Representations to West Lancashire
Local Plan Consultation –
Land at St Joseph’s College, Up Holland 1
Contents
Executive Summary ______2 1 Introduction ______7 2 Site and surrounding area ______8 3 Planning background ______11 4 The heritage value of the college ______17 5 Development opportunity______21 6 Issues and Opportunities ______31 7 Site Assessment and Sustainability Appraisal Review ______40 8 Deliverability and scenario testing ______46 9 Exceptional circumstances for Green Belt release ______55 10 Recommended policy amendments ______60 11 Summary and conclusion ______63
Appendices
A - Secretary of State’s decision letter for appeal APP/P2365/A/2022651/NWF B - Inspector’s Report for appeal APP/P2365/A/2022651/NWF C - Heritage Statement D - Masterplan E - Environmental Sensitivity Map F - Policy Map G - Transport and Access Strategy H - Historic Landscape Assessment I - Ecology Technical Note J - Arboriculture Opportunities and Constraints Plan K - Agricultural Land Classification Survey Map L - Site Assessments M - Up Holland School Places Report N - Residential Viability Report O - Green Belt Assessment
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
2
Executive Summary Introduction These representations are submitted on behalf of Anglo International Up Holland Limited (AIUH) to West Lancashire Borough Council’s (WLBC’s) consultation on the Local Plan Review Preferred Options draft. They relate specifically to land at St Joseph’s College, a listed and now derelict former education establishment. The representations set out how the college can be restored and brought back into long-term use through enabling development on land to the south.
Figure A: St Joseph’s College Background The former St Joseph’s College is listed Grade II and comprises a sprawling complex of 3-5 storey buildings, mainly of stone construction. It includes a chapel of dramatic scale and an imposing quadrangle along with some smaller additions of lesser character. It is of considerable heritage significance but in the 20 years since it was last occupied it has fallen into disrepair. Parts of the building, notably the north, east and south wings of the quadrangle, are now structurally unsound. There is an urgent need to address its decline.
The college sits in its own extensive grounds which extend to 29 hectares. South of the college is a 34.8 hectare site lying between the road known as Stoney Brow and the northern edge of Up Holland. This is in the same ownership and comprises scrub and unmanaged grassland, trees and ponds. All of the land lies outside the settlement boundary and within the Green Belt.
Since the college closed the owners have attempted to find alternative uses for the buildings. In the mid- 2000s, permission was granted for conversion of the college to apartments. However, this proved not to be viable without the support of enabling development. In 2007, permission for enabling development of three new-build apartment blocks in the college grounds was granted on appeal by the Secretary of State. The need to restore the college and bring it back into use was considered a “very special circumstance” justifying new development in the Green Belt. Unfortunately, this scheme for significant numbers of apartments was also
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
3
not viable as it was not aligned with market demand in the area, which is for detached and semi-detached family houses with gardens. The 2007 appeal scheme was therefore not fully implemented.
The proposal The 2007 appeal scheme nevertheless establishes the model for restoration of the college: enabling development filling the funding gap to bring the college back into use. The challenge is to find a sustainable long-term use for the college that can be made viable by enabling development that will be acceptable in planning terms.
We have considered various options for re-use of the college including residential, hotel and leisure uses. The scale of the building creates a challenge for finding a sustainable use and so we have considered options whereby the areas of lesser heritage value are demolished. These are the mid-20th Century additions (which are of no heritage value) and the north, east and south wings of the Quadrangle, which are of lesser value than the older parts of the college and are the areas that have suffered the greatest structural damage. Though the loss of the quadrangle wings is regrettable, the cost of the engineering work required to restore them would be prohibitive. Having considered the options, our view is that the future of the college is best served by retention of the most significant elements and their conversion to approximately 110 apartments.
The enabling development would comprise family houses that will meet local market demand. The best site for this is the land to the south of the college. This was considered for housing by WLBC as part of the evidence base for the new Local Plan, including as enabling development linked to restoration of the college. The council eventually decided to meet its housing need through establishment of three garden villages west of Skelmersdale, but the merits of the land south of St Joseph’s College was noted:
“While the allocation of this site [Site SSE004] for development would have an impact on the Green Belt by extending Up Holland northwards and on an area of particular historic landscape character, it is otherwise a fairly sustainable location and would enable the restoration of a Grade II Listed building. However, the uncertainty over the highways access, alongside the Green Belt and historic landscape impact currently counts against allocating this site. As such, this site should only be considered for the allocation of 900 dwellings if one of the preferred allocations falls out of consideration and if the highways issues can be resolved”.1
The site was designated as an alternative housing site in the draft Local Plan. However, we have now undertaken survey work that was unavailable to the council at the time of their assessment. In particular, the issues of historic landscape character, highways access and agricultural land value (mentioned elsewhere by the council as a concern) have been addressed. We have re-run the council’s assessment with the benefit of this additional information and concluded that the reasons for its rejection as an allocated housing site can be overcome.
Our proposal is for this site to be elevated to a full housing allocation, with a policy linking its development to restoration and re-use of the college.
1 West Lancashire Local Plan Review Issues & Options Consultation (February 2017)
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
4
Development potential The site’s constraints in terms of ecology, topography, flood risk, drainage, access and ground conditions have been assessed and the findings used to inform a masterplan for the site. This allows us to estimate the number of houses that could be delivered when policy requirements for open space, roads and social infrastructure are all satisfied. Our view is that the site could yield 756 houses in a sustainably-located urban extension to Up Holland.
Figure B: Masterplan Concept Diagram Exceptional circumstances for Green Belt boundary alteration This development would require alteration of the Green Belt boundary, for which exceptional circumstances must exist. We have commissioned an assessment of how the site contributes to the purposes of Green Belts (set out in national planning policy) and the conclusion is that its contribution is no better than “moderate”. The exceptional circumstances justifying alteration of the boundary are:
• The listed college building is in urgent need of repair and re-use, and the land to the south is uniquely placed to provide viable enabling development to assist this.
• There is a need for greater capacity and flexibility in the Local Plan in terms of meeting housing need. Currently, the plan meets housing need exactly, but additional sites are required to provide insurance against potential shortfalls on sites elsewhere. Furthermore, under the current draft of the Local Plan, Up Holland misses out on the growth agenda being promoted elsewhere.
• There will be considerable economic benefits to expanding Up Holland, including £8.5m of additional annual spending, some of which will be captured locally; a £5.1m windfall to WLBC through the New Homes Bonus; £1.3m of additional Council Tax receipts annually; Gross Value
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
5
Added (GVA) of approximately £130m; 240 construction jobs; and greater support for local social infrastructure arising from the additional population.
• The site has clearly defined and permanent physical boundaries in all directions, making it a clear opportunity for an urban extension.
In considering whether these amount to exceptional circumstances, it is necessary to consider the conclusions of the Secretary of State regarding the 2007 appeal:
“…the Secretary of State considers that, in this particular case, securing the future of the listed building should be regarded as a very special circumstance that would justify inappropriate development in the Green Belt, and that the benefits of the proposal would outweigh the harm as a result of conflict with Green Belt and housing location policy.”
Green Belt policy has not changed materially since that time. It follows that if the need for enabling development meets the “very special circumstances” test justifying development in the Green Belt, it must also meet the lesser test of “exceptional circumstances” justifying alterations to the Green Belt boundary.
Viability The conversion of the college to apartments and the development of the land to the south for family housing has been assessed as part of a financial model to determine viability. In broad terms, the cost of restoring and repurposing the college is likely to be £27.44m. The cost of delivering the enabling development will be £7.76m with finance costs adding a further £3.89m. Total costs therefore come to £39.09m.
Against this, income from the sale of the apartments and enabling development will amount to only £36.76m, a shortfall of £2.33m. This would leave the project unviable.
There is no scope for increasing revenue from the college and very little scope for increasing the housing yield from the land to the south if the policy requirements for green space are to be met. The remaining options are to extend the site north beyond Stoney Brow or to reduce the associated costs, specifically the Community Infrastructure Levy (CIL). We have considered the first option but rejected it, for two reasons. First, Stoney Brow offers an obvious, permanent physical boundary for the Green Belt, something required by national planning policy. It is not obvious what else might act as the new boundary if it is not to be Stoney Brow. Second, development to the north would risk encroaching into the setting of the college building, potentially harming its significance. Our view is that the boundaries of the site area the correct ones, something that is supported by the council’s own site assessment work, which also adopted Stoney Brow as the northern boundary.
Therefore, the only way to make the overall development viable is to remove the burden of CIL. When this is done, the additional income takes the project from a £2.33m loss to a profit of £4.62m. This is a profit on value of 11.12%, less than the 15-20% advocated by English Heritage for enabling development schemes, but acceptable to AIUH nonetheless.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
6
Table A: Viability summary
OPENING UP COSTS COSTS, ENABLING LISTED RELATING FINANCE DEVT BUILDING SCENARIO SCHOOL AND COSTS INCOME PROFIT PROFIT ON VALUE % TO LISTED COSTS INCOME (CIL APARTMENT ECOLOGY INC BUILDING ADJUSTED) INCOME PROF FEES
MASTER DEVELOPER £27.44m £7.76m £3.89m £16.84m £19.93m £39.09m £36.76m -£2.33m -6.34% INCLUDING CIL MASTER DEVELOPER £27.44m £7.25m £2.24m £21.62m £19.93m £36.93m £41.55m £4.62m 11.12% EXCLUDING CIL
Recommended policy changes We recommend the addition of a site-specific policy to the draft plan, linking any development there to restoration of the college. The policy would also set out requirements for the development in terms of its form and associated infrastructure. If this is accepted, other policies should be amended to reflect the elevated status of the enabling development site. These are:
• SP2: Strategic Development Requirements;
• Policy H2: Housing Site Allocations;
• Policy H3: Affordable Housing;
• Policy SP7: The Creation of Garden Villages and Employment Areas to the west and south-west of Skelmersdale; and
• Appendix A: Area Maps.
Conclusion The proposal put forward represents the only viable option for restoring the listed college and bringing it into sustainable long-term use. Doing so will require compromise regarding which elements of the building can be saved and policy changes regarding the Green Belt and the application of CIL. These representations provide detailed evidence supporting this approach.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
7
1 Introduction 1.1 These representations are submitted on behalf of Anglo International Up Holland Limited (AIUH) to West Lancashire Borough Council’s (WLBC’s) consultation on the Local Plan Review Preferred Options draft. They relate specifically to land at St Joseph’s College, a listed and now derelict former education establishment. The representations set out how the college can be restored and brought back into long-term use through enabling development on land to the south.
1.2 AIUH forms part of the Derwent group of companies, being a wholly owned subsidiary of Derwent Holdings Ltd. The Derwent Group is now owned by the Albert Gubay Charitable Foundation (since 2016) to provide a legacy and so that the dividends can be used for general charitable purposes.
1.3 AIUH has owned the subject site since October 2000, when it was acquired from the Catholic Church. Since then, there have been a number of proposals for development that would facilitate the re-use of the heritage assets through enabling development, however, none have proven to be viable. The deterioration of the building means there is now an urgent need to find a viable solution that secures the future of the listed college. These representations evaluate a series of options and identify a preferred approach.
1.4 AIUH have engaged a team of specialist consultants to advise on the project. The team comprises:
• Planning consultants: Quod and ATP;
• Masterplanners: Wood;
• Heritage advisors: Emma Adams & Partners;
• Viability advisors: Grasscroft;
• Transport consultants: i-Transport;
• Landscape advisors: Open Spaces;
• Communications advisors: Social Communications;
• Environmental planning advisors: Quod;
• Cost consultants: Turner & Townsend.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
8
2 Site and surrounding area 2.1 The site comprises two parcels of land: The former St Joseph’s College and land south of Stoney Brow (the Sites). These are shown on the map below.
Figure 1: The Sites 2.2 The former St Joseph’s College is located 900 metres north of the village Up Holland. It sits in its own extensive grounds and is accessed via a long driveway from the road known as Stony Brow. The site extends to 29 hectares and other than the college building and the gatehouse it comprises mainly trees, unmanaged grassland and ponds. There is an ornamental lake adjacent to the college and a burial ground to the north.
2.3 The college itself is a sprawling complex of 3- to 5-storey buildings, mainly of stone construction. It includes a chapel of dramatic scale and an imposing quadrangle along with some smaller additions of lesser character. The building is Grade II listed with this listing encompassing some other structures within its curtilage such as boundary walls, playing field shelters, steps and terrace to the ornamental lake, those to the quadrangle, gates and memorial stones within the burial ground.
2.4 The land south of Stony Brow extends to 34.8 hectares and comprises scrub and unmanaged grassland, trees and ponds. It is bound to the north by Stony Brow, to the west by Mill Lane, to the east by St Teresa’s Catholic Church and Primary School, the rear gardens of houses fronting College Road, and an area of open space including allotments. To the south is an area of agricultural land and the rear of properties at Hallbridge Gardens. The site is adjacent to the built-up area and settlement boundary of Up Holland. To the west, on the opposite side of Mill Lane is the Beacon Country Park and beyond that,
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
9
of a distance of approximately 0.5 kilometres, is the urban edge of Skelmersdale. To the east of College Road is a row of houses with agricultural land beyond.
Figure 2: St Joseph’s College
Figure 3: East Range
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
10
Figure 4: North elevation
Figure 5: North Range
Figure 6: The chapel
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
11
3 Planning background Site designations 3.1 The site is subject to the following designations in the adopted development plan:
• Green Belt. • Nature conservation site (Policy EN2). • Area of landscape history – county importance (EN2). • Local wildlife site.
3.2 The site is crossed by a public right of way (PROW) which passes east to west along Stony Brow. There is another PROW passing along the southern boundary. There are also a number of Tree Preservation Orders (TPOs) on the land.
3.3 Nearby designations include an “Improved Existing Countryside Recreational Facility” – Beacon Country Park – west of Mill Lane (Policy EN3.2(f)); an area of land safeguarded for future housing development (Policy GN2(a)); and the settlement boundary of Up Holland (GN1(a)).
