Comments received and Oldham Council's responses

Across health and care we are endeavouring to co-ordinate services across a Primary Care Network geography servicing populations of between 30k to 60k. It might be helpful to seek the involvement of the PCN Clinical Director and PCN leads. Therefore we will need to make the links to ensure a resident focus is taken.

From a social care perceptive it would help to see how the plan takes account of any ASC requirements identified in the Market Position Statement particularly where we may have identified shortages of any particular type of provision in that area. Often social care is not thought about it until somebody needs it, so understanding local population health needs would be useful.

National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities.

It is essential that the neighbourhood plan reflects and complies with NPPF for sport with particular reference to Paragraphs 98 and 99. Sport England has a statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our Playing Fields Policy and Guidance document (link provided).

Sport England provides guidance on developing planning policy for sport and the need for evidence (link provided).

Sport England works with local authorities to ensure their Local Plan is underpinned by robust and up to date evidence. This takes the form of assessments of needs and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.

Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area. Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may help with such work (link provided).

If new or improved sports facilities are proposed Sport England recommend they are fit for purpose and designed in accordance with our design guidance notes (link provided).

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.

Consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

Active Design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence-gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people, to lead active lifestyles and what could be improved.

Natural England does not wish to make comment on the suitability of the proposed plan area or the proposed neighbourhood planning body.

Natural England have provided information sources the neighbourhood planning body may wish to use in developing the plan, and to highlight some of the potential environmental risks and opportunities that neighbourhood plans may present. We have set this out in the annex to this letter.

The local planning should advise the neighbourhood planning body when Natural England should be consulted further on the neighbourhood plan.

Neighbourhood plans and orders present significant opportunities, but also potential risks, for the natural environment. Proposals should be in line with the NPPF. The key principles are set out in paragraphs 170-177.

The planning system should contribute to and enhance the natural and local environment by:

• protecting and enhancing valued landscapes, geological conservation interests and soils;
• recognising the wider benefits of ecosystem services;
• and minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures.

The neighbourhood planning body should consider the natural environment policies in the area’s Local Plan. The neighbourhood plan or order should be consistent with these, and the neighbourhood planning body may decide that the emerging Neighbourhood Plan should provide more detail as to how some of these policies apply or are interpreted locally.

Annex 1 - Neighbourhood planning and the natural environment: information, issues and opportunities attached. This contains information and links to sources of natural environment information sources; natural environment issues to consider; and improving your natural environment.

Do not have any comments to make on the designation of the proposed neighbourhood area or forum.

The Chadderton area contains a substantial number of textile mills that make a significant contribution to the area’s unique character and identity. The neighbourhood planning process provides a fantastic tool for identifying and acknowledging the importance of historic textile mills to the local area; and developing proactive plans to enable their longer-term sustainable reuse.

Encourage you to consider historic textile mills in your area as part of the process. This will help ensure that: these assets can be enjoyed by future generations; and the plan is in line with the requirements of national planning policy as defined in the National Planning Policy Framework (NPPF). We have a dedicated ‘Mills of the North’ Campaign aiming to secure the sustainable future of mills and the myriad benefits this brings to local people and areas (weblink for further information proved).

To ensure that the protection and enhancement of the historic environment is fully embedded within the neighbourhood plan we recommend that you refer to Historic England’s advice on Neighbourhood Planning and the Historic Environment and particular our Advice Note No.11 (weblink provided).

NPPF indicates that neighbourhood plans have the power to develop a shared vision for their area, to shape, direct and help to deliver sustainable development. This can include detailed policies on conserving and enhancing the historic environment and on design. The National Planning Practice Guidance (NPPG) is clear that, where relevant, neighbourhood plans should include enough information about heritage to guide planning decisions and to put strategic heritage policies into action at a neighbourhood scale.

