THE FUTURE OF HORWICH
SEEKING A FAIRER DEAL FOR OUR COMMUNITY
October
Dear Councillor Morris,
Many thanks for agreeing to meet us to discuss our concerns about Horwich. These mainly concern the recent and proposed growth in the town and its ability to keep pace with the expected demands which will be placed on its transport, education, health & welfare, sport & recreation and cultural & heritage facilities.
As you will be aware, Horwich has a proud tradition based on its railway heritage which it is keen to preserve. It was an independent and self-supporting town before Local Government reorganisation in 1974 and there are many people who believe it has not had its fair share of investment and support from Bolton Council for many years. The Middlebrook development has certainly benefited the area but at the expense of the prosperity of Horwich Town Centre and in these financially constrained times, Horwich Town Council has become increasingly powerless and penniless when it comes to influencing local affairs.
There is certainly a growing feeling that Bolton Council is becoming increasingly ‘centralist’ in its outlook as it struggles to maintain the town centre as a viable commercial entity. The recently quoted figures of over £10 million being spent on the Town Hall, precinct and surrounding streets together with the massive investment in Bolton One and the College & University serve to emphasise this point. There is no public investment on anything like this scale in any
of the ‘outlying districts’. You might argue that this ‘centralised’ investment is necessary for the future prosperity/attractiveness of the town centre and therefore the Borough as a whole but, on top of the lack of investment elsewhere, it is also ‘sucking the lifeblood’ out of facilities in the surrounding areas and resulting in the closure of places like Horwich Market, Horwich College and potentially Horwich Baths/Leisure Centre. All this is happening when a mass of new housing is about to descend on Horwich!
With regards to the recent poll we carried out asking whether ‘Horwich would be better off without Bolton’, out of the 500 people who voted, 82% voted yes and there was an equal split (9%) between those that said no or don’t know. This was a sample poll which was promoted on a variety of Horwich based community Facebook sites that have a fairly representative demographic within the town. Extrapolate those figures and you have an overwhelming sense of dissatisfaction within Horwich.
The purpose of this Poll was to highlight a clear disconnect between the people of Horwich and Bolton Council. During a recent visit to Horwich by BBC North West Tonight they where unable to find a single person on that day who supported Bolton. There is a rising tide of dissatisfaction concerning all manner of issues that the people of Horwich feel Bolton Council have ignored, over-ruled or neglected, this in our opinion is not healthy and needs to be addressed.
This then brings us to the questions we would like to ask about Bolton Council’s commitment to Horwich over the next few years, which are as follows:
1. SUSTAINABILITY
Following the approval of Horwich Vision’s planning application which includes 1700 houses and 20 acres of employment and retail space on the former Loco Works site (equivalent to a small new town of c.5000 people) together with another 1000+ houses ‘in the pipeline’ on allocated and ‘windfall’ sites (this does not include the proposed development at Horwich Golf Club). Horwich will see its population increase by an estimated 8-10,000 people in the next decade and will no doubt continue to grow as Bolton Council expand upon its draft allocation plans further.
We as a community do not see a matching commitment to provide the necessary transport, education, health/welfare, and sport/recreation facilities. It certainly isn’t contained in the information provided by the developers, Horwich Vision. So where is it to come from and when?
2. LOCAL TRANSPORT
All this proposed development relies on the upgrading of Chorley New Road/De Havilland Way A6 & the M61 Junction. We are told that the proposed upgrades will be phased in according to the numbers of houses built at Rivington Chase but everyone knows that Chorley New Road is already overloaded at peak times and these proposals do not
take account of the extra 1000 houses which will be built nearby, all feeding traffic onto Chorley New Road. Why are the traffic models not being re-run to take account of ALL the likely growth in the area (and that includes the recently-approved Bolton Wanderers Macron Stadium developments) and why aren’t the proposed improvements being introduced BEFORE the traffic situation gets any worse not somewhere down the line? What is your response to this?
