Metropolitan ! Borough of Wirral

APPENDIX 1

WIRRAL METROPOLITAN BOROUGH COUNCIL

INTERIM PLANNING POLICY FOR NEW HOUSING DEVELOPMENT

REPORT OF CONSULTATION

SEPTEMBER 2005

Wirral Interim Planning Policy for New Housing Development Report of Consultation 1 [blank for copying]

Wirral Interim Planning Policy for New Housing Development Report of Consultation 2 1 BACKGROUND

Introduction

1.1 This document sets out the results of consultation undertaken by the Council to inform the preparation of an Interim Planning Policy for New Housing Development in Wirral.

1.2 The Interim Planning Policy is intended to provide a context for decisions on planning applications for new housing development, pending the adoption of policies within the emerging Local Development Framework Core Strategy and Land Allocations for Housing Development Plan Documents.

1.3 The Council’s Unitary Development Plan has been “saved” until the adoption of the new Development Plan Documents, which are being prepared under the new development planning system introduced by the Planning and Compulsory Purchase Act 2004.

1.4 The Interim Planning Policy does not form an alteration to the UDP, which remains part of the statutory development plan for the Borough, alongside the Regional Spatial Strategy, in accordance with section 38 of the Planning and Compulsory Purchase Act 2004. The Interim Planning Policy will be considered as a material consideration in the determination of planning applications for new residential development in the areas affected.

The Consultation Process

1.5 Public consultation on the potential content of the Interim Planning Policy was undertaken over a six-week period from 5th August to 16th September 2005.

1.6 Letters inviting comment on the draft Interim Policy were sent to a wide range of organisations and individuals. The list of contacts was drawn from the Unitary Development Plan database, the Area Forums, the Local Strategic Partnership and the Wirral Voluntary and Community Sectors Network.

1.7 A link to the Council’s website was given, allowing the public to directly access the document Respondents were also given the opportunity to purchase a paper copy of the document. Paper copies were made available for public viewing, free of charge, at the public counter of the Department of Technical Services in and at Town Hall. The draft Interim Policy was viewable at http://www.wirral.gov.uk/planning/nhd1.asp.

Wirral Interim Planning Policy for New Housing Development Report of Consultation 3 Report of Responses

1.8 The consultation drew 58 responses from a wide range of organisations including developers, house builders, public sector agencies, local amenity societies, community groups, and individual local residents.

Summary of Main Points

1.9 Twenty-four respondents supported or welcomed the Interim Policy. Twelve respondents would support the Interim Policy subject to a revision of the boundaries to protect established residential areas in Bromborough Ward. Five respondents objected to the inclusion of New Brighton Ward within the regeneration priority area. Nine respondents, principally housing developers, objected to the Interim Policy on the basis that it would be too restrictive.

Wirral Interim Planning Policy for New Housing Development Report of Consultation 4 2 SCHEDULE OF INITIAL CONSULTATION RESPONSES

No1. Organisation/Individual Consultation Response Director’s Comments

1 Antler Homes (Emery Planning Partnership) Concerned that there is no evidence of a Principle of harm has been established in detrimental impact on HMRI from relation to previous policy restricting development outside the regeneration development in west Wirral, where priority areas. If demolition replacement is development contrary to the RSS strategy on less than one-for-one on-site, is in itself harmful. displacement will occur. Demolition rates will be monitored, in The purported supply of 2,858 dwellings accordance with the principles of Plan, does not allow for clearance replacement. Monitor and Manage. The proposed demolition rate at 250 pa is less than recent past performance and is No allowance has been made for new build too pessimistic. The housing requirement windfalls, which should continue to come should be 410 pa and the supply required is forward in sustainable locations within the therefore 4,100. The current supply is only regeneration priority areas. adequate for 6.97 years and not the 17.8 years suggested.

To allow for clearance replacement as a The principle of ‘front-loading’ has been result of HMRI activity, a pool of suitable proposed by consultants advising the housing will be required in the early years NewHeartlands Pathfinder. Within the of the plan period, ‘front-loading’ supply. existing Masterplans, the need to find displacement sites has not proved The Council should delay implementing the insurmountable. In any event, such policy until full justification is given that displacement housing should be provided development outside the HMRI will harm locally and not outside the regeneration

1 Respondent Number

Wirral Interim Planning Policy for New Housing Development 5 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments the HMRI, until clearance assumptions can priority areas. be assessed and a 10 year land supply can be calculated.

2 Barnston Conservation Society (Mrs E Asks if the 160 dwellings limit includes the Each individual dwelling within an Rafferty) numerous apartment blocks as one new apartment block counts towards the dwelling or the number of apartments. housing land requirement.

3 Bromborough Society (Susan Nicholson) Welcomes introduction of policy. Supports Support noted. re-use of existing buildings. Wishes to see only one-for-one replacement outside regeneration priority areas.

Wishes to redefine the regeneration areas to exclude parts of Bromborough Ward, Accepted, boundary to be reviewed. leaving the regeneration area of and Village (where one- for-one replacement of previously demolished dwellings would be appropriate). No comment on the Lever Faberge site. Exclude Village and housing areas to the east of New Chester Road, south of the Lever factory. Supports criteria (d)(ii) and (d)(iv) of draft policy. Supports flat development SPD.

