78% in an independent poll said build Saddleworth School on the existing site in Uppermill

(source: Saddleworth School Poll on Saddleworth News)


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Over 3000 people have signed a door to door petition asking for the EFA and OMBC to build new Saddleworth School on the existing site in Uppermill and it's growing

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Saddleworth School planning application and Oldham Council's failure of duty to our heritage assets

Saddleworth School planning application has been submitted

The Saddleworth School Planning Application (PA/337301/15) is now live and the public has until 27th August 2015 to submit their objections.

However most of the documents for download are illegible and unreadable and sections 11 to 17 are entirely missing from the Environmental Statement Main Text document.

The tenor of the school planning application is written in a way to support the Council's objective irrespective of the facts involved. For instance it states that building the school on the Uppermill site is over the EFA's budget. This is actually not true. The EFA has stated to Diggle residents at an earlier meeting that all four options assessed in their feasibility study were within their total budget. The EFA still say that should the planning application at Diggle be rejected then they would reconsider building the school in Uppermill. Building the school in Uppermill is still a viable option.

Please be aware that ONLY objections to material planning conditions as outlined by the National Planning Policy Framework will hold any weight at a planning committee. View the National Planning Policy Framework and its Planning Practice Guidance Notes

Also cost is not a material planning consideration. So the excuse that it would be more expensive for the EFA or the Council to build the school on an alternative site, holds no weight in planning terms.

Oldham Council and WYG ignore requests made by statutory consultees and the Conservation Officer

Oldham Council have told WYG, working on behalf of Interserve, that as the demolition is not part of the school development planning application, that the impact of the demolition of the Dobcross Loom Works buildings DOES NOT need to be included in their Environmental Statement for the school planning application.

However, Historic England, the Canal and Rivers Trust and their own Conservation Officer do not see it this way.

Within the Environmental Impact Assessment (EIA) Screening and Scoping letter, date 14th May 2015, sent to Oldham Council by WYG, they described the site as:

"The previously developed part of the site currently comprises industrial buildings of various ages and forms ranging from older stone and brick built mill buildings of up to two storys in height to more modern, open-sided steel-framed storage buildings. The buildings were originally built as the WH Shaw, Dobcross Works a loom works and office buildings. The office building, is located outside of the redline boundary and is a Grade II listed building (LB 1068167). A number of the other buildings within the development site would be considered curtilage listed."

During the Environmental Impact Assessment Scoping Opinions process Historic England, the Canal and Rivers Trust and Oldham Council's Conservation Officer all requested that the impact of the demolition of the Dobcross Loom Works buildings should be included in the Environmental Statement for the school planning application.

Response from Historic England:

"The site contains the majority of what was once the Dobcross Loom Works. On the basis of the information provided, many of the structures on site appear to date back to the 19th and earlier half of the 20th century, lending context and understanding to the Grade II listed Dobcross Works office building."

"We appreciate that the proposal to demolish the structures curtilage listed to the Dobcross Works office building (we refer to the Scoping Report) will be subject to separate application for listed building consent and required tests of Chapter 12 of the NPPF. However, given that the purpose of an EIA is to predict the environmental consequences (including heritage impacts) of a proposal, it is unclear why the demolition aspects of the proposal are not addressed within the Scoping Report. Given that this may have a notable environmental impact, and its relevance to the proposal, we recommend that it is scoped into the assessment in line with paragraph 128 of the NPPF."

"We recommend that you involve the Conservation Officer and the county archaeologist in the development of this assessment."

Response from The Canal and Rivers Trust:

"The Trust would advise that the demolition works should be included in the scope of the EIA, to enable a full assessment of the heritage value of the existing buildings and the impact of their loss. The canal corridor should be considered as an undesignated heritage in its entirety and the impact on it assessed, along with the impact on the setting of the listed bridge and subway. As stated above, the impact of the additional works required to the canal infrastructure must be included in the scope."

Response from Oldham Council's Conservation Officer:

The Conservation Officer at Oldham Council has classed the Dobcross Loom Works complex of industrial buildings in Diggle as a non-designated heritage asset.

  1. I believe the former Dobcross loomworks complex should be considered a non-designated heritage asset due to its potential for historical (illustrative and associative), aesthetic, communal, and to a lesser extent evidential value. The loomworks buildings proposed for demolition also contribute to the setting of several Grade II listed buildings.

  2. I understand the proposed demolition of the buildings on the site, excluding the listed building, is necessary to facilitate the construction of the proposed school on this site. Therefore, I consider the demolition proposals should form part of the statement and its loss in terms of the impact on the surrounding area, listed buildings, and the impact upon Saddleworth as a whole of the loss of a large scale industrial complex adjacent transportation links, should be considered.

Oldham Council's Planning Department response back to WYG

In Oldham Council's letter to WYG on 9th July 2015 detailing the findings of the Scoping Opinions, they omitted both the requests made by the Canal and Rivers Trust and Oldham Council's Conservation Officer. They also appear to have watered down the request made by Historic England, suggesting that they were only concerned with the link bridge structure which was not the case. It is obvious that they were referring to all the buildings on the site which were built prior to 1948, as mentioned by their reference to "curtilage listed", which was also WYG's description of these buildings. (see definition of a listed building)

They also changed Historic England's words of “Given that this may have a notable environmental impact” into “Given that this may have an environmental impact” further weakening their response.

