Rainhill Civic Society Response to St Helens Council Consultation ...

Rainhill Civic Society Response to St Helens Council Consultation – December 2016/January 2017. Rainhill Civic Society is a local amenity society founded nearly 50 years ago in Rainhill. One of its aims is the preservation and enhancement of the local area. It currently has about 200 members. It has a wide range of contacts within the community and has a good working relationship with the Parish Council. This response has been drawn up by the Society’s Planning sub-committee and has been approved and minuted by the full committee of the Society.

Draft Green Belt Review The Society strongly supports the concept of the Green Belt as set out in the five purposes described in paragraph 1.16 of the review. In considering the review we have concentrated on land in and around Rainhill but we realise that there are other important areas in the Borough under threat. We have no general observations to make about the draft, including the methodology used. However we would like to comment on paragraph 3.13 which states that the Borough has no nationally recognised historic towns or villages and goes on to say that historic links will be recognised in the assessment of constraints. While it is strictly true that historic towns as defined, may be absent, Rainhill is the birthplace of the railways and site of the 1829 Locomotive Trials at which Stephenson’s Rocket became world famous. The Liverpool Manchester railway still runs through many of the sites considered in the review. The tourist potential of this historic link and those in other parts of the borough, such as Earlestown and Newton, should be encouraged and are not mentioned in paragraph 3.21, which discusses restraints. We wish to comment on the conclusions presented in Appendices 2 and 4. Appendix 2 It would be helpful if the numbering system used in this extensive table corresponded to the GBS codes given in the body of the report and in appendices 3 and 4, or a brief name were given for each site. Parcel ref 89 Land to the south of Mill Lane. We would strengthen purpose 1, as we feel that the loss of the site would lead to “unrestricted sprawl”. We would also strengthen purpose 3 and would add that the parcel has extensive views to the south over the Mersey Plain. As we will note in our comments to Appendix 4 it is also adjacent to the listed ancient cross in Mill Lane Appendix 4 GBS_044 Eccleston Park Golf Club. While being situated in Eccleston, this parcel of land has traditionally been regarded as part of Rainhill, especially as it was part of the former Rainhill Hospital. Loss of a sports facility and open land would be detrimental to the public good. Rainhill Road currently has chronic traffic problems © Rainhill Civic Society 2017

near its junction with Warrington Road and could not stand further pressure. We note the need for provision of education and if the development were to go ahead this must be insisted on, together with improved medical and other facilities. GBS_070 Elton Head Road, Thatto Heath. We agree with the conclusion that the site should be limited to a small area to the east. This site has an open visual aspect from Rainhill and Purpose 3 should be strengthened. GBS_113 and 115 Hanging Bridge Farm and Land off Elton Head Road. Though “safeguarded”, these sites would have access via Elton Head Road and would worsen traffic problems caused by any development of GBS_044. GBS_032, GBS_136, GBS_160. These three parcels of land to the south of Mill Lane are treated as one in the options document and are “safeguarded” land. GBS_032 is a relatively small area of land almost adjacent to the junction of Mill Lane and Warrington Road. According to the Review it would be suitable for two houses. Taken in isolation this site could be commented on through the normal planning procedure. GBS_136 and GBS_160 are contiguous parcels of land to the south of Mill Lane and east of Hall Lane, equivalent to Parcel ref. 89, referred to above in Appendix 2. We note that both sites are considered to be within the buffer zone of an ancient monument. We feel that this is a significant drawback to the development of these sites, as the stone cross is intended to be visible across the Mersey plain looking towards Rainhill. As noted above, the aspect looking from Rainhill is a significant part of the visual appeal of the area. We were glad to see that other adjacent sites, adjoining Blundells Lane, (GBS_161, GBS_163, GBS_168,) were considered to be too valuable to be lost from the Green belt and we reiterate our view that Purpose 1 and Purpose 3 should be strengthened so that GBS_136 and 160 can be treated in the same way. GBS_146 Rainhill High School The proposal is to release part of the site from the green belt, that comprising the school buildings, but not the playing fields. As the only viable access to any development would be via the school it is not clear what justification there is for removing this site unless it is being reserved in the long term for the eventual demolition of the school. If the other developments in the Plan were to go ahead the need for the High Scholl would remain for many years GBS_164 Loyola Hall. It is to be welcomed that this important site is to be retained within the green belt. However, the site has been up for sale with the suggestion that houses should be built on land surrounding the listed building.

© Rainhill Civic Society 2017

St Helens Local Plan General The Society supports the overall aims of the Plan to bring prosperity to the Borough and to provide a desirable place in which to work and live. The following comments refer to the questions in the Response Form.