4 Mr I Coulthard Concurs with Mrs Wollers. Use A41 and Accepted, boundary to be reviewed. Levers factory as boundary.

5 Countryside Agency No comment.

Wirral Interim Planning Policy for New Housing Development 6 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

6 Dr Michael Day Strong objection to further development in Accepted, boundary to be reviewed. Port Sunlight Village, given existing planning permissions for Wood Street, Wharf Street and Water Street and generally low demand for new housing across Wirral.

7 Trish Derraugh Strong objection to new housing Accepted, boundary to be reviewed. development in Port Sunlight, given existing planning permissions in Water Street, Wharf Street and Wood Street.

8 Design Planning Development Refers to land at the rear of Glenavon Site is classified as greenfield and therefore Road, , formerly used as playing should not be developed before more field by Pershore House School. School sustainable previously developed sites. closed 5 years ago and school site There is no evidence of a shortage of developed with new housing. Former housing land in the Borough. playing field is land-locked and not open to the public so should not be considered as general amenity space. Government policy is attempting to provide new housing for which this land would be ideal. Any other use than housing would have an effect on the existing housing. There is no other land available in the area.

9 Councillor Bill Duffey Draft Interim Planning Policy offers no New Brighton falls within the protection against new housing in New Objective 1 Strategic Investment Area, Brighton ward. Where land is allocated for which extends from Bromborough to New employment purposes the applicant has to Brighton. RSS Policy SD8 sets out a ‘need

Wirral Interim Planning Policy for New Housing Development 7 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments demonstrate that there is no prospect of the to ensure the reshaping of resort towns for site being taken up for employment use but new and more varied purposes…’ this was not applied to 102 Albion Street. Over development is evident in the ward, Only land allocated or designated for with 5 school sites being redeveloped for employment purposes is subject to the housing, 4 garage sites and the Hotel requirement to demonstrate that such uses Victoria site. Good quality housing is being cannot be continued. 102 Albion Street is demolished and replaced with flats and the within the Primarily Residential Area, where Neptune development will have over 140 residential development is, in principle, apartments. The annual replacement figure appropriate. for Wirral as a whole will be built in New Brighton. Site W5166 is described as Sites under construction and with planning brownfield but was a National Playing field permission account for 209 new dwellings and should not have been granted outline in New Brighton. This represents 7.3% of planning permission. Every small area of the total 2,853 new dwellings identified in greenspace is due to be built on, including the Borough at April 2005 the corner of Montpellier Crescent, Albion Street and Portland Street. The Council’s Cabinet on 11th May 2005, agreed that site W5166 (Weatherhead Upper, Laburnum Road) be sold at auction. At its meeting on 31st March 2004, Cabinet agreed notification of the disposal to DfES prior to disposal. DfES require that a proportion of the proceeds of the sale should be recycled into playing field provision.

The corner site at Montpellier Crescent, Albion Street and Portland Street is not designated as Urban Greenspace in the UDP adopted in February 2000 and is

Wirral Interim Planning Policy for New Housing Development 8 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments previously developed land.

10 Eleanor Road Residents Association (Dr Welcomes the policy. Severe pressure Support noted. Lillian Potter) placed on areas of East Wirral since embargo in west Wirral. In last 5 years planning permission granted for 72 (net 71) new dwellings on the slopes of Hill and a further 11 (net 9) applied for. Some schemes have breached density guidelines in the Eleanor Road brief and decimated trees and green cover. Agrees with Wirral Society comments. Council should consult local community on planning applications and take account of cumulative impact. Urges early preparation of the flats SPD. Shares Bromborough residents concerns about pressure being directed towards established areas of Bromborough ward.

11 Environment Agency Supports aim of policy to focus new Support noted. housing development into the HMRI areas.

12 Flintshire County Council Sees merit in regenerating poorer Flintshire CC is a statutory consultee on the communities but concerned that review of Regional Spatial Strategy and has development pressure will be redirected to previously commented on the impact of Flintshire. restraint in the North West on Flintshire. However, migration flows between Wirral and Flintshire are not large. For example, in 1998/99 150 people moved from Flintshire to Wirral and 260 from Wirral to

Wirral Interim Planning Policy for New Housing Development 9 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Flintshire (net –110 from Wirral). In 1999/2000 the corresponding figures were 130 and 240 (net –110), 2000/2001 110 and 240 (net –130) and in 2001/2002 160 and 220 (net –60) (NHS Central Health Register). At an average household size of 2.31 (2001 Census), this would require between 26 and 56 dwellings per year across Flintshire (new and second-hand).

13 Friends of Birkenhead Park (Professor W R Endorse approach to focus new housing Support noted. Lee) development in the designated Housing Market Renewal Initiative Areas. Recent pressure has been seen on the Birkenhead Park Conservation Area for redevelopment for high-density modern flats.

14 The Garden History Society No comment.

15 Reginald Gibson Support. Support noted.

16 Government Office North West Welcomes the introduction of the interim Amendments to be made to draft policy to policy in order to manage the supply of reflect prominence to be given to RSS, housing coming forward in the Borough. issue of over-supply and clear focus on Welcomes the introduction, which sets out HMRI and other regeneration priority areas. clearly how the interim policy relates to the Boundary in Bromborough to be amended. current Plan. More prominence should be given to RSS being part of the Development Plan (s.1 or s.4). Oversupply 2002-2005 should be elaborated at s.5.

