WEST LANCASHIRE BOROUGH COUNCIL
Local Plan Review – Preferred Options
Friday 12th October – Thursday 13th December, 2018
Comments can also be submitted online at www.westlancs.gov.uk/lpr
The Council is ambitious for West Lancashire - our economy, the environment and for the health and wellbeing of residents. These Local Plan Preferred Options propose a new Local Plan that reflects those ambitions, seeking to ensure that West Lancashire improves as an attractive place that people will want to live, work and visit, and does so in a sustainable, planned manner over the next 30 years in a way that provides a degree of certainty for all.
The Council initially consulted on the Scope of, and the Issues and Options for, the Local Plan Review in 2017, and we are now asking for your views on the second stage – The Preferred Options for development, which is essentially a first draft of a new Local Plan. The consultation process will allow the Council to hear and consider your views and take them forward to the next stage of the process. This will be the production of a revised Draft Plan, known as the Publication document.
Copies of the Local Plan Review- Preferred Options document are available to view online at www.westlancs.gov.uk/lpr or at WLBC Council Offices (Derby Street, Ormskirk & the CSP, Skelmersdale Concourse) or the libraries in Skelmersdale, Ormskirk, Burscough, Tarleton and Parbold.
Please provide your comments on the proposals within the Local Plan Preferred Options document. Your views will be considered and will assist the Council in preparing the next stage of the Local Plan process. This will be the production of a revised Draft Plan knowns as the Publication document.
Please provide your comments before Thursday 13th December, 2018. Comments received after the consultation period has ended will not be considered.
Please return your forms to firstname.lastname@example.org or Local Plan Team, West Lancashire Borough Council, 52 Derby Street, Ormskirk, L39 2DF by Thursday 13th December, 2018.
Level 3 Privacy Notice
West Lancashire Borough Council
Development and Regeneration Services – Strategic Planning and Implementation
Strategic Planning Consultations / Correspondence
How we handle your data
We will use the information you provide to us to help develop planning policies and strategies. We would encourage you to provide your personal details (name and address / email address) in order for us to properly consider your response. However, providing your personal details is not mandatory, except where legislation requires it (for example at the Submission / Examination stage of the Local Plan). If you choose to submit your personal details, we will hold them in line with our Level 2 Privacy Notice.
For further information as to how we handle your data, please see the Level 2 Privacy Notice. Hard copies are available on request, or they can be found at https://www.westlancs.gov.uk/planning/planning-privacy-notices.aspx. If you would like to discuss this notice, or how we will use your personal data, you can contact the Planning Policy team via email@example.com or on 01695 585284.
How we will use your data
As this is a public consultation, your comments will be available for public inspection. We may publish your name (first name and surname) and the organisation you are representing (where applicable) against any comments you make. Please make sure you only give information you are happy for others to see. All other personal information (e.g. address, email address) will be kept confidential by the Council.
We may retain your personal information when you respond to planning policy consultations. This data will be held securely. Information you supply, including your contact details, will be held for an appropriate period to support the service. We may share your information with other council officers to respond to your comments. Other than publishing your name (first name and surname) and the organisation you are representing alongside any comments you submit, your personal information will not be disclosed to any third parties without your prior consent.
Your comments, but not your contact details, will be published on our website and reported to officers and members. Your comments will be considered as we prepare final recommendations and our response will be reported through a feedback report.
WEST LANCASHIRE BOROUGH COUNCIL
Local Plan Review – Preferred Options Consultation
12th October, 2018 – 13th December, 2018
Organisation (if applicable)
Including post code
Are you submitting comments on behalf of someone else?
Have you read our privacy statement and do you consent to providing your details?
Please use the comment box overleaf to comment on a specific site allocation or policy (Please include the site reference or policy reference). If you wish to comment on more than one policy or site in the Local Plan Review Preferred Options document, please just provide those comments on additional sheets as necessary.
