Planning Committee 24th November 2020
APPLICATION NUMBER: P/2017/0254/OUP PROPOSAL: Outline Planning application with all matters other than access reserved for the development of the site for up to 167,225 square metres of B8/B2 (up to 20% B2 floor space), ancillary office and associated site facilities floor space, car parking, landscaping, site profiling, transport, drainage and utilities infrastructure. LOCATION: Land to the North East of the A580 East Lancashire Road / A49 Lodge Lane, Haydock WARD: Haydock Ward APPLICANT: Peel Investments (North) Ltd CASE OFFICER: Melanie Hale RECOMMENDATION: See section 9
1. BACKGROUND
1.1 This application was submitted and made valid on the 21st March 2017. Agreements were reached with the applicant on a timescale for determination up until the 21st June 2020, where time extensions were requested and agreed. The time taken to deal with the application to this point was due to a number of issues, but primarily over the adequacy of the transport assessment. However, the applicant notified the Council of the intention to submit an appeal on the grounds of non-determination of the application on the 3rd July 2020 (see letter attached). The Council was notified of the start date of the appeal by the Planning Inspectorate on the 11th August 2020.
1.2 At the time of the appeal, the applicant had recently submitted a substantial amount of information, revising the Environmental Statement, the parameter plan, green infrastructure mitigation plan and had provided updates to a significant number of the documents. The submission was the subject of consultation and publicity by the Council. Not all of the technical consultee responses were received at the time of the appeal, as in part, it was during the height of lockdown. Your officers do not accept that the application could have been determined more quickly. This position is accepted by the applicant. Correspondence from the applicant to the Council at the time acknowledged the efforts of officers in dealing with the application but that an appeal on grounds of non-determination was made so that the proposals could be considered at the same time as other schemes currently before the Secretary of State.
1.3 Members will recall that the planning committee resolved to grant planning permission for Parkside Phase One and Parkside Link Road at the meeting held on the 17th December 2019. The applications were subsequently recovered for determination by the Secretary of State. A public inquiry is to be held early next year. The appeal on non-determination of this scheme has also been recovered by the Secretary of State and will be considered alongside the Parkside proposals in
P/2017/0254/OUP Planning Committee 24th November 2020
addition to developments in Wigan and Bolton. A public inquiry is scheduled to be held in February 2021.
1.4 The Council has to determine the position it will take at the appeal and consider what decision would have been reached had the Council remained as the determining authority. This report sets out the relevant considerations and makes a recommendation within this context.
2 APPLICATION SITE
2.1 The application site is commonly referred to as Haydock Point. It is 42.3 hectares (ha), irregular in shape and used for arable farmland. It is in the Green Belt. The site is relatively flat and open. An overhead electricity line runs through the centre alongside a watercourse. The existing access into the site is from the A49, in the form of a single width hardcore track.
2.2 The watercourse runs east-west and divides the site into two areas. The southern area adjoins the A49 Lodge Lane and runs parallel with the M6. An area of arable farmland separates the northern area of the site from the A49 by around 400m.
2.3 Haydock Park Racecourse lies to the north of the site where a tree band/woodland separates the two. The residential street, Haydock Park Gardens and a hotel are located around 300m and 190m respectively to the north east of the site. A tree band/woodland lies in between.
2.4 A woodland and an area of arable land lie to the east of the site. The southern boundary adjoins the A580 East Lancashire Road. The M6 Junction 23 ‘Haydock Island’ is located to the south east of the site. Beyond the A580 to the south lies an area of farmland and a brain injuries rehabilitation centre.
3. PROPOSAL
3.1 This application seeks outline planning permission with all matters other than access reserved for the development of the site for up to 167,225 square metres of employment floor space within use classes B8 and B2 (up to 20% B2) with ancillary office and associated site facilities, car parking, landscaping, site profiling, transport, drainage and utilities infrastructure.
3.2 Access would be taken direct from the A580 by introducing a three-way signalised junction approximately 550m to the east of Haydock Island. The A580 would be modified to introduce dedicated left and right turn lanes on the eastbound and westbound carriageways respectively. Access is also proposed onto the A49 Lodge Lane approximately 300m north of Haydock Island. Access would be via a three- armed roundabout. The section of the A49 between the proposed site access roundabout and Haydock Island would be stopped up in a southbound direction preventing access to junction 23 helping to facilitate a future improvement scheme.
