Lancashire Branch, including Merseyside and Greater Manchester

Transcription

1 Campaign to Protect Rural England Springfield House, Chapel Brow, Leyland, Lancashire PR25 3NH Lancashire Branch, including Merseyside and Greater Manchester Deadline: 12 noon on 30th January 2017 Telephone: working locally and nationally for a beautiful and working countryside Local Plan Team St.Helens Town Hall Victoria Square St.Helens WA10 1HP 29 January 2017 Dear Local Plans Team, 1. The Lancashire Branch of the Campaign to Protect Rural England (CPRE Lancashire) is delighted to respond to the New Local Plan for St Helens Preferred Options consultation, including the Draft Green Belt Review. 2. CPRE and its members view the English countryside as iconic. It is unique, essential and precious, and it s in danger. Every year, a little more is lost forever to urban sprawl, new roads, housing and other developments. Rural shops and services are under pressure and intensive farming is changing the character of the countryside. Based on evidence, we believe climate change will have serious impacts on the rural environment and local plan policies must address this important environmental issue. 3. We advocate local plan making to form the legal bedrock of all local planning decisions. Local plan policies and allocations should accord with the National Planning Policy Framework (NPPF) and enable sustainable development within local environmental limits. And, it should not be forgotten that environmental capacity issues include air quality and carbon emissions. 4. Essentially CPRE supports the right development, in the right places for the right reasons, or smart growth identifying where needed development should go based on sound town and country planning principles, such as urban concentration, reliance on sustainable travel patterns, improvement of existing infrastructure, reuse of previously developed (brownfield) land and provision of high quality green spaces to achieve true sustainable development. 5. CPRE is keen to see that local planning authorities have properly exercised the new duty to co-operate to ensure strategic issues are adequately addressed and by doing 1

2 so ensure greenfield development, particularly Green Belt loss, is avoided, minimised or where absolutely unavoidable is adequately planned. We believe policies need to require adequate community infrastructure, such as affordable housing, school places, public transport to be provided to ensure development is sustainable in the long term. New development ought to be designed to enhance the natural environment and reflect local character. 6. Our detailed comments are set out below to the New Local Plan for St Helens Preferred Options consultation in Appendix 1, and the Draft Green Belt Review in Appendix If you would like further information please contact me without delay. Yours sincerely, Jackie Copley MRTPI MA BA(Hons) PgCert Planning Manager Patron Her Majesty the Queen President Emma Bridgewater Chairman Nick Thompson A company limited by guarantee Registered number: Registered charity number:

3 Appendix 1.0 CPRE comments concerning the New Local Plan for St Helens Preferred Options LPA01 Presumption in Favour of Sustainable Development CPRE has concerns about a policy presumption in favour of sustainable development when sustainable development is not defined either in the NPPF the local plan. Therefore we recommend a definition is provided under LPA01. We also urge that this key policy should contain a commitment in relation to air quality. CPRE is pleased to see that urban regeneration and quality of the environment is a focus of the spatial vision and is broadly supportive of the stated Strategic Aims and Objectives. Policy LPA02 Spatial Strategy CPRE Lancashire is supportive of the key element of the spatial strategy being to support the existing town, district and local centres within the hierarchy of centres by preventing inappropriate new town centre development outside of these centres that may harm their vitality and viability. CPRE Lancashire agrees with the status of several distinct spatial areas as Key Settlements, but would oppose development being focused at Rainford Junction; Crank; Bold Heath; and, Kings Moss due to the harm this would cause to Green Belt protected land. The NPPF does say local authorities should encourage effective use of previously developed land, provided that it is not of high environmental value, therefore CPRE is supportive of Bullet 3 stating that the reuse of previously developed land in sustainable locations will remain a key priority for the Borough. CPRE is supportive of: a) setting lower and more appropriate thresholds for developer contributions within existing urban areas to reflect viability constraints associated with regenerating sites; b) keeping an up to date Brownfield Register of suitable development sites. We advocate all brownfield sites are recorded, not just ready to go sites, as it is the constrained sites that will require targeted action to remove the constraints in partnership with relevant local stakeholders. The latest National Land Use Database showed that hectares of land was previously developed, roughly a third was suitable for housing, meaning two thirds, or 140 hectares could be used for needed employment uses. The NPPF states that local brownfield targets can be used. CPRE therefore recommends strongly that St Helens Council imposes a brownfield target in a bid to focus as much development as possible on brownfield land. The North West Regional Spatial Strategy had set a target of at least 65% brownfield development and CPRE sees no good reason why this target could not be reasonably applied in the future. CPRE strongly opposes Bullet 4, which refers to the removal of land from the Green Belt for housing and employment development allocations over the plan period. Land is also to be removed from the Green Belt and Safeguarded to meet housing and employment 3