As we’re sure you can appreciate, we are a little perplexed to read that in 2008 Bolton Council’s Employment Land Study (Transport Infrastructure) highlighted ‘serious concerns about the main and secondary road network, in particular in Horwich and around Bolton Town Centre’ - clearly raising the issue of capacity. That was 7 years ago and the traffic situation has obviously worsened since this report was published. In addition, in a pre-application discussion with Network Rail, access onto Chorley New Road was rejected on the grounds that the road was ‘at capacity’ (as stated in the ORR disposal notice).
Why is it then that a recent highways study in 2014, which formed part of the application for the Horwich Loco Works development, appears to contradict these previous findings over capacity. How can this be explained?
If as we suspect, traffic congestion in Horwich has increased since 2008, then we must conclude that the traffic model used in support of Horwich Vision’s planning application is incorrect. Please investigate this, and if this is the case, then we ask that you
insist on a review of the traffic modelling and the S106 funding agreement relating to highways and congestion triggers.
As you will no doubt be aware, road traffic in the UK has risen by 25% in the last 15 years with an estimated 10% annual increase predicted in forthcoming years. With the expected concentration of house building, employment and retail space within Horwich this figure will be very much higher than the national average creating even greater congestion along Chorley New Road/ De Havilland Way and at the primary pinch points throughout Horwich. What is the Council’s solution to this problem?
NB This increase in congestion may also deter companies from relocating to Horwich’s existing & proposed employment zones. What is your response to this?
3. EDUCATION
We are told that a new Primary School will be required (the existing ones are already at capacity) and that additional secondary provision will also be required – has anybody asked RBHS or St. Joseph’s where this might go? Due to financial viability concerns we are told that the Primary School will be OFF- SITE (thereby exacerbating peak-time traffic congestion). This seems to be a short-sighted decision given the ‘spare capacity’ available in the ‘heritage core’ buildings and where is the preplanning for all the other developments and the impact these will have on educational provision?
4. HEALTH
Having spoken to the largest GP surgery in Horwich they seem to have grave concerns regarding not only the level of funding but also the manner of its phased release. This ‘drip, drip’ approach to funding defies logic when you consider the influx of new residents, not just from this proposed development but from all the developments which will commence during the same period. This practice alone has seen an increase of approximately 732 patients in the past 12 months, which have no doubt come from the present programme of housing development happening throughout the town. This 12 monthly patient increase will pale into insignificance when all the other developments commence alongside Rivington Chase.
It appears to us that there is a certain amount of financial ‘buck passing’ regarding funding and this needs to be challenged so to secure investment for all the Local GP surgeries, enabling them to manage effectively the anticipated population growth (8-10,000) through some ‘joined-up’ thinking and a planned approach. Health provision like educational provision cannot be left to chance.
Horwich has unfortunately never been regarded as a high priority for capital investment by the CCG or previously by the PCT as it was not deemed to be a deprived area. The largest GP practices have not receive any Capital Funding to date to cater for their existing patients, and there doesn’t appear to be any in the pipeline. How does this tally with both the Councils and developers assurances that Health Provision will be delivered?
As the architects of this proposed growth, will
Bolton Council take a more proactive role in finding a workable solution both practically and financially to allow these GP surgeries to expand and therefore cope with growing demand? We understand that Bolton Council owns land in Horwich which might be suitable both financially and geographically for a new state-of-art medical centre?
5. SPORTS AND RECREATION
Since 1974 Horwich has lost a substantial number of sporting facilities from bowling greens, tennis courts, cricket and football pitches as well as large amounts of open recreational space. Most recently we have witnessed the partial loss of Green Lane playing field, Horwich Technical College football pitch and the recreational/play area behind Berne Avenue.
We have serious concerns that with a planned population increase of c5,000 from the re-development of Horwich Loco Works and a further population increase of approximately 4-5,000 from other developments within the town there is little or NO funding proposed for new or existing sporting facilities to accommodate an extra 10,000 residents.
The recent Officer’s Report on Rivington Chase stated that ‘no new playing field provision is required’ which is in direct contradiction to the Councils’ own reports and Sport England’s report. Clearly there is a deficiency (according to national standards) and this needs to remedied and remedied ON SITE where it will be needed. Since the developers will no doubt argue that they cannot use valuable residential land,
wouldn’t it be more practical for additional sporting facilities to come out of the over-generous allocation of ‘ecological’ open space set aside between the new development and Red Moss. Can you review the green space allocation with a view to setting aside some of this land for sporting facilities, in particular an adult size football pitch which can be run and managed locally?
