Sandra Jones, Clerk to the Council
10 Priory Close, Burscough, Ormskirk, Lancashire, L40 7UY

November 2018
Newburgh Parish Council welcomes the opportunity to comment on the West Lancashire Borough Council Local Plan Review.
We strongly oppose the Preferred Options in their current form and submit the following comments:

1 The Local Plan
1.1 Time horizon
Newburgh Parish Council questions the need for a Plan with a time horizon of 2050.
The distant time horizon must make the population forecasts and the consequences for the Borough less reliable than forecasts over a shorter timescale.
The usual Local Plan period is much shorter than the one now proposed. The current Local Plan covers a 15 year timespan to 2027. All the Local Plans for the Liverpool City Region which share the population challenges of West Lancashire have timescales no further out than 2037. The adjacent Borough of Sefton has a Local Plan from 2015 to 2030. Housing needs projections for Liverpool City Region and the Borough use the timeframe up to 2037 (SHELMA ( Reference 1) ; HEDNA (2)). The WLBC Plan addresses housing requirements for 13 more years up to 2050 including the “unmet needs” of the Liverpool Clty Region with major consequences including the release of Green Belt for the whole period. Why does West Lancashire need a Plan out to 2050 – effectively adding the timespan of a second Local Plan – when other Boroughs whose housing requirements it is being asked to help provide are on shorter timescales?
In addition we are unclear why the Council now believes that it is appropriate to seek to accommodate housing from Sefton’s unmet need when a similar request in 2012 was considered inappropriate (3). It is a remarkable turnaround from arguing in 2012 a case for not being able to release Green Belt to absorb housing from Sefton to acceptance of 6256 additional houses from Liverpool City Region. We recognise that there is a duty to cooperate but that does not mean it is obligatory to accept an unmet housing need from elsewhere.
1.2 Absence of phasing
The impact of the sheer scale of the Plan is aggravated by the lack of phasing of the developments required to provide 15,992 houses. The argument is that this should encourage competition in the market and remove barriers to development of a number of sites. The counter argument is that the result could be an uncontrolled and random programme of developments driven by developer choice which could result in houses being built before there is market need and in locations that might be least suitable for development such as rural villages.
The Council’s Infrastructure Delivery Plan Update Oct 2018 9.28 says Highways England, commenting on the lack of phasing, “consider it would be considerably more difficult to plan for strategic infrastructure to meet the needs of the likely demands upon it”. The same must apply to the provision of key services included in social infrastructure such as medical, schools and emergency services.
Finally, National Planning Policy Framework (para 67 says) planning policies should identify “specific deliverable sites for years one to five of the Plan, specific developable sites or broad locations for growth for years 6 – 10 and, where possible for years 11 – 15…”
1.3 Green Belt
The release of the total requirement of Green Belt land for the whole period to 2050 will presumably allow developments at any stage in the Plan period. There is surely an argument for gradual release of Green Belt in conjunction with phasing of developments and subject to the normal five-yearly Local Plan reviews?
1.4 Infrastructure
With allocations of housing in Burscough, Newburgh, Parbold, Skelmersdale and Appley Bridge, it can be expected that there will be a major traffic increase on the A5209 which is a main artery to the M6.
Traffic has increased significantly in the past few years not only of cars but also of very large heavy good vehicles for which the road is totally unsuited. In a Lancashire County Council count in 2014 the average daily total number of vehicles over five days was around 6200 travelling east – west and a similar number travelling west – east. Recent counts by the Parbold speed camera record an average daily total travelling east – west of around 7000.
Can developments be justified on this route which will add further increases to this load without an infrastructure solution?

2. The place of Newburgh in the Local Plan
2.1 The impact of 100 houses and proposed developments
The 100 houses proposed for Newburgh have been determined by allocation rather than meeting a specific need for the village.
The requirement for 100 houses in Newburgh would have a major impact on loss of productive Green Belt, on services and infrastructure.
In particular, Newburgh has no medical services which means the most likely impact will be on Parbold surgery. The developments of 100 houses in Newburgh and 100 houses in Parbold will potentially add around 500 new residents. Parbold Surgery reports on the difficulty of recruiting new GPs and the need to expand premises to house any additions. It is noted that Community Infrastructure Levies funding would have to be sought for any building expansion. But in the absence of any knowledge of when any developments are likely to be built, planning is impossible.
Newburgh’s ageing population is also faced with the challenge of travel to the surgery and other services not available in the village with more dependency on cars and a sparse bus service which is only guaranteed up to 2021.
If the major proposed Newburgh sites were included for development, large areas of productive Grade 1 agricultural land would be sacrificed. The Lawrensons Farm site (Ref TEP003) also presents difficult access problems for large volumes of vehicles from a narrow track on to an over-worked main road and removes the amenity of an attractive open aspect over the Green Belt. The alternative site Strawberry Farm site (TEP001) presents similar problems of the impact of large volumes of vehicles and visual amenity.
The Preferred Options paper (Policy IF1 I.a) says that development will be permitted “where it would provide safe and adequate pedestrian, cycle and vehicular access to, from and within the development and would not materially add to highway safety concerns….” The large Newburgh sites do not meet these criteria.
2.2 The case for small development
Newburgh has conducted a Housing Opinion Survey (4) that sought residents’ views on the scale of developments and the number and type of houses that would be acceptable to the village if some growth was required.
The results from a significant 40% response rate show conclusively that the preference is for Infill/ small developments.
There is an argument for some amount of growth as a result of the changing population. Some need has been expressed for smaller properties for downsizing or for younger people seeking starter homes.
Newburgh Parish Council submits that, if the village has to meet some of the requirements for growth under the Local Plan, sites should be sought which
– respond to the preference for infill/small development
– do not use productive land
– would require only marginal alterations to the Green Belt
– have limited impact on services and infrastructure
– allow more variety of design that can add to the character of a rural village.
The National Planning Policy Framework (para 68(a)) states that 10% of the Local Plan housing requirement should be made up of sites of no more than one hectare. But the Local Plan claims this target cannot be met because of the long plan period, significant housing requirement and lack of sites. This further argues against the time period and housing requirements of the Plan.

3 The importance of involvement in design
Whatever the outcome of the Local Plan for housing development in Newburgh it is essential that there should be full cooperation on the composition and design of any development, large or small.
The National Planning Policy Framework (para 127) says:
“Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussion between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests. Applicants should work closely with those affected by their proposals to evolve designs that take account of the views of the community. Applications that can demonstrate early, proactive and effective engagement with the community should be looked on more favourably than those that cannot.”

Newburgh Parish Council strongly advocates that West Lancashire Borough Council incorporates this policy in the Local Plan.

4 Conclusion

In conclusion Newburgh Parish Council opposes the Local Plan in its current form for the above reasons applying to the whole Borough and to Newburgh village. We are happy to engage with West Lancashire Borough Council on a revised Local Plan which better identifies a realistic housing growth requirement for West Lancashire over a more realistic time period.

(1)Strategic Housing and Employment Land Market Assessment January 2017
(2)Housing and Economic Needs Assessment March 2017
(3) Letter from Kim Webber MD West Lancashire Borough Council to Margaret Carney Chief Executive Sefton Council 8 June 2012.
(4) Newburgh Housing Opinion Survey