Question 1 LPA02 Spatial Strategy We urge that the re-use of previously developed land should be the first priority. One minor example in Rainhill is the former care home Cranford in Warrington Road, which has lain idle for some years. In addition, a parcel of land to the north of Mill Lane, adjacent to Stonecross Park has been set aside for building but it too has remained undeveloped. Yet land opposite to it is to be removed from the Green Belt. Examples of brownfield sites in Rainhill that have recently been successfully used or permitted for building are the Stephenson Grove development on the site of the former Oak Tyres.and the former Elm Construction site in Blundells Lane. Housing land is to be provided in each key settlement. This assumes that the key settlement will benefit from such a policy. We feel that in Rainhill’s case the opposite may be true; that increased strain will be put on the existing infrastructure without any gain. Has sufficient attention been paid in preparing the Plan to the existing infra structure by analysing current traffic, health and education needs? Paragraph 4.13 speaks of under-delivery of housing in relation to settlement size. We believe that this is not true of Rainhill. Paragraph 4.5 contains a table detailing each key settlement. We feel that Rainhill’s excellent transport links via the railway and the M62 should be added to its description as these influence people’s choice of the township as a place to live as well as providing residents with easy access to work, leisure and shopping.

Question 2 LPA04 Employment land. We feel that the Council seems to be excessively reliant on large scale distribution and warehousing investments. It is becoming apparent that these facilities will employ fewer and fewer staff as automation advances during the period covered by the Plan. A greater emphasis on small businesses would distribute employment opportunities throughout the Borough and might reduce the need to use green belt land.

Question 3 LPA05 – proposed number of houses. Justification of the need for the projected number of houses, 570 per year, is difficult to find in the document. The first part of LPA05 derives its figures from economic forecasts – no details of methodology are given. Later, the document says that the © Rainhill Civic Society 2017

SHELMA report, due later in 2017, will provide a better picture of housing needs throughout the Liverpool City Region. It is therefore premature to base housing needs in St Helens on the forecasts used in the Options paper. Paragraph 4.97 indicates that the census showed that expected population growth might be less than predicted. In addition, if reliance were put on warehousing and distribution as employment drivers, as noted above staffing levels might be low and even if that were not the case many jobs would be low-paid, creating a group of people less likely than the average to be house-owners. The population of the Borough is ageing and this will eventually lead to the release of houses into the market. In Rainhill this trend is noticeable, as many houses are owned by the occupants who bought them when they were built in the 1960s. Paragraph 4.37 (actually part of LPA02) states that focussing on brownfield and greenfield land, as opposed to Green Belt land, would proportionately deprive areas such as Rainhill from having their needs met. We dispute this. Overall, a more realistic target for housing might be Alternative Option 1 (para. 4.115) which reduces the need for Green Belt land to zero in the first period. Alternative Option 4 (para. 4.124), a stepped housing target, could be a feasible option once actual housing needs have been clarified.

Question 4 LPA02 Release of Green Belt land. We have submitted a detailed response to the Draft Green Belt Review.  

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We said that preference should be given to previously developed or brown field sites We highlighted sites in or near Rainhill that we felt should remain in the green belt, especially those to the south of Mill Lane, Eccleston Park Golf Club, and some sites off Elton Head Road. We felt that development of these sites would harm the infrastructure of the area and lead to urban sprawl and the merging of built up areas.

We would like to add the following. The concept of “safeguarded land” is misleading. In normal speech the term would imply that the land is not available for development. This is not the case. The National Planning Policy Framework states that Councils should:where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a Local Plan review which proposes the development © Rainhill Civic Society 2017

The safeguarding process is therefore to be used “where necessary” and such land should only be developed after a further review of the Local Plan. LPA06 covers this issue in more detail and again states that any development of safeguarded land would need a further assessment for a new Local Plan. There is a strong argument for leaving such land in the Green Belt until a valid need to develop it is identified.

Other general points. 1) Section 5 of the Options document gives details of Area Policies. These are limited to the Town Centre and Earlestown. We feel that Rainhill has a distinct identity resulting from its origins as a small village before it became part of the enlarged St Helens in 1974. Its world famous Locomotive Trials of 1829 offer potential for tourism and increased visitor numbers. Its geographical situation, especially its southern fringe, overlooking the Mersey Plain and Welsh Hills, contributes to its unique appeal. Further large scale development in the area would be damaging. 2) The dangers of unrestricted urban sprawl and the merging of neighbouring towns were points we raised in our comments on the Draft Green Belt Review. However, the recent announcement by the Government of a Garden Village at Halsnead, adjacent to Rainhill’s southwest border adds to this concern. This development together with possible expansion of Halton in a northerly direction towards the M62 makes the case for preserving St Helens southern Green Belt even stronger. The land south of Mill Lane and East of Hall Lane is a significant part of this portion of the Green Belt and should be retained. 3) An uncertainty raised in the document is the concept of “Permission in Principle” (para.4.113). This will allow a first level of permission to be granted to developers for specific sites. It is reported that a body of opinion holds the view that this may weaken control over Green Belt sites. The implications of this, as yet unclear, policy should be given more consideration in the Local Plan.

© Rainhill Civic Society 2017