4 development needs for the following 15 years (2033/34 to 2047/48). CPRE argues the exceptional circumstances have not been met. LPA03 Development Principles LPA04 A Strong and Sustainable Economy CPRE is supportive of planning for a healthy economy, but questions the validity of the jobs assumptions. Are the uplifts based on robust evidence, will the aspirational quantum of development ever be achieved in reality. CPRE believes more attention ought to be given to the importance in rural jobs such as farming and forestry and linked sectors such as food and drink. If the population of Mid- Merseyside is set to grow then more local produce will need to be grown to feed the people. We ought to be ensuring the protection of high grade farming land. Best and Most Versatile land (grades 1-3a) should not be included as local plan allocations. Once countryside/productive agricultural land has been built over, it has gone forever. The total employment land figure is clearly extremely inflated based on fanciful assumptions and arbitrary uplifts, on top of very high job growth assumptions applied to the forecast economic growth projections by both Cambridge Econometrics and Oxford Economics, leading to a workforce size that is unlikely to be delivered. CPRE finds it difficult to follow the magical calculations where the St. Helens Estimated Employment Land Needs range of between 177 and 214 hectares, has an arbitrary additional 70 hectares, equating to 306 hectares. It must be recognised that all St Helens surrounding geographies are also planning for jobs uplifts based on similar assumptions. CPRE queries whether it is mathematically possible for the whole of the UK, North West and areas of Mid-Merseyside to simultaneously plan for jobs growth. Assuming the Government is not going to alter its immigration policies we are not sure what the source of the people is to fill the level of jobs being planned. The economic consultants view for employment land is that large scale logistics is the most active market in the region and a particular opportunity for St. Helens and as there are no existing suitable sites for such large scale distribution and manufacturing uses. Consequently, their evidence suggests new provision is needed, and it has encouraged speculative applications to be submitted by a number of developers on Green Belt sites (Florida Farm, etc) in advance of the new Local Plan. Will such development provide needed skilled jobs, higher wages and represent a good use of land? Swamping the property market with an abundance of greenfield sites, particularly Green Belt, will just erode the viability of existing vacant brownfield sites in existing urban areas. As the local plan notes, the Borough s history is inextricably linked with the industrial revolution, coal mining and a world famous glass industry, which employed many of the local residents. Now those sectors are in decline it is important to reuse previously developed sites to bring forward new opportunities. Possible alternatives must be properly considered with the possibility of land assembly exercises in partnership with the 4

5 private sector to enable former factory sites coming forward at a scale appropriate for needed new uses. CPRE Lancashire queries whether the duty to cooperate has been evidenced properly as all areas of Greater Manchester especially on the M6 and M61 corridors are also planning for big shed distribution and warehousing sites. The same is true for authorities in Merseyside, Warrington, Greater Manchester, and Cheshire authorities. The aspirations of neighbouring authorities mean there will be duplication in employment premises provision. There is a real absence of strategic planning in this regard. CPRE is not convinced that exceptional circumstances have actually been fully justified for Green Belt land. LPA04.1 Strategic Employment Sites CPRE is strongly opposed to the development of Green Belt protected farmland for the following three employment sites: EA2: Land at Florida Farm North, Slag Lane, Haydock A recent planning application approved the Florida Farm development in protected Green Belt. It appears there is no stopping motorway based big shed developments, irrespective of Green Belt protection, local objection, generation of unsustainable traffic patterns and harm to the environment. The cumulative impacts of similar developments in Wigan, St Helens, Chorley and Knowsley do not seem to have been fully considered. Local people are totally opposed to this development due to the loss of countryside and adverse impact to visual amenity, landscape, ecology (including protected species such as water vole), transport congestion, flood risk, significant noise, air pollution, loss of residential amenity, the list goes on. The planning statement does not adequately address all of the adverse impacts and local people have expressed their concern about the harm to urban regeneration, and the threat that speculative applications have in countryside locations on the economic viability of more centrally located urban sites. Residents are calling for the decision to be called in by Sajid Javid, the Secretary of State for the Department of Communities and Local Government, who has promised Green Belt land will be protected by the Government. The proposal is in the wrong location, and it will cause significant countryside land loss and add severely to traffic congestion, and associated environmental harm including a reduction in air quality and loss of tranquillity to a large green area. EA4: Land north east of Junction M6 J23 south of Haydock Racecourse, Haydock CPRE is opposed to the development of greenfields for employment use at this location. As stated above there is a lack of exceptional circumstance evidence, a lack of clarity concerning the duty to cooperate with neighbouring authorities, with huge shed developments, irrespective of Green Belt protection, local objection, generation of unsustainable traffic patterns and harm to the environment coming forward here, there, and everywhere. The cumulative impacts of all similar proposed developments in Wigan, St Helens, Chorley and Knowsley must be fully considered. 5