To which policy or site in the Local Plan Review Preferred Options document do your comments relate?
I am objecting length and scope of the Local Plan Review – Preferred Options as I consider the rationale is flawed given there is an incomplete evidence base and as such it fails to comply with the Government’s National Planning Framework.
(If you wish to comment on more than one policy and / or site, please provide clear headings in the box below so that it is clear which policy / site each comment is referring to.)
Please provide your comments
Adopted Local Plan 2012/27
The existing Local Plan is meeting Local Housing Need, still has 9 years to run and has proven to be robust as evidenced earlier this year when the High Court ruled against the two rogue Applications for the land off Parrs Lane, Aughton. Since the adoption of the existing Local Plan in October 2013 there have been no rogue developments in West Lancashire.
It is performing to an acceptable level in terms of delivering the required housing numbers, is maintaining a 5 year supply of housing land and has the added safety net of providing additional land should it be required by way of the designated Safeguarded Plan B Sites.
The existing Adopted Local Plan 2012/27 specifically includes the provision of 5 yearly reviews to ensure it continues to deliver the required housing numbers and maintain a 5 year supply of housing sites.
Lack of evidence to support the need for a new 30 year Local Plan to 2050
A Local Plan for 30 years covers an extremely lengthy period, well beyond usual Local Plan timescales. It exceeds the period covered by the Strategic Housing and Employment Land Assessment (SHELMA) produced by Liverpool City Region Combined Authority that covers the period to 2037. It is impossible to forecast, in spatial planning terms, the housing and employment needs up to 2050.
None of the other local authorities in the Liverpool City Region are working on a new Local Plan to 2050. Indeed, it has not been possible to identify any other local authority in England that has embarked on such a course of action.
Release of 1,500 acres of highly productive agricultural land from the Greenbelt
A New Local Plan to 2050 is a high risk option as it is likely to be unacceptable to the Planning Inspectorate when it is tested at the required Public Enquiry. There is a lack of certainty regarding the housing and employment land need and demand for so far into the future. As such it fails to meet the Government's requirement as set out in the National Planning Policy Framework which states there has to be exceptional circumstances that are fully evidenced and justified before releasing land from the Greenbelt. This is clearly not the case given there are no official forecasts for population and household growth in West Lancashire beyond 2041.
The Council’s own Preferred Options Report, under Key Issues, states "the amount of best and most versatile agricultural land in the Borough is a regionally important resource and is vital to the high performing agricultural industry (farming) in West Lancashire”. Yet the Council wants to build on 1,500 acres of Grade 1 highly productive agricultural land. Given the lack of evidence to justify the excessive term and scope of the Preferred Options Report, the proposals are clearly flawed and unjustified.
There is a lack of evidence to justify the need for 16,000 new houses by 2050. In fact, there is no evidence at all beyond 2041 as no official forecasts exist beyond that year. Based on 2.5 persons per home this equates to a population growth of 40k. It is appreciated that there are hidden households (e.g. young families living with grandparents) and a trend for more people living alone but these will only make a marginal difference.
The Lancashire County Council Website carries forecasts (based on the latest information published by the Office of National Statics) that states the present population of West Lancashire as 113,534 (2018) and forecasts that it will be 116,921 (2041), an increase of just 3,387. It also gives the current number of households as 46,530 (2018) and forecasts that it will be 49,030 (2041), an increase of just 2,500.
Taking a cautious average of 2.5 persons per household, 16,000 indicates a population increase of 40,000 by 2050 which is totally out of line with the official forecast of 3,387 by 2041.
The SHELMA (Strategic Housing & Employment Land Market Assessment) Consultation Draft prepared for Liverpool City Region Combined Authority includes the needs of West Lancashire and was produced in co-operation with WLBC but forecasts to 2037. The SHELMA forecasts the housing need for West Lancashire, even on a growth scenario, as 241 per annum plus 57per annum for specialist need e.g. care homes for the elderly.