Wirral Interim Planning Policy for New Housing Development 10 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Section 6 would be better if clearly stated that housing development will be directed towards the HMRI and other regeneration priority areas and only allowed outside in limited circumstances. Set out demolition replacement approach more clearly. Do not encourage low-density development. Review local housing needs. Review boundary in Bromborough so as to focus on regeneration priorities.

17 Health and Safety Executive No comment.

18 Stephen Hesford MP Supports draft revised policy, including Support noted. restraint in Prenton.

19 Highways Agency How long is policy to be in place? Has any Interim policy to be retained until adoption assessment been carried out of the impact of Core Strategy. No allocations are being of proposed allocations on the existing road made as a result of the interim policy. Any network? Without further information on highway impacts will be considered by the potential impact, the Highways Agency Highways Division of the Technical objects to the proposed Interim Planning Services Department, consulting with the Policy document. Highways Agency as appropriate.

20 and District Civic Society Considering whether to make a response.

21 Mr M F Lewis Understands need to stimulate mixed Accepted, boundary to be reviewed. tenure developments in certain parts of Bromborough ward but concerned about arbitrary nature of boundaries. Lever site is

Wirral Interim Planning Policy for New Housing Development 11 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments legitimate for regeneration and provision of new mixed tenure housing, using A41 as main access. Re-consider boundaries, protecting Port Sunlight Village and other areas to west of A41.

22 Linden Homes (Cass Associates) Understands rationale for policy but seeks Cass Associates do not specify the further revision: identified locations to which this revision might apply. The great majority of planning ‘To permit an element of housing in mixed applications for new housing development use regeneration schemes where this can has been brought forward on previously be shown to provide the essential catalyst developed land in recent years. This has for the delivery of a range of uses and led to an over-supply of new housing activities together with other planning against the RPG13 figure and to pressure benefits. This provision will apply to on established residential areas in East previously developed land at identified Wirral, as restraint has been applied in locations for new development across the West Wirral. Cass Associates only suggest Borough as a whole. The housing that part of local housing needs would be component of such mixed use development met by their revision. schemes will, in part, meet local housing needs’.’

This would clarify (d) (iii) and (d) (iv) and would not adversely impact on the HMRI area. It would apply to a limited number of identified locations of sufficient scale to accommodate a mix of uses and activities.

23 Mersey Docks & Harbour Company/Peel Reservations about further restraint but The Dock Estate is already within a Holdings (Knight Frank LLP) support focus on new housing development regeneration priority area, falling within the within the HMRI and Regeneration Priority Merseyside Objective 1 Strategic

Wirral Interim Planning Policy for New Housing Development 12 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Areas in the Borough. Propose that the Investment Area, the HMRI Area. The Dock Estate should be specifically identified Dock Estate also includes a Strategic as a Regeneration Priority Area where Regional Site, identified by North West higher density housing is appropriate. Regional Development Agency. MDHC cite the following reasons:

The Docks are in desperate need of urgent investment and regeneration in order to The future use of land within the Dock capitalise on a significantly underused Estate will need to be considered in a location – residential can be used to ‘pump- comprehensive manner. prime’, provide commercial viability and sustain dock-related employment

The Docks are highly sustainable in terms of access to jobs, shopping, services and public transport and offer views across an internationally significant skyline

Should not miss the opportunity provided by 150 hectares of land in an area suffering from decline

High density private residential development in the Docks would benefit the HMRI area

24 Merseytravel Broadly supportive. Clear guidance should The integration of the draft Merseyside be offered on the levels of car parking Transport SPD will be considered in the proposed for residential areas, in context of the UDP and the emerging Local accordance with the draft Merseyside Development Framework. Travel Plans Transport SPD. Guidance should be and accessibility issues are to be

Wirral Interim Planning Policy for New Housing Development 13 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments provided requiring that all new housing considered by the Development Control development is fully integrated with the service within the Technical Services public transport network and that only Department and will be an issue for the proposals that meet this criteria would be Core Strategy DPD. permitted for development (important for ex-employment sites). Density and design should facilitate the provision of good quality public transport. In order to support the draft Merseyside Transport SPD, effective action is required to promote the use of sustainable forms of travel. Planning applications for all developments of 50 residential units or more should be accompanied by a Travel Plan. Merseytravel would wish to see that all developers are required to construct good quality walking and cycling routes to the nearest appropriate public transport access points. All new residential development should comply with the Disability Discrimination Act and be fit for lifetime use.

25 Peter Miller Draft policy far too restrictive. Sites outside The draft policy extends the level of control the HMRI area may be more sustainable already applied to west Wirral, by adopting and economically viable and could provide the same criteria, allowing exceptions for substantial elements of affordable housing. local housing needs when other criteria also Concerned at policy approach on two sites, satisfied. The interim policy does not apply Rockland Road, (appeal) to the two cases referred to, as both are and the former Great Western Social Club valid applications, in process before the (application). interim policy will be adopted.

Wirral Interim Planning Policy for New Housing Development 14 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

26 Councillor Bob Moon/Councillor Alan Taylor Generally welcome policy as a means of Accepted, boundary to be reviewed. dealing with pressure from developers as a consequence of restraint in west Wirral. Do not object to including New Ferry or Lever Faberge site within regeneration area. However, much of Bromborough ward is of similar character to Eastham ward, which proposed for restraint. Map produced showing an alternative boundary, excluding areas of Bromborough ward from the regeneration area.