6 EA8: Parkside East, Newton-le-Willows We comment below in more detail under comments on Policy LPA10. EA9: Parkside West, Newton-le-Willows. The massive scale of the warehouse sheds are inappropriate at this location it is wholly unsympathetic to Newton-le-Willows historic village centre and would engulf the existing houses in Newton-le-Willows and proposed new housing at Vulcan Urban Village. The loss of 672 acres equal to 31% of Newton-le-Willows Green Belt will cause it not to fulfil its statutory purposes, and is non-compliant with the Government s NPPF. LPA05 Meeting St. Helens Housing Needs Full Objectively Assessed Housing Need CPRE has considered the Mid-Mersey Strategic Housing Market Assessment (MM SHMA, January 2016) for the period 2014 to 2037 by Halton, St. Helens and Warrington Councils. Based on the high forecast economic growth from both Cambridge Econometrics and Oxford Economics, uplift in the Full Objectively Assessed Housing Need (FOAHN) to 445 dwellings per annum. An uplift (1.2%) to improve affordability and so allow more households to form was added, increasing the Full Objectively Assessed Need (FOAHN) to 451 dwellings per year. CPRE has done work with two expert demographers recently and both would recommend a policy-off FOAHN. Housing Requirement The Housing Requirement runs from 1st April 2014 (the base date) and continues for the entire Local Plan period of 1st April 2018 to 31st March 2033 (15 years). Added to the FOHAN was backlog, and buffer of just over 20% from the FOAHN (an increase to 541 per year) to take account of: the Borough s ambitions to continue stabilising and increasing the population; allow for more housing choice and competition so more households can afford to form, allow for significant economic growth; and, to reflect the high levels of housebuilding achieved in years before and after the recession. The Housing Requirement also is adjusted to reflect loss of dwellings averaged at 26 dwellings per year. A 20% uplift, a further requirement of 29 per annum is added to accommodate the demolitions and round the figure up to 570 dwellings per annum. The Preferred Housing requirement of 570 dwellings per annum is the same as the annual average net housing target of 570 set in the St. Helens Local Plan Core Strategy (2012). It is also the target was set by the Regional Spatial Strategy for the North West, which was above housing need estimates. CPRE whilst supportive of delivering enough needed houses of the right type and tenure does question whether the high jobs assumptions causing associated uplift to the housing 6

7 requirement in compiling this evidence are robust, and whether the housing industry has the capacity to build at this level. The housing industry is technically in recession at present, and is constrained with regard to risk, accessing finance, skills and raw materials to deliver such a high number of completions. Setting Up to Fail The Council will be assessed against this impossibly high Housing Requirement figure in the future. It must be remembered that the Council can only allocate land and process applications, it cannot actively build itself. An bloated, overly-ambitious Housing Requirement will enable developers to unfairly pursue the development of land never intended for development if the Council is identified as failing. CPRE advocates a more cautious plan, monitor and manage approach rather than crude predict and provide and the phasing of housing delivery to test whether in reality the employment and housing is needed, before allocating land in the countryside. The current resident population of St. Helens is 177,612 (2015 ONS Mid-year Estimate), with the population forecast to grow steadily over the next years at a slower rate than the North West and England. For three decades St Helens had a consistently declining population, and only since 2007, has it achieved a modest growth rate of 0.2 percent per annum. CPRE agrees that adequate affordable housing and types suitable for aging population must be delivered. Strategic Housing Land Availability Assessment The St. Helens Strategic Housing Land Availability Assessment (2016) identified and assessed potential housing land supply and planning permissions on sites over 0.25 hectares. LPA05.1 Strategic Housing Sites CPRE is opposed to the release of Green Belt land for housing. As stated above because of the bloated housing figures based on high job growth rates, we believe exceptional circumstances have not been demonstrated. LPA06 Extent of Green Belt and Safeguarded Land There is a strong general public understanding of Green Belt, which is: the fundamental aim of Green Belts is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. CPRE was involved in the establishment of Green Belt planning policy to limit the urban sprawl of towns and cities into our rural areas. The fact that 65% of St Helen s 136 km2 is Green Belt is a tremendous success and it should be celebrated and protected. It seems the New Local Plan for St Helens Preferred Options sees Green Belt protected land as fair game for allocation and development. It is contrary to national planning policy and explicit Government promises to protect it. 7