Figure 7: Policy context
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
12
Figure 8: Environmental context
Planning History 3.4 The planning history of the site reflects many attempts by the previous and current owners to bring the college back in to use and thus secure its future. It also reflects the difficulties involved in doing so.
3.5 The college was previously owned by the Trustees of the Roman Catholic Archdiocese of Liverpool who sold it to AIUH in October 2000 following its closure as an educational establishment. In 2001 applications for planning permission and listed building consent were made to convert the college into a hotel and conference centre with 9-and 18-hole golf courses on the surrounding land2. 112 apartments in four 3-storey blocks were proposed as enabling development. These applications were refused on 8th November 2001. However, a further application for a similar proposal was approved in July 20033.
3.6 The golf course and hotel scheme was never implemented. An alternative scheme for conversion of the college to 92 apartments was granted planning permission and listed building consent on 4th April 20034. It was recognised, however, that this scheme would not be viable without some form of enabling development. An application for such enabling development was made in 2004, proposing
2 Application references 2001/0602 and 2001/0603 3 2002/0689 4 2002/0926 and 2002/0925
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
13
210 apartments in two blocks built in the college grounds, along with eight houses at College Farm5. This was refused on 1st August 2005 and an appeal was withdrawn.
3.7 Further applications for enabling development were made in 2006. The first scheme comprised 75 apartments in a 5-storey block6. The second scheme proposed 205 apartments in three 5-storey blocks, together with listed building consent7. Despite recommendations to approve, both schemes were refused by committee on 1st August 2006. The decision on the larger scheme was appealed and was considered at a public inquiry in February and March 2007. The decision was called in by the Secretary of State who agreed with the Inspector’s recommendation that the appeal should be allowed. This decision is very relevant to the issues raised by the current proposal and is worth considering in detail.
The Secretary of State Decision 3.8 The proposal considered by the Secretary of State comprised the following.
• Two extensions to the college (Blocks A and B on the plan below), comprising 75 apartments in all. These would be constructed largely on the sites of the existing 1950s and 1960s additions, demolition of which had already been permitted. The blocks would be of five storeys – roughly the same height as the quadrangle buildings of the existing college.
• A detached 5-storey block of 130 apartments in an “H” configuration, sited within the grounds of the college (see Figure 9).
• 345 surface car parking spaces mostly located close to the new blocks.
3.9 The application to WLBC was refused for the following reasons.
1. The erection of the proposed building(s) constitutes inappropriate development in the Green Belt and so conflicts with Policy DS2 of the West Lancashire Replacement Local Plan and advice given in Planning Policy Guidance Note 2 Green Belts.
2. The proposed development conflicts with Policy DS2 of the West Lancashire Replacement Local Plan in that the scale of the proposed buildings and associated car parking would have a significant detrimental impact on the openness of the Green Belt.
3. The proposed development conflicts with Policy DE1 of the West Lancashire Replacement Local Plan; Supplementary Planning Guidance ‘Managing Housing Supply’ (November 2004); Policy 12 of the Joint Lancashire Structure Plan 2001-2016; Planning Policy Guidance Note 3 (Housing) and Policies UR.7 and UR.8 of the adopted Regional Spatial Strategy for the North West (RPG13), in that it would contribute to an oversupply of housing land in West Lancashire based on the current Structure Plan target.
5 2004/1683 6 2006/0325 and listed building consent application 2006/0327 7 2006/0326 and 2006/0328
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
14
4. The proposed development conflicts with Policy EN5 of the West Lancashire Replacement Local Plan in that the scale and siting of the proposed buildings and associated car parking areas would have a detrimental impact on the character and setting of the listed building.
5. The proposed development when taken alongside other approved development on the St Joseph’s site would result in traffic generation which would prejudice the safety and free flow of traffic along the local highway network.”
Figure 9: Appeal scheme site plan 3.10 WLBC subsequently chose not to pursue reasons 4 and 5 at the Inquiry. The Inspector considered the main issue to be, “whether the proposal would secure the future of the listed building and if so, whether this would amount to a very special circumstance that would justify inappropriate development in the Green Belt and outweigh any other harm.”8
3.11 In making a judgement on this matter, the Inspector had to weigh harm to the openness of the Green Belt caused by the new development against the benefits of securing the future of the listed college building. On the first matter he commented:
“For many decades Green Belts have formed a key component in national planning policy. Their fundamental aim is to prevent urban sprawl by keeping land permanently open. Government guidance
8 Report to the Secretary of State for Communities and Local Government, paragraph 156
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
15
in PPG2 makes clear that inappropriate development is by definition harmful to the Green belt and that such development should only be approved in very special circumstances. This is reflected in policy 6 of the Joint Lancashire Structure Plan and policy DS2 of the West Lancashire Replacement Local Plan. The proposed new residential development would be inappropriate development. If the principle of the development was to be accepted, very special circumstances would have to be demonstrated.”9
3.12 He noted the increase in the development footprint of around 4,800 sqm built development and 4,432 sqm of hardstanding:
“By any measure this would be a significant increase and as a consequence the proposal would adversely affect the openness of the Green Belt.”10
3.13 Against this was the importance of the listed building. The Inspector noted the requirements of the Planning (Listed Buildings and Conservation Areas) Act 1990, section 66 of which requires that
“…special regard be had to the desirability of preserving the building or setting or any features of special architectural or historic interest that it possesses.”11
3.14 The Inspector recognised the quality of the building in this regard:
“I would agree that St Joseph’s college is a building of both architectural and historic significance. In architectural terms it is one of the best examples of a modern religious institution. Of particular note is the monumental mass and scale of the east quadrangle and the carefully considered chapel with its late ‘Arts and Crafts’ alters which are of art historical interest. In terms of its historic interest it is the first purpose built college constructed since the reformation and as such is of importance as an expression of the new-found status of English Catholicism, following Catholic emancipation earlier in the 19th Century. Whilst along with the vast majority of the country’s listed buildings the College is listed Grade II, it is in my view among the more significant buildings included in this grade.”12
3.15 The Inspector also considered the issue of housing need, concluding that the then over-supply was unlikely to endure13. He considered how the proposal complied with the English Heritage (as it was then known) guidance on enabling development, concluding that although the scale of development was very significant, it was the minimum necessary to secure the future of the listed building14. His overall conclusion was as follows:
“On balance I am inclined to agree with the Planning Officer of the LPA that securing the future of the listed building would be regarded as a very special circumstance that would justify inappropriate development in the Green Belt and that the benefits of the proposal would outweigh what must be recognised as significant harm as a result of conflict with the Green Belt and housing location policy. I am also satisfied that the proposed enabling development is the minimum required to ensure the
9 Paragraph 159. PPG2 has since been replaced by the NPPF but the Green Belt policy remains largely unchanged. 10 Paragraph 160 11 Paragraph 169 12 Paragraph 170 13 Paragraph 190 14 Paragraph 176
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
16
restoration and reuse of the listed building and that the special interest of the listed building would be preserved.
It is therefore my opinion that the appeal should be allowed.”15
3.16 He recommended that the Secretary of State allow the appeal and grant planning permission. The Secretary of State agreed with the Inspector on all matters and concluded:
“Taking the above issues into account, the Secretary of State considers that, in this particular case, securing the future of the listed building should be regarded as a very special circumstance that would justify inappropriate development in the Green Belt, and that the benefits of the proposal would outweigh the harm as a result of conflict with housing location policy.16
3.17 The Secretary of State allowed the appeal and granted planning permission on 25th June 2007. Copies of both the Inspector’s Report and the Secretary of State’s letter can be seen at Appendices A and B.
15 Paragraphs 194 and 195 16 Secretary of State’s decision letter, 25 June 2007, paragraph 30
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
17
4 The heritage value of the college 4.1 The proposed scheme is focused upon enabling development to support the refurbishment and ongoing sustainable use of the heritage asset. The subject land is currently designated as Green Belt, and the proposed scheme does involve partial demolition of the heritage asset.
4.2 We have set out elsewhere in these submissions an exceptional circumstances case to justify the release of the site from the Green Belt, but this is intrinsically linked to the need to protect and bring back into use a heritage asset of significance.
4.3 The submitted material includes a Heritage Statement (Appendix C) which follows the process set out within section 16 of the National Planning Policy Framework (NPPF) which is:
• Firstly determine which heritage assets may be affected by the proposed development.
• Establish the significance of those assets.
• Assess the extent of harm which may arise (with reference to significance).
• Undertake a balancing exercise where the extent of harm to a heritage asset reaches the threshold of substantial.
4.4 The Heritage Statement has identified a number of heritage assets (including the college building) and has provided a Statement of Significance to determine their relevance and to inform the harm assessment in respect of the impacts of the development proposal.
4.5 The Statement of Significance advises that St Joseph's College is a large purpose-built seminary which stands as a representative example of the building type, albeit one with limited cohesion having been built to various evolving plans over a prolonged period of time. The college as a whole comprises a group of buildings of varying significance. These include the original Gothic-style 1880s refectory, dormitory and teaching ranges (built by local architect J O'Byrne) together with later interwar quadrangle ranges and chapel (by Pugin & Pugin), built in a similar style, and other post-war additions.
4.6 It goes onto advise that the college buildings have experienced extensive change over time, as a result of adaptation or alteration. However, they retain much of their original character and plan form as a seminary. As found today, the buildings are vacant and elements are in a poor state of repair.
Significance of Building Elements 4.7 The Statement then moves on to consider the significance of specific parts of the college building, before then moving on to discuss wider elements of significance.
4.8 In terms of the building itself, the Statement identifies that the most significant elements of the college are the original historic 1880s North West Range and West Range, and the later chapel (completed 1930) which is of importance as a key element of the complex and retains interiors of some quality.
4.9 It goes on to add that the North, East and South Ranges which form the quadrangle are of lesser significance; being much later additions and built to a somewhat old-fashioned style for the period.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
18
College areas A: West Range B1/B2: North West Range B3: North West Annex C: Gymnasium D: North Range E: East Range F: South Range G: Chapel H: West Teaching Block J: Lower Line Latrine
Figure 10: Building ages
Wider Significance 4.10 The college is of religious and social historic interest as an example of a late 19th Century seminary building; albeit with larger 20th Century extensions. The layout, plan form and fabric of the building, as it survives, illustrate its original function.
4.11 The site is of significance in the history of the re-establishment and development of the Catholic Church in England, especially in the context of the Diocese of Liverpool. However, in the national context there survive a number of other purpose-built seminaries which were established earlier and which are of greater architectural significance and/or completeness.
4.12 The college enjoys group value with the listed Entrance Lodge and Gate Piers at the south eastern gateway to the estate (contemporary with the first phase of the college's development). The college also stands within its own extensive grounds. Elements of the original landscape design, together with later developments of interest, survive and contribute to an understanding of the history and appreciation of the architecture of the listed building.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
19
Setting 4.13 The Statement has also had consideration of the potential for the proposal to impact upon setting and it follows the relevant guidance as laid down in The Setting of Heritage Assets, Historic Environment Good Practice Advice in Planning: 3 (Second Edition), Historic England (2017).
4.14 The analysis of setting is undertaken in detailed form and we refer you to the Heritage Statement for detailed review as may be helpful. The Statement does conclude in this respect that:
“Taking note of the distance between the site and asset and the draft strategic proposals presented to support the allocation along with the assessment above, it is concluded that the proposals will have a neutral effect upon the setting of the heritage asset and thus preserve the significance of the heritage asset.”
Extent of Harm 4.15 The draft proposals presented include a degree of demolition necessary to provide a scheme that is considered economically viable. The Statement recognises (by consequence of viability advice) that due to the extent of demolition required to make a scheme viable and deliverable, the council will in all likelihood conclude that the works potentially cause substantial harm to the heritage asset. This will engage paragraph 195 of the NPPF.
Balancing exercise 4.16 Paragraph 195 provides a mechanism to demonstrate that the perceived harm is necessary to achieve substantial public benefits that outweigh the harm or loss of a heritage asset. The Statement identifies a number of public benefits which arise from the proposal which include:
• In excess of 750 family homes including policy-compliant affordable housing;
• Refurbishment of the heritage asset to bring it into active sustainable use (which will itself provide circa 108 apartments);
• £8.5m of additional household spending, a proportion of which will be captured locally.
• A £5.1m windfall to WLBC through the New Homes Bonus.
• £1.3m in additional annual Council Tax receipts.
• Approximately 240 construction jobs.
• Gross Value Added (GVA) of approximately £130m.
4.17 In addition to the benefits noted above, the Statement also provides a detailed tabular response to the specific tests as laid down in Paragraph 195 of the NPPF. These provide positive responses to all of the specific tests and demonstrate that the balancing exercise has been considered and there is sufficient evidence to demonstrate that the benefits do outweigh the harm.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
20
Previous Secretary of State decision 4.18 The site has been the subject of a number of enabling development proposals to bring the heritage asset back into use. Regrettably, none of these have been capable of delivery in the marketplace so the refurbishment works have not been able to be undertaken.
4.19 It is important to note that in relation to the 2007 appeal that it was set out by the Inspector (and confirmed through the Secretary of State) that the significance of these buildings was such that it met the threshold of very special circumstance to outweigh the general presumption against new development in the Green Belt. As such, whilst the development was by definition inappropriate it was concluded acceptable in planning terms. The relevant quotation is extracted below:
‘I am inclined to agree with the Planning Officer of the LPA that securing the future of the listed building should be regarded as a very special circumstance that would justify inappropriate development in the Green Belt’
4.20 The Heritage Statement concludes that the significance of the building now is unchanged, and the need to secure its future is at least as pressing given the passage of time and the clear decline in the building’s fabric. As such, the opportunity to deliver a sustainable and viable scheme to facilitate those works through Green Belt release should now meet the exceptional circumstance threshold relevant to the plan-making process.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
21
5 Development opportunity Finding the right scheme 5.1 More than a decade on from the Secretary of State’s decision, St Joseph’s College remains at risk. Although planning permission was granted for conversion of the building to apartments and for enabling development in the grounds, the scheme has never been viable and so has not brought the building back into use. Given the deterioration of the building, there is an urgent need for an alternative form of development that brings it back into use and secures its future. This section outlines how this can be achieved.
