Matter 1/Lathom South Parish Council/E A Broad/217
EXAMINATION OF THE WEST LANCASHIRE LOCAL PLAN – RESPONSES TO
INSPECTOR’S MATTERS, ISSUES AND QUESTIONS MATTER 1
a) Is the proposed housing requirement of 4,650 dwellings based on a sound analysis of the available and relevant evidence?
If the real needs of the population of West Lancashire are the subject of this question, there are several points that need to be made.
The first point is that the total of 4650 includes provision for a deemed under-supply from 2003 onwards against the then non-existent RSS target. However, this fails to take into account that the Council was operating a policy of constraint to correct a previous significant over-supply. This policy of restraint was adopted after local consultation and was endorsed by the Inspector at the 2005 Inquiry into the Replacement Local Plan.
The second point is that a realistic target should take into account the capacity of the Borough to provide housing at any given rate. Taking into account infrastructure constraints that have been caused by under-investment by United Utilities, the Council has reacted by over-emphasising growth in the South East of the borough to make up the numbers. The question that this begs is whether the purpose of the Plan is to achieve numbers “willy-nilly”, rather than providing housing where it is needed.
There is also the third point that housing need is not a single issue. It encompasses the need for affordable housing and the parts of the Borough where housing is needed.
The Council’s analysis is therefore a response to external pressures, rather than a sound analysis of the available and relevant evidence.
b) Does the proposed housing requirement reflect the full, objectively assessed need for housing over the Plan period?
“Housing need” relates to unmet need, since needs that have already been met do not lead to demand. It is also a function of people’s expectations and their personal capacity to meet their expectations. If they cannot afford particular housing, because of either low earnings or a lack of available credit financing, there is little point in building such houses for them to buy.
With this Plan, the Council is failing to provide for housing of the right types in the right places, for the right people and at the right prices.
c) Does the proposed housing requirement take account of any past under-supply of housing in the Borough?
We have already referred to past constraint to correct a period of significant over-supply. Since the economic implosion of 2008 the problem has been one of the developers failing to develop sites which they own and have planning permission to develop or which are available for development (e.g. Whalleys). Some developers have had economic problems of their own.
There is thus some considerable doubt as to whether there has been any under-supply of market priced housing, compared with demand. What appears to us to be irrefutable is that there is a large unmet demand for truly affordable housing. The tragedy of this Plan is that it fails miserably to address that demand, area by area and consequently it is quite likely that the need for affordable housing by the end of the plan period will be considerably higher than it is now. Perversely, this could then lead the Council to plan for even more market-priced housing in the hope of gaining some more affordable housing, again in low numbers and in the wrong places. We are already in a vicious circle and this Plan would make matters worse.
d) Is the proposed housing requirement in general conformity with the Regional Strategy and is it consistent with National Planning Policy?
The stated requirement, overall, is broadly consistent with the RSS numbers but the RSS did not extend to 2027 and was based on figures and economic assumptions that are now hopelessly out of date. Also, West Lancashire was supposed to plan for the needs only of West Lancashire (subject to the duty to co-operate), whereas it provides for an overall influx of people from other places, thereby leading to double-provision overall. In detail, the Plan still has the weaknesses identified in document EX114 (Nevin Leather Associates Draft Report “The requirement for a housing market assessment in West Lancashire”). It reflects the NPPF but that Government Policy is being misused successfully by developers to render the Plan useless. The Plan contains loopholes that will allow developers the scope to continue undermining the Council’s policies by cherry-picking development sites and the Council’s current proposals for a Community Infrastructure Levy could exacerbate that situation.
e). Should the proposed housing requirement be increased or reduced?
The requirement for market housing should be reduced and a greater effort should be made to meet the requirement for affordable housing in the areas of need. In Skelmersdale there is a need for decent affordable housing and to tackle the problem areas that first justified Regeneration Priority status. In contrast, the Plan provides for more and more fringe housing, whilst hardly touching the surface of problem areas that have stigmatised the reputation of Skelmersdale for many years.
f) Is the proposed phasing of the housing requirement justified and deliverable?
The Council has over-stated the need for new housing in Skelmersdale and then front-loaded planned provision to make up for late provision in Burscough and Ormskirk/Aughton. This is bound to distort the housing markets of the Borough. The Council has also abrogated responsibility for determining the supply of housing to meet different components of the housing market, leaving the whole subject to the mercies of an imperfect market.
Once the real housing needs of Ormskirk, Burscough and the western and northern parishes have been properly assessed, provision in those areas should be timed to reflect a realistic pace of possible provision, in view of infrastructure constraints. It will be of no advantage to build houses in areas where they are neither needed nor wanted, in the hope of providing for people who are seeking houses in other areas. In fact, such building could lead to very undesirable consequences.
g) Should there be a different phasing for the housing requirement and would that be deliverable?