8 The NPPF (paragraphs 79 and 80) maintain existing policy on the intentions and purposes of designation. The important five Green Belt purposes are: I. stopping urban sprawl; II. preventing coalescence (or joining together) of settlements; III. safeguarding the countryside from encroachment; IV. protecting the setting of historic towns; and V. encouraging urban regeneration. Loss of Green Belt stirs strong emotions and CPRE still strongly defends Green Belt land and we note that the exceptional circumstances test remains. Green Belt boundaries should only be the subject of review through the preparation local plans. There must be full justification of reasons for a review, and because of exceptional circumstances no more than one or two sites should be released for development at any one time. We set out further comments to Green Belt under Appendix 2. LPA07 Transport and Travel The local plan should ensure as much development as possible in the future is reliant on public transport infrastructure to ensure development is truly sustainable. At 26.7% the number of residents in St. Helens without access to private transport (car or van) is lower than the regional average of 28% but higher than the national average of 25.8%. Much more progress should be made to provide improved public transport infrastructure and sustainable modes such as walking and cycling. LPA08 Infrastructure and Funding CPRE agrees that the provision of high quality infrastructure to support existing and future development is a key element in delivering successful, sustainable communities. LPA09 Green Infrastructure CPRE agrees that green infrastructure within the countryside and urban areas provide vital functions and is essential for recreation, ecology, public access, health, water management, and mitigation of climate change, landscape enhancement, regeneration, and the economy. We agree with policies set out in: LPC05: Open Space and Outdoor Sports Facilities; LPC06: Biodiversity and Geodiversity; LPC07: Greenways; LPC08: Ecological Network; LPC09: Landscape Protection and Enhancement; LPC10: Trees and Woodlands; and LPC12: Flood Risk and Water Management. 8

9 It is important in the future that new development contributes to the expansion and/or improvement of the functionality and connectivity of the green infrastructure network, in accordance with local circumstance. LPA10 Development of Strategic Rail Freight Interchange (Parkside) Policy LPA10 sets out a proposal for the allocation of 130ha of land at Parkside East and West for the development of a Strategic Rail Freight Interchange. CPRE has consistently objected to these plans on this site, pointing out: how little spare capacity is available on this stretch of the West Coast Main Line to service the site how various plans for the site have failed to make adequate provision for the longer freight trains to be able to make use of it and the excessive amount of Green Belt land proposed for de-allocation around the proposed rail freight site pointing to the likelihood that rail freight in this location is being used as a stalking horse to open up vast swathes of Green Belt for other purposes. Extract: Whilst CPRE Lancashire agrees that a modal shift for freight from road to rail is important, we maintain our strong objection to the development of a Strategic Rail Freight Interchange (SRFI) at the Former Parkside Colliery as it would severely harm the ability of the Newton-le-Willows Green Belt to fulfil its statutory purposes specifically separation. Moreover, it causes adverse environmental and social impacts, specifically concerning landscape value, heritage, ecology, air quality and local amenity. As noted above the NPPF states as a Core Planning Principle that land in Green Belt should be protected. The designation of the area at Newton-le-Willows as Green Belt is long- 9

10 established and the five purposes of Green Belt remain. Therefore any such development in this area would be inappropriate. It is not consistent with Government policy to speculatively remove an area of Green Belt, where it is clear and acknowledged that such an action will cause severe harm to the Green Belt, on the basis that an appropriate proposal may at some time in the future come forward. We believe the site ought to remain in the Green Belt, and any future proposal should be judged against its own merits and satisfy the test of demonstrating very special circumstances. Removal from Green Belt would render the land under threat of smaller ad hoc proposals coming forward. CPRE queries the robustness of the AECOM Study concerning the alternative options for the SRFI scheme. LPC06 Biodiversity and Geological Conservation CPRE Lancashire agrees that development on or outside a proposed or designated Site of Special Scientific Interest which is likely to have a detrimental effect (either singly or in combination with other developments) should not be permitted unless the benefits of the development can clearly be demonstrated to outweigh the impacts it is likely to have on the features for which the site has been designated. LPC07 Greenways CPRE Lancashire is supportive of a strategic network of greenways, being protected from inappropriate development and enhanced, in order to improve public access for recreation, wildlife corridors, sustainable travel links etc. Tranquillity is a highly valued characteristic of the English countryside and a key indicator of its quality. Local plans can identify areas of tranquillity, therefore we encourage St Helen s Council to show in its evidence base, use spatial maps, to identify such areas. We also encourage policy to set out criteria for appropriate forms of development and specific measures which it will take to protect such areas. These criteria in turn could enable the Council in future to ensure as development proposals come forward St Helens more tranquil areas are better protected. LPC08 Ecological Network LPC09 Landscape Protection and Enhancement LPC10 Trees and Woodland 10

