPPF indicates that “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere


Policy 5.16 of the CS states that “The Council will seek to control development in areas of risk of flooding……This will involve a sequential approach to determining the suitability of land for development….”.  Policy 5.17 goes on to state that “Developers will be required to demonstrate, where necessary by an appropriate Flood Risk Assessment at the planning application stage, that account has been taken of flood risk from all sources (our emphasis) (including rivers, canals, sewers, surface water run off and groundwater) as identified in the Council’s Strategic Flood Risk Assessment….and that the proposed development incorporates flood mitigation and management measures appropriate to the use and location.”  Policy 5.18 continues by stating that “Developers will be required to improve water efficiency and reduce surface water run-off through the use of appropriate measures.”


The FRA submitted with this application fails to comply with these policies.  There has been no sequential test applied in any context other than Flood Zones.  No account has been taken of flooding due to groundwater other than stating that the site is underlain by sand and gravel deposits which tend to be permeable.  No survey has been done on this issue.  Since the eastern part of the site has only recently become prone to significant flooding, it would appear to any reasonable person that the permeability of the site has reached saturation point and that the water table, as well as the existing drainage provision, requires a full and appropriate survey.  This has not been done in the document, despite the site appearing on Map 2.1 of the Council’s SFRA as an area at risk of groundwater flooding.  


Para 101 of the NPPF states that “The aim of the Sequential Test is to steer new development to areas with the lowest probability of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower probability of flooding. The Strategic

Flood Risk Assessment will provide the basis for applying this test. A sequential approach should be used in areas known to be at risk from any form of flooding.”  (our emphasis).  This has not been done.


Para 103 of the NPPF states that “When determining planning applications, local planning authorities should ensure flood risk is not increased elsewhere and only consider development appropriate in areas at risk of flooding where informed by a site-specific flood risk assessment following the Sequential Test”.  Again the submitted FRA does not provide any assessment whatsoever of the possibility of flood risk being increased elsewhere, and therefore fails unacceptably short of meeting the requirements of established National Planning Policy.


The description of the proposed development omits mention of a proposed large irrigation tank adjacent to the proposed Academy Gym to serve the First Team Pitch.  This presumably would necessitate installation of under pitch irrigation mechanisms, but this also is not mentioned anywhere in the description – nor does it appear on any plans other than the revised car park masterplan – it was not included on the original car park masterplan.  Further consultations are now necessary since this will have an effect on engineering works affecting the wider site and will of necessity have an impact on the Flood and Drainage assessments.  This adds to the inadequacy of the report in dealing with drainage issues associated with the proposals.


Appendix E shows the proposed 3G pitch with a north-south alignment, whereas every other plan shows it with an east-west alignment.  The drainage strategy is therefore obviously wrong – as well as being totally inadequate for purpose.


Finally, on this particular issue, we would stress that on a Green Belt Site that has special landscape quality, wildlife interest, and a wide range of recreational uses, the sequential test should have been applied fully in line with national and local planning policies.  There has been no attempt to consider other sites and, in particular, no attempt to investigate the Manor Farm site noted earlier, which would appear to be suitable in all relevant regards for use by SCFC and which is sited in Flood Zone 1.

With regard to the proposed drainage strategy, there would not appear to be one, other than a statement that land drainage will discharge to watercourse.  It is clear that this current situation is unsatisfactory – as accepted by the Council.  There has been no survey done of existing drains or related equipment and the Plan in Appendix E has no key and no detailed indication of any new works other than a brief note on the plan that surface water drainage will connect to the existing on-site network and that new areas will be limited to the greenfield rate.  This is totally inadequate, inappropriate and unacceptable.  The whole assessment needs to be carried out again with proper surveys and full application of the sequential test.  As it stands the FRA fails to meet the requirements of both national and local planning policy.


Technical Issues


The Lighting Assessment, prepared on behalf of Zerum Consult is confusing and inadequate.  Issues of concern include:

Para 2.1.7 – the lighting can only potentially improve security for the section of the proposal relating to the access road and the central hub.

Para 2.1.9 – the visual appearance of the luminaires during daylight hours will be harmful to the openness and the visual appearance of the Green Belt, especially the 15 metre high columns.

