With apologies for the length of this detailed document – read it when you have some time to spare.
Sefton Council Lib Dem Opposition Group
Leader Cllr. Iain Brodie Browne
26th September 2013
Labour’s draft Local Plan for Sefton is inadequate, fails to protect high grade agricultural land and lacks ambition
The Liberal Democrat Group on Sefton Council have major concerns about the draft Local Plan and the preferred ‘Option 2’ put forward by the Labour administration on Sefton Council.
Our fundamental concerns are:-
• The draft plan lacks robustness in terms of population predictions and therefore the housing requirements flowing from the data used can’t be anything more than vaguely informed guestimates.
• The effect of taking the plan forward based on potentially flawed data means that high grade agricultural land, within Green Belt, will be designated for house building when this may well not be necessary.
• The seeming lack of detailed working with West Lancashire Borough Council is worrying as they are the local authority that Sefton has by far the largest boundary and most significant community of interest with.
• The leading references in the draft plan to Merseyside Councils are misleading and unhelpful because the centre and north of the Borough (the majority of the Sefton) rightly expects the Council to be heavily engaged with West Lancashire as a priority with the southern Merseyside Councils being of less significance for two thirds of the Borough’s population.
• The flawed method of public consultation used by the Council may well have reduced the number of residents who felt able and comfortable to participate in the process.
• The plan is all but silent on some major issues across the Borough that need to be planned for.
GENERAL & BOROUGHWIDE COMMENTS ABOUT THE DRAFT PLAN
Why is 500 the answer again?
The plan’s preferred Option 2 will mean that each year 510 houses will be built in the Borough – this is a remarkably similar figure to the target of 500 houses per year which was previously imposed on the Borough via the last Labour Government’s Regional Spatial Strategy.
Bearing in mind that after the RSS figure was imposed the UK entered into and is still suffering from the effects of a massive economic recession and that the draft plan is allegedly built upon new economic and population data etc. the similarity of the proposed house building figures is at best questionable.
It is also the case that the draft plan seems to indicate a much higher figure (above 660) of houses ‘need’ be built per year. In another context the Council’s public statements say that 5,000 houses need to be built in the existing urban areas. These figures are at best confusing.
Concerns about the quality and accuracy of data
We have great concern about the quality and accuracy of the data used in the production of the options within the plan. This point is made in the context of the Council’s lead consultants, NLP, openly saying at a Local Plan Stakeholder meeting in May of 2013, at Bootle Town Hall that the Borough’s year on year declining population is suddenly going to go into reverse and significantly rise again. What’s more they said to this forum that the rise would be caused by inward migration. When questioned to explain this statement they said that the migrants would be made up of people moving into Sefton from other parts of the UK, people returning to Sefton who had moved away and migrants from outside the UK. To date we have not seen what we accept as credible data to robustly back up these assertions.
Loss of ‘best and most versatile’ agricultural land
The Green Belt surrounding Sefton’s diverse communities is almost totally comprised of high grade agricultural land often referred to as ‘best and most versatile’. However, Option 2 clearly indicates that a significant part of this land, which is presently used for the growing of food, will be lost to housing developments if the Council presses ahead and confirms the preferred option of the Labour administration.
Our clear view is that compromising high grade agricultural land is a hugely negative step backwards and that it is environmentally unsustainable.
The potential size increases of some communities, e.g. Maghull to increase by nearly 25% and Lydiate by 35% will fundamentally change the character of these parishes. The Local Plan process was supposed to prevent such significant increases and we feel that the scale of the proposals is therefore unacceptable.
Some small Green Belt compromises are possible
We do realise that some land that technically falls within Green Belt can sensibly be developed because it is often not high quality agricultural land.
The Power House in Formby, land east of Southport at Kew, the Pontins site in Ainsdale and the presently vacant Ashworth South site in Maghull are examples of sites where a reasonable compromise can be made. The Power House, Pontins and Ashworth South are clear examples of sites which have previously been built upon to some extent and therefore lend themselves to being developed.
This approach can take the pressure off building on high grade agricultural land. However, such reasonably developable sites within the Green Belt are few.
Lack of detailed working with West Lancs
We understand that West Lancs Borough Council has some concerns about Option 2 particularly with regard to the reserved sites in Lydiate which if developed will leave too narrow a Green Belt with Aughton. We share this concern.