The Council might wish to argue that they have invested in Bolton Wanders FC and Bolton Arena but we would like to point out that this has been done to the detriment of Horwich town facilities partly because Bolton Wanders FC have no pitches to hire out and the prohibitive cost/lack of availability of the Bolton Arena facilities has caused both hardship and disruption to the local football leagues.
At the present time, Horwich has just a single Council run adult football pitch, which in our view is poorly maintained. Will you commit to additional maintenance of this pitch?
We also have concerns regarding the findings presented in and subsequent lack of action resulting from Bolton Council’s ‘2007 Open Space, Sports & Recreational Study Assessment’ which highlighted a lack of provision for Allotments, Green Space, Recreational Areas and Sporting Facilities within Horwich. Since the delivery of this report 8 years ago not a single recommendation has been actioned or implemented leaving the community feeling shortchanged yet again.
We would also like to make a ‘formal complaint’ regarding the misuse of the DRAFT Report, ‘2014 Playing Pitch Strategy Assessment ’. As Council
Leader you will be aware that to date this report has still not been presented to Council for final approval and we have already reported 6 major errors within the ‘draft report’. Knowing that these inaccuracies existed how can the Council justify the use of this ‘draft report’ on two important occasions:
i) As supporting evidence in a Hearing with the Planning Inspector into the Housing Allocation Plan in May 2014 - which invariably allowed him to make uninformed decisions to the detriment of Horwich’s green spaces and football pitches.
ii) In support of Horwich Vision’s application which led to a decision in which the developer was not required to contribute funding towards sporting facilities off site based on an inaccurate assumption that ‘no new playing field provision is required’ as detailed in the Officers Report.
Will you now undertake the following actions: make the necessary corrections to the ‘2014 Playing Pitch Strategy Assessment’ and in light of these review your decision and seek an additional contribution from the developer for sporting facilities on and off site?
Having one of only two public swimming baths in the Borough we would like to know the future plans for Horwich Leisure Centre when Serco’s’ contract expires in 2019? Is there any truth in the rumour that Horwich will lose these facilities after this contract expires?
When sports facilities are being lost or not provided in Horwich, is it true that Bolton Council has given or leased land at a non-commercial rate to Bolton Wanderers?
6. HERITAGE
After all the fine words uttered about the importance of the heritage of the site and its Conservation Area status, it was particularly disappointing to find that (again because of financial viability issues) there was no money available for the preservation of the ‘heritage core’ buildings in the early years of the Rivington Chase development - which will inevitably lead to their demise unless new uses can be found.
This surely goes against Bolton’s Core Strategy Development Plan in which it clearly states in Policy OA1 ‘The council and its partners will: Conserve and enhance the character of the existing landscape and physical environment, especially the conservation areas at Horwich Town Centre, Horwich Loco Works and Wallsuches’.
All the more reason for the new facilities in the ‘heritage core’ area to be accommodated in these buildings rather than in new ones. Will you ensure that this requirement is legally imposed on the developer?
7. AFFORDABLE HOUSING
We are told that the local community is in desperate need of affordable housing and yet again the developers have been granted special consideration in order to ensure the viability of the scheme by being allowed to defer the building of a single affordable house until (8 years/849th house) at which point the situation (profitablility) will be reviewed. Surely a Labour-run Council cannot condone a situation where only the wealthy can afford to live in this area?
In light of the recent ruling by the Planning Inspectorate on the supply of affordable housing by Redrow on the Swallowfield site, which would appear to create a precedent for developers to challenge all such provision nationwide, what is Bolton Council prepared to do to ensure that housing for ALL income groups is provided in Horwich as part of this major programme of new development?
Is there a guarantee in place that the delivery of desperately needed affordable homes for those on low incomes will not be delayed beyond the (8 years/849th house) and certainly not be left until the final phase of the development 15 years after it commences?
Can we also have a commitment that within the delivery of affordable housing a proportion is set aside to reflect the ageing population with suitable accommodation for our elderly residents?