5.2 The main reason that the previous scheme17 was never implemented is that it was never aligned with market demand in the area. Local demand is mainly for detached or semi-detached family-sized homes with gardens and private car parking. Provision of almost 300 apartments would saturate demand for this type of property while failing to address real demand. Advice received from local property agents is that the market will support around 90 apartments.
5.3 The permitted scheme is therefore not the solution, but it does establish the principle of how the objective can be achieved: restoration and use of the college with the funding gap filled by enabling development. The key difference with the earlier scheme is the form of the enabling development, which must be aligned with local demand. In other words, the enabling development must provide detached and semi-detached family homes with less reliance on apartments.
5.4 AIUH owns a significant amount of land around the college – as far north as Farley Lane, Roby Mill and as far south as the settlement boundary of Up Holland. This extensive landholding has been examined for sites capable of supporting housing development, taking into account the environmental and policy constraints on the land. A full site assessment and appraisal is set out at section 6 and this concludes that the most appropriate site for housing development is the land between Stony Brow and the northern settlement boundary of Up Holland. The remainder of this section therefore examines the options considered for the college site and the land south of St Joseph’s College (or its designation in the council’s own site assessment: SSE004).
Options appraisal: St Joseph’s College Option 1 5.5 Option 1 for the college reduces the scale of the building to more manageable proportions by retaining only those areas of highest heritage value, i.e. the chapel, the West Range, North West Range and North West annex. The 20th Century additions, which are of lesser heritage value are cleared. This includes the north, east and south ranges of the quadrangle, the areas that have suffered the greatest structural damage.
5.6 Option 1-A envisages this reduced form of the college in residential use as apartments. We estimate that this could support 108 apartments.
17 Comprising the 2003 conversion scheme for 92 apartments and the 2007 Secretary of State-approved scheme for enabling development of 205 apartments
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
22
Figure 11: Option 1-A 5.7 Option 1-B envisages use of the northern part of the retained college, comprising the North West Annex, North West Range and part of the West Range, as apartments. The southern part comprising the remainder of the West Range and the chapel, would be converted to a hotel and wedding venue. In this scenario, the building yields 77 apartments and a 27-room hotel. The significant benefits of this arrangement are that the number of apartments is within the likely level of demand and the chapel can be retained for its intended purpose.
5.8 Option 1-C would see the whole of the retained building converted to a hotel and wedding venue. Based on the retained floorspace, we estimate that this could yield 89 hotel rooms.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
23
Figure 12: Option 1-B
Figure 13: Option 1-C
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
24
Option 2 5.9 Option 2 envisages demolition of the North, East and South Ranges of the quadrangle, as well as the low value 20th Century additions, but reinstatement of the quadrangle with new development. The remainder of the original building would be converted.
5.10 The advantage of this approach is that the scale and mass of the college can be retained but the new development can be built in a configuration that meets the requirements of the market. In other words, there would be none of the compromise on layout and design that is required when working with historic buildings.
5.11 Option 2a envisages residential use throughout, with 217 apartments in total.
Figure 14: Option 2-A 5.12 Option 2-B envisages use of the retained building as a hotel and wedding venue – again making best use of the chapel – with the hotel extending to 89 rooms and the new build residential extending to 117 apartments.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
25
Figure 15: Option 2-B 5.13 Option 2-C is for a larger hotel scheme, with 183 rooms and more extensive facilities.
Figure 16: Option 2-C
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
26
Option 3 5.14 Option 3 is for full retention of the existing building, for residential, a mix of residential and hotel or for a hotel only.
Option 3a, for residential use only would yield 189 units.
Figure 17: Option 3-A 5.15 Option 3-B, for a mix of uses, would yield 89 hotel rooms and 89 apartments. Option 3-C, for hotel use only, would yield 161 rooms.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
27
Figure 18: Option 3-B
Figure 19: Option 3-C 5.16 The viability of these options is discussed in detail at section 8. For the reasons explained in that section, Option 1-A is the preferred approach.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
28
Land South of St Joseph’s College – Masterplan 5.17 The masterplan drawings are set out in full at Appendix D. This section summarises the key issues and how they have been addressed.
Key issues 5.18 The land south of St Joseph’s College comprises 34.8 hectares of undeveloped, unmanaged land. It is a mixture of scrub, grassland, trees and shrubs with some areas more densely vegetated than others. There is a large pond located in the northern part of the site, part of a watercourse that runs south to north east. The land is highest in the west, adjacent to Mill Lane, and falls away to the east.
5.19 The land is enclosed by roads on three sides (north, east and west) and by built development on two (south and east). Agricultural land to the south has been safeguarded for future housing development which in time will mean a continuous line of such development along the site’s southern boundary. It is an obvious opportunity for expansion of the village and to deliver a significant number of new homes.
5.20 The following principles have guided development of the masterplan:
• Preserve and celebrate existing features;
• Maximise views and adapt to the sloping topography;
• Connect the site to its surroundings.
5.21 The masterplanning work has also had regard to the requirements of planning policy, most notably Policy GN3 Criteria for Sustainable Development which looks for new development to be (inter alia):
• of a high-quality design;
• well integrated with the surrounding area with safe, convenient and attractive pedestrian and cycle access;
• sufficiently landscaped including buffer zones and areas of open space.
5.22 With regard to natural features, Policy GN3 looks for loss of trees and hedgerows to be minimised but where removal is unavoidable the features should be replaced or those of ecological value enhanced. The creation of new habitats is encouraged, as is incorporation and enhancement of existing water features.
5.23 Regard has also been had to the emerging plan, notably Policy GI2: Open Space and Outdoor Sports / Recreation Facilities. The Supplementary Planning Document (SPD), Provision of Public Space in New Residential Developments has also influenced the masterplan. In the latter, Policy OS1 Provision of On- site Public Open Space requires 15 sqm of open space per bedroom developed (for schemes of 290 dwellings and above). These requirements have informed the masterplanning process.
Masterplan concept 5.24 Figure 21 below shows the masterplan concept. The key features are:
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
29
• Creation of “green connections” through the site, linking it to its surroundings, notably the country park, the existing village and the college grounds.
• These green connections converge on a central water feature – making use of the large existing pond and water courses.
• Primary access is from College Road along an enhanced Stony Brow. Secondary access is from Mill Lane. This reflects the greater capacity of College Road to support additional traffic.
• A buffer zone of green space along the Mill Lane boundary preserves views across the site looking west down the slope. It also preserves the countryside setting of Mill Lane.
• The primary streets are envisaged as tree-lined, some as boulevards making use of existing trees and water courses. Secondary streets are “home zones” with slow traffic.
• The street network is designed for permeability through the site with easy access to homes off of these routes. The steep topography of the west side of the site presents a challenge, therefore the streets curve gently down the hill to minimise the gradient. The street network includes provision for a connection to future developments on the safeguarded land to the south, thus unlocking that site for future development.
Figure 20: Masterplan Concept Diagram 5.25 The masterplan is designed to preserve as many natural features as possible and connect the green spaces across the site. By making use of the existing pond, the masterplan creates a central green space with all of the green connections meeting at that point. Other green spaces and ponds are
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
30
connected through a series of pathways and green routes that are legible and create a leafy green setting for the neighbourhood.
5.26 The layout of the streets and green infrastructure sets the pattern for the residential areas:
Figure 21: Development zones
5.27 By applying assumptions about plot and unit sizes, as well as density and unit mix, this development mix could yield around 756 new family homes.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
31
6 Issues and Opportunities Introduction 6.1 This section identifies the key opportunities and constraints for future development on the Land to the south of St Joseph’s College site and the St Joseph’s College site (both sites have been considered together and are subsequently referred to as the ‘Sites’, although distinctions are made between the two Sites where necessary). The findings demonstrate that both Sites have potential for significant development without resulting in unacceptable environmental impacts. Opportunities to enhance heritage assets and provide socio-economic benefits through new housing have also been identified. Environmental sensitivities and planning policy designations relevant to the Sites and their surroundings are mapped in Appendices E and F. Topography 6.2 The council highlighted in their site appraisals that topography may be a constraint on the net developable area of Land to the south of St Joseph’s College. Across this site there is an elevation difference of 80m, sloping from northwest (high) to east (low). Topography is particularly challenging in the northwest of the site where the gradients are steepest. 6.3 Accommodating the sloping topography will require careful consideration at the next stages of design, however, as set out in Section 5, the masterplan can overcome this by designing the streets to curve gently down the hill to minimise the gradient. As such, the topography is not considered to be a significant constraint on the net developable area. Transport & Access 6.4 Uncertainty over how highways access could be achieved on Land to the south of St Joseph’s College (Site SSE004) was identified as a concern by WLBC in their assessment of the site’s suitability for development in September 2018. In order to address this concern, to examine the capacity of the local transport network and the potential for sustainable transport links, a Transport and Access Strategy has been prepared by i-Transport and is provided at Appendix G. 6.5 Access to the Sites is currently available from two points off Stoney Brow (the northern point accessing the existing college and the southern point accessing the existing residential properties in the centre of the Sites), although Mill Lane also offers potential for access from the west. Junction 5 of the M58 can be easily reached via the A577 in less than 15 minutes, providing links to the M6. The A577 is generally free flowing and provides good links into Skelmersdale and Wigan. The nearest train station is Up Holland which is approximately 1.9 km to the south. Bus stops are located on Stoney Brow / College Road providing links to Wigan, Skelmersdale and Ormskirk. Two PROWs traverse the Land south of St Joseph’s College site on an east-west alignment. 6.6 Land to the south of St Joseph’s College is close to services in Hall Green and local primary schools and so is sustainable in this regard (especially the southern end of the site). 6.7 The Transport and Access Strategy demonstrates that the Sites are accessible by a range of transport modes, and that development would provide an opportunity to further enhance the Sites’ accessibility. 6.8 Traffic surveys and estimates of likely trip generation indicate that development would not result in a severe impact on the operation of key local junctions including the Mill Lane / A577 / Hall Green double mini-roundabout or the College Road / A577 mini-roundabout. Initial traffic modelling of a future year scenario (i.e. in 2028) predicts that with development of the Sites, the College Road roundabout would operate with spare capacity and the A577 double-mini roundabout would also operate at (but not exceed) capacity. 6.9 Access to the Sites could be gained via three vehicular access points. The primary access would be from College Road along an enhanced Stoney Brow and the existing College access to serve the refurbished
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
32
College buildings. Secondary access would be from Mill Lane where a new three-arm priority- controlled access junction would be created. This reflects the capacity of College Road to support higher volumes of traffic than Mill Lane. These accesses would be capable of accommodating the predicted development traffic levels. 6.10 The section of Mill Lane to the southwest of the Sites (to the north of Mayfield Road) represents a potential constraint in terms of the on-street parking that can occur in this location (as the adjacent properties on the western kerb-line have no-off street parking provision). This can reduce Mill Lane to single way road in places. To overcome this, appropriate design and traffic management would direct a greater amount of traffic to Stoney Brow / College Road, rather than Mill Lane. 6.11 The Transport Appraisal demonstrates that a range of education, employment, retail, health and leisure facilities are accessible from the Sites by active and sustainable transport modes including walking, cycling and public transport routes. 6.12 Development of the Sites would create a number of ‘active user’ access points. Three active user access points have been identified which could be shared with the vehicular access points and three could be dedicated pedestrian and cycle accesses. The active user access points would connect to the existing local footway network to provide direct routes between the Sites and Up Holland. This would ensure the Sites act as a sustainable urban extension of Up Holland with strong links to local facilities in the village centre. 6.13 Overall, in relation to the key tests set out in the NPPF, it can be concluded that the Sites are suitable for development as: • Opportunities for sustainable transport modes can be taken up to reduce the need for major transport infrastructure; and
• Safe and sustainable access to the Sites can be delivered for all.
6.14 The Transport and Access Strategy demonstrates that the residual impacts of the development would not be severe, and therefore from a highway and traffic perspective “there should be no reason to prevent a positive planning outcome”. Heritage and Historic Landscape 6.15 The St Joseph’s College site contains three Grade II listed buildings: • St Joseph’s Roman Catholic College;
• College Farmhouse; and
• Entrance Lodge and Gate Piers to St Joseph’s College.
