Agenda item

Public Question Time

To receive Questions from the Public, in accordance with the Council’s Constitution.


A question was received from Councillor Quigg:

There have been several concerns raised already about the preliminary ecological appraisal for the Oldham sites in the Places for Everyone plan.

In recent correspondence the Leader of the Council advised that the preliminary ecological appraisal was carried out in accordance with the broad principles of the Chartered Institute of Ecology and Environmental Management (CIEEM) guidelines.

Under the CIEEM guidelines, a preliminary ecological appraisal is broadly broken down into three phases:

1.    An initial desktop survey is carried out.

2.    Appropriate field surveys informed by the desktop survey.

3.    A report that details the findings from the desktop and field surveys, which identifies the priority habitats present, records the likely presence of protected and priority species, and includes an evaluation of the potential impacts and necessary interventions.

In accordance with the CIEEM guidelines, the desktop survey recommended up to seven types of field survey for the site visit phase.

Therefore, is the Council able to tell us which of the recommended field surveys were carried out for the preliminary ecological appraisal, and provide any protected or priority species or habitats that were identified as present by the field surveys?

Also, whilst the forthcoming consultation is on the proposed modifications only, several of the modifications to policies affecting the Oldham sites relate to ecology, and therefore the soundness of the modifications can only be considered within the context of up-to-date and accurate ecological assessment.

Only the desktop survey was made available as part of the Places for Everyone plan evidence base, so will the Council commit to making the field survey reports available, to facilitate Council and public scrutiny of the site allocation modifications?


Councillor Taylor, Deputy Leader of the Council and Cabinet Member for Housing and Licensing replied: The proposed modifications to Oldham site allocation policies in PfE that are related to ecology have been proposed simply to ensure consistency across all the PfE site allocation policies and to avoid duplication of policy.  The modifications referred to amend or remove the ecology criteria in the allocation policies where this would be a duplication of policy JP-G9 in chapter 8 of PfE.  The modifications are not a result of concerns raised about the ecological evidence behind the proposed allocations.

Further to discussions at the examination hearings GMCA submitted a note explaining the ecology evidence used to inform the choice of allocations and contents of their respective policies. This note can be found on the examination website at PfE-Response-to-IN24-AP91-Ecology-ISSUED.pdf ( and sets out that:

·         It is considered that the ecological evidence published on the GMCA website represents relevant, up-to-date, adequate and proportionate evidence on ecology. 

·         It has suitably and robustly informed the choice of allocations and the contents of site allocation policies in the plans. 

·         Whilst PfE does allocate some land with environmental or amenity value, the evidence has enabled this to be kept to a minimum and ensured that the most important ecological assets have been identified for inclusion in allocation policies. 

·         The evidence has enabled recommendations for likely mitigation and enhancement to be included within policies, where appropriate. 

·         The evidence provides appropriate justification for the thematic policies in the plan which include safeguards for protecting and enhancing ecological assets, and a requirement for development to achieve a net gain in biodiversity.

The Inspectors in their robust assessment of the Plan have considered the ecological evidence prepared to support the PfE allocations and in doing so have concluded that the proposed modification are necessary to make the plan sound. Therefore, the issue of soundness being addressed by the modifications is not one related to the evidence, but whether the specific criteria previously proposed in allocation policies is necessary given JP-G9.

It is important to note that the full extent and distribution of priority habitats, and the presence of protected and priority can only be established by detailed species surveys, which are beyond the scope of the high-level Preliminary Ecological Appraisals considered necessary and proportionate for a plan such Places for Everyone (as outline in the aforementioned note prepared for the examination). Fully comprehensive surveys would be required to inform full planning applications. In the PEAs the Greater Manchester Ecology Unit have identified the likely presence of priority habitats on some sites, but they do not consider these to be of such high quality, or so extensive, so as to exclude sites from allocation. Proposals for mitigation and compensation measures for development can only be made when detailed development proposals come forward, not at allocation stage when details of site layouts, quantum, scale and type of developments etc are unknown.

Therefore, given that the proposed modifications are not related to the ecological evidence, the field survey reports are not needed to facilitate Council and public scrutiny of the site allocation modifications.