8. CONTAMINATION
As you have no doubt heard, behind all the above concerns over the provision of necessary facilities to support ALL the new development that is proposed in Horwich over the next 10-15 years, there is one issue that will not go away and that is the treatment of contamination on the former Loco Works site.
The serious contamination including asbestos from over 100 years unregulated industrial manufacturing and waste disposal on the Loco Works site is a very serious concern for the residents of Horwich and it is clear that far more detailed investigation is necessary to fully determine the actual contaminants on the site and the extent & position of them.
In 2001 Bolton Council issued its Contaminated Land Strategy Document. Why has this not been updated for 13 years (despite it stating it should be reviewed annually)? Surely this should have been done prior to this application being considered to ensure the application complied with current DEFRA & other government guidance on Contaminated Land & its development.
Why was the decision on the development not deferred until the Strategy had been updated and how can the Council guarantee the proposed remediation strategy is correct when it has used a severely outdated 13 year old document as a reference?
Since this Strategy was approved in 2001 and in light of further disclosure from Bolton Council, why has the Loco Works site NEVER been identified, appraised or designated by the Local Authority as Contaminated Land as per PtIIA Environmental Protection Act 1990, when it is clearly contaminated with 1000’s of tons of carcinogenic asbestos and many other dangerous pollutants. This contamination is not just buried on site but during its 100 years of industrial activity dust and asbestos fibres would have accumulated in voids and cavities inside the buildings and the ‘fallout’ from historic processes would have allowed asbestos fibres and dust to settle within the surrounding land.
Having never been identified, appraised or designated as contaminated the site would therefore not come under the same scrutiny for testing or monitoring. This has allowed it to continue unchecked. Buildings have been demolished and
surrounding land interfered with without the correct ‘accompanying Risk Assessments/ Method Statements’ being implemented. This could have exposed both the employees of the businesses on site and the community at large to contamination from carcinogenic asbestos fibres and other dangerous airborne pollutants from the Human Health Receptor’s already there. To our knowledge there has been NO TESTING on site of employees, airbourne dust particles or the fabric of the buildings to determine either way. I’m sure the community of Horwich will find this level of oversight appalling. What is your response to this?
Both the planning application and the ORR documents show the land IS contaminated so why is the site not on the register now? Will you commit to its inclusion onto the register?
Has the designation as a ‘special site’ due to waste acid tars (i.e. coal tars from coal cracking which in turn negatively react to the clay base of the site) been considered and if not, why not, considering all the industrial processes that have occurred on this site?
Given the seriousness of the contamination present, surely it is in the Council and public interest that an independent body such as the Environment Agency take control of the investigation and identify & oversee the necessary remediation to ensure public health is fully protected. Why is this not being implemented?
Has the Council ensured that adequate liability & indemnity insurance is in place by ALL parties to protect the employees and the public and have they ensured that the contamination issues on this site,
the investigations & the remediations are covered by this insurance?
Planning permission has been given for demolition of buildings on the site: These buildings were used for the installation and removal of asbestos in the locomotives and carriages and contained asbestos as insulation and pipe lagging. What tests have been conducted on the buildings to ensure that dust and fibre accumulations in voids and cavities of the buildings including the mortar and brickwork of the buildings do not contain any asbestos fibres?
What measures will be taken to protect people during the demolition from contaminated dust and will accompanying Risk Assessments/Method Statements be available for public scrutiny?
Some knowledgeable residents believe the cost of remediating the land correctly & fully could put the viability of the whole development in jeopardy. Having given planning permission, the Council has a legal duty to ensure that the WHOLE site is now remediated whether the development goes ahead in full, part or not at all; If any of the phases do not go ahead, how is the contamination or remaining contamination going to be remediated and who will be responsible for it?
Given the land involved has a number of owners how is the responsibility and the cost of the remediation going to be split particularly if parts of the development do not proceed? Network Rail, Armstrongs and Hong Kong Racing are currently legally responsible for the costs of remediating their land even if it is sold to Horwich Vision.
Are there measures in place to stop Horwich Vision from developing the least contaminated areas of land and building their 849 houses were the remediation costs would be significantly lower and then declaring the rest of the development unviable? This would leave untreated the land owned by Bluemantle where the highest concentration of known asbestos is located both in the tips and within the buildings themselves and where decontamination costs are potentially the highest.