See the answer to f) above. Some provision beyond the Plan period might be necessary but the Council would be planning, monitoring and managing the situation, according to planning best practice.
h) Is the proposed settlement hierarchy justified by evidence?
No. Skelmersdale is not in the same league as neighbouring towns – Wigan, Kirkby, Southport and St Helens - which have not been described as Regional Towns. Although it is the largest town in West Lancashire it is not as important as Ormskirk, which is the administrative centre, the centre with the best transport links to Liverpool and Preston and the home of a hospital and an increasingly dominant University.
i) Should Burscough’s status in the settlement hierarchy be lowered.
Yes and Skelmersdale’s should be on a par with Ormskirk’s. No town should be afforded the status of Regional Town. West Lancashire is a small rural borough which should be proud of its green credentials.
j) Should the Blaguegate Lane/Firswood Road area be regarded as a rural settlement separate from Skelmersdale?
We are disappointed that we are being forced to go through the same arguments as were resolved in our favour in 2006, in a mandatory decision of the Inspector at the inquiry into the Replacement Local Plan. The area’s history is that it is part of the Lathom Estate and came into the District of West Lancashire by a Local Government merger with Ormskirk when Skelmersdale was not part of the District but a New Town under its own administration. Until 2002 it was part of Ormskirk Derby Ward and then off-loaded to Bickerstaffe in a numbers-balancing exercise. Thus it has never, in administrative terms, been considered a part of Skelmersdale, even through a relatively recent Boundary Commission review. The Inspector’s decision was taken after he had viewed the area and it was mandatory. The Council itself had agreed that it should be separate.
The Blaguegate Lane/Firswood Road area of housing is ribbon development of a type which is common across the Borough but the Council is now drawing arbitrary and inconsistent lines through areas of ribbon development which provide for significant urban sprawl. Blaguegate Lane extends to Hollands Lane, not just to Firswood Road and that shows where the commonality of community lies. The lane shares its numbering scheme even further out to Dickets Lane. It is only the postcode that indicates a link to Skelmersdale and that is merely because it is operationally convenient for Royal Mail to split the delivery rounds between Ormskirk and Skelemrsdale delivery offices in the way it does. It is worth noting that Newburgh, Parbold and Dalton also have WN8 postcodes but the Council does not represent them as being a part of Skelmersdale.
By contrast with Blaguegate Lane/ Firswood Road, the Council continues to represent similar areas bordering Southport as being separate settlements in their own right. This is a wholly inconsistent approach which shows the Council’s comment, that administrative boundaries are irrelevant, to be false.
k) Should Southport be included in the settlement hierarchy as a Regional Town?
We are not sure that this should be done through the Local Plan for West Lancashire but the population of Southport is about equal to the population of the whole of West Lancashire and it is quite clear that most of its hinterland lies within West Lancashire. It is most likely, in our view to be a Regional question that was not properly addressed in the RSS.
l) Is the overall distribution of housing allocations across the settlements justified by the evidence?
The short answer to this is “No”. The evidence that exists is unsatisfactory but there is enough to show that there is too much dependence on development in and around Skelmersdale.
m) Should policy SP1 promote town centre uses and mixed-use development in appropriate locations?
Subject to the terminology being applied with its common meaning, yes Policy SP1 should promote these points. It does not help matters, however, when Council documents refer to all areas of housing in Skelmersdale and Upholland, together with outlying areas of ribbon development as the “inner areas” of Skelmersdale and Upholland, as in the paper on the Community Infrastructure Levy.
Town centres are the most sustainable areas and mixed-use (including live/work) development (so long as the uses are compatible) reduces people’s reliance on travelling to work by car.
n) Is the brownfield land target for housing justified?
This depends largely on what happens to employment areas. Subject to individual cases, such as the Old Toby site in Ashurst and the ex-TPT site in Old Skelmersdale the answer is broadly “Yes”.
o) Should brownfield housing sites be brought forward sooner in the Plan period?
In general terms they should take precedence over greenfield development but that depends upon availability, location and other factors which apply to housing development in general.
p) Should there be a sequential approach, similar to that proposed in Policy GN5, to the allocation of housing land?
We are confused by the question. It seems to us that Policy GN5 does apply to some housing applications (and permissions) but this question refers to allocations .
In principle, the most sustainable (and brownfield) sites should be developed first but there are aspects of the tests set out in Policy GN5 that would not be applicable. Much would depend upon the size of development sought and the local market to be served (so no borough-wide consideration) and we would want to see exclusion for small development sites owned by self-builders.
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LSPC Matter 1