6.16 The most significant elements of the college are the original historic 1880s North West Range and West Range, and the later chapel (completed 1930). The layout, plan form and fabric of the building, as it survives, illustrate its original function. The college is of religious and social historic interest as an example of a late 19th Century seminary building; albeit with larger 20th Century extensions. The proposed scheme is focused upon enabling development to support the refurbishment and ongoing sustainable use of the college and maintaining these heritage assets, which are currently in decline. Section 4 of this document (and the Heritage Statement at Appendix C) includes a detailed summary of the current status and heritage value of the college and associated listed buildings. 6.17 In summary, the development of the St Joseph’s College site would be designed to ensure that it does not materially detract from the archaeological/architectural/historic or landscape interest of the
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
33
heritage assets, or materially harm its setting. Development of the site would secure the long-term future of this heritage asset which is currently deemed ‘at risk’. 6.18 Land to the south of St Joseph’s College does not contain any designated heritage assets. The closest designated assets include 2, 2A and 4 Stoney Brow located opposite the entrance to Stoney Brow on College Road; the Grade II listed St Theresa of the Child Jesus Roman Catholic Church and attached Parish Rooms, also located on College Road, and the Grade II listed Mill House located on Mill Lane to the south west. 6.19 There are no other statutory or non-statutory heritage assets located within or adjacent to the Sites (for example scheduled monuments, Registered Parks and Gardens, conservation areas or locally listed buildings). The closest scheduled monument to the Sites (Up Holland Benedictine Priory) is located approximately 1.5km to the south east of Up Holland. The closest conservation areas are located in the village centres of Up Holland to the south and Roby Mill to the north of the Sites. 6.20 Taking note of the distance between the Site and heritage assets and initial masterplan principles described in Section 5, our view is that development of Land to the south of St Joseph’s College is likely to have a neutral effect upon the setting of Grade II listed college buildings, thus preserving their significance. Other heritage assets mentioned above may experience some change in setting due to changes in the surrounding landscape or traffic/noise, although these are unlikely to result in substantial harm. 6.21 In their assessment of Site SSE004, WLBC noted that historic landscape character was a concern when considering Land to the south of St Joseph’s College as a potential site allocation. In order to understand this issue, a Historic Landscape Statement (see Appendix H) has been prepared to examine the historic landscape context and consider the potential effects of development. 6.22 The Sites lie within an area defined by the Local Plan as an ‘Area of Landscape History of County Importance’. The Historic Landscape Characterisation Programme (2002)18 identifies that the Sites fall within the ‘Ancient Enclosure’ historic landscape character type19. These designations are not unique to the Sites (see Figure 2 & 3 in Appendix H) which demonstrates that a large area of West Lancashire is within this historic landscape designation and character type, as are a number of the sites identified as preferred housing allocations. Analysis of the Sites and surrounding area has found no evidence that this designation should present a constraint to development. 6.23 No historic landscape relationship exists between the Sites and the Up Holland Benedictine Priory scheduled monument, which is located approximately 1.5km beyond the urban area of Up Holland and the listed College and associated buildings would be maintained and enhanced as a result of development. In line with Local Plan policy, any development would respect the historic characteristics of the landscape through careful siting, design and use of materials. Landscape and Visual Impact 6.24 The Sites are not subject to any statutory landscape designations such as Areas of Outstanding Natural Beauty (AONB), and there are none within the potential zone of influence of the Sites. The Sites are
18 https://www.burnley.gov.uk/sites/default/files/Lancashire%20Historic%20Landscape%20Characterisation%20Progra mme%202002.pdf 19 Historic landscape characterisation (HLC) can be used to help secure good quality, well designed and sustainable places. It is a method of identification and interpretation of the varying historic character within an area that looks beyond individual heritage assets as it brigades understanding of the whole landscape and townscape into repeating HLC types.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
34
located within Landscape Character Area 4 (Wood/Pasture) under policy EN2 of the Local Plan, characterised by pastures, hedges and well-wooded areas. 6.25 In line with policy EN2, development will be required to maintain or enhance the distinctive character of the landscape. Future development of the Sites therefore would, where possible, adhere to the council’s Landscape Character 4 mechanisms for minimising environmental impact (outlined in Supplementary Planning Guidance on Natural Areas and Areas of Landscape History Importance)20 such as ensuring substantial landscaping of developments to minimise visual impact and in particular landscaping internally to break up roof lines. 6.26 The mature woodland belts surrounding St Joseph’s College are substantial and protect views to and from the existing college buildings. These existing woodlands would be retained with any future development. Therefore restoration and repurposing of the site would not significantly alter existing views to or from the college. 6.27 Key viewpoints of the Sites are predominantly from PROWs through the Sites, the west (from Mill Lane), east (residential properties on College Road overlook the Sites) and south (Hallbridge Gardens which forms the northern extent of Up Holland). Boundary hedgerows along the western and southern boundaries provide some visual screening of Land south of St Joseph’s College. Development of this site would strengthen these boundaries, through creation of a buffer zone of planting and green space along Mill Lane to preserve views from the west looking down the slope to the east. This buffer zone would also help to preserve the countryside setting of Mill Lane. 6.28 Development on Land to the south of St Joseph’s College would impact on local views. The significance of this impact would be limited, where possible, through a carefully designed green infrastructure strategy, high quality design, use of materials and architecture (referencing local character) and a lighting strategy which minimises light spill. In addition, preservation of natural features alongside creation of green spaces would limit adverse visual effects. Biodiversity 6.29 The Sites have been subject to a preliminary ecological appraisal which included a review of nature conservation designations and Phase 1 habitat survey in July 2018 to identify constraints and opportunities for development at the site. A Phase 1 habitat map is included within the Ecology Technical Note at Appendix I. 6.30 There are no international or European protected sites within 10km of the Sites. The closest Site of Special Scientific Interest (SSSI) is Ravenshead Brickworks approximately 0.6km a way which is designated for its geological value only. The Sites are not located within any impact zones for other SSSIs. 6.31 14 Biological Heritage Sites are located within 2km of the Sites. One of these, Rough Park and College Woods Biological Heritage Site (Local Wildlife Site), is almost entirely situated within the site of St Joseph’s College (extending slightly outside the western boundary) and contains several ‘Lancashire Key Species’21 including native bluebell, Red-List bird species, and invasive species including Japanese knotweed and rhododendron. This mature woodland also provides a habitat for breeding red squirrels.
20 West Lancashire Borough Council, 2007. Natural Areas and Areas of Landscape History Importance (Local Plan Supplementary Planning Guidance). 21 ‘Lancashire Key Species’ is used by Lancashire Environment Record Network (LERN) as a collective term to refer to species which have a recognised status, either (inter)nationally or locally.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
35
In any future development of St Joseph’s College, the Rough Park and College Woods Biological Heritage Site would be protected and opportunities sought for enhancement where possible. 6.32 Beacon Country Park is located adjacent to the west of the Sites, along Mill Lane. All other Local Wildlife Sites are located over 1km from the Sites boundary and as such are not likely to be affected by development. 6.33 The Sites contain a mosaic of habitats comprising large areas of unmanaged semi-improved grassland and poor semi-improved grassland, mature mixed and broadleaf woodland, ponds, hedgerows and young self-seeded woodland and scattered scrub across grassland. 6.34 Mature woodland belts and copses within the Sites are notable features, in particular those surrounding the main College building and the mature woodlands adjacent to Stoney Brow. In addition, internal and boundary hedgerows form defined boundary features of the Sites. 6.35 Two large ornamental ponds are located adjacent to the main College building, and two further ponds are present on Land to the south of St Joseph’s College which are surrounded by trees. A pond is also located in the southern part of Land to the south of St Joseph’s College, although this was dry at the time of survey. 6.36 Development of the Sites would seek to retain and enhance these ponds for their biodiversity and amenity value, providing focal points for the green infrastructure. 6.37 Habitats within the Sites offer the potential to support protected species including badgers, bats, great crested newt and reptiles. Buildings within the College in particular, have potential for roosting bats. With appropriate detailed surveys, and the adoption of sensitive design principles, Priority Habitats and Species at the Sites could be protected. 6.38 As set out in Section 5, the masterplan would be designed to preserve as many natural features as possible and connect the green spaces across the Sites. Development there would be in line with the following principles: • Retention of the Rough Park and College Woods Biological Heritage Site;
• Retention of on-site ponds with buffer zones, where feasible;
• Retention of mature woodland and hedgerows with buffers, where feasible;
• Use of the existing green infrastructure network, where possible, to inform arrangement of development parcels and establish green linkages and habitat corridors; and
• Sensitive grassland management (to mitigate and enhance habitat for bird and bat species).
Arboriculture 6.39 The Sites have been subject to an initial arboriculture appraisal to identify constraints and opportunities for development. The main findings of this appraisal are shown in Appendix J. Trees within the Rough Park and College Woods are subject to a Tree Preservation Orders (TPO) (No 31, 2003). This includes trees around the pond to the south and west of the main College building. Trees within this TPO would be protected from development. There is some scope to remove connective groups of trees to the north of the main College building to allow easier access onto the existing sports pitches.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
36
6.40 Further TPOs are located close to the boundary of the Sites including TPO 5 (2004), which covers woodland to the west of the College, and TPOs adjacent to the south east boundary of the Land to the south of St Joseph’s College. 6.41 Internal and boundary hedgerows form defined boundary features and provide a visual screen into the Sites, specifically to the southern and western boundaries and along Stoney Brow and Mill Lane. 6.42 In summary, development of the Sites would be in line with the following principles: • Retention and protection of areas of woodland and associated trees where feasible, particularly high value woodlands to the north of the St Joseph’s College which are subject to TPOs;
• Enhancement of retained mature trees and woodland through selective thinning to create more diverse species mix and remove non-native species;
• Retention and enhancement of hedgerows where feasible, through re-stocking;
• Strengthening tree and hedgerow cover along existing roadsides to enhance visual containment of the Site and habitat connectivity; and
• Removal of lower value woodlands, subject to mitigation planting elsewhere, such as north of the College and west of the woodlands subject to TPOs.
Agricultural Land Quality and Soil 6.43 Agricultural Land Classification (ALC) data available from the former Ministry of Agriculture, Fisheries and Food (Appendix K) indicates that the southern portion of Land to the south of St Joseph’s College, is made up of Grade 3b agricultural land (moderate quality), with the exception of approximately 3 ha of Grade 3a agricultural land (good quality) in the north-western part of the site. 6.44 The St Joseph’s College site contains a small area of Grade 3 agricultural land around the College buildings. It is not known at this time what Grade 3 classification the land is, although the land is not currently in agricultural use and is unlikely to be used as such due to other constraints. 6.45 Development of Land to the south of St Joseph’s College would result in loss of a small area (approximately 3ha) of best and most versatile (Grade 3a) agricultural land. Despite this, the loss is not thought to be significant given the site is currently not in agricultural use and its challenging topography limits the productivity potential of the land. A detailed ALC Report22 on Land to the south of St Joseph’s College stated its agricultural potential was also limited by soil wetness and soil droughtiness. The potential loss of approximately 3ha of best and most versatile land should therefore not be considered a significant constraint to development of the Sites. Social Infrastructure 6.46 The Sites have good access to healthcare with a number of GP surgeries within 1km, in Up Holland, and Wrightington Hospital within a 30-minute journey on public transport. There are further hospitals in Ormskirk and Wigan. Up Holland (Hall Green) village centre is approximately 1km from the centre of the Sites. For comparison shopping and for larger supermarket, residents of the development would likely use Skelmersdale town centre or Wigan town centre / retail parks.
22 West Lancashire Borough Council, 1997. West Lancashire Local Plan, Objection 1462 – Agricultural Land Classification Map and Report.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
37
6.47 The Sites also have good education provision nearby being within the Upholland and Crawford Village Primary Planning Area (PPA) which contains four primary schools. The closest primary schools to the Sites are St Teresa’s Catholic Primary School and St Thomas the Martyr CofE Primary School. LCC has identified that across the four schools, there were 90 surplus places (as of January 2018)23. This surplus is expected to reduce to 80 places by January 202324. Development at the Sites would fill these surplus spaces, but more would be needed to accommodate all primary school age children accommodated within the Sites. LCC’s preference for providing additional places is by expanding existing schools25, therefore AIUH will enter into discussions with LCC to establish the potential to expand the school(s) closest to the Site, all of which are rated Good or Outstanding by Ofsted. 6.48 Up Holland High School is situated just under 3km from the centre of the Sites. West Lancashire BC’s Infrastructure Delivery Plan Update 201826 (IDP) demonstrates there are sufficient secondary school places to address demand likely to arise from the development. 6.49 The Sites are located in an area with open space and recreation/play facilities, including Beacon Country Park to the west, Abbey Lakes to the south east, Up Holland play area to the south together with allotments to the east. The nearest leisure centres are at Ormskirk or Wigan, although a new leisure centre is proposed at Skelmersdale which could serve the development when built. 6.50 Public realm is another important component of social infrastructure. It is understood that at present, the Sites are used informally by dog walkers. Development of the Sites would provide opportunity for improvements to public open spaces and leisure with the creation of green infrastructure (including community green spaces, play parks and a nature park) as well as possible development of a spa in the College. 6.51 Development at the Sites would deliver a mix of housing to the Skelmersdale and Up Holland area. Development at Land to the south of St Joseph’s College alone has the potential to accommodate approximately 1,800 people (based on applying average household size figures to the c.750 new homes on-site)27, with additional accommodation from residential development at the College. Residential development across both Sites would bring an opportunity to provide elderly care which would aid West Lancashire Borough Council in coping with an ageing population by providing care facilities and access to services. 6.52 Overall, new residents across both Sites would likely use local services and businesses, and join local clubs, groups and attend places of worship, in Up Holland and surrounding settlements. This would help improve the long-term sustainability of services and activities in the area. For example, development on Land to the south of St Joseph’s College could generate approximately £8.5 million of household spending (based on average weekly household spending data for c.750 new homes)28, of which a substantial proportion would be captured locally. 6.53 Development would also bring employment opportunities. Construction of development on Land to the south of St Joseph’s College alone would generate in the region of 240 jobs and contribute approximately £130 million to the UK economy29. Permanent employment would also be generated
23 Lancashire County Council (September 2017) Infrastructure and Planning – Annex 2 Education (p.9) 24 Lancashire County Council (April 2018 Version 1.1) School Place Provision Strategy Appendices 2017/18 to 2019/20 (p.55) 25 Lancashire County Council (August 2017) School Place Provision Strategy 2017/18 to 2019/20 (p.7) 26 West Lancashire Borough Council, 2018. Infrastructure Delivery Plan Update (Local Plan Review Preferred Options) 27 Average household size calculated using Census 2011 data for West Lancashire 28 Based on ONS, 2017, Detail household expenditure by countries and regions 2015 29 Based on Lichfields and Home Builders Federation, 2018, The Economic Footprint of House Building in England and Wales
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
38
by the development associated with the sustainable re-use of the renovated College buildings. This employment would be linked to non-residential development options currently being considered including a hotel, spa and wedding venue. 6.54 Financial and other contributions, including Community Infrastructure Levy (CIL) and Section 106 contributions, could provide further economic benefits to local communities if used to fund new services and infrastructure in the local area. Utilities Infrastructure 6.55 There are existing gas, water and electricity services serving the surrounding area and the Sites are well located to take advantage of these. Cadent Gas, United Utilities and Electricity North West are the respective statutory undertakers for these services and future development at the Sites would require early consultation to confirm whether sufficient capacity exists in the local utility networks or if off- site reinforcement works would be required to serve development. 6.56 West Lancashire BC’s IDP (part of the Local Plan Review evidence base) states that the Up Holland (and Skelmersdale) area has “excellent capacity” in terms of water supply, as well as “significant capacity” in the sewer network. The IDP states that Electricity North West’s network has spare capacity in the Skelmersdale area (of 4MVA or more). There is therefore no reason to expect that utility infrastructure in the region could not cope with the additional demand of the development. 6.57 Within the Sites, there is no major utility infrastructure that would pose a significant constraint to development (e.g. high-pressure pipelines). The Mill Lane reservoir and pumping station operated by United Utilities is located off Mill Lane to the west of the Land to the south of St Joseph’s College. 6.58 Connections and upgrades to utility infrastructure within and adjacent to the Sites would be expected, whilst details of this would be subject to agreement with statutory providers, there is nothing to suggest that development at the Site could not be accommodated. Minerals Safeguarding 6.59 The Sites lie within a Mineral Safeguarding Area under Policy M2 of the Joint Lancashire Minerals and Waste Local Plan (September 2013). This policy seeks to prevent the sterilisation of mineral resources by non-mineral development. 6.60 The Minerals and Waste Local Plan Proposals Map identifies all deposits of certain minerals (e.g. limestone, sand and gravel, gritstone) under Policy M2. Policy M2 states that “planning permission will not be supported for any form of development that is incompatible by reason of scale, proximity and permanence with working the minerals, unless the applicant can demonstrate to the satisfaction of the local planning authority” that certain criteria can be met. These criteria include consideration of whether the minerals could be feasibly extracted and if “there is an overarching need for the incompatible development that outweighs the need to avoid the sterilisation of the mineral resource”.