It is important that the future plan identifies heritage assets in the area and includes a positive strategy to safeguard those elements that contribute to their significance. This will ensure that they can be appropriately conserved and enjoyed now and in the future. For example, policies might consider addressing the following:

1.  How the plan’s objectives can maximise the wider social, cultural, economic and environmental benefits flowing from heritage. For example, regeneration, tourism and wellbeing.

2.  Offering solutions to heritage assets that are at risk from their condition or vacancy or are vulnerable to becoming so during the life of the plan. The plan area contains one entry on our Heritage at Risk Register (Foxdenton Hall - Grade II*), however the national register does not ordinarily cover Grade II listed buildings or non-designated heritage assets, so your plan could usefully consider whether any are at risk.

3.  Considering how heritage assets can be enhanced.

4.  Locating new development to protect the significance of heritage assets and their settings.

5.  Giving detail on the expected scale, density, massing, height, landscape, layout, materials and access of new development.

As well as designated heritage assets your future plan is also an important opportunity to include a positive strategy for local heritage assets. Such ‘non-designated heritage assets’ may include buildings, monuments, sites, places, areas or landscapes that are important to the local community for their heritage value. If identifying these, your plan should include enough information to set out the elements that make them special so they, too, can be appropriately conserved and enjoyed.

The strategy and policies in the future plan should be based on proportionate, robust evidence. For heritage, this might include a characterisation study, historic area assessment or archaeological appraisal, a summary historical narrative, or identifying locally significant buildings, areas and other assets. Rather than just the presence or absence of heritage assets, evidence should focus on what makes them significant and, where relevant, vulnerable. This helps you to identify the issues and options for your policies to address.

We recommend that you seek the advice of the planning and conservation staff at Oldham Council and speak to the staff at GMAAS who look after Greater Manchester’s Historic Environment Record (HER). They should be able to provide details of locally-important buildings, archaeological remains and landscapes (non-designated heritage assets) as well as designated heritage assets. Some Historic Environment Records may also be available on-line via the Heritage Gateway (weblink provided).

You will need to consider whether or not the plan would be likely to have significant environmental effects and require Strategic Environmental Assessment (SEA) to comply with EU obligations. This is established by following the Environmental Assessment of Plans & Programmes Regulations 2004, which require the neighbourhood plan qualifying body to consult Historic England (and others) on the matter in the form of a Screening Opinion. Your local planning authority can advise on this, and we publish HE Advice Note 8, Sustainability Appraisal and Strategic Environmental Assessment to support this process (weblink provided).

Other Historic England advice that you may also be of use includes (weblink provided):

HE Advice Note 2 - Making Changes to Heritage Assets; HE Good Practice Advice in Planning 3 - The Setting of Heritage Assets; HE Advice Note 3 - Site Allocations in Local Plans (which also applies to neighbourhood plans); and HE Advice Note 7 - Local Heritage Listing.

We recommend that you familiarise yourself with the terminology of historic environment planning (such as “historic environment”, “conservation”, “significance”, “heritage asset”, and “setting”) by referring to the glossary in the NPPF. You can familiarise yourself with basic legislative and policy protections that heritage assets in England enjoy by browsing our online Heritage Protection Guide (weblink provided).

Object to forum and area designations. Since the refusal of their grant of designated forum under the name of "The Chadderton Partnership, this group have again not acted in a proper open and democratic manner. The New Chadderton Partnership (TNCP) behave in an exclusive manner in matters of membership, they have expanded the membership in a secretive manner to 37 from 21, but still refuse to process the membership application without reason of an individual who has lived in Chadderton for 58yrs.

TNCP while describing the types of persons making up the list of committed person still refuse to identify the persons involved. Surely in the application consultation period the 55,000 people resident in Chadderton should know who is applying for such a powerful authority, let us be reminded that in the last application it was only found after scrutiny following an objection, that one of the committed person did not fit criteria as that person did not reside or work in the designated area.