In general we have concerns about the seemingly lack of detailed joint Local Plan development with West Lancs Borough Council. This is evidenced by West Lancs’ comments about the Lydiate reserve sites and the lack of detail in either the Sefton or indeed West Lancs plans to address transportation issues (both rail and road) to the east of Southport.
The fact that the Local Plan process seems not be developing a common detailed agenda to address traffic congestion between Southport and Ormskirk and the improvement of rail services to and from Southport along the Wigan Southport railway line is regrettable. The reconnection of the Wigan – Southport and Ormskirk – Preston railway lines at Burscough (via the Burscough Curves) is also surprising by its omission from the draft.
Negative impact developments in retail units
Prevention of retail ghettoisation – The Local Plan should aim to restrict the spread of betting shops (particularly given the prevalence of fixed odds betting terminals) and pay day loan shops.
Whilst raising issues such as global warming, climate change and sustainable development the plan is far from being ambitious in this crucial area of environmental sustainability. Sefton’s Local Plan and indeed those of our neighbouring Councils need to major on energy conservation and the highest possible energy-saving/low carbon targets for all new developments. District heating is being embraced in one area of Kew in Southport but this can only be the start. Biomass boilers on a communal basis are another way forward that must be grasped.
Whilst doing this the Council should be seeking effective ways to improve, as far as possible, the Borough’s current stock of commercial and domestic buildings with regard to energy usage.
Should we not also be considering the aims of Merseyside Fire & Rescue Authority by pushing hard the policy of encouraging the installation of sprinkler systems in all new commercial property builds in the Borough and retrofitting into older properties?
Shale Gas extraction has to be a major issue for Sefton as exploration work is already happening in neighbouring West Lancashire and the license under which that is taking place also covers parts of our Borough. It is almost certain that the UK will need to exploit this source of fuel within the next few years yet the Local Plan is all but silent on the matter. As the plan is meant to cover the next 15 to 20 years for it to virtually ignore this issue is far from being a sound planning process.
Flooding – the two large greenbelt sites proposed for building in the north of Southport and one of the ‘reserved’ sites in Lydiate are prone to flooding and they add to concerns that the draft plan does not give enough emphasis to flood prevention.
We fear that planning for future school requirements is not a robust part of the Local Plan and that this needs to be addressed especially if the Council presses ahead with major housing developments. A sit and wait to see what develops approach will be irresponsible where significant developments are to take place especially when half of the Borough is already very close to experiencing stresses with regard to primary school places.
It also has to be held in mind that schools in Sefton are popular for parents from West Lancs, Knowsley and Liverpool to send their children to, so housing developments in those neighbouring council areas will have an impact on the demand for places within the Borough.
We have concerns about the impact of major housing developments in the Borough (and indeed in surrounding council areas) as they will have an impact on the capacity of our local NHS facilities and hospitals. The Local Plan needs to addresses the problems that will occur with extra pressure on hospitals, GP surgeries and NHS dentists. These health aspects have to be a major part of all future major planning applications as accessibility to and the capacity of NHS facilities to cope are big issues
The challenges of Liverpool’s greatly declined population
Demand for housing in Sefton and indeed in other Boroughs surrounding Liverpool has been ratcheted up by the city’s ever declining population over many generations since the Second World War. Whilst Liverpool has stemmed that loss it needs to rebuild its lost population and use up brownfield sites across the city for housing. The longer it takes to address this issue the greater the pressure will be on Sefton to sanction the building of houses on its high grade agricultural land. This is a sub-regional matter that urgently needs to be addressed.
Questionable public consultation process
Before the 12 weeks public consultation was embarked upon (July to September 2013) we and indeed independent environmental campaigners from across the Borough raised such concerns but they were not taken on board. We suggested that the planned method of public consultation was inappropriate and would not engage people fully. What concerned us was the need for members of the public to book an appointment to enable them to express their views on the draft Local Plan face to face. We said this was an unreasonable barrier to the consultation process and that it would effectively hold residents at arms length instead of welcoming them into it. We still hold to that view and are concerned that a true picture of the concerns of residents across the Borough may well not have been obtained.
SPECIFIC ISSUES NOT ADEQUATELY COVERED BY THE DRAFT PLAN
Need for social housing not effectively addressed
Social housing is in great need in some parts of the Borough with Southport being an obvious example where there is significant need. We do not believe that the draft plan is suitably robust in making the case for a greater proportion of new-build housing being designated for social housing than is the case via the Councils present UDP plan and policies. There is evidence of councils across the UK making social housing a higher priority (in some cases 40% of developments) and we would point to Cambridge as good example.