6.61 A mineral resource assessment would be submitted with any future planning application, in line with LCC’s guidance30. This assessment would establish the potential for mineral extraction at the Sites, including the level of economically viable reserves, in order to satisfy Policy M2. Due to the widespread nature of the Minerals Safeguarding Area and provided the Policy M2 requirements are fulfilled this should not preclude development at the Sites.
30 Lancashire County Council, 2014. Guidance Note on Policy M2 – Safeguarding Minerals (Minerals Safeguarding Areas) (Lancashire Minerals & Waste Local Plan).
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
39
Air Quality and Noise 6.62 The Sites are not located within an Air Quality Management Area (AQMA). The closest AQMA is located approximately 1.7km from the eastern boundary of the Sites, along the M6, based on exceedances of the annual mean nitrogen dioxide (NO2) air quality objective. The distance of this AQMA is such that it would not be a constraint to development. Due to the high volume of traffic on the M6, road traffic generated by the development is unlikely to significantly affect the AQMA. 6.63 The Sites are likely to be influenced by road traffic noise on the adjacent local highway network, although there is no reason to expect that the Sites would require significant noise mitigation measures for residential development. 6.64 These issues therefore would not pose a constraint to the future development of the Sites. Flood Risk, Drainage and Ground Conditions 6.65 The Sites are at a very low risk of flooding, situated entirely within Flood Zone 1 where land is assessed as having a low (less than 1 in 1000) annual probability of river or sea flooding (<0.1 %). This is a zone in which all uses of land are considered appropriate. 6.66 Any surface water drainage strategy for the Sites would be developed with careful regard to the topography of the Sites and use of sustainable urban drainage systems which protect the quality of existing wetland features. • A historic landfill associated with the former Rough Park Quarry is located to the west of the St Joseph’s College site. The Rough Park Quarry opened in the 1880s to provide almost all the stone for construction of the College and was subsequently infilled. The historic landfill extends slightly over the western boundary into the St Joseph’s College site, as demonstrated in the Environmental Sensitivity plan (Appendix E). Development of the St Joseph’s College may therefore require gas protection measures, although the need for such measures would be confirmed by ground investigation. The presence of the historic landfill does not pose a constraint to development.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
40
7 Site Assessment and Sustainability Appraisal Review Introduction 7.1 This section considers the site assessment and appraisal evidence base which has informed preparation of the West Lancashire Local Plan Review Preferred Options.
7.2 This has involved a review of the following documents in particular: • West Lancashire Local Plan Review Preferred Options Sustainability Appraisal and Appendices (the ‘Preferred Options SA’) – this contains an appraisal of each of the identified potential site allocations against 13 Sustainability Objectives.
• West Lancashire Local Plan Review Technical Paper 1: Strategic Development Options and Site Allocations (the ‘Technical Paper’).
7.3 Land to the south of St Joseph’s College (as shown on Figure 1) corresponds largely to ‘Site SSE004’ in West Lancashire Borough Council’s site assessment process, although the proposed site allocation area excludes allotments and an arable field adjacent to College Road. 7.4 St Joseph’s College site (see Figure 1) has been appraised as part of a larger site (‘Site SSE003’) in the Site Assessment process but the proposed site allocation development boundary as defined at Figure 1 has not been previously considered by West Lancashire Borough Council. Site SSE003 was identified as a potential site allocation at the Issues and Options stage of the Local Plan Review31, but was not carried forward to the preferred options stage. It is unclear from the SA why this land parcel was discounted, although it should be noted that the land parcel SSE003 was much more extensive than that now being promoted. 7.5 Site SSE004 has not been taken forward as a site allocation in the Local Plan Review Preferred Options, but has been identified as an ‘alternative’ residential development site if other larger sites do not come forward. Table 1 in Appendix A of the Technical Paper states: “While the allocation of this site [Site SSE004] for development would have an impact on the Green Belt by extending Up Holland northwards and on an area of particular historic landscape character, it is otherwise a fairly sustainable location and would enable the restoration of a Grade II Listed building. However, the uncertainty over the highways access, alongside the Green Belt and historic landscape impact currently counts against allocating this site. As such, this site should only be considered for the allocation of 900 dwellings if one of the preferred allocations falls out of consideration and if the highways issues can be resolved”.
7.6 The promoter has therefore commissioned feasibility work to provide evidence that the concerns raised above by the West Lancashire Borough Council site assessment are capable of being addressed and that the issues should not prevent allocation of the site as a preferred option for residential development, alongside the restoration and repurposing of St Joseph’s College. Site Appraisals 7.7 West Lancashire BC’s appraisal of Site SSE004 against the identified sustainability objectives included in the Preferred Options SA has been reviewed. Due to the differing nature of the site boundaries, an appraisal has also been undertaken by Quod of the proposed site allocation boundary of Land to the south of St Joseph’s College together with an appraisal of St Joseph’s College site following the same
31 West Lancashire Local Plan Review Issues & Options Consultation (February 2017)
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
41
approach. The sustainability appraisals of each proposed site allocation are provided at Appendix L, with the key findings summarised below. SSE004 (Land to the south of St Joseph’s College) 7.8 West Lancashire BC’s appraisal of site SSE004 Land to the south of St Joseph’s College (included at Appendix 3 of the Preferred Options SA) against the 13 Sustainability Objectives is generally considered to be accurate and the promoter agrees with most of the scoring and commentary. The site performs well and is generally considered to be a sustainable location. However, Quod’s further site appraisal (included at Appendix L for the full appraisal) concluded that the site scored better against four objectives than that reported in the Preferred Options SA. The areas where Land to the south of St Joseph’s College scored better included health and inequalities, sustainable transport, land resources and biodiversity. Further detail is provided below and in Appendix L. Health & Inequalities 7.9 As shown in Table 1, the West Lancashire Borough Council site appraisal concluded that the site would have ‘No Effect’ against this objective. The promoter considers however, that as development of this site would include open space, play space and green links and trails provision which would promote physical exercise and an active lifestyle, it would have beneficial effects on physical and mental well- being. Overall a positive effect is anticipated on the health and wellbeing objective. Table 1: SA Appraisal Health and Wellbeing
WLBC Promoter SA Objective WLBC Comments Promoter Observation Score Score Development would include features that aim to improve health and well- Developing this site being such as community green spaces, for residential is play parks and a nature park. These unlikely to have a features would promote exercise and an Will the site significant effect on active lifestyle, which in turn would improve health health and well- improve physical and mental well-being. 0 No and well-being being unless the + Positive Green links/trails would be located Effect and reduce specific design of throughout the site and linkages would inequalities? the site includes be delivered to the south to allow features that aim to residents to walk and cycle to the nearby improve health and village centre. On this basis well-being. development of the site has the potential to result in a positive effect on health and well-being.
Sustainable Transport 7.10 We believe that development of this site would have a positive effect against this objective which seeks to ensure development contributes towards a sustainable transport system. West Lancashire Borough Council’s score recognised the potential for positive effects, but uncertainty was noted. Now that further analysis of the site and an initial Transport and Access Strategy (see Appendix G) has been undertaken, the potential to develop sustainable transport links can be confirmed. Development of the site provides an opportunity to contribute to sustainable transport improvements which is a particular focus of the Local Plan Review and Infrastructure Delivery Plan as the Skelmersdale and Up Holland region is currently lacking in sustainable transport links.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
42
Table 2: SA Appraisal Sustainable Transport WLBC Promoter SA Objective WLBC Comments Promoter Observation Score Score Development would provide new footpaths/ cycleways through the site, as well as enhancing the existing Public Right of Way (PRoW) along the northern and southern boundary. In addition, the site would provide pedestrian connections between St Joseph’s College to the north and Up Holland to the south of the site. The site is accessible by walking, cycling and public transport and a number of local facilities are available within walking distance (approximately 2km) from the centre of the site, including convenience stores, leisure and healthcare facilities. A Transport Development of the Will the site Appraisal undertaken in August 2018 site is unlikely to contribute found development would not result in involve any direct towards an a severe impact on the operation of key provision of new efficient, local junctions and that the two sustainable transport equitable, safe +/? proposed accesses would be capable of infrastructure except and Uncertain, accommodating the predicted potentially new + environmentally probably development traffic levels. In addition, footpaths/cycleways, Positive sustainable positive the appraisal demonstrates that but through CIL / transport overall opportunities for sustainable transport S106 would make system / modes would be taken up to reduce the financial network and need for major transport infrastructure. contribution to such help improve air infrastructure off- quality? Significant impacts on the closest site. AQMA located along the M6, 1.7km east of the site, are considered unlikely.
Overall, development of the site would not significantly affect the existing transport network, and instead would provide opportunity to enhance the network through the provision of public transport services, footpaths and pedestrian links between St Joseph’s College and Up Holland, as well as between the west and east of the site, such as between Mill Lane and the existing primary school. On this basis, the site is capable of achieving a positive score against this objective.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
43
Land Resources 7.11 Agricultural land in England and Wales is graded between 1 and 5, depending on the extent to which physical or chemical characteristics impose long-term limitations on agricultural use. Grade 1 land is ‘excellent quality’ agricultural land with very minor or no limitations to agricultural use, and Grade 5 is ‘very poor quality’. Natural England mapping32 indicates that the site predominantly comprises Grade 3b agricultural land (moderate quality) which is not considered to be ‘Best and Most Versatile (BMV) land’. A small portion in the north of the site comprises Grade 3a (good quality) agricultural land. The site’s topography is challenging, and is not currently in agricultural use, we therefore consider that development of this site would not result in a significant negative effect against this SA objective, and a ‘No Effect’ score is more appropriate to that which was reported by the Preferred Options SA. 7.12 It is noted that the Technical Paper states agricultural land value is often not the “deciding factor” in whether a site is preferred for allocation or not, given most of the land outside existing built-up areas in West Lancashire is BMV agricultural land. It also states that in the Up Holland area, development may not have an impact on BMV agricultural land as topography here limits the quality and productivity of the land which applies to this site.
Table 3: SA Appraisal Land Resources WLBC Promoter SA Objective WLBC Comments Promoter Observation Score Score According to Natural England’s Agricultural Land Classification (ALC) data, the site predominantly comprises Grade 3b agricultural land (not Best and Most Development of Versatile (BMV) land), with a small portion this site would Will the site in the north of the site comprising Grade involve the loss of preserve and 3a agricultural land (BMV) of -- Very a large area of enhance the No Effect approximately 3ha. Negative Grade 3 Borough’s land Development of the site would lead to loss agricultural land resources? of agricultural land but given its limited and open productivity potential it is not thought the countryside. loss would have significant consequences. We therefore considered that development of this site would result in no effect against this SA objective.
Biodiversity Assets 7.13 Development of the site would seek to maintain and enhance biodiversity assets, the scheme would be designed so that a net gain in biodiversity would be achieved. Instead of an uncertain score, we consider that appropriate development of the site can result in a positive net effect on biodiversity.
32 Provisional ALC maps intended for strategic use http://publications.naturalengland.org.uk/publication/141047?category=5954148537204736
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
44
Table 4: SA Appraisal Biodiversity Assets WLBC Promoter SA Objective WLBC Comments Promoter Observation Score Score Whilst the site does not contain any designated biodiversity sites, it does contain Priority Habitats and support ponds, hedgerows and numerous copses and areas of trees and shrubbery, some areas are more densely vegetated than others. A preliminary ecological walkover survey in July 2018 did not identify any ecological features that would affect Given site has no the principle of development. biodiversity assets on Development of the site would seek to the site itself, assuming preserve Priority Habitats including Will the site development is ponds and woodland and create a maintain and, designed in such a way green network that enhances them. where to respect the Development would adhere to the possible, ? biodiversity assets + Positive Council’s Landscape Character 4 enhance the Uncertain nearby and to allow mechanisms33 for minimising biodiversity green corridors environmental impact including assets of the through it, retention and enhancement (where Borough? development of the possible) of existing habitats including site should have no net ponds to the south of the site, copses harm to biodiversity. and trees, as well as creation of appropriate new habitats. Further detailed survey work would be undertaken prior to application and sensitive design principles would be adopted. Overall, development of the site would result in a net gain for biodiversity. Instead of an uncertain score, we consider that appropriate development of the site could result in a positive net effect on biodiversity.
7.14 Taking the above assessment into account, we consider that the site performs well compared to other site allocations considered in the Preferred Options SA. St Joseph’s College Site 7.15 St Joseph’s College site has been considered as part of a larger site (SSE003) in the Local Plan Review Process. Site SSE003 was identified as a potential site allocation at the Issues and Options stage of the
33 West Lancashire Borough Council, 2007. Natural Areas and Areas of Landscape History Importance (Local Plan Supplementary Planning Guidance).