The Preferred Option Report cites the NPPF Duty to Co-operate with Neighbouring Authorities as justification for the inclusion of 6,256 new houses to meet the alleged unmet future housing need of Sefton and other authorities in the Liverpool City Region.
Yet this is unjustified as all these local authorities have made provision to meet their forecasted housing and employment needs in their own Local Plans - Liverpool 2013/33, St Helens 2018/33, Knowsley 2010/28, Sefton 2012/30 Wirral 2012/28 and Halton 2014/37.
Employment Land Need
The Employment Land Requirement set out in the SHELMA is 63 hectares for the period to 2037 yet the Preferred Options Report proposed 190 hectares for the period to 2050. This is a disproportionate increase that is not justified by the additional 12 years so the obvious conclusion to be drawn is that West Lancashire is looking to compete for commercial developments with the Liverpool City Region. It is also proposing to release land in the Greenbelt to meet these developments when the LCR already has the necessary land, much of it Brownfield Sites, allocated in their existing Local Plans.
The Draft West Lancashire Local Plan Transport Assessment published on the Council's website gives forecasts for a huge increase in traffic flows should the Preferred Options be implemented and states that considerable investment would be required to facilitate sustainable growth.
Given the substantial cost and the very poor track record for infrastructure investment in West Lancashire, the likelihood of such investment in the future must be questionable and cause for serious concern.
While the Council's application for assistance from the Government's Housing Infrastructure Grant Scheme has been shortlisted, if eventually approved it would only fund the enabling infrastructure in respect of the Greater Skelmersdale proposals i.e. moving the gas pipeline and the access roads for commercial development either side of the M58 and the 3 Garden Villages.
The Preferred Options does not give any assurance about the impact on the already inadequate highway structure in West Lancashire. The volume of traffic on the rural roads during the daily peak times is already a problem and the lack of information must give rise to serious concerns that the situation will continue to deteriorate.
Congestion is particularly bad around Ormskirk’s gyratory system, the A580 and the A59 in Burscough and Banks Bridge in Tarleton. The use of our rural roads as rat runs will substantially increase particularly in relation to traffic trying to access the M6 and avoiding the M58.
There are various vague statements in the Preferred Option for highway improvements across the Borough and these in themselves give rise to further concern e.g. a new relief road linking St Helens Road to Prescot Road that will worsen the existing traffic congestion in Aughton by the creation of a large rat run for traffic trying to avoid Ormskirk Town Centre.
The Preferred Options include dispensing with the use of Safeguarded Land and allowing the market to decide when the identified sites will be developed. Such an abdication of responsibility by the Council would lead to a free for all with the Developers being able to cherry pick and build on the most desirable sites. It would also delay the development of less desirable sites i.e. in the less affluent areas or those more difficult to develop which usually provide the most affordable housing.
Failing to protect or release sites in line with the planned delivery of housing numbers will prove problematic particularly in relation to Skelmersdale. The rationale that letting the market decide will avoid planning appeals is unsound. While there will be no Plan B sites to defend, the change in policy will lead to more appeals in relation to contesting onerous planning conditions e.g. infrastructure investment, housing numbers and affordable housing percentages.
Impact on the Environment
Pollution from vehicles is already a major national issue given Nitrogen Dioxide is reported to cause 80,000 deaths a year. 16000 new homes equate to 40,000 additional residents and say 25,000 more cars plus the additional traffic, both cars and commercial vehicles, from the development of the proposed employment sites.
There is already a long-standing problem with pollution, in excess of the legal maximum, on parts of the Ormskirk gyratory system that is caused by congestion and the resultant stationary traffic. The Preferred Options can only increase traffic congestion and the resultant pollution.
Thank you for your comments.
Please return your forms to firstname.lastname@example.org or Local Plan Team, West Lancashire Borough Council, 52 Derby Street, Ormskirk, L39 2DF
by Thursday 13th December, 2018.