The constitution of TNCP is not fit for purpose, for the size of the designated area the quorums required in the constitution are too small and appear to give too much power to a small number of people.

The Council must be satisfied that the Forum is made up of a minimum of 21 people who live in the neighbourhood area, work there or is an elected member whose area falls in the neighbourhood area concerned in line with Section 61F of the Town and Country Planning Act 1990.

The Forum's constitution addresses membership. It is understood that the Forum have a membership form, and, should the Forum be designated, individuals will be able to use this form to apply to be Forum members (section 6.3). The Forum will need to make this available once designated.

The constitution sets out an appeal process (6.5).

The Council made the decision not to publish the details of the Forum members. This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

Oldham Council has redacted all personal information for consultation.

The regulations only require details of one member to be shown and the Forum application does not include consent for personal information to be published.

The Council must be satisfied that the Forum has provided a constitution in line with Regulation 8 of the neighbourhood planning regulations 2012 and Section 61F of the act. The constitution has however been amended since the last application to address concerns of the membership.

I am not happy with this forum as they have not consulted people who live in the area.

I don't know and cannot see who they are and therefore if their names are not available why would I want them to represent me.

I object to this. They should be made to follow rules to engage with the people who live here and just be because they may work in the area does not give them the right to make decisions about my area, property and environment

To designate a Forum there must be a minimum of 21 members and the requirements of the neighbourhood planning regulations 2012 and the Town and Country Planning Act 1990 (Section 61F) must be met.

However, as they prepare any Neighbourhood Plan for Chadderton, the Neighbourhood Forum will be required to publicly consult on those proposals before submitting any Neighbourhood Plan to the Council. This will take place in line with the neighbourhood planning regulations.

The Council made the decision not to publish the details of the Forum members. This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

Oldham Council has redacted all personal information for consultation.

The regulations only require details of one member to be shown and the forum application does not include consent for personal information to be published.

There is a document in the consultation that says member list but there are no names.

Is this a secret organisation and is that how the Council will allow them to operate?

I would like to know who these people are and why they feel they are able to represent the whole of Chadderton, without even speaking to anyone.

Please advise who the members are and their role in the forum.

Please see the above response.

The role of the Forum is to help progress and coordinate the neighbourhood plan in consultation with the community and other stakeholders.

I would like to see the member list. This is part of the documentation set but only talks in general. Surely if they are representing me then I should know who they are.

Is this a secret organisation that the Council are allowing to make decisions on the whole of the Chadderton area, that could affect me and be made with no consultation or input.

People who work here have no right to represent me. It should be people who live in the area and have the residents interests at heart.

Very concerning and I don't really understand what they will be able to do.

More information is needed on this before anything is approved. I would like them to arrange a meeting and present themselves to the residents and be confident in their ability to represent us.

Many residents have not heard anything about this and that in itself speaks volumes

Please see the above two responses.

Consultation on the Forum applications has taken place in line with the neighbourhood planning regulations.

This is simply to establish a Forum group, that can then consult with the wider community on a neighbourhood plan for the designated neighbourhood area of Chadderton.

The plan once prepared will be subject to a referendum and an independent examination.

I am objecting against the New Chadderton Partnership as, same with the previous application the group are not being transparent in who they are, many times they have been asked who they actually are and who or what could I do if I wanted to join, and never had a clear answer, going forward could you trust a group you know nothing about?

The group should have no political interest but if it’s correct a Labour Councillor is on the group's panel then questions will be asked if any decisions have a political agenda.

I, like many other people, would like to see who the group are and how could other public apply to be a member, as it stands it looks like a group of friends have got friends together to make the 21 member group, and no one within the Chadderton Partnership has said anything to prove different.

The Forum's constitution addresses membership. It is understood that the Forum have a membership form, and, should the Forum be designated, individuals will be able to use this form to apply to be Forum members (section 6.3). The Forum will need to make this available once designated.

The constitution sets out an appeal process (6.5).