27 Morris Developments (North) Ltd (McDyre Surprised at timing of the policy, given The interim policy has been introduced to & Co) issue of PPG3 in March 2000 and RPG13 address the urgent and important issue of in March 2003. Both documents subject to over-supply and the impact on established review and interim policy will soon be out of residential areas. There is no current date. Welcomes clause (d)(ii) but should pressure to develop greenfield sites. not tie criterion to provision of affordable housing. It is impractical and unworkable, as such groups of people cannot be adequately identified, nor can future occupiers be controlled. Genuine regeneration sites are usually difficult to develop and will often only be viable if full market dwellings can be built. Several other Councils allow alternative schemes on sites that have an extant planning permission, allowing an increase in the number of units to comply with PPG3. This

Wirral Interim Planning Policy for New Housing Development 15 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments would reduce pressure on greenfield sites.

28 The National Trust Supports the draft policy as consistent with Support noted. RSS and the need to secure regeneration within the metropolitan area.

29 New Brighton BRAVO Voluntary Objects to inevitable increased urban New Brighton falls within the Merseyside Neighbourhood Network (Miss C Stonall) density, traffic and parking overload. Objective 1 Strategic Investment Area, BRAVO’s opinion that New Brighton which extends from Bromborough to New already has enough new housing already Brighton. RSS Policy SD8 sets out a ‘need completed or in pipeline. New Brighton to ensure the reshaping of resort towns for should be protected from further new and more varied purposes…’ development as a great deal more residential building has been taking place Sites under construction and with planning within New Brighton compared to permission account for 209 new dwellings neighbouring Wallasey Village, which is in New Brighton. This represents 7.3% of accorded protected status. the total 2,853 new dwellings identified in the Borough at April 2005.

30 New Brighton Community Partnership Supports regeneration of New Brighton but Control will be exercised through UDP (Rusty Keane) wishes to be assured that the Council will Policy HS4 and the emerging Flats SPD exercise firm control on future (when adopted by Council). developments proposed for New Brighton.

31 New Brighton Heritage Action Group (Miss Objects to planning implications of the Control will be exercised through UDP C Stonall) interim policy. Grave concerns about the Policy HS4 and the emerging Flats SPD increase of residential building in multiple (when adopted by Council). units. Members aware of increased noise, parking demand and traffic encroaching upon public amenity space and roads.

Wirral Interim Planning Policy for New Housing Development 16 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

32 New Ferry Regeneration Action Group Concerned at inclusion of entire Accepted, boundary to be reviewed. (Mark Craig) Bromborough ward, as developers will target more affluent areas by converting perfectly acceptable larger family homes into multi-occupancy apartments. Supportive of new development in New Ferry where regeneration benefits. Former Park Hampers could be redeveloped for housing. Propose new housing above new shops in New Ferry to revive centre. Whilst supportive of new housing in Port Sunlight, this should be strictly controlled.

33 North Western and North Wales Sea No comment. Fisheries Committee

34 North West Regional Assembly Interim planning policy is appropriate policy Support noted. to manage new housing development. Policy supports adopted RSS policies SD1, UR1, UR6, UR7 and UR8

35 Mrs Patricia O’Brien Does not support further new development Accepted, boundary to be reviewed. in Port Sunlight. In addition to design concerns, market is not strong enough to support further development. Third phase of Lodge redevelopment is derelict, whilst second phase is still vacant.

36 Oxton Society (Alan Chape) Strong support for proposed approach, Support noted. Draft policy to be revised. particularly paras 3.9 to 3.13, focusing

Wirral Interim Planning Policy for New Housing Development 17 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments development on HMRI. However, policy framework does not recognise the economic importance of protecting the environment in ‘character’ housing areas. Para 3.10 could be revised as follows:

‘Protecting the environmental quality in such established residential areas will have economic and environmental benefits, whilst helping to support regeneration elsewhere. Much of the character of these areas, including built forms and tree cover, is of architectural and landscape value. The existence of such areas helps the Borough to attract and retain highly skilled and qualified individuals and their families. This in turn assists in creating a social balance, an economic asset in terms of skilled and qualified labour supply, and increases spending power in the local retail and leisure sector.’

37 Redrow Homes (North West) Ltd Concerned that land supply situation in The alleged conflict with SD1 has not been Wirral does not justify additional restraint raised as an issue by GONW or NWRA. over new housing within parts of the The interim policy is required to control NWMA, which would also be contrary to potential over-supply and to focus new Policy SD1 of RSS. In addition, the interim housing development within the NWMA, in policy is being introduced at a time when support of Policy UR6 and UR7 of RSS. RSS is subject to review. There may be significant changes to the scale and

Wirral Interim Planning Policy for New Housing Development 18 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments distribution of new housing within NWMA. The company believes that the Council’s existing UDP Policy HS4 could be used to control potentially harmful development in east Wirral, within the NWMA. 10% slippage is not required, as other windfall sites will come forward each year, The approach now proposed by the Council maintaining an adequate supply, in is predicated on a number of assumptions, accordance with Plan, Monitor and including that all commitments will come Manage. Monitoring of the annual land forward as completions. An allowance of supply has shown an increase in sites 10% slippage should be made, reducing the identified, without allocations and in the supply with planning permission to 587 on context of restraint outside the NWMA. large sites and 1180 on small sites. Similarly, demolition levels and replacement Secondly, demolition assumptions are too requirements will be monitored. Any low at 200 and should be 300 pa. This demolitions outside HMRI and regeneration would reflect the need for demolition in the priority areas will be replaced one for one HMRI and would be consistent with on site. Replacement requirements within and Sefton assumptions. the HMRI will take account of the prevailing Demolition replacement will require vacancy rate and the potential to rehouse additional land, as existing densities of 80- within the existing stock or on site. 100 dph for terraced property will not be replicated. Redrow agree that a five-year supply can be provided. Redrow calculate the 10 year requirement (in accordance with Government advice) as 460 pa and the supply as 2,656 (5.7 years at 460 pa). There is a residual requirement of 1,900 units.

