28th September 2004.

RE: Public Inquiry closing on 29 September 2004.
Rochdale Unitary Development Plan- Revised Deposit Draft Development Plan 2003.
Chapter 12- Regeneration
R/4(j)- ROOLEY MOOR ROAD AREA OF OPPORTUNITY

Save Spodden Valley was created in May 2004 by many hundreds of local people
who live in the vicinity of the former Turner Brothers Asbestos factory. This site is
referred to at R/4(j) of the draft UDP as an “Area of Opportunity” to be considered
for a mixed-use urban village type redevelopment.

We have been told that because we did not submit a response before 6 June 2003
that we have no right to submit any evidence and that the closing of the Inquiry is a
formality.

This submission is based upon new information that may not have been available
in June 2003.

Local concerns were galvanized by the actions of the site’s new owners in May 2004.
Without any notice to local people, Rochdale Council or the HSE, a large team of
forestry contractors went onto the site of the former asbestos factory early on a
Saturday morning and destroyed significant amounts of woodland.

The woodland clearance uncovered a capped coal pit shaft. A former Turner and
Newall (T&N) Health and Safety Officer, who is now a national Health and Safety
Commissioner, has recently spoken in public about the destruction of woodland
where the pithead is. He has expressed utter disbelief at the decision to disturb
soil and vegetation around the coal shaft used by the former asbestos factory to
dump many tonnes of industrial waste.

At a recent public meeting, a letter written in early 2004 was read out. In it, the
Administrators of Turner and Newall described the site as “…an asset of dubious
value (possible [sic] even a liability)…”

An insight to the potential scale of dumped asbestos on site was recently
uncovered from research of archived T&N documents released from the USA:
A Turner Brothers Asbestos Company document from 1957 describes how
15,000lbs of asbestos dust was dumped every week. The Rochdale factory
processed asbestos for over 100 years. It was the largest asbestos textile
factory in the world, yet there is no specific reference to Asbestos in the wording
of R/4(j).

New allegations are now being investigated that parts of the factory site, constructed
in the 1940’s and 1950’s, may be built on land where asbestos was dumped.
This is in addition to “land to the North of the site” mentioned at paragraph (iv)
in the Principles of Development of R/4(j).

Recent pubic meetings have heard local people give eyewitness accounts of
nearby trees and land covered, until the 1960’s, with deposits of dust and fibre.

It has also been discovered that local people, who never worked at the asbestos
factory, have died of the pernicious cancer, mesothelioma. This is a disease whose
only known cause is exposure to asbestos dust. Recent information from Barking
and Dagenham has described how the redevelopment of a former asbestos factory
site in the 1960’s may now be the cause of mesothelioma in local residents.

We are under the impression that much information regarding the extent of potential
contamination at the site is not publicly available. We have received anecdotal
accounts that T&N records have been destroyed in the past 10 years.

We understand that in the mid 1990’s (c.1995), a national building company conducted
a major survey of the whole site. The site’s former owners, T&N, commissioned this
document and it was distributed to Rochdale MBC and the Health and Safety Executive.
It has been suggested that this report has been destroyed.

The c.1995 report may or may not be the basis for Rochdale M.B.C and the Health
and Safety Executive’s confidence in knowing where all contamination is on site. It is
our submission that this information must be open to public scrutiny. Local people
who have lived by, or worked near, the site may have further information regarding
the dumping of asbestos, the extent and nature of airborne releases of asbestos
dust and fibre together with other contaminants including phenolic resins and benzene.

Whilst the draft UDP acknowledges “the whole site is contaminated”, the full extent
of potential contamination may not be recognized in R/4 (j). Any responsible developer
of the site should welcome accurate, factual dialogue with people that have first-hand
knowledge of contamination. In that way, safe, open, responsible and accountable
decisions can be made about any future development.

In light of this new information and the recent actions of the new owners of the site,
we are concerned that the wording of the draft UDP may not give sufficient safeguards
for a safe redevelopment of the Area of Opportunity R/4(j):

Paragraph 12.45 states that “the site’s problems and issues are best addressed
through comprehensive redevelopment”. We submit that the overriding consideration
when determining future use of the site must be the safeguarding of public health.

Paragraph 12.48 suggests that an agreed solution to the site’s many issues may
be secured through a legal agreement. We submit that the use of the word “may”
should be strengthened to the term “must”. Such legal agreements must bind
future owners or developers of the whole site.

Paragraph 12.49 suggests that the financial viability of different development options
be subject to “negotiation with any developer”. We submit that any such negotiations
must be open and accountable to the local community and its representatives.

We understand that the new owners of the site, together with a development Public
Limited Company, have been in frequent correspondence with officers of various
Rochdale Council departments and the Health and Safety Executive. During the same
period of time the owners of the site have issued just one public press release. There is
an impression within the local community that decisions, that may directly affect public
health, are being made behind closed doors.

Because of these recent events, it is submitted that in order to regain the confidence
of the local community, there must be a commitment to impartial and independent
testing and assessment of the whole site within R/4(j).

Jason Addy
Save Spodden Valley

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STATEMENT ENDS.