11 LPC11 Historic Environment LPC12 Flood Risk and Water Management LPC13 Low Carbon and Renewable Energy Development LPC14 Minerals LPC15 Waste LPD01 Ensuring Quality Development in St. Helens CPRE supports new housing being required to be of a minimum good quality to continue to be desirable in the future. St Helens decision makers must promote a sense of pride in its places as new development comes forward in the future. LPD02 Design and Layout of New Housing To protect and enhance local rural character local building styles and local materials should be encouraged. We are seeing too many copy book housing developments coming forward that are incongruous with the St Helens locality. LPD03 Open Space and Residential Development CPRE promotes the provision of a good standard of local urban green space as new development comes forward. It is important for ecosystem services to have space to absorb rainwater, provide habitat and connections for wildlife, and space for people to play sport and spend time relaxing outdoors. LPD05 Extension, Alteration or Replacement of Dwellings or conversion to dwellings in the Green Belt LPD09 Air Quality The air quality policy is not strong enough, focusing as it does on not making existing air quality management areas worse. It should make firm commitments to work towards improved air quality (including reducing the need to travel through good planning policies) - for the benefit of the health of the borough s citizens. The existence of green space helps to provide for a green lung function to filter air and water borne pollution and provide much needed oxygen. The value of the countryside must be fully recognised. Green space should not be sacrificed so easily. 11

12 LPD11 Health and Wellbeing CPRE notes life expectancy in St Helens is considerably less than national averages, in the main due to cancer, heart disease and respiratory disease being significantly worse than the national average. Child obesity is also an issue. The value of outdoor exercise is well evidenced. We all feel de-stressed with a walk in fresh air, especially if it involves pleasant green landscapes, trees, wildlife. CPRE believes access to good quality urban green space, and local countryside is vital in the future to promote improved fitness of the population through walking, cycling and other leisure activities. 12

13 Appendix 2 - St. Helens Local Plan Draft Green Belt Review 2016 CPRE, as stated in Appendix 1, believes too much employment and housing development has been identified over the local plan period based on flawed thinking and inaccurate assumptions that bear little relation to reality. A realistic level of development should be planned for in the future. St. Helens has been really successful in regenerating brownfield land in the past and must continue to maximise its contribution in the future. CPRE agrees that the Borough must identify a robust five year supply of housing and suitable sites for employment, but we believe the duty to cooperate as set out in the NPPF must be applied in advance of preventable countryside sacrifice. CPRE believes the local plan underestimates how much needed development could be delivered on available brownfield sites CPRE has considered the Review that considered the development potential of each of the sites which were promoted through the Call for Sites together with three additional site considered suitable by officers. We note the site specific constraints such as flood risk, ecology and access, as well as the performance of the Green Belt parcel in which it is contained, although we would argue that some parcels of land perform well against Green Belt purpose. Some 165 promoted sites within Green Belt. This number is staggering. 59 sites were screened out: More than 2/3rds in flood zone 2 and 3; More than 2/3rds in covered by LWS; More than 2/3rds covered by TPO trees or woodlands; Suitable highways access was not deemed to be feasible; Impact on the Green Belt; Sites in isolated locations in the Green Belt. Three further sites were included for assessment (as safeguarded land only at this stage) even though they have not been actively promoted. They are: 13

14 GBS 169, Land west of Red Delph Farm (included in HS19 of the Preferred Options) GBS_166, Land at the corner of Higher Lane and Mill Lane, Rainford (Safeguarded site HS20 in the Local Plan Preferred Options) GBS_167, Land north of Gorsey Lane, Bold (included in Safeguarded site HS03 in the Local Plan Preferred Options). CPRE has considered the 109 sites assessed in Stage 3 and 4. We set out our concerns for four of the 9 proposed allocated sites in Appendix 1. CPRE is opposed to all of the 16 sites for housing due to an excessive number of houses being planned, due to more brownfield delivery being possible and that neighbouring authorities, particularly Liverpool could supply much needed housing. Liverpool is also trying to boost jobs and housing and the St Helen s Local Plan could severely undermine Liverpool s urban regeneration ambitions. 14

15 CPRE believes the two sites for employment and twenty-four housing should continue to be safeguarded. CPRE strongly opposes the proposals to release 1, 187 hectares of land to be released from the Green Belt. 15