Did the Local Authority (Bolton) adopt the “Precautionary Principle” to this site in its decision making?
We have had promises of a Liaison Group to monitor how the contamination will be dealt with, how it’s investigated, the remediation methodology and ongoing site monitoring. Can you confirm the Council’s commitment to forming this Liaison Group, that it will be put in place before any work or demolition begins on any part of the site and that we will be invited to participate?
As we are sure you can appreciate, especially in light of the disclosure that this site has never been determined as contaminated with all the risks and dangers to human health this presents, the people of Horwich have little faith and trust in the agencies who should have taken responsibility for it decades ago. The developers/owners of the site have so far shown scant regard for HSE Regulation 4 of the Control of Asbestos Regulations 2012 whilst undertaking their ‘duty to manage’ and their recent actions concerning the ‘erecting shop’ have in fact made matters worse.
There is no getting away from the fact that this site is seriously contaminated. We therefore would like to see an independent agency/consultancy appointed to corroborate all the environmental examinations/testing, remediation methodologies and regular monitoring throughout the lifetime of this development funded by the Council and obliged to make regular public reports. What would your response be to this?
If Horwich Vision are unable to complete the development and walk away after developing the least contaminated parts of the site, has Bolton Council set in place any contingency plans to make sure the rest of the site is safely remediated?
9. HORWICH TOWN CENTRE
As recent as the mid 1990s Horwich town centre was a vibrant and prosperous town centre presenting a diverse shopping experience that catered for every need. The closure of Railway Works in 1983 did have an impact but nothing on the scale of the decision to allow Middlebrook to be built. Bolton Council offered to ‘support’ its fragile economy when the Middlebrook development was built by ensuring that competing retailers would not be allowed to open there but those promises have been broken. Horwich Town Centre like Bolton Town Centre has struggled in recent years. It is apparent from the multi-million pound investment in Bolton Town centre that this problem is being addressed but as far as we can see there is no matching financial commitment or investment for Horwich Town Centre. If anything we are seeing investment withdrawn as
the Council has in recent years closed down the town market and the public toilets and there has been no significant investment in the area’s infrastructure or environment
Rivington Chase now poses a further threat to the town centre’s viability by offering additional retail facilities even closer than Middlebrook. Bolton Council will no doubt point to all the benefits of this additional retail space and suggest that it won’t have an adverse effect on Horwich Town Centre but we have the benefit of hindsight now and know that it will.
After Middlebrook was built Horwich saw its Retail Ranking fall 231 places! Since then Middlebrook has expanded even further allowing comparison goods to be sold with the further addition of restaurants and bars in recent years. This has created further difficulties for Horwich and now it is going to have to compete with a further 6000sq.m2+ (64,583sq. ft) of additional retail, bars, restaurants and an outdoor market space within the new development. This will divert even more footfall towards the new retail area and Middlebrook. This surely goes against Bolton’s Core Strategy Development Plan in which it clearly states in Policy OA1 that ‘The Council and its partners will: continue to promote Horwich town centre as being suitable for a mix of retailing, leisure, employment and housing uses. How can further ‘unfair’ competition possibly do this?
What is Bolton Council prepared to do to support Horwich Town Centre? Are there any plans of a proportional investment similar to that being delivered in Bolton to help with improvements to facilities and general environmental improvements?
Could we suggest some financial support to resurrect Horwich Chamber of Trade and grant support for shopkeepers to improve the exteriors of their premises? Could they also tap into the expertise being made available to Bolton Council by experts in retail and regeneration that could help drive a positive agenda for change through the Chamber of Trade?
Can we also look into the ridiculous situation in which Horwich Town centre is being taken over by too many of the same retailing outlets. The success of any town centre is based on the ‘diversity of retail experience’ as seen in places like Bishopthorpe Road, York for example. To compound matters, an application was refused at Horwich Parish Council for yet another Café, but was then approved by Bolton Planning Committee. This has to stop.
Horwich is on the foothills of the West Pennine Moors and has the potential to become a fantastic ‘gateway’ location. Rivington has 841,000+ visitors a year in which a large number pass through Horwich, presenting a clear opportunity for the town to tap into their spending power. Is Bolton Council prepared to support Horwich to unlock this potential?