Opportunity for vacant retail property not exploited
We are concerned that vacant retail property across the Borough is not being identified for conversion into dwellings wherever this is possible and desirable. Our view is that this aspect of local planning policy requires greater innovation and imaginative thinking from the Council so to actively encourage property owners to convert vacant retail property which is unlikely to have a secure future in retail use going forward.
COMMUNITY SPEFIFIC COMMENTS
Maghull’s urban extension & Lydiate’s ‘reserved sites’
The proposal to allow a huge swath of land to the east of Maghull to become an ‘urban extension’ will increase the number of houses in Maghull by nearly 25%. We do not believe such a move is in any way commensurate with Maghull’s housing need. To build on this vast area of presently farmed and food growing high grade agricultural land is simply wrong.
Likewise the two ‘reserved sites’ in neighbouring Lydiate are also presently used for food growing and the semi-rural nature of the Lydiate community will clearly be compromised if they are developed. What’s more there will an unacceptable narrowing of the remaining Green belt with Aughton which we referred to earlier in this submission.
Maghull desperately needs its second railway station to be promoted and built at Ashworth South as soon as possible. The plan lacks ambition to ensure this is achieved.
Our divided Borough which resembles a finger and a thumb pointing northwards to Southport along the coast and Maghull inland could be united via the completion of the rail loop (electrified) from Ormskirk through to Southport. This would be good for the Southport tourist and retail economy. The Pier Tram needs to be extended through the shopping area to Southport Station and on to Central 12 Retail Park.
The Town Centre requires significant redevelopment in the area between London Street and Eastbank Street via an iconic development which includes high–quality energy-efficient homes to fit a variety of income groups. Such a development would take pressure off the Green Belt via a mix of retail, leisure and housing in the Town Centre.
A zone within Southport Town Centre for independent shops, possibly around the Market Street area needs to be pursued. The Town Centre needs both small independent shops offering a unique retail experience and sufficient modern retail floor space of the size that many national retail companies require. Both need to be facilitated via the Local Plan for Southport to continue to flourish as a shopping destination of choice and quality.
The brownfield sites such as the former Phillips site off Rufford Road in Meols Ward would easily take several hundred houses and this is an example of where pursuing brownfield development will take pressure off the Green belt.
The fact that Formby Town Council and Little Altcar Parish Council feel the joint need to pursue a far from cheap Neighbourhood Plan indicates to us that the draft Sefton Local Plan is not addressing community development concerns and issues there either in enough detail or indeed at all. Melling Parish Council seems to hold similar concerns as it is also considering producing a Neighbourhood Plan. Bearing in mind that these plans can cost in the region of £80,000 to complete (according to Government estimates) the fact that they are being worked upon or seriously contemplated shines a poor light upon the draft Local Plan.
Green Belt loss is clearly a big issue in Formby with one of the most effective independent environmental campaign groups in England (Fragoff) rising to the challenge of fighting against what Formby residents see as inappropriate development.
The future of the sadly rather messed up Crosby Town Centre needs to be properly planned because the interventions by small and large developers in recent years have hollowed out a formerly thriving Town Centre. Without a clear direction which has community support via the Local Plan processes this issue will not be successfully resolved and Crosby will continue to suffer further retail stresses instead of developing a sustainable economic future.
Bearing in mind the preponderance of gun crime in the communities that make up Bootle Constituency we are surprised not to see a greater emphasis on designing new developments to alleviate serious crime issues.
Developing the presently all but mothballed rail link to the docks has to be a high priority especially as the Seaforth Container Terminal is to undergo significant expansion. The environmental benefits of rail over increased road traffic (and potentially a major new road) for the movement of containers must make the rail connection and its full use a very clear objective for the Council.
Our overwhelming view is that the draft plan and the administration’s preferred ‘Option 2’are not robust, the quality of the data is not satisfactorily evidenced, some of England’s best and most versatile agricultural land is unnecessarily threatened with development and insufficient weight has been given to protecting the Green Belt. The plan is not ambitious nor does it meet the aspirations of Sefton’s diverse communities.
The Local Plan process should provide the opportunity for the Council to show its vision for the future of the Borough over the next 15 to 20 years but we fear that a great opportunity will be missed without substantial changes to the administrations present draft.
The plan is not suitable to be taken forward in its present form.
Cllr. Tony Robertson
Lib Dem Deputy Leader and Planning Spokesperson