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
45
Local Plan Review34, but was not carried forward to the Preferred Options stage and has therefore not been appraised by WLBC against the 13 sustainability objectives. 7.16 An independent appraisal of the St Joseph’s College Site (based on the boundary shown at Figure 1 and not including the land to the north of the College) against the Sustainability Objectives has therefore been undertaken by Quod to understand how the site performs and compares to other site allocations. The full appraisal is included in Appendix L and a summary is provided below. 7.17 This appraisal has found that St Joseph’s College site would either have positive or no effects against all of the Sustainability Objectives. In particular, a significant positive effect has been noted against the objective which seeks to conserve and enhance built and cultural heritage as the enabling development on site SSE004 Land to the south of St Joseph’s College would fund restoration and repurposing of the Grade II listed College building. Positive effects are also noted in relation to the sustainable economic growth and employment objectives as development of the site for one of the potential options (hotel / spa / wedding venue) would provide a range of employment opportunities. Positive effects were also found in relation to health and inequalities, meeting housing need and biodiversity. Summary 7.18 Having reviewed the Technical Paper for the Local Plan Review Preferred Options, it is unclear how the SA process and assessment has informed the selection of the Preferred Options. 7.19 Based on our review of the WLBC SA and site assessments, Site SSE004 appears to perform well against other reasonable alternatives considered by the council and taken forward as Preferred Options. Areas of ‘improvements’ in the SA scoring have also been identified as set out in the table above. 7.20 The council’s site assessment findings for SSE004, concludes that development would impact on "an area of particular historic landscape character, it is otherwise a fairly sustainable location and would enable the restoration of a Grade II Listed building”. The promoter hopes that uncertainty identified by the council with regards to “…highways access, (alongside the Green Belt) and historic landscape impact” which counted against allocating this site has been answered by the information provided within these Representations. 7.21 The mechanism for SSE004 being considered further for the allocation of 900 dwellings if one of the preferred allocations falls out of consideration and if the highways issues can be resolved is unclear. For example, what further consultation and further SA work would inform this decision? 7.22 With regard to SSE003, the appraisals provided in Appendix L are intended to demonstrate how the proposed site allocation boundary performs against the SA objectives. Again, Land at St Joseph’s College appears to perform well against other reasonable alternatives considered by the council and taken forward as Preferred Options. Overall, both sites perform well against the SA objectives and therefore merit further detailed consideration as part of the ongoing Local Plan Review and SA process.
34 West Lancashire Local Plan Review Issues & Options Consultation (February 2017)
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
46
8 Deliverability and scenario testing Introduction 8.1 This section sets out the key issues in terms of deliverability and shows that there are no impediments that cannot be addressed. It then sets out a number of scenarios for re-use of the college and examines their financial viability.
Deliverability Designation 8.2 Whilst the site is currently outside the development limit for Up Holland, it is immediately adjacent to it. The proposal seeks enabling development on land south of Stoney Brow to facilitate works to the listed buildings to the north.
8.3 The enabling development land contains a number of protected trees which are identified on the submitted arboricultural report. The site also includes a number of other ecological assets which have been considered and assessed as part of the submission material.
8.4 The land has a Green Belt designation, and also falls under a broader designation for an area of Landscape Importance. Both of these matters have been considered in some detail as part of the submission material.
Ownership and Control 8.5 The site is under one ownership and is free from legal impediment. The principle of the use of the land for residential purposes is agreed with the landowner which is also acting as promoter. The proposed residential use can be executed immediately. The land is therefore available now, with no associated legal impediment to delivery of housing in the first five years of the plan period.
Development Mix 8.6 The feasibility work undertaken shows enabling development comprised of a range of housing types to meet market requirements, inclusive of affordable units to meet Local Plan requirements. In terms of the retained listed building, the promoter has considered a number of development scenarios but the preferred approach is partial retention and the use of the building for residential apartments (Option 1-A).
8.7 The promoter is likely to take the development forward directly and will be able to do so upon securing planning consent. Completion of the works to the listed building and early phases of enabling development are achievable within the first five years of the plan period. Completion of the development as a whole is achievable within the first 10 years of the plan period.
8.8 The promoter is content to explore a range of development options to ensure that the optimal solution is reached in terms of delivering a viable re-use of the listed buildings and an appropriate quantum of enabling development. The extent of retention of the listed buildings and the type of uses sought will have a considerable impact upon deliverability and the extent of enabling development required.
Transport 8.9 The promoter has commissioned feasibility highways analysis showing that a range of access points can be provided including a principal access onto College Road. This vehicular access can be achieved
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
47
through the proposed access (widening of Stoney Brow) which meets relevant design standards and provides a range of improvements to ease traffic flow and facilitate pedestrian safety.
8.10 Please see the detailed transport note at Appendix G which includes analysis in terms of accessibility and transport capacity. It also provides feasibility site access drawings for this principal access and the identified secondary access points which shows the extent of improvements being provided.
8.11 The submitted material includes a Masterplan (Appendix D and section 5) which clarifies the cohesive approach in terms of route choices through the site which shows that the site is highly accessible and that the scheme is clearly deliverable in these respects.
8.12 The transport analysis provides a robust framework and demonstrates that the increase in local traffic movements is expected to be relatively modest and not detrimental to the existing operation of the local highway network. We would envisage that through further dialogue with Lancashire County Council (LCC) (as highway authority) they will be able to conclude that the development site is acceptable for allocation in highways terms.
Flood Risk and Drainage 8.13 The site is located entirely within Flood Zone 1 and therefore represents very low flood risk. The promoter is committed to implementing SuDS both as an engineering solution but also to add to the landscape approach to any future development.
8.14 The promoter has secured feasibility advice in terms of foul and surface water drainage which clarifies that drainage design can be straightforwardly undertaken to meet relevant design standards and that these details can be agreed with the Local Lead Flood Authority (LLFA) and United Utilities in due course. We are not aware of any evidence in terms of capacity issues or other points of principle.
Biodiversity 8.15 The promoter has commissioned feasibility work in terms of ecology which includes desktop and site- based surveys (Appendices E and I). This evidence demonstrates that there is no biodiversity constraint in terms of the site’s use for housing. The boundary treatments and parkland will represent net measurable gain in terms of biodiversity as encouraged expressly by the revised NPPF.
School Places 8.16 Assessment has been undertaken in terms of the supply of school places to clarify whether the development would be capable of being supported without requiring consideration of additional facilities (Appendix M). This analysis has demonstrated that there are no supply-side issues in terms of secondary school places, but that there could be a minor shortfall in terms of primary school places within the Primary Planning Area upon full implementation of the proposed allocation.
8.17 The proposal has therefore allowed for land to be identified for school facilities to meet that requirement in a location which would not necessitate considerable journey times and could secure the opportunity for (some of) these trips to be made by a range and choice of modes of transport.
8.18 The site can support educational facilities as part of a well-laid out approach which connect through to the existing development to the south. This could take a number of forms including:
• standalone facilities on-site;
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
48
• extension of adjacent school; and
• extensions to facilities off-site.
Infrastructure 8.19 Infrastructure requirements have been considered in the scheme design and the promoter committed to ensuring that the development delivers a range of infrastructure as may be needed to make it acceptable in planning terms. This includes affordable housing, on-site open space, sustainable drainage, school facilities, improved woodland management, footpaths and cycleways. In terms of additional infrastructure through the Community Infrastructure Levy (CIL), the promoter is aware that the development plan as worded would require this in relation to new build development subject to any balancing mechanism.
8.20 The council will be aware that AIUH did provide evidence at the CIL Examination to seek the enactment of a Discretionary Relief and Exceptional Circumstance (DREC) policy as is available and is encouraged through the CIL Regulations. The council decided to adopt the Charging Schedule without DREC but did agree that it would reconsider that as may be appropriate. AIUH is clear that the introduction of CIL would have a very considerable adverse effect upon the extent of enabling development which would be required so we would encourage that DREC be adopted in the context of this site in due course.
Scenario Testing 8.21 The promoter is of course aware that the heritage assets are substantial in terms of scale and massing, and their significance in heritage terms.
8.22 It is a matter of regret that the buildings have fallen into disuse over what is now a generational period (they were last occupied in 1999) and that in the more recent period their decline has accelerated. The appeal scheme in 2007 considered a proposal for a more substantial retention of the listed building and enabling development through a very modern apartment scheme.
8.23 The simple scale of the buildings has always created a challenge in terms of securing an end use for the building which would be appropriate, sustainable and where the viability implications would be manageable. The fundamental point has always been to seek to secure a use which would be capable of occupying the building on an ongoing and sustainable basis.
8.24 By consequence of global economic conditions and the inherent difficulty in delivering apartment- driven schemes in this type of location, the appeal scheme was not fully implemented. The interim period has seen significant vandalism and the need to try to protect and safeguard the building. Regrettably, those efforts have not been able to prevent substantial water ingress through the roofing which has resulted in the 1920s wings (D, E and F on Figure 10) becoming structurally at risk.
8.25 The promoter has secured viability and marketing advice which clarifies that there is market demand for a quantum of apartments in the retained listed building as part of a wider development of the site. The extent of that latent demand is limited, and they have advised that the proposed scheme (which delivers circa 110 apartments) represents the upper limit of what can be supported in the marketplace.
8.26 The structural integrity of the buildings is mixed as set out above, and it is concluded that those areas which are structurally unsound should be cleared alongside the 1960s additions which are
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
49
unsympathetic to the main building. The residual volume provides an appropriate basis to deliver circa 110 apartments within the retained listed building.
Enabling Development 8.27 The proposed allocation would seek the inclusion of a site-specific policy to bring forward a package of development that would facilitate the refurbishment of the listed buildings. This process is intrinsically linked to assessing what extent and future use of the listed buildings would be acceptable in the context of the extent of enabling development that would be required.
8.28 This process will inevitably have regard to a range of development scenarios. This submission has had reference to a range of development scenarios (35 scenarios tested at high-level) for a range of uses and forms of development and related obligations in terms of infrastructure or taking forward further enabling development as may be necessary.
8.29 In addition, the promoter has commissioned detailed viability analysis in terms of what is considered to be a preferred approach which demonstrates that it is deliverable and can support necessary infrastructure and affordable housing provision in the new build development.
8.30 We anticipate providing an updated viability assessment of these development options and the analysis of their deliverability (in financial terms) and also an assessment in terms of the broader planning framework prior to the Examination. This will inevitably refer to infrastructure requirements and the implications of a CIL levy upon the extent of enabling development needed.
The Master Developer Approach 8.31 The Viability Statement (Appendix N) demonstrates that the preferred approach is deliverable but accepts that the return on investment is below the 15% level that would typically be sought. It also relies upon the Master Developer approach which creates efficiencies and means that AIUH is both obliged to deliver the scheme and all of its infrastructure in a timely manner.
8.32 The alternate approach would be to dispose of the land by parcel but with added complication in terms of how site infrastructure is delivered and costs apportioned. Through experience, those piecemeal approaches are more protracted and considerably less efficient. None of these aspects would support the timely delivery of the scheme and the works to protect and bring the heritage asset back into use.
8.33 The Master Developer approach does provide the opportunity for efficiency savings and the financial model allows for that and therefore in essence facilitates the opportunity to deliver more on-site infrastructure and to expedite the delivery of the scheme as a whole.
Scenario Testing Summary 8.34 The scenarios look at a number of key considerations, all of which are cross-referenced to provide a granular approach to what might be deemed the best way forward to meet the aims of the scheme which is of course to secure the re-use of the heritage asset.
8.35 The key considerations comprise:
• The extent of the listed building that can be preserved;
• The type of uses that should be supported in the retained listed building;
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
50
• The types of use that should be supported in the chapel;
• Whether the analysis should assume the additional costs of CIL on the new build enabling development;
• Whether the scenario should consider the prospect of additional enabling development which would have ramifications for heritage setting and/or Green Belt harm;
• Whether the scenario should consider new built form to recreate the quadrangle in those scenarios where the structurally unsound wings would be cleared; and
• By consequence of all of the above, which scenarios have a reasonable or strong prospect of deliverability in practice.
8.36 Our very strong view is that all of the above points are material and relevant. However, it is our firm belief that the most crucial consideration should be deliverability of the proposed use of the retained listed buildings.
8.37 In the context of CIL, the council has the opportunity to introduce a DREC in due course should it deem that appropriate. That could be secured on a general basis, or specifically implemented in relation to schemes such as this (or simply this scheme) where the imposition of CIL would fundamentally impact upon the opportunity to deliver an acceptable scheme for enabling development to catalyse the re- occupation and ongoing sustainable use of the heritage assets.
The Preferred Approach 8.38 The preferred approach seeks the retention of the important aspects of the buildings (from the 1880s through to the 1930s) other than those areas which are now found to be structurally unsound. The retained building would be converted for apartment use and this should yield circa 108 apartments. The Preferred Approach is represented by Option 1-A in section 5.
8.39 This will require enabling development to sustain the scheme given that the costs of bringing the building back into use are considerably greater than the likely end value, even having disregard for the profit motive for doing so or the inherent costs of holding the land.
8.40 The submitted analysis demonstrates that the land south of Stoney Brow can accommodate residential development having given proper regard to the site’s planning constraints which include:
• protected trees;
• ponds;
• other protected habitats;
• topography; and
• other important woodland and landscape features.
8.41 Through all of the above and providing an appropriate design framework (including a notional school site, a network of roads and paths and open space), the developable area falls from 34.8 hectares to
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
51
22.3 hectares. The Masterplan then arrives at a yield of 756 family dwellings which equates to 22 dwellings per hectare (dph) at a site level and 34 dph in terms of the developable area.
8.42 The submitted Viability Statement concludes that this scheme is deliverable in viability terms subject to the proviso that new build enabling development would not be subject to the CIL levy. Comments in terms of the impact of a CIL levy are provided below at paragraphs 7.50-7.52 inclusive. The remainder of this submission demonstrates that this should be acceptable in planning terms. The return to the developer is not ideal and is below the level many developers would seek, but it is a position that AIUH is willing to accept.
8.43 For absolute clarity, we summarise below the conclusions reached in terms of viability in relation to the preferred approach. A more detailed analysis is provided within the submitted Viability Statement.