One way the Council can demonstrate that it cares about Horwich is by diverting some of the millions of pounds of additional Council Tax Revenue about to be generated over the next 10–15 years by the 30% increase in the housing stock into local improvements to facilities and the environment. What is your response to this?
10. COMMUNITY INFRASTRUCTURE LEVY (CIL) -vs-
SECTION 106
We have serious concerns as to why the CIL wasn’t applied to this development considering its strategic importance and the inevitable impact it will have on the local and borough-wide infrastructure.
It would appear that the developers have been granted special consideration in order to ensure the viability of the scheme (and guarantee a 20% profit). This is clearly demonstrated in the Section 106 agreement where any payments will either be deferred or phased until the 849 house is built (or into the 8th year of development). Why has the Council felt it necessary to be so accommodating at the expense of much-needed infrastructure & facility benefits to Horwich
Has this application been rushed through to avoid the developer’s application falling under the CIL agreement, which Bolton Council has to legally adopt by April 2015? Equally, has the adoption by Bolton Council of CIL been delayed for this same reason? Bolton Council could have speeded up the approval process for the CIL, like many other local authorities up and down the country who have already adopted CIL, thus maximising the benefit from developments such as Rivington Chase. Why hasn’t it?
Will CIL be adopted by the Government deadline of 6 April 2015 and will any developments within Horwich contribute through the CIL prior to this deadline. If so which developments will these be?
Once the CIL is introduced who will be responsible for the distribution of this funding and how will it
be done? Will Horwich retain the full amount of any CIL funding that is delivered through future developments and will this be in addition to the existing Town Council Precept?
11. SECTION 106 AGREEMENT
The Section 106 Agreement appears to be a poor substitute for CIL.
In the interests of transparency would you be willing to calculate a comparison based on Bolton Council own ‘Draft Charging Schedule from 2013’ to illustrate the difference in contributions between the CIL and the S106 agreement proposed for Rivington Chase?
Will the community of Horwich have the opportunity to scrutinise the final Section 106 agreement and its legal provisions before it is signed?
12. TRANSFER OF SERVICES
We would like to know your thoughts about the possibility of Horwich Town Council taking over responsibility for certain Council-run services e.g. Sports and Recreation Facilities, Community Centres, Parking Enforcement, Play Areas and Parks, Green Open Spaces and Cemeteries? This we believe may take some of the pressure off Bolton Council and may help generate much needed income for the town using a subsidy from Horwich Business Rates, Council Tax or any future Community Infrastructure Levy (or even a contribution from all 3).
Would you also be open to discussing the possibility of devolving certain powers back to Horwich Town
Council in relation to local issues & management? e.g. local planning, Horwich Leisure Centre, Green Lane Playing Fields.
NB. Horwich Leisure Centre and Green Lane Playing Fields are two examples of sporting facilities that were paid for by the people of Horwich. We would like your views on returning them to Horwich Town Council ownership.
13.BOUNDARIES AND WARDS
Have there been any discussions about changing local ward boundaries? If so, what would be the implications for local representation?
14. CONCLUSION
The above issues are of great concern in relation to the future development of Horwich and its ability to cope with the demands of such a rapid growth in population within the next decade. Executed properly, this major programme of development could be of real benefit to the town.
Just as we can see a huge amount of effort and investment going into the regeneration of Bolton Town Centre, we ask that the same amount of energy and investment is put into the future development of Horwich as a WHOLE.
We recognise the strategic importance of Horwich to both Bolton Council and the wider region, but it appears the ones driving the agenda are the developers not Bolton Council. This balance of power has to change for the benefit of the town.
We obviously want to feel confident that Bolton Council are looking seriously and comprehensively at all these issues and are planning ahead to ensure the right outcome not only for Horwich but also the wider community.
Thank you for taking the time to read this, we look forward to hearing your response to our questions and concerns.
Rotheram
Kindest Regards, Craig
On behalf of the following Horwich Community Groups: Horwich First, Horwich Loco Works Action Group, Friends of Horwich Football and Horwich RMI Cricket Club.