3.3 The parameter plans show details of a newly created road, footway and cycleway within the site. The proposal is for the site spine road to provide a route for a
P/2017/0254/OUP Planning Committee 24th November 2020
realigned northern arm of the A49 through the application site, via the two new junctions, to provide unhindered access between the A49 and the A580 thus delivering an operational improvement to J23 for all road users. An area of safeguarded land for the realignment of the A49 along the site spine road is also shown, to be dedicated to the Council to enable unhindered delivery of the scheme.
3.4 The parameters plan divides the site into two development parcels, north and south, divided by the central watercourse. Vertical no build zones are shown to be located adjacent to the development parcels and a landscape buffer zone runs around the periphery of the site. The parameters plan set out that the maximum floor space of the development would be 167,225 square metres with a maximum building height of 21.5 metres to the ridge or 60.15 above ordnance datum (AOD).
3.5 At the outline stage, the applicant must demonstrate (in principle) how the site could be developed acceptably. Two illustrative masterplans show how the site could be developed as per the parameters plan should planning permission be granted. Both plans show how the maximum floor space could be provided across 3 units as follows.
Illustrative Masterplan Option 1:
Unit No Floor Area (square metres) Total Floor Space (square metres) 1 83,909 87,172 2 33,008 40,026 3 33,008 40,026
Illustrative Masterplan Option 2:
Unit No Floor Area (square metres) Total Floor Space (square metres) 1 83,909 87,172 2 23,383 30,181 3 22,298 29,096
3.6 The main difference between the plans is that units 2 and 3 have a smaller footprint in option 2, where the layout shows a cross docked arrangement (access for HGV’s on both northern and southern elevations of the proposed buildings).
3.7 The parameters plan shows a landscape zone located around the perimeter of the site. It would have a minimum depth of 15 metres of woodland planting on the northern, eastern and western boundaries using at least 95% native species, as well as grassland meadow, scrub and reed beds elsewhere. An ecology corridor would be located through the centre of the site around the watercourse. This is reflected in a Green Infrastructure Mitigation Plan. Should planning permission be granted a condition to ensure that development is carried out in accordance with the parameters plans will need to be attached, to ensure that what has been assessed is secured in any consent.
P/2017/0254/OUP Planning Committee 24th November 2020
3.8 The proposals include a new 3 metre footway/cycleway along the northern side of the A580. This will connect the existing cycle lane at Haydock Island to the A580 site access junction. Controlled crossing facilities are proposed at the A580 site access and will provide a link to the southern side of the A580 where there is an existing footway.
3.9 The application also proposes site re-profiling works on a balanced cut and fill basis to form site levels necessary for the development of the buildings and their associated infrastructure. Around 250,000 cubic metres of material would be re- profiled.
Application History, Supporting Information & Documentation 3.10 As stated above, the application was submitted in March 2017. The proposal comes under schedule 2 development under the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (as amended) and an Environmental Statement (ES) accompanied the application.
3.11 Further information and an addendum to the ES was submitted in January 2018. A further substantial submission was put forward in June 2020, including a second addendum to the ES. The application is accompanied by the following information:
• Updated parameter plans and 2 illustrative masterplans • Updated site access plans • Planning Statement (updated) • Alternative Sites Assessment (updated) • Economic Statement (updated) • Environmental Statement including non-technical summary, main report, technical appendices and figures/plans • Environmental Statement Assessment Addendum (including the above) • Environmental Statement Addendum 2 (including the above) • Sustainability and Energy Statement (updated) • Design & Access Statement (updated) • Agricultural Land Classification and Soil Resources Report • Statement of Community Engagement
Planning Statement
Strategic Policy Drivers Update & Growth Ambition for the Liverpool City Region 3.12 The applicant states that there are a number of policy drivers that reflect the growing support for the expansion of the logistics centre. These include Northern Powerhouse; Transport for the North; Liverpool City Region Growth Strategy; SuperPort; Atlantic Gateway; St Helens Growth Strategy; City Growth Plan; and the Draft Liverpool City Region Strategic Housing and Employment Land Market Assessment (SHELMA)
3.13 The applicant describes this as a ‘game changing’ sector for the Liverpool City Region (LCR) and one which will play a critical role in fulfilling many of its social and economic objectives. The LCR will benefit from the significant investment in
P/2017/0254/OUP Planning Committee 24th November 2020
Liverpool2 which can be a genuine catalyst for the realisation of the logistics sector’s full growth and economic potential. Capitalising on this opportunity requires the provision of new, high quality distribution floorspace of a size and format to meet the needs of major national and regional logistics operators.