Viability Statement Summary 8.44 The Viability Statement runs a number of development scenarios, and is predicated upon a well- grounded approach wherein the enabling development is effectively sub-divided to provide parcels for land sales through which the proposed housing can be delivered. The appraisals consider the relevant costs and returns for each of these development parcels to arrive at a residual land value for each parcel which can be delivered within the subject land.
8.45 The two key scenarios here are considered at Appendix 4 and Appendix 6 of the Viability Statement and these demonstrate the impact of the CIL levies to the residual land valuation of the parcels which of course impacts upon the extent of enabling development necessary to make the development acceptable to the promoter.
8.46 The assessment also considers the relative costs and returns which would be incurred in relation to the proposed refurbishment of the heritage asset, which therefore informs the extent of enabling development which might be required. This is described within Section 6 of the Viability Statement.
8.47 Finally, the master developer approach is utilised which includes reference to a number of site-wide costs which need to be absorbed and include matters such as:
• opening up costs;
• schools infrastructure;
• green infrastructure;
• professional fees; and
• finance costs.
8.48 The following table may assist in terms of clarifying the likely returns on investment based upon the scenarios which have been assessed in detail and whether these will be acceptable to AIUH as landowner and promoter.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
52
Table 5: Viability summary
OPENING UP COSTS COSTS, ENABLING LISTED RELATING SCHOOL AND DEVT BUILDING TO LISTED ECOLOGY INC FINANCE INCOME (CIL APARTMENT SCENARIO BUILDING PROF FEES COSTS ADJUSTED) INCOME COSTS INCOME PROFIT PROFIT ON VALUE % MASTER DEVELOPER INCLUDING CIL £27.44m £7.76m £3.89m £16.84m £19.93m £39.09m £36.76m -£2.33m -6.34% MASTER DEVELOPER EXCLUDING CIL £27.44m £7.25m £2.24m £21.62m £19.93m £36.93m £41.55m £4.62m 11.12%
8.49 Grasscroft clarify through their analysis that they have assumed a zero existing land value for absolute robustness. They have also clarified that whilst the NPPF does identify that typical developer margins should be anticipated to be in the region of 15-20%, that in this instance AIUH is willing to promote the scheme on the basis of a profit margin of 11.12%.
8.50 Grasscroft have also clarified that the same scheme on the basis of a CIL levy would result in a loss of £2.33m which equates to a negative return of 6.34%. AIUH has confirmed that it could not promote the scheme on that basis.
CIL 8.51 The preferred approach would not be able to support the costs of a CIL levy imposed on the new build enabling development. We would point out here (in very general terms) that the implications of imposing CIL on the proposed 756 dwellings necessary as enabling development in the preferred approach would be to put the development as a whole into loss.
8.52 The Viability Statement can be used to demonstrate that the implications of a “CIL on” option are of real importance, because it transforms the viability of the preferred approach from a £4.62m profit to a £2.33m loss. To overcome that and get back to the profit level (simply in £ and not %) which was sub- optimal but accepted by AIUH in the “CIL off” scenario would require the release of a further 14.2 hectares of land which would therefore need to add to development alongside and north of the College which would have greater Green Belt and heritage implications.
8.53 Clearly any options which would require review of alternate uses or greater retention of the listed buildings would result in the need for further enabling development. By consequence of this, the imposition of CIL on that enabling development would mean that the additional requirement in terms of Green Belt release would increase even more.
Alternate Uses 8.54 Through previous dialogue with the Council, a number of different development models have been explored. Through all of these discussions and more detailed review and dialogue with potential occupiers and developers, it has consistently been clear that market signals do not support those approaches as there is no evidence of demand.
8.55 We have also received advice that clarifies that the construction costs of alternate uses (such as hotels and function venues) are very likely to be higher whilst the potential returns are extremely volatile and are unlikely to provide the return provided by apartments. In summary, the reversion to an alternate use is very likely to result in a more substantive heritage deficit in any circumstance. The key issue
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
53
however is deliverability, because there is a very grave risk that there will not be adequate market demand to provide a sustainable ongoing use of the building for a use such as a hotel.
8.56 It is understood that the financial return on investment for these alternate uses will inevitably be reduced for these alternate uses and development scenarios. The promoter agrees to provide detailed financial modelling of these alternate uses prior to the Examination, but in summary it is understood that the financial implications (even in a CIL off scenario) would be at least as adverse as the situation outlined above in terms of the preferred approach scheme. This would result in a considerable increase in the requirement for enabling development and/or a reduction in the delivery of affordable housing and school provision.
Replacement of the Quadrangle 8.57 The preferred approach recommends the clearance of elements which are structurally unsound which will include three wings of the listed building (D, E and F on Figure 10). This is of course regrettable because these elements are imposing and do contribute positively to the character of the building.
8.58 If it is accepted that those elements should be lost, then they could theoretically be replaced in some sense (see option 2 at section 5). However, that then leads us to the twin issues in terms of viability. Firstly that the costs of doing so will inevitably outweigh the realistic returns and then that market signals direct that there is no evidence to justify that this approach could represent a sustainable and ongoing use of the building.
8.59 All of the above makes it likely that the extent of enabling development would need to increase by at least the same margin as would be the case for the introduction of CIL (i.e. circa 320 dwellings on 14.2 hectares of land).
8.60 We feel that it would be inappropriate to take forward a scheme with such significant enabling development and where there is a residual risk that it would not represent a sustainable ongoing use.
Repair and Retention of the Quadrangle 8.61 The loss of the three wings would be regrettable. We would also agree that it is possible that an engineering solution could be reached wherein the existing quadrangle could be repaired albeit that this would require significant structural engineering input.
8.62 This would (if successful from an engineering perspective) re-provide the building as it stood say twenty years ago where it was geared for use as a seminary. That use no longer exists, and the next step would be to seek to convert it so that it could meet other requirements which might most obviously comprise apartments or a hotel (see option 3 at section 5).
8.63 The fundamental issue arising is scale, and the absence of any market evidence to justify that this scale of development would have any credible prospect of being in sustainable ongoing use.
8.64 We have already set out that the costs of conversion of the listed building to either apartments or alternate uses outweigh the realistic returns. The extent of that loss is compounded in the event that the end use is a hotel or similar.
8.65 All of the above (of course) makes it likely that the extent of enabling development would need to increase by at least the same margin as would be the case for the introduction of CIL (i.e. circa 320 dwellings on 14.2 hectares of land). We think in practice that this third scenario (retain and repair) is
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
54
the one which would have the most adverse implications in terms of enabling development and also the worst prospect of full ongoing occupation.
Summary 8.66 We have set out that the preferred approach is viable and deliverable. We have also had regard for numerous other scenarios at a higher level, and they represent a fundamental shift in terms of deliverability and the need for enabling development.
8.67 We are not comfortable promoting those alternate uses or scale of accommodation in the heritage asset because all of the evidence points to the fact that those uses would not be deliverable and it would not accelerate the gainful re-use of the heritage asset.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
55
9 Exceptional circumstances for Green Belt release 9.1 The National Planning Policy Framework sets out the government’s position on Green Belts, their purposes and the process that must be followed if their boundaries are to be altered. At paragraph 133, the “fundamental aim” and “essential characteristics” of Green Belts are explained:
“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
9.2 The five purposes are set out at paragraph 134:
“Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”
9.3 Paragraph 136 explains the process and level of justification required if Green Belt boundaries are to be altered:
“Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans.”
9.4 Thus, the proper process for altering the Green Belt boundary in Up Holland is through the current Local Plan review process. This, however, should only be done in exceptional circumstances.
9.5 In defining new Green Belt boundaries, local plans should (inter alia), “define boundaries clearly, using physical features that are readily recognisable and likely to be permanent.”35
9.6 What constitutes exceptional circumstances is left undefined by the Framework. This is deliberate as it is very much dependent upon the particular issues affecting the local authority and the nature of the land in question. In this case there are a series of exceptional circumstances that justify alteration of the Green Belt boundary. These are:
1. Enabling development for restoration of the listed college.
2. Housing need.
35 National Planning Policy Framework, paragraph 139
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
56
3. The economic benefits of housing growth to Up Holland.
4. The presence of physical features that allow for clearly defined boundaries that are likely to be permanent.
9.7 Each of these is addressed below.
Enabling development for restoration of the listed college 9.8 The benefits to the listed college of the enabling development constitute an exceptional circumstance that, in itself, justifies amendment to the Green Belt boundary. This is supported by statute, national planning policy and appeal precedent.
Statute 9.9 Section 66(2) of the Planning (Listed Buildings and Conservation Areas) Act 1990 makes it a duty of local planning authorities to, “have regard to the desirability of preserving features of special architectural or historic interest, and in particular, listed buildings.” Thus, preserving the architectural and historic interest of the listed college is a matter of law, not just policy.
National planning policy 9.10 Paragraph 185 of the Framework sets out the requirement of local plans to plan positively for the historic environment:
“Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account:
a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;
b) the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring;
c) the desirability of new development making a positive contribution to local character and distinctiveness; and
d) opportunities to draw on the contribution made by the historic environment to the character of a place.”
9.11 The Planning Practice Guidance elaborates:
“What is a positive strategy for conservation and enjoyment of the historic environment?
In line with the National Planning Policy Framework, local authorities should set out [in] their Local Plan a positive strategy for the conservation and enjoyment of the historic environment. Such as a strategy should recognise that conservation is not a passive exercise. In developing their strategy, local planning authorities should identify specific opportunities within their area for the conservation and enhancement of heritage assets. This could include, where appropriate, the delivery of development within their settings that will make a positive contribution to, or better reveal the significance of, the heritage asset.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
57
The delivery of the strategy may require the development of specific policies, for example, in relation to use of buildings and design of new development and infrastructure. Local planning authorities should consider the relationship and impact of other policies on the delivery of the strategy for conservation.”36
9.12 The preferred approach set out in these representations are just such a “positive strategy” for conserving and enhancing the enjoyment of St Joseph’s College. There is no other strategy that would achieve this, as these representations have made clear. Therefore, a failure to adopt this strategy would leave the Local Plan at risk of failing in its duty to plan positively for this matter.
Appeal precedent 9.13 As explained in section 3, in 2007 the Secretary of State supported significant enabling development in the Green Belt that was intended to subsidise the cost of restoring the college. This decision was on a planning application for development in the Green Belt, not a plan-led approach to redrawing the Green Belt boundary. The test was therefore not one of “exceptional circumstances” but the sterner test of “very special circumstances”. On this matter, the Secretary of State concluded:
“…the Secretary of State considers that, in this particular case, securing the future of the listed building should be regarded as a very special circumstance that would justify inappropriate development in the Green Belt, and that the benefits of the proposal would outweigh the harm as a result of conflict with Green Belt and housing location policy.” 37
9.14 Green Belt policy has not changed materially since that time. It follows that if the need for enabling development constitutes very special circumstances justifying development in the Green Belt, it must also constitute exceptional circumstances justifying alterations to the Green Belt boundary (provided those boundaries are justifiable – see below).
Housing need Housing need and supply 9.15 The draft Preferred Options plan includes an ambitious strategy for housing growth. Policy SP2 states that there is a need for 15,992 new dwellings between the start of the plan period in 2012 and its end date of 2050, with annual delivery rising in stages to 475 dwellings per annum (dpa) by 2027. The plan recognises that a bold approach is required if this need is to be met and so much of the housing growth is directed to three new garden villages to the west of Skelmersdale. Together, these will deliver 6,000 new homes.
The need for spare capacity 9.16 This positive approach to housing delivery is welcome but it does leave the plan vulnerable should issues arise with any of these three garden villages. These will be controversial schemes and for a variety of reasons it is possible that one or more might fail to deliver all of the housing proposed. In that situation the council would have insufficient land allocated to meet its needs because there is no extra capacity in the land supply, which matches the need exactly.
9.17 The Land south of St Joseph’s College could provide a “buffer” of 756 new homes that would insure against such a shortfall in provision. Paragraph 3.52 of the draft Preferred Options plan identifies this site as one of two potential alternatives that together could deliver 2,100 homes, 900 of them at the
36 Reference ID: 18a – 004 - 20140306 37 Appendix A, Paragraph 30
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
58
Up Holland site (in fact we believe that the site would yield less than this). This illustrates how limited the alternatives are and how strategic sites can easily fail to yield the volume of houses expected. It would be prudent to include a measure of spare capacity in the plan, rather than wait for the need for alternatives to arise.
Distribution of growth 9.18 One criticism of the otherwise commendable approach preferred by the council is that it concentrates the most significant development on one area, the land west of Skelmersdale. There are benefits to this which are identified in the plan, not least the capacity for shared infrastructure delivery38. However, the new growth areas avoid Up Holland which consequently will not feel the benefit of population growth and the economic and social benefits that would follow. Development of new homes at the college and the land to the south would more equitably distribute the growth and the benefits that come with it.
9.19 As Up Holland is largely surrounded by Green Belt, this growth can only be achieved through development in the Green Belt or on land released from it. The Green Belt is therefore stifling growth in Up Holland just as the areas around it are embarking on an ambitious plan for growth. There is a need to amend the Green Belt boundaries if the town is to share in the draft Local Plan’s growth agenda. The need to allow this and prevent Up Holland falling behind its neighbours constitutes an exceptional circumstance.
Economic benefits 9.20 The economic benefits to Up Holland have been set out elsewhere in these representations. In short, they are:
• £8.5m of additional household spending, a proportion of which will be captured locally.
• A £5.1m windfall to WLBC through the New Homes Bonus.
• £1.3m in additional annual Council Tax receipts.
• Approximately 240 construction jobs.
• Gross Value Added (GVA) of approximately £130m.
• Support for the long-term viability of local social infrastructure, such as schools, clubs and voluntary groups in Up Holland through the increase in population (forecast to be approximately 1,800 people). We understand that the Post Office in Up Holland has recently closed. A greater population makes further loss of social infrastructure less likely.
9.21 These benefits include some that will have a direct effect on Up Holland particularly, for example additional expenditure in the village centre and support for local schools. Growth of the village is the only way to provide these benefits and as noted above, the Green Belt is inhibiting this growth.