The Council made the decision not to publish the details of the Forum members. This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

Oldham Council has redacted all personal information for consultation.

The regulations only require details of one member to be shown and the Forum application does not include consent for personal information to be published.

The Council has analysed the Forum membership and is satisfied it meets all of the requirements (set out in the

Neighbourhood Planning (General) Regulations (2012) and Section 61F of the Town and Country Planning Act 1990). This can include elected members for that area.

The Council must be satisfied that the Forum has provided a constitution in line with Regulation 8 of the neighbourhood planning regulations 2012 and Section 61F of the act. The constitution has, however, been amended since the last application to address concerns of the membership.

Our records indicate that within the Chadderton Neighbourhood Plan area, as defined, there are coal mining features present at surface and shallow depth which may pose a risk to surface stability and public safety. These features include; mine entries and shallow coal workings. Our records indicate that surface coal resource is present in the area.

We note that this current consultation relates to the designation of the Neighbourhood plan boundary only and on this basis, we have no specific comments to make.

Diane

I feel Chadderton is too big an area to have one group representing it. We have three wards and I am sure the councillors will confirm that they are very different indeed, with very different needs and problems.

Membership is still cloaked.

How to join? There is no website/Facebook group for CNP2.

Whilst it is said there's a spread of people now across Chadderton, I don't think 59 people is sufficient, I think they should have some proper consultation via Zoom/other digital platforms to enable people to discuss this.

I am concerned my particular area of South Chadderton will have no representation.

I am concerned that I have not been able to join this group. I am concerned there are no minutes published, no list of members. There is no transparency, and this must mean that it fails again. Their constitution is not being pro-actively used. There is no encouragement and involvement of the wider community due to the secrecy of this group.

There is no chance of community spirit being built up by starting off this way and being spread over such a wide area means that there are tremendous difficulties.

Would the councillors feel they could be reduced in number from 9 to 3 and maintain good levels of communication and action for the ward? No!

The CNP2 still does not have the support or even a level of awareness across the wards. It is still a secret organisation. Democracy is more difficult during a pandemic. But please ensure that it is allowed to have a chance. We need pro-active meetings across the three wards before any such group should be allowed to take over.

If the people organising CNP2 want this to go ahead, they have to stand up and allow democratic questioning and debate.

Size of area:

There is no size limit on a neighbourhood area in the Regulations, the Act or national planning guidance.

National planning guidance gives considerations when deciding the boundaries of a neighbourhood area. This states ward boundaries can be a useful starting point. It is not a limitation of only one ward however.

The Regulations require a statement explaining why this area is considered appropriate to be designated as a neighbourhood area. Therefore, the neighbourhood area boundary needs to be justified and deemed to be appropriate.

The New Chadderton Partnership have justified their boundary in the area application (‘Justification of the Boundary’). This explains that it includes the town centre, residential and employment areas as well as areas of open land and smaller settlements of Chadderton Heights and Healds Green.

The justification acknowledges that the neighbourhood area is a large area but reflects that there is nothing in the legislation to prevent its selection and other neighbourhood areas of this size have been designated.

The justification recognises that Chadderton contains many different communities which may have different priorities which will have to be accommodated through the development of the plan.

The justification adds that planning at scale will also allow some larger issues such as transport links to have a better chance of being improved than if proposals are made on a more micro-scale.

The future of the town centre has also been identified as an important issue which again will have an impact on all residents so needs to be considered in the context of the Chadderton area as a whole.

In addition, additional grant funding is available for neighbourhood areas with a population of over 25,000. This also demonstrates that there is not a cap on the population size for a neighbourhood area.

It is for a neighbourhood planning group to consider how to best engage with and listen to the community as part of the neighbourhood plan preparation and informal consultation and how to best reflect the different needs and ambitions within the designated area.