Because recent performance has only marginally exceeded RPG13’s rate of 160

Wirral Interim Planning Policy for New Housing Development 19 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments pa. Any further restraint risks a shortfall, which would be in conflict with RSS Policy UR7. Support noted. Redrow supports that element of the policy reflecting para 42(a) of PPG3.

38 Dr Karnail Singh Wholeheartedly welcome policy as it Support noted. restrains further housing development in Oxton, Claughton, and Bidston Ridge.

39 WMBC Technical Services Sustainable Only concern relates to potential increase in Development within the A41 corridor will be Transport Co-ordinator traffic and congestion on A41, leading to discussed with the Council’s Sustainable raised levels of air pollution. No conflict Transport Co-ordinator. with Merseyside Supplementary Planning Document on Transport, or Accessibility Strategy being produced as part of LTP2.

40 Tulip UK Interested if any development planned in No residential development is proposed in proximity to site. proximity to the Tulip site.

41 Turley Associates Question use of interim policy as an The interim policy has been introduced to appropriate mechanism. Wirral’s LDS did address the urgent and important issue of not include housing land supply as an issue over-supply and the impact on established and no DPD or SPD was proposed. No residential areas. The policy also reflects provision for interim policy in PPS11 or need to control over-supply in context of PPS12. Issue should be considered within RSS Policies UR6 and UR7. The interim Core Strategy. policy will only be used as a material consideration. Housing land supply calculation does not

Wirral Interim Planning Policy for New Housing Development 20 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments make appropriate allowance for clearance. Turley’s agree that a housing land supply in RSS figures are net of clearance excess of five years can be provided. replacement. Turley’s calculation is that there is less than 7 year’s supply, when high levels of clearance (particularly in the HMRI area) are taken into account. Government advice is for a 5 year rolling programme within a 10-year supply.

A realistic clearance replacement rate of The clearance replacement rate will vary, 60% should be applied, demonstrating from one for one outside the HMRI and need for additional housing. regeneration priority areas, to lower rates within the HMRI, dependent upon prevailing Whilst the housing land supply equation vacancy rates. Cleared sites will provide a includes an element of windfall, this is not supply for an element of clearance included as one of the exceptions to the replacement. policy. Windfall sites outside the HMRI and Implementation rates have fallen in recent regeneration priority areas will not be years as supply, constrained by policy considered as exceptions to policy, as reduces the number of sites that are majority of Wirral’s new housing has come brought forward for planning permission. from windfall (only 800 of 10,800 new Further restraint may ultimately prevent the dwellings provided 1986-2001 were from strategic target from being met. allocated sites).

However, Turley’s support the policy The supply of new permissions has not applying to HMRI and regeneration priority been constrained by the restraint policy in areas. west Wirral. In contrast, more sites have been brought forward in the HMRI, both to Outside HMRI and regeneration priority planning permission and to construction. In areas, policy should recognise the benefits

Wirral Interim Planning Policy for New Housing Development 21 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments in terms of physical/environmental and 2004/2005, planning permission was economic regeneration: granted for 1,419 new dwellings across the Borough. Criterion (d)(I) requires clarification in terms of information required to demonstrate that The principle of harm has been established there is no harm to urban regeneration in relation to the previous policy of restraint in west Wirral, where development contrary Criterion (d)(ii) should be expanded to to the RSS strategy is in itself harmful. permit the development of degraded vacant land and buildings and the removal of non- The proposed amendment to the policy conforming uses form residential areas would render the policy unworkable, as it where amenity, traffic, environmental or would place an intolerable pressure on other benefits would result existing non-residential uses outside HMRI and regeneration priority areas. An additional criterion should be added to give priority to development on previously Listed buildings are already subject to the developed sites that are highly accessible requirement to consider their preservation. to facilities such as shops, schools, jobs This has to be weighed against other and services. material considerations, such as the Interim Policy. A further criterion (e) should be included to allow the use of vacant listed and other GONW and NWRA have not suggested that buildings of architectural merit. the Interim Policy is inconsistent with the spatial strategy of RSS. The additional flexibility should be applied to that part of the Borough lying within the NWMA, since this would be consistent with the spatial strategy of RSS.

42 Unilever PLC (Corporate Property Site of the former laboratory at New Previous appeal on this site was dismissed Chester Road should be included within the on grounds of conflict with Primarily

Wirral Interim Planning Policy for New Housing Development 22 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Solutions) priority regeneration area. It is previously Industrial Area policy. UDP Proposed developed land outside the Bromborough Alterations (now withdrawn) excluded site International Business Park, formerly used from the PIA and placed it within the PRA. for industrial purposes but now derelict. It Para 42(a) of PPG3 is now a material is in a sustainable location, adjacent to consideration. residential property, with good public transport links.