Table 3.1 - The site is not a residential area but an area of open countryside beyond the residential boundaries.  It should be classified as E1 and results recalculated and re-calibrated accordingly.  This will affect the overall conclusions.

Paragraph 5.3.4 notes correctly that “The pitch is currently approximately 180m from the closest residential boundary to the North”.  However, paragraph 6.2.6 the report states that “The Floodlight luminaires to the proposed 3G pitch have sufficient cut-off optics and shall be positioned so as to avoid luminaire luminous intensity from affecting residence. This is further negated by the approximate 350 metre distance from proposed pitch”.  It would appear that the report is incapable of ensuring even internal consistency.


The report acknowledges that there is no coverage of the impact of the lighting on wildlife or the visual impact on the Green Belt.  The impact on bats foraging, in particular, is not considered in this report or anywhere else in the documentation.


Appendix B would appear to relate to a different scheme altogether since the client is given as Salford City Reds – a Rugby League Team.  This needs to be corrected with a presentation of the correct proposed lighting design.   We would expect better from such a report, unless the project has perhaps been rushed.


Ground Conditions

The ground conditions report is a desk study with one walkover only, and it is restricted to the road access and central hub.  For this reason, it omits any consideration of the Historic Landfill Site identified in the Environmental Searches Table, which should have been investigated, and it does not follow up the Discharge Consents, also identified in the same table.

A moderate to high level of risk to human health has been identified with regard to an above ground storage tank on the site. The same level of risk has been associated with the Controlled Waters.  We note that this is a Conceptual Model and would question the ability to draw any reasonable conclusions relating to the specific groundwater conditions from a desk study and a conceptual model only.

The extent of landfill and associated contaminants is stated as unknown and the level of risk set at moderate to low.  If it is unknown, then how can a level of risk be allocated?  Surely the precautionary principle must be applied here in the interests of human health and welfare.  This needs further survey.

It is stated that asbestos is not covered in the report, yet other documentation notes that one existing building on the site cannot be used because of the presence of asbestos.  There is a contradiction here that needs clarification.  Again the issue of human health is involved and this should not be glossed over.

Notification of a phase 2 intrusive site investigation is given in the recommendations, with a statement that such an investigation was to be carried out from late-January, with results available at a later date.  We request that no decision is made on this application until the results have been made available for public consultation, in the interests of the health and welfare of potential users of the site.


Noise Impact Assessment

No noise impact assessment has been submitted and we contend that no decision can be made on this application until such a study has been carried out.  The development will result in use of the eastern part of the site by a professional football club during the week and at weekends.  It will also result in a 3G pitch being used potentially all day and well into the evening all year round.  These facilities will be within around 40 metres of the nearest residential property in the case of the SCFC training facility, and around 180 metres of the nearest residential property in the case of the 3G pitch.  In addition to noise associated with the usage, there will be significant additional noise due to traffic generated – especially in winter evenings when there has, up until now, been only quiet enjoyment of the area.  This impacts upon both local residents and wildlife, but has not been covered.




We object to this planning application in the strongest possible terms.

The documentation and plans give every impression that a major proposal has been rushed in its conception and preparation, such that there are fundamental inconsistencies, omissions, inaccuracies and factual errors within and between them.  It is impossible to determine what precisely is being proposed on many levels, and it is not possible for the local planning authority to make a decision on this basis.

Any permission granted on the basis of so many flawed documents, and in the light of clear non-compliance with national and local planning policy on Green Belt; clear non-compliance with a number of adopted local development plan policies; and repeated failures to consider requirements of nationally accepted policy and guidance documents, would render the Council liable to lose a Judicial Review.  

We make this contention in the light also of fundamentally flawed procedures in the consultation process relating to the “Refreshed Stretford Masterplan”, on which much of the support for the proposal is based. In the absence of a fully informed consultation process on the Masterplan, it makes it even more essential that full and accurate facts should now be put to the public on these proposals.  The nature of the documentation as submitted and currently available makes this impossible and we request that the application be withdrawn until such time as this situation is rectified.

In the light of the non-compliance with planning policy, the scale and scope of the various impacts of the proposals, and the confusion regarding the relationships between the agencies involved in the scheme and its documentation (including the Council, UA92, A92, SCFC, and Zerum Consultants), we request that the application be notified to the Secretary of State for possible call-in, in order that the situation can be satisfactorily resolved.