Forum Membership:

The Council must be satisfied that the Forum is made up of a minimum of 21 people who live in the neighbourhood area, work there or is an elected member, whose area falls in the neighbourhood area concerned in line with Section 61F of the Town and Country Planning Act 1990.

The Forum application has exceeded the minimum requirement significantly.

The Forum's constitution addresses membership. It is understood that the Forum have a membership form, and, should the Forum be designated, individuals will be able to use this form to apply to be Forum members (section 6.3). The Forum will need to make this available once designated.

The constitution sets out an appeal process (6.5). The Council made the decision not to publish the details of the Forum members. This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

Oldham Council has redacted all personal information for consultation.

The regulations only require details of one member to be shown and the Forum application does not include consent for personal information to be published.

The Forum members include individuals living in South Chadderton. 

The New Chadderton Partnership forum could, once designated, choose to make available the names and details of the forum members but they would need to make sure this is in line with data protection. The Council would have no responsibility for any publication of personal details of the forum.

It is expected that minutes will be published once meetings take place as a designated forum (see section 9.8 of the constitution).

Additional comment:

Comment refers to a post on Facebook explaining the formation of the New Chadderton Partnership.

1. By "agreeing to publish a membership form" - this already makes it sound like they are struggling with the concept of openness and transparency. This group should be fully open at this stage. They are trying to garner support for what is currently and looks likely to remain a closed shop.
2. Not being able to process application forms until the forum is registered seems to be counter democracy again and a deliberate attempt to maintain a small close-knit group of people who agree politically.
3. This statement does not inspire confidence in the openness of this organisation.
4. Unless there is full democracy within this organisation at all times then it should not be approved.

The Council must be satisfied that the Forum is made up of a minimum of 21 people who live in the neighbourhood area, work there or is an elected member, whose area falls in the neighbourhood area concerned in line with Section 61F of the Town and Country Planning Act 1990. The Forum application has exceeded the minimum requirement significantly.

Once the Forum is designated The New Chadderton Partnership will be able to publish a membership form and invite further members.

The Forum will also be required to consult the wider community and stakeholders (in addition to the Council carrying out formal consultation) and therefore being a member of the Forum, is not the only way to be involved in the preparation of a neighbourhood plan.

Object to application. Believe this application is not in the best interest of the people of Chadderton.

This application is undemocratic as it will allow twenty people, who have refused to be named, the authority to pass any future planning for the whole of Chadderton, without those of us who live here, being involved. The whole thing seems to have been carried out under very Clandestine Conditions.

I also have concerns as to why such an important issue as this is being heard by a single councillor, surely this is too big an issue to be decided by a single person?

I request this application be refused, as it does not represent the best interest of the majority of the people of Chadderton.

The Council must be satisfied that the Forum is made up of a minimum of 21 people who live in the neighbourhood area, work there or is an elected member, whose area falls in the neighbourhood area concerned in line with Section 61F of the Town and Country Planning Act 1990. The Forum application has exceeded the minimum requirement significantly.

The Council made the decision not to publish the details of the forum members. This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

Oldham Council has redacted all personal information for consultation.

The regulations only require details of one member to be shown and the Forum application does not include consent for personal information to be published.

The Forum is made up of over 21 people and therefore is not in the control of one single councillor.

Future planning applications will still be determined by Oldham Council for the Chadderton neighbourhood area. However, the neighbourhood plan, if and when adopted (following an independent examination and referendum) would be considered as part of the decision making process.

It is important that United Utilities is consulted at an early stage and kept aware should you look to allocate any sites, over and above the allocations determined by the Council in the wider development plan for Oldham. United Utilities wishes to build a strong partnership with neighbourhood groups to aid sustainable development and growth.

Our Assets:

We will not normally permit development over or in close proximity to our assets. All United Utilities’ assets will need to be afforded due regard in the masterplanning process for sites and any transport or public realm improvements. This should include careful consideration of landscaping proposals in the vicinity of our assets and any changes in levels of land over our assets.