43 Unilever Home and Personal Care Comments relate to main factory site at Accepted that the factory site is within a Research and Development Port Sunlight Port Sunlight, within which land has been regeneration priority area. The boundary (Drivers Jonas) identified as surplus to production will be amended to include the Research requirements. Need for rationalisation has Laboratory site been recognised by Wirral MBC in the preparation of a draft brief for the site.

Surplus land is previously developed, formerly used for employment/industrial purposes. Redevelopment would be consistent with PPG3. Site is highly accessible by a range of modes of transport and adjacent to existing residential development.

Drivers Jonas suggests a number of Agree amendments. amendments to the draft policy, including deleting the list of ward names and the provision of a plan with clearly identifiable boundaries.

(d)(iii) should be amended as follows:

Wirral Interim Planning Policy for New Housing Development 23 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

‘That the proposal will assist the sustainable regeneration of the site delivering demonstrable regeneration benefits by:

Being highly sustainable with shops and services within walking distance and access to public transport;

Delivering a good quality of design achieving significant environmental enhancements;

Replacing a non-conforming use within a residential area, enhancing significantly the overall quality of life for the existing and future community and particularly in terms of residential amenity; and

Bring back into use redundant institutional or industrial land and buildings in predominantly residential areas, which are vacant or significantly under-used.’

Similarly, the final part of the proposed policy should be amended as follows:

‘Where the application relates to a site allocated for employment purposes, in employment use, or within a Primarily

Wirral Interim Planning Policy for New Housing Development 24 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Industrial Area, the applicant must further demonstrate that:

(i) that there is no realistic prospect of the site being taken up for employment use;

(ii) residential development of the site would not harm regional or the Council’s economic strategies; and

(iii) the development can assist/support re- investment and growth in existing firms to protect employment.’

(d) (v) should be amended as follows: Amendment not agreed as the definition of local housing need is taken from RSS ‘Subject to viability the proposal will (p.149 of RPG13) contribute towards meeting an identified local housing need.’

44 Unilever UKCR Ltd (Jones Lang LaSalle) Comments relate to Research Laboratory Boundary to be amended to include site to west of -Chester railway Research Laboratory site line. Site is considered to be highly accessible by both private car and public transport, being adjacent to Port Sunlight Railway Station. Site is bounded by residential development on three sides and well located in terms of local shops.

Wirral Interim Planning Policy for New Housing Development 25 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

Jones Lang LaSalle are concerned that the Interim Policy does not reflect emerging national advice on housing in the ODPM consultation paper on Housing Choice. The Interim Policy should also be set in the context of the review of RSS.

Jones Lang LaSalle request that the Research Laboratory site should be identified as an exception to the restraint policy. Flexibility is required to allow future investment decisions to be made that could facilitate further expansion and potentially attract Research and Development operations that are provided in locations outside Wirral.

Propose following amendments to the final part of the policy: Accept amendments.

‘Where the application relates to a site allocated for employment purposes, in employment use, or within a Primarily Industrial Area, the applicant must further demonstrate that:

(i) there is no realistic prospect of the site being taken up for employment use;

(ii) residential development of the site would

Wirral Interim Planning Policy for New Housing Development 26 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments not harm regional or the Council’s economic strategies; and

(iii) the development can assist/support re- investment and growth in existing firms to protect employment.’

The Interim Housing Policy provides an opportunity for the Council to prioritise developments that contribute towards core objectives to promote sustainable development and regeneration.

Proposed amendment to (d)(iii):

‘That the proposal will assist the sustainable regeneration of the site delivering demonstrable regeneration benefits by:

Being highly sustainable with shops and services within walking distance and access to public transport;

Delivering a good quality of design and achieving significant environmental enhancements;

Replacing a non-conforming use within a residential area, enhancing significantly the overall quality of life for the existing and

Wirral Interim Planning Policy for New Housing Development 27 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments future community and particularly in terms of residential amenity; and

Bring back into use redundant institutional or industrial land and buildings in predominantly residential areas, which are vacant or significantly under-used.’

Proposed amendment to (d)(iv) to reflect Amendment not agreed as the definition of broader view of housing need: local housing need is taken from RSS (p.149 of RPG13). ‘Subject to viability the proposal will contribute towards meeting an identified local housing need.’

45 United Utilities No comment other than to request that any This is not an issue for the interim policy exceptions should be qualified by: Policy WA4 of the UDP addresses the ‘No permissions will be granted for any availability of water supply and Policy WA5 proposals within the maintenance access addresses the impact on sewerage. strip of any utility underground assets and where utility service capacity is not available.’

46 Wallasey Civic Society Society welcomes extension of restraint into New Brighton falls within the Merseyside east Wirral but is greatly concerned that Objective 1 Strategic Investment Area, New Brighton is not within restraint area. which extends from Bromborough to New New Brighton has seen increase in number Brighton. RSS Policy SD8 sets out a ‘need of planning applications for housing to ensure the reshaping of resort towns for

Wirral Interim Planning Policy for New Housing Development 28 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments development. new and more varied purposes…’

Sites under construction and with planning permission account for 209 new dwellings in New Brighton. This represents 7.3% of the total 2,853 new dwellings identified in the Borough at April 2005.