"Historic England acknowledge that the proposal to demolish the link bridge will be subject to a separate application for listed building consent. However, given that the purpose of an EIA is to predict the environmental consequences (including heritage impacts) of a proposal, Historic England state that it is unclear why the demolition aspects of the proposal are not addressed within the Scoping Report. Given that this may have an environmental impact, and its relevance to the proposal, Historic England advise that it is scoped into the assessment in line with paragraph 128 of the NPPF."

So does the submitted Environmental Statement for the school planning application include the impact of the demolition?

In one word: NO

Looking at the Environmental Statement (incomplete - currently missing sections 11 to 17) and the Archaeology and Heritage Assessment under PA/337301/15 on Oldham Council's website, this does not appear to have taken place.

It is now obvious that the impact of the demolition of the buildings has not been assessed as part of the EIA, even though two statutory consultees and the Council's Conservation Officer have already requested that this should be done.

The Archaeology and Heritage Assessment under PA/337301/15 states:

"The Dobcross Loom Works (6244.10) is the only recorded heritage asset within the development site and these buildings, some of which are are attached to the listed office building or may be curtilage listed, are being demolished under a separate planning application and Listed Building Consent application. As a result, the impacts of their demolition and any associated mitigation measures or other works that might be recommended are not considered in this DBA. However, effects on the setting of the retained listed office building of the Dobcross Loom Works, which is located outside the redline boundary for the proposed development, are considered below in relation to the construction of the new school buildings and associated works."

"Listening Council" fails to listen to statutory consultees and own colleague

We are constantly told by Council officers, Cabinet members and more recently by our MP Ms Debbie Abrahams that Oldham Council is a "listening Council".

However, it appears that not only are the Council not listening to the concerns by Saddleworth residents in relation to the move of the Saddleworth School to Diggle, but now they appear to be not listening to the statutory consultees and even their own Conservation Officer, in relation to the demolition of the Dobcross Loom Works building.

The Council has adopted a "salami sliced" approach to the various aspects of building a new school on the Diggle site. There is no justification for this and the Council have been reminded that the courts have rules this practice unlawful by the specialist legal representation engaged by SDAG. So, it would not be unreasonable to expect a council with a moral compass to reappraise their position.

The only reason for the demolition of the link bridge and the other buildings is to facilitate the construction of the replacement Saddleworth School.

Two statutory consultees and Oldham Council's own Conservation Officer gave their professional opinions, during the EIA scoping opinion, that the impact of the demolition of these buildings should be included in the school planning application.

The Conservation Officer also stated that the former Dobcross Loom Works complex of industrial buildings should be considered a non-designated heritage asset for the borough.

Consequently, this raises questions as to:-

  • why the Planning Department ignored the requests made by Historic England, the Canal and Rivers Trust and the Conservation Officer?

  • why they have not required the Environmental Statement and the Archaeology and Heritage Assessment for the school development to fully justify the demolition of the Dobcross Loom Works complex of buildings (a non-designated heritage asset), so that this development can take place?

Oldham Council failing in duty to the borough's heritage assets

Under the planning system, Oldham Council has a duty to protect and conserve the heritage assets within their borough. Both classed as designated (i.e. a listed building) and non-designated (those identified by the local planning authority).

By not requiring the school development applicant to fully justify the loss of a borough's non-designated heritage asset, Oldham Council is failing in this duty.

Why are Oldham Council so intent on not viewing the demolition as part of the new development. To the extent of going against the requests made by Historic England, the Canal and Rivers Trust and their Conservation Officer?

It should be the duty of Oldham Council to facilitate a holistic EIA process, which considers all the impacts which a new development will have. This school development requires the demolition of the buildings. So the planning application for the development of the new school should include the impact that this demolition will have on all the heritage assets and conservation areas in the vicinity.

Even more so as this will result in the loss of a non-designated heritage asset to the borough.

The National Planning Policy Framework (NPPF) paragraph 135 states: “The effect of an application on the significance of a non-designated heritage asset should be taken into account in determining the application. In weighing applications that affect directly or indirectly non designated heritage assets, a balanced judgement will be required having regard to the scale of any harm or loss and the significance of the heritage asset.”

How can Oldham Council justify their actons?

What justification is there for Oldham Council to:

  • ignore requests made from Historic England, the Canal and Rivers Trust and their own Conservation Officer

  • ignore paragraph 135 of the NPPF - the Council's Planning Committee will be required to consider the loss of the buildings when determining the school planning application (PA/337301/15), as they are classed as a non-designated heritage asset by their own Conservation Officer.
    Therefore the school planning application should fully assess the impact of the loss of this non-designated heritage asset.

Listed Building Consent Application LB/337133/15 should be withdrawn

The current Listed Building Consent Application LB/337133/15 for the demolition of the linked bridge, which is due to be decided on Wednesday 12th August 2015, by the Planning Department, should be withdrawn until a full assessment of the impact of the loss of this non-designated heritage asset on all the heritage assets and conservation areas in the vicinity can be completed.

Otherwise Oldham Council is failing in its duty to protect and conserve the significance of our borough's heritage assets, both designated and non-designated.

Also with the publication of the school planning application it has come to light that the Bat Survey submitted to LB/337133/15 is outdated. This outdated version states that no bat roosts were found. A slightly updated version of this Bat Survey is now included in the school planning application (page 192), which now states that a bat roost has been found.

Having an outdated inaccurate Bat Survey should also require LB/337133/15 to be withdrawn.