This can be done using our free preapplication service using the contact details (details provided).

Sustainable Drainage

There is an opportunity for the local community to prioritise sustainable drainage systems. We request the inclusion of a policy that prioritises the use of multi-functional sustainable drainage systems in preference to traditional underground piped and tanked storage systems. This allows for attenuation features which are an integral part of the landscaping and which deliver wider benefits. (e.g biodiversity, wellbeing and recreation).

Provided recommended policy wording.

Landscaping and Public Realm Improvements

We encourage the proposed approach to landscaping and public realm improvements in the Neighbourhood Plan to be evaluated early in the design process to identify opportunities for landscaping to be integrated with sustainable surface water management design objectives.

We request that the Council and applicants consider opportunities for source control and slowing the flow of surface water as part of any public realm improvements, which could be achieved through: permeable surfacing; retrofitted swales; and bio-retention tree pits/rain gardens.

Also encourage water re-use opportunities in redevelopment proposals such as greywater recycling.

Case study examples of the above provided. Recommended policy wording provided.

Development next to Wastewater Treatment Works and Pumping Stations

We have Oldham Wastewater Treatment Works within the proposed Neighbourhood Plan boundary (site plan enclosed). Recommend that the location of this key infrastructure, and any other wastewater treatment works / wastewater pumping stations, are considered in the preparation of any new neighbourhood development plan. It is important to explain that:

1. Wastewater treatment works are key infrastructure for the borough which may need to expand in the future to meet growth needs or respond to new environmental drivers. Maintaining a space around a treatment works is desirable to respond to any future investment requirements.

 2. A wastewater treatment works is an industrial operation that can result in emissions. These emissions include odour and noise. A wastewater treatment works can also attract flies. A wastewater treatment works is also subject to vehicle movements from large tankers which need to access the site.

It would be more appropriate to identify new development sites, especially sensitive uses, such as housing, which are not close to a wastewater treatment works. This position is in line with the ‘agent of change’ principle set out at paragraph 187 of the NPPF and Paragraph: 009 Reference ID: 30-009-20190722 and Paragraph: 005 Reference ID: 34-005-20140306 of the National Planning Practice Guidance.

Recommended policy provided.

Water efficiency

Building Regulations Part G includes an optional standard for water efficiency of 110 litres per person per day (l/p/day) for new residential development which can be implemented through local planning policy where there is a clear need based on evidence. We have enclosed evidence prepared by Water Resources West to support the adoption of the Building Regulations optional requirement for local authorities in North West England.

The recommended policy provided’.

Improving water efficiency makes a valuable contribution to water reduction as well as carbon reductions and We also wish to note the associated societal benefits by helping to reduce bills.

I support the New Chadderton Partnership and its quest to register as a Neighbourhood Forum for Chadderton.

Initially, I had concerns about the membership makeup of the New Chadderton Partnership but of the 11 published names I have no problem; however I am disappointed that names and details of the remaining 10 members has not been published.

I am no longer troubled at the potential prospect of members forming an alliance to promote their own material self interest. My doubts were allayed after I read online a detailed and comprehensive report on the present situation and the progression that led to it.

Regrettably, I fear that many people within the 3 Chadderton wards will be unaware of this proposal, and perhaps those that are aware have formed a negative opinion as a result of lack of information. I sincerely hope the prospect does not collapse on the back of these shortcomings.

Support noted.

Oldham Council has redacted all personal information for consultation.

The Council made the decision not to publish the details of the Forum members.

This is explained in the 'Summary of The New Chadderton Partnership Forum Members'.

The application included 61 members on the Forum application therefore this has exceeded the minimum requirement of 21 members.

It is understood that in relation to these comments, some members details have been published by the proposed Forum.

Any publication of the members details must be done in line with data protection requirements by the proposed Forum.

The Council has published the applications in line with the Neighbourhood Planning Regulations. The report referred to is not part of the consultation as this is external activity.