47 Clive Watkin Partnership Property market is very slow at present and It is accepted that in the short-term there preventing the renewal of planning will be an increase in implementation rates consents in east Wirral will produce chaotic as sites granted permission under previous or over-supply conditions, as applicants are policy of no restraint are developed out. forced to develop sites. There are occasions where landowners have planning consents that they have no intention of implementing in the medium-term but are now forced to sell, thereby increasing the supply and having the opposite effect to what is intended. Wirral Borough Council has commented on House prices in the UK are amongst the the Barker approach in its response to the dearest in the world. This is partly caused ODPM consultation paper on Housing by economic factors but is also clearly Choice. caused by low supply. Kate Barker concluded in her interim report that continuing at the current rate of housebuilding would cause increasing problems of homelessness, affordability and social division.

An extra 120,000 private sector houses per

Wirral Interim Planning Policy for New Housing Development 29 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments annum might be required. On current replacement rates, houses built now would have to last for 1,200 years. Households are getting smaller. There is an urgent need to focus resources Planners should be looking to modernise on the HMRI area in the medium-term. The and improve the housing stock in all areas position will continue to be monitored. for the benefit of families and future generations and not ‘moth-balling’ or allowing districts to decay. National policy on planning for housing has Whilst the Government is planning to build been set out most recently in an ODPM hundreds of thousands more houses, consultation paper on Planning for Housing sometimes on Green Belt land in the South Provision. Future housing needs in the East, it would be far better to allow North West are subject to revision through reasonable numbers of new houses in all the RSS review process. areas across the North West (including Wirral) and to enhance job opportunities.

Family structures are changing with smaller The need for sheltered housing in the households caused by families splitting and restraint areas can be addressed as a local elderly couples or single people living need, subject to evidence. Very little considerably longer than in the past. evidence has been shown that such need Housing stock needs to continually adapt to cannot be accommodated within the this changing environment. A typical existing housing stock. sheltered apartment scheme for 30 single people releases 30 houses to be sold to families.

Clive Watkin does not accept that small infill developments in affluent areas will

Wirral Interim Planning Policy for New Housing Development 30 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments materially affect the development of the In considering appeals in west Wirral, since HMRI area. the introduction of the Council’s west Wirral restraint policy, Inspectors have accepted Over time a moratorium will blight sites that even small infill developments can where re-development is necessary. Such have a cumulative impact on the sites include semi-derelict land and regeneration priority areas. redundant places of worship. No evidence has yet been seen of blight in Clive Watkin fully supports the retention of restraint areas. the Green Belt and agrees that greenland within the urban area should only be built The emerging SPD on the control of new on as a last resort. Current planning flat development will address issues related policies should be sufficient to prevent over- to the suitability of locations for new development. Apartments should be apartments. concentrated in selected designated areas, particularly around District Centres.

An alternative policy approach would be:

(a) ‘Re-development proposals will only be considered on ‘brownfield’ sites where the site is vacant, derelict or clearly not viable The proposed amendment to the policy as a business use or substantially outdated would render the policy unworkable, as it or substandard as a residence’ would place an intolerable pressure on existing non-residential uses outside HMRI (b) Alternatively, the policy currently and regeneration priority areas. proposed by Ellesmere Port and Neston BC would seem appropriate:

‘On brownfield sites, housing development will only be allowed if it falls into one of the

Wirral Interim Planning Policy for New Housing Development 31 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments following categories:

Schemes for 10 or less units; The situation in Ellesmere Port and Neston Borough is different to Wirral, where very Schemes over 10 units where a minimum of severe levels of low demand have justified 50% affordable housing is to be provided; the HMRI. Excluding schemes of less than Extra care housing schemes; 10 units would not encourage redirection of resources towards the regeneration priority New housing or conversions within Neston areas, as before the introduction of the west town centre that would help revitalise and Wirral restraint policy, between 16% and regenerate that centre; 27% of all new build completions were on sites of 1-10 units. Between 26% and 39% The conversion of a statutory listed or of all new build housing development in the locally listed building of architectural or years 1999-2004 was outside the NWMA. historic merit that is unsuitable or incapable of being converted to/remaining in other uses, and which would otherwise become at risk.’ Listed buildings are already subject to the requirement to consider their preservation. These policies should also be re-introduced This has to be weighed against other to west Wirral. material considerations, such as the Interim Policy. Clive Watkin cites a series of developments in west Wirral that would not have progressed with the restraint policy in place. In addition, he cites a number of sites that are or will be blighted by the extension of the restraint policy:

Wirral Interim Planning Policy for New Housing Development 32 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

Springfield Avenue,

Kings Gap, West Kirby The house at Springfield Avenue appears capable of re-use as a single dwelling. Former Great Western Social Club, Park Road West, Birkenhead This Kings Gap site was the subject of an appeal last year. Although the appeal was TA Centre, Bidston Road dismissed, the appellant has challenged the Inspector’s decision and a High Court hearing is awaited.

The Great Western Social Club is the subject of a valid planning application.

The TA Centre has not been declared surplus by the MOD.

