Parish Council Response To Local Plan Review Preferred Options Consultation

Downholland Parish Council’s response to the West Lancashire Borough Council’s Preferred Options Plan Review

Downholland Parish Council undertook a “Housing Needs and Opinions Survey” in Spring/Summer 2018 and have developed this response considering this evidence base and through discussion with Parish Councillors and residents.

We are a rural area with extensive views across agricultural land and this is of primary importance to the residents of our area.

General Principles

  1. We support Paragraph 15 of the NPPF which states that the plan be “a platform for local people to shape their surroundings”
  2. We are opposed to any development on agricultural land.
  3. We believe recent and planned developments (that have permission) will be sufficient for our area given its population and current level of infrastructure.
  4. Infrastructure problems such as drainage, sewerage and electricity that have beset certain areas should not be exacerbated by any future developments.

Response to the Policy H2, II Major Residential Development Sites.
Specifically 50 dwellings at Blundells Farm Haskayne (HW6 Site)

We believe that the 23 dwellings granted permission on the site (Planning Application 2017/0026/HYB), combined with the 50+ additional local dwellings since 2010, represents the maximum sustainable development level possible within the area in the time period of the plan.

Referencing Section 2 NPPF guidelines on Achieving Sustainable Development, the current level of infrastructure in relation to health, employment, transport services and lack of any retail services does not support any further development beyond this growth level.

We found insufficient evidence of a local need for affordable housing, retirement accommodation or general market housing to support further development.

As noted in the evidence base “Site has direct access onto A5147 (although this may be inappropriate at this location close to a junction), and also onto School Lane via two ‘strips’)”. The layout in the existing application 2017/0026/HYB removes the possibility that additional dwellings could enter/exit onto School Lane, and this in turn would necessitate an additional entrance on to the A5147 Wanisher Lane, widening the planned “Agricultural Access” (2017/0021/FUL). This would exacerbate the traffic issues locally, require relocation of the bus stop and shelter even further away from the settlement (currently 550m from the centre) and physically isolate the additional dwellings from the rest of the settlement.

Even if 2017/0026/HYB was set aside and a further plan developed for the whole site, the traffic would enter/exit onto School Lane (described in TWP014 as a “quiet lane”) which has already had an increase of 50+ dwellings since 2010.

Response to Policy H2 5.32 Alternatives Considered.
Specifically “Land at Hollin Farm, Haskayne”

We disagree with the site assessment “Site unlikely to be developed for employment uses” as the site is currently a working farm employing local residents.

We agree with the assessment that the loss of a working farm in an agricultural area would have “a detrimental impact on a heritage asset within the site”.

Response to “H1. III. Rural Exception Sites”

We believe this policy should be amended to include the following statement and our justification and reasoning are detailed below.

“Pre-application determination of requirement, size and location should include engagement with the local community and the Parish Council along with other statutory consultees”.

We feel that this engagement needs to occur at the pre-application stage, as once an application has been submitted there is little scope within the process for suggesting alternatives.

While we support the aims of this proposed policy, we found little evidence of a local requirement for affordable housing. If a development is to be proposed, then we would maintain that it should address a locally identified need for such housing, rather than to satisfy a wider quota. We would encourage cooperation with developers at the “requirement determination” stage of the planning process.

In specific regard to any RES developments, we support and would like to see a strengthening of the role of the Parish Council as a statutory consultee [1] in Pre-application Engagement as per the NPPF Decision Taking guidelines [2].

The main settlement (contiguous developed area) of Haskayne is approximately 10 Hectares.

Paragraph 71, Footnote 33 of NPPF regarding “entry-level exception sites” states that the sites “should not be larger than a hectare in size or exceed 5% of the existing settlement”.

5% of our 10 Hectare settlement is around 0.5 Hectares and we would therefore not support any development that exceeds this size.

We note NPPF Paragraph 71, Footnote 34 which states that “Entry-level exception sites should not be permitted in … land designated as Green Belt”.

We note Paragraph 145 Section F “limited affordable housing for local community needs under policies set out in the development plan (including policies for rural exception sites); “.

Considering this, we make further comment below in respect to the location of such sites.

in respect to Policy H1. III / Rural Exceptions Sites Point a.

“The site is located immediately adjacent to the settlement boundary”

and in respect to 5.13 p83

“Rural Exception Sites (RESs) should lie immediately adjacent to the settlement boundary, in order to minimise the impact on the wider countryside and to maintain as far as possible the ‘form’ of the settlement. Planning applications for development on RESs should be accompanied by a statement demonstrating that careful consideration has been given to the development of suitable sites within, or closer to the centre of, the settlement area, including contact having been made wherever possible with landowners or site agents, prior to proposing the development of land outside the settlement.”

We maintain that:

The principle of “proximity” present in these policies is too blunt a metric to determine the ideal location of these developments, and consideration of local factors and issues should be considered also.

Other Factors Include:

  1. Openness of Green Belt & Visual Amenity.Paragraph 141 of the NPPF states that

    Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.

    Referencing this, impact on landscape and the number of dwellings whose visual amenity would be impacted upon by any development should be given weight during the consideration of the location of any developments, and the selection of any site should not be based solely upon the distance from the “centre of the settlement area”.

  2. Distance from the school and the communal areas of the village such as the Village Hall, the park and BMX track and the Parish Council’s building which is used as a part time post office and youth club.
  3. Avoidance of sites that currently suffer with problems such as traffic, parking and infrastructure reliability.

We would encourage cooperation with developers at the “site selection” stage of the planning process.

Justification for this preference is to be found in:

Parish Council minutes concerning traffic issues, parking problems and infrastructure issues.

Paragraph 8, section b of the NPPF, not least the aims “well designed” & “open spaces”

Our survey which holds landscape views and rural character as being of primary importance.

Paragraph 145, section e of the NPPF:

Limited infilling in villages;

Paragraph 145, section g of the NPPF:

“limited infilling…. which would not have a greater impact on the openness of the Green Belt than the existing development; or ‒ not cause substantial harm to the openness of the Green Belt”

Local Plan Policy SD2/I/d, specifically “appropriate siting, orientation, mass, height, density, materials, landscaping and landscape context”.


[1] Representations by Parish Council before determination of application
The role of a Parish Council as Statutory Consultees as defined in Town and Country Planning (Development Management Procedure) (England) Order 2015

[2] National Planning Policy Framework. Paragraph 190. Pre-application engagement and front loading.

The more issues that can be resolved at pre-application stage, the greater the benefits. For their role in the planning system to be effective and positive, statutory planning consultees will need to take the same early, pro-active approach, and provide advice in a timely manner throughout the development process. This assists local planning authorities in issuing timely decisions, helping to ensure that applicants do not experience unnecessary delays and costs.