38 Paragraph 3.51
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
59
Clearly defined and permanent boundaries 9.22 Paragraph 139 of the Framework requires Green Belt boundaries to be defined clearly, “using physical features that are readily recognisable and likely to be permanent.” The land south of the college benefits from just such physical features:
• The site is enclosed by roads or built development on all sides. Mill Lane and College Road (or the church and school buildings west of it) are recognisable and permanent physical features that would provide very strong Green Belt boundaries to the west and east.
• To the south, the existing built up area of Up Holland is already a strong Green Belt boundary.
• To the north, Stoney Brow is an obvious opportunity to mark the new Green Belt boundary with a permanent physical feature. This boundary will only strengthen through the upgrading of this road to provide access to the development land.
9.23 The suitability of these boundaries has already been recognised by the council in its Strategic Development Options and Site Allocations Technical Paper which also identified the boundaries described above as appropriate for defining site SSE004 Land to south of St Joseph’s College, Up Holland. The fact that the site is enclosed by development on three sides and benefits from permanent boundaries in all directions makes it a natural location for an urban extension. This matter is assessed in the Green Belt Assessment at Appendix O.
Summary and conclusion 9.24 Exceptional circumstances are required to justify alterations to the Green Belt boundary. In this case there are several. The town is likely to miss out on the benefits of the growth agenda promoted in the draft plan unless that growth is more evenly distributed, including the significant economic benefits we have identified. There is a need for spare capacity and flexibility in the plan to ensure that housing needs are met and this site is one of very few that can assist in this regard. Most obviously, this site can assist with the restoration and repurposing of the listed college, something it is uniquely placed to do.
9.25 Significantly, the Secretary of State is already on record as confirming that the test of very special circumstances for development in the Green Belt is met by the enabling development then proposed. That being the case, it is reasonable to assume that the lesser test of exceptional circumstances is also passed.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
60
10 Recommended policy amendments Specific policy for the Sites 10.1 These representations have set out how the college can be restored and its long-term future secured through cross-subsidy from enabling development. For this to be effective the Local Plan must include a specific policy related to the development of this land. The policy should control the circumstances in which development will be permitted, the development parameters and the infrastructure requirements.
10.2 Our suggested policy wording is set out below.
Policy SP9: St Joseph’s College, Up Holland and land to the south The primary purpose of this designation is to facilitate initiatives to maximise the opportunity to bring these important heritage assets back into active use. A site-specific masterplan for the area covered by Policy SP9 comprising St Joseph’s College and land to the south adjoining Up Holland will be prepared and shall advise all development within the area covered by the allocation will be required to adhere to it. It would be envisaged that the subject land could support up to 760 new dwellings south of the listed College and up to 110 apartments within the reconfigured College.
Any future development should provide an evidence-based approach to maximise the retention of the heritage asset and a package of works to bring it into active use including any enabling residential development which may be necessary on land to the south of St Joseph’s College. This should consider alternative uses and establish the deliverability implications in terms of enabling development and contribution to infrastructure. In delivering this new area of development, the following will be required as part of the proposals:
• Detailed assessment of the Grade II St Joseph’s College to establish the extent of the buildings which can be brought back into ongoing active use;
• To provide affordable family housing to meet Local Plan requirements;
• To provide a residential-driven development of land to the north of Up Holland which reflects the need to facilitate the regeneration and repurposing of St Joseph’s College;
• The retention of a green buffer between St Joseph’s College and the land to the north, which should be kept open and protected from the construction of new buildings except those related to agriculture and forestry and to facilities for outdoor sport and recreation.
• The provision of primary school facilities to meet the increased demand for school places created by the proposed developments if that demand cannot be appropriately accommodated elsewhere in existing schools in Up Holland, which would ideally be on site;
• Development should improve access to the footpath network and green spaces so as to integrate the development with the local and wider Green Infrastructure network;
• Any development of the site should have consideration to its impact on nearby heritage assets and implement appropriate mitigation measures to minimise any negative impact on these assets;
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
61
• The provision of new and improved highway links connecting to College Road (to the east) and Mill Lane (to the west) to enable better access for the proposed development to appropriate design standards to the strategic highway network;
• Measures to address surface water drainage to the satisfaction of the Environment Agency, United Utilities and the Lead Local Flood Authority so that all surface water is attenuated within the development to discharge to the local watercourse at greenfield run-off rate;
• Protect, and where possible enhance, the Biological Heritage Sites at the grounds of St Joseph’s College;
• To ensure that any redevelopment provides for works to safeguard retained elements of the heritage assets at an early stage; and
• Provision of maintained Green Infrastructure and cycle links, areas of public open space, play areas and playing pitches in line with the requirements of the Provision of Public Open Space in New Residential Developments SPD and other policies in this Local Plan and to provide sustainable connections into Up Holland local centre by means other than the car.
Development should be of a high quality of design and be of a high standard in relation to energy efficiency. Development should seek to conserve and enhance green infrastructure, biodiversity and landscape value wherever possible, seeking to bring the countryside into the developments through their layout and design. All developments should consider how the design of development within the site can actively enhance biodiversity through habitat creation. Development should also improve access to recreation opportunities and green space.
Other policy changes 10.3 In addition to the new policy set out above, we recommend the following amendments to existing draft policies:
Policy SP2: Strategic Development Requirements 10.4 We recommend that this policy should be amended to include the spare capacity for meeting housing need, as set out at 9.16 – 9.17 above.
Policy H2: Housing Site Allocations and Appendix A: Area Maps
10.5 We recommend that the site Land south of St Joseph’s College (SSE004) be elevated from its current status as an “Alternative Housing Option” to a full Housing Site Allocation and included in the table “Major Residential Development Sites”. This should also be amended on the Area Map at Appendix A.
Policy H3: Affordable Housing 10.6 If our other recommendations are accepted, it would be appropriate to extend the settlement boundary to include site SSE004. Policy H3 should therefore be amended to include the site in “Zone B” of the plan within this policy.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
62
Policy SP7: The Creation of Garden Villages and Employment Areas to the west and south-west of Skelmersdale 10.7 Paragraph 3.52 of the supporting text to this policy states that the Land south of St Joseph’s College has been considered as an alternative site. In line with our other recommendations, this reference should be removed.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
63
11 Summary and conclusion 11.1 This Deliverability Statement has been prepared by ATP on behalf of AIUH as part of a suite of documents to respond to the council’s Preferred Options consultation.
11.2 This statement demonstrates there is a credible opportunity to deliver residential-led development on land south of Stoney Brow to facilitate the refurbishment and repurposing of St Joseph’s College which is a vacant statutorily listed building complex to the north of Up Holland.
11.3 The work undertaken demonstrates that there is a strong case for the scheme which would deliver up to 756 family dwellings and through the partial refurbishment of the listed building would support additional apartments (circa 110). This development can be completed within the earlier part of the Local Plan period.
The Heritage Asset 11.4 The listed building has deteriorated in recent years, and there is an urgent need to address its decline. The submitted material clarifies that the listed buildings are of significance and that great planning weight should be afforded to securing the opportunity for their active re-use. It is important to note that through a previous scheme subject to appeal during 2007, the Secretary of State did make very clear that the significance of the buildings was very substantial and that the opportunity to bring them back into active use should be afforded very strong weight in the planning balance.
11.5 The council will be well aware of previous planning schemes, including that considered by the Secretary of State, for a range of development options that have not been fully implemented due to issues in respect of deliverability. These representations are the first step toward finding a permanent, viable solution.
Scenarios for re-use of the college 11.6 Various scenarios for the building’s future have been considered and evaluated. The key issues are to ensure that as much of the building’s heritage value as possible is retained, and to ensure that the new use is viable over the long term. Our assessment of these scenarios leads us to conclude that selective demolition of parts of the college and conversion of the remainder to apartments would preserve the most historically valuable elements of the building. Other scenarios would not be viable and would therefore fail to secure the buildings’ long term future.
11.7 The cost of restoring the college and bringing it into residential use is estimated to be around £27m. Together with other costs, the potential income from the development would be exceeded by a considerable margin. A form of enabling development is therefore necessary – following the principle accepted by the Secretary of State in 2007. That scheme proposed apartments in the college grounds, but this was not viable as the market demand in the area is for family-sized detached and semi- detached homes. The preferred approach is therefore to cross-subsidise the conversion of the college through development of such homes on land to the south.
Enabling Development 11.8 The proposal is for allocation of the site for housing in the Local Plan. That development that would be controlled through a site-specific policy making development conditional upon refurbishment of the listed buildings. The site in question (Land south of St Joseph’s College, or SSE004) was examined in the drafting process for the Preferred Options Local Plan document and is identified as an “Alternative Housing Site”. Our masterplanning work has shown that the site can be developed for 756 new homes,
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
64
together with a green infrastructure network of open spaces and retained ecology, connections to the surrounding area, roads and land for school provision.
11.9 This development would fall short of covering the costs of the preferred approach to re-use of the college, by £2.33m. However, if granted relief from CIL the scheme reaches a level of profit (4.62m). This represents a profit on value of 11.12% which is below the level recommended by English Heritage (15%) but is nevertheless acceptable to AIUH. The summary of the viability assessment is set out below.
Table 6: Viability summary
OPENING UP COSTS COSTS, ENABLING LISTED RELATING SCHOOL AND DEVT BUILDING TO LISTED ECOLOGY INC FINANCE INCOME (CIL APARTMENT SCENARIO BUILDING PROF FEES COSTS ADJUSTED) INCOME COSTS INCOME PROFIT PROFIT ON VALUE % MASTER DEVELOPER INCLUDING CIL £27.44m £7.76m £3.89m £16.84m £19.93m £39.09m £36.76m -£2.33m -6.34% MASTER DEVELOPER EXCLUDING CIL £27.44m £7.25m £2.24m £21.62m £19.93m £36.93m £41.55m £4.62m 11.12%
11.10 We would anticipate that we would provide updated viability assessment of these development options and the analysis of their deliverability (in financial terms) and also an assessment in terms of the broader planning framework prior to the Local Plan Examination. This will inevitably refer to infrastructure requirements and the implications of a CIL levy upon the extent of enabling development needed.
Green Belt Release 11.11 The site is identified within the Green Belt, and its use for enabling development would require it to be released. In the context of plan-making, this requires reference to the exceptional circumstance test.
11.12 The council’s evidence base for the Local Plan Review does not include any recent submissions in terms of the assessment of Green Belt parcels in reference to their contribution to the Green Belt purposes and any harm arising to those purposes by consequence of the realignment of those boundaries. The last study in these respects was undertaken during 2011.
11.13 The promoter has commissioned independent assessment of the development parcel with reference to its contribution to the purposes for Green Belts (set out in the Framework) and any impact arising from its release. It has also sought to refer to the council’s evidence base in terms of its earlier 2011 study and cross-reference to conclusions with comparator sites. This approach has sought to provide a granular assessment of the site and through its form and strong defensible boundaries its contribution to the five purposes are no better than “moderate”. It is implicit that through well- considered design which maintains and enhances these development edges, the extent of any harm (caused by release) is limited.
11.14 There are exceptional circumstances that support the release of the land from the Green Belt. Most notably there is the benefit of securing the future of the listed college. This was something the Secretary of State considered a “very special circumstance” – an even sterner test – justifying inappropriate development in the Green Belt. In addition:
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
65
• There is a need to provide additional capacity and flexibility in housing land supply if there is to be confidence that housing need will be met. In addition, the benefits of housing growth should be more evenly distributed across the borough.
• There will be clear economic and social benefits to increasing the population of Up Holland.
• The site benefits from permanent physical features on all sides that can act as Green Belt boundaries.
Legal Constraints 11.15 For the purpose of clarity, there is no legal impediment or development constraint that would prevent commencement upon consent and completion within the first 10 years of the Plan period. The works to protect the listed building and its refurbishment would be carried out at an early stage.
11.16 This is notwithstanding the following technical features of the site:
• Feasibility work shows that the proposed access solution and highway improvements ensure that traffic effects on the local network will be limited;
• The site is in Flood Zone 1 and therefore represents very low risk;
• Feasibility work in terms of drainage demonstrates that the subject land can incorporate SuDS and that there are no known capacity issues in terms of foul water drainage;
• The listed buildings are a significant heritage asset which has been identified as a Building at Risk. The scheme provides the best opportunity to put the heritage asset back into viable active use;
• Feasibility work in terms of ecology demonstrates that whilst there are ecology designations the scheme proposal clarifies that there is no evidence of any material biodiversity constraint in terms of the site’s use for housing;
• The site is in the Green Belt but it has been demonstrated that its contribution to Green Belt purposes is limited as is the prospect of Green Belt harm through its release;
• The scheme ensures that there are no residual issues in terms of primary school places;
• There is no evidence of any supply issues in terms of secondary school places; and
• The site can provide a meaningful contribution to the council’s housing need which will be better distributed across the borough.
11.17 We respectfully reserve the right to add to these comments as and when the council do make any further comments on these representations and our submissions as a whole.
Recommended policy changes 11.18 We recommend the addition of a site-specific policy to the draft plan, linking any development there to restoration of the college. The policy would also set out requirements for the development in terms of its form and infrastructure requirements.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018
66
11.19 Other policies to be amended are:
• SP2: Strategic Development Requirements;
• Policy H2: Housing Site Allocations;
• Policy H3: Affordable Housing;
• Policy SP7: The Creation of Garden Villages and Employment Areas to the west and south-west of Skelmersdale; and
• Appendix A: Area Maps.
11.20 These should be amended to reflect an elevated status of the enabling development site.
Conclusion 11.21 There remains a long-standing need to address the future of St Joseph’s College. Our proposal, set out in these representations, would repurpose the college buildings and preserve the most historically important elements. To do so there would be a need for enabling residential development on the land to the south. This would have other benefits to the town of Up Holland and to the robustness of the development plan. We therefore recommend that the policy changes set out in these representations are incorporated into the next iteration of the Local Plan.
Quod | Land at St Joseph’s College, Up Holland | Representations to West Lancashire Local Plan Consultation | December 2018