48 Wellington Road Conservation Area Objects to inclusion of New Brighton in New Brighton is within the Merseyside Advisory Committee (Mrs J Hockey) regeneration priority area. Objective 1 Strategic Investment Area, which extends from Bromborough to New Since the late 1960’s, 14 leisure sites have Brighton. RSS Policy SD8 sets out a ‘need changed their original use to housing, to ensure the reshaping of resort towns for including the Winter Gardens Theatre, The new and more varied purposes…’ Tivoli Theatre, Tower Grounds, Trocadero Cinema and Magenta Café. New Brighton’s character has changed since the 1960’s, with changing leisure In the last 20 years, other sites have been demands. The former theatres were developed for large sheltered schemes and derelict before their redevelopment for the lower length of Victoria Road has been housing. demolished and used to accommodate a

Wirral Interim Planning Policy for New Housing Development 33 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments Tay Homes Housing Estate. The Merseyside Development Corporation promoted the Tay Homes development. Many Victorian Villas (including a listed MDC’s area included New Brighton one) have been demolished to make way because of the need for regeneration. for high-density flats. Sites under construction and with planning School sites on the outer fringes of New permission account for 209 new dwellings Brighton are now composed of further flat, in New Brighton. This represents 7.3% of maisonettes and houses. the total 2,853 new dwellings identified in There has been a noticeable increase in the Borough at April 2005. traffic and side streets are cluttered with on- street parking. This appears to be due to the uncontrolled supply of housing in the area.

49 Welsh Water (Dwr Cymru) No comment.

50 Mr and Mrs Weston Support policy, in particular the extension of Support noted. control to encompass Prenton, Noctorum, Claughton and Oxton. Support principle of encouraging re-use of existing buildings.

51 Councillor Jerry Williams Concerned at ‘postage stamp’ Support noted. developments in , which are adversely affecting character of area. Traffic generation and ecological impacts of new development not considered adequately.

Wirral Interim Planning Policy for New Housing Development 34 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

Supports a housing ban in Bebington.

52 Councillor Patricia Williams Supports proposal to protect area from Support noted. Bidston Hill to Prenton.

53 Wirral Footpaths & Open Spaces No comment other than expects Council to These areas are already protected by other Preservation Society (Barry Lello) continue to protect Green Belt, Public policies in the UDP and national advice. Rights of Way, Open Spaces, playing fields and public parks.

54 Wirral Green Belt Council (Neil Parry) Most concerned that Green Belt not Green Belt policy does not allow for addressed in interim policy. Support focus residential development, except in very on re-use of land and continuation of special circumstances. The policy moratorium on development west of the approach already operating is not a M53. moratorium but restraint subject to a set of criteria, which are unchanged in this revision of the policy.

Suggest some flexibility for re-development Flexibility is already provided by Interim west of the M53, providing for specific local policy criteria. need, with the redeveloped site comparable in size to the original.

Ask about relation between greenfield and Greenfield restrictions apply to sites within Green Belt development. the urban area, as well as within the Green Belt. National policy in PPG3 does not allow for greenfield sites to be permitted when the supply of previously developed land is adequate.

Wirral Interim Planning Policy for New Housing Development 35 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

55 Wirral NHS Trust (DTZ Pieda Consulting) Recognise intent of Council in seeking to focus new housing development in those locations that will have regenerative benefit.

However, policy should start at second Regeneration priority areas are within the paragraph and emphasis the criterion urban area. The Hospital site approach to considering planning is allocated as a major developed site in the applications for housing development. Green Belt under Policy GB8 and Proposal Council should have sufficient flexibility to GB9 in the adopted UDP. The surplus land consider in a balanced way proposals that at Clatterbridge is not appropriate for new may come forward for development on sites general housing, being isolated from the outside the urban area that offer significant urban area and services such as schools regenerative benefits. and shops.

Criteria (b) and (c) should be modified such The intention of the Interim policy is to that all applications for planning permission prevent further units being granted planning are considered on their merits. As worded, permission in areas outside HMRI and the policy suggests a general presumption other regeneration priority areas. As the in favour of the renewal of extant planning Interim Policy is a material consideration, permissions even where they may be planning applications will be considered unacceptable against current planning against the development plan and if policy advice and guidance. necessary other material considerations, including national planning advice. Suggest additional criterion:

‘New housing development would form part of a regeneration scheme offering substantive social, environmental or economic benefit to the local area and its residents, or it is demonstrated that such

Wirral Interim Planning Policy for New Housing Development 36 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments development is necessary to allow the continued viable operation of an existing service provider or significant employer of the borough’s residents.’

Such a criteria will provide for continuing investment and retention of existing employers offering economic benefit and continued opportunity for the residents of the Borough. Where necessary, sites capable of fulfilling this criterion can be identified through the LDF.

56 Wirral Society (David Casement) Welcome draft policy as essential corollary to west Wirral restraint policy. The 2003-based Urban capacity study has Authority needs to work closely with local been completed (see Wirral website LDF communities. Urban potential studies to be evidence base): completed. http://www.wirral.gov.uk/ldf/ldfeb.asp Society wishes to see SPD on flat development completed as soon as possible.

Share Bromborough residents concerns at boundary within Bromborough ward. Accepted, boundary to be reviewed.

57 Wirral Wildlife Trust (Dr Hilary Ash) Generally support policy. Established Accepted, boundary to be reviewed. residential areas in Bromborough ward should be excluded from regeneration area

Wirral Interim Planning Policy for New Housing Development 37 Report of Consultation No1. Organisation/Individual Consultation Response Director’s Comments

Concerned that development in HMRI and regeneration priority areas should incorporate adequate high quality greenspace.

58 Mrs Gill Wollers Welcomes extension of restraint to east Accepted, boundary to be reviewed. Wirral. However, established residential areas in Bromborough ward should be excluded from regeneration area.

Wirral Interim Planning Policy for New Housing Development 38 Report of Consultation