3.14 The applicant explains that at a national level, the Government’s goals and expectations for economic growth remain clear and provide an important and positive investment context for the North West region, built around an aspiration to create a nationally resilient economy. The Government continues to recognise that ‘improving productivity is vital to building an economy fit for the future’. Boosting productivity and earning power throughout the UK represents the central aim of the Government’s Industrial Strategy White Paper.
3.15 The Industrial Strategy explicitly seeks to transform the country’s economic geography through investment in infrastructure. The applicant states that this requires a more geographically balanced approach which links up people and markets to attract and target investment
3.16 The critical economic ambitions for the North, Liverpool City Region and St Helens and weight of strategic policy behind the growth and expansion of the logistics sector provides the strategic context to the proposed development and the opportunity it presents.
Evidence of Employment Land Need 3.17 The applicant states that significant land needs to be released from the Green Belt to meet the employment land requirement identified through the employment land need studies. This is reflected in the proposed release of numerous sites from the Green Belt and their development during the development of a new local plan. Members will be aware of grants of planning permission at Florida Farm North and Haydock Green (Penny Lane); and Council resolutions to grant planning permission at Parkside Phase One, Parkside Link Road and Omega West. In addition, the Secretary of State has recently refused planning permission for the redevelopment and expansion of the Eddie Stobart distribution centre at Appleton Thorn, Warrington.
3.18 It appears to be the applicant’s case that previous recent decisions are material considerations because there should be consistency in administrative decision making. Members should therefore have in mind the recent decisions regarding logistics development in the Green Belt, although such previous decisions are not technically binding on the Council. It is nonetheless good practice to give reasons if reaching a decision on an issue which has previously been considered, such as the level of overall need.
3.19 The applicant submits that meeting the employment land requirements is deemed to constitute the basis of very special circumstances to justify development in the Green Belt, as reflected in the positive determination of applications in the Green Belt (in St Helens) to date. That a site which a landowner or developer may seek to bring forward at a point in the near future benefits from a draft allocation in the St Helens Borough Local Plan Submission Draft should have no bearing on the acceptability of
P/2017/0254/OUP Planning Committee 24th November 2020
the current scheme. There is no basis for determining that any such sites are sequentially preferable as a point of principle.
3.19 Significant weight should be placed on clear demand and market signals from both a quantitative and qualitative point of view (including the location and size of sites and individual units). The recent high levels of delivery in Warrington and St Helens over the last 2 to 3 years, present a clear indicator that demand (and therefore need) is substantially higher than the Council’s evidence, which continues to use past trends as its starting point, would indicate.
3.20 Notwithstanding this, the applicant states that if future baseline need were to be based on past take up between 1998 and 2008, the residual unmet need would increase to 155.63 hectares with no non-Green Belts available to deliver this requirement and no sites with a more favourable adopted policy designation than the subject site. At 42 hectares, the application site would deliver only a proportion of this need, with a residual need remaining.
3.21 The applicant therefore submits that there is an overwhelming need for the proposed development by reference to the Council’s most recent employment land evidence.
Green Belt 3.22 The applicant states that the proposal is inappropriate development in the Green Belt and will cause substantial harm by definition (applying national policy). It should only be permitted in very special circumstances, in accordance with national and local planning policy.
3.23 The extent and type of harm to the Green Belt set out by the applicant can be summarised as follows.
3.24 The applicant states that the impact of the development on the openness of the wider Green Belt is not considered insignificant, but the site’s physical context reduces the visibility of the development and its perceived impact on the openness of the wider area from publicly accessible areas.
3.25 The development will have a limited direct impact on the ability of the wider Green Belt function in this area to be retained on a permanent basis.
3.26 In terms of the purposes of the Green Belt:
Purpose 1 – Preventing Sprawl: The development is a form of sprawl from which a significant impact will arise. However, the impact on the wider area is reduced as a result of strong, defensible boundaries. The development will not weaken the boundary between the developed area and the remaining undeveloped part of the Green Belt. There is moderate harm.
Purpose 2 – Preventing Neighbouring Towns from Merging: The site is on part of the land which forms a gap between Ashton-in-Makerfield, Golborne, Haydock and
P/2017/0254/OUP Planning Committee 24th November 2020
Newton-le-Willows. The development will reduce the scale of the gap and the extent of separation, however a significant gap will remain. There is low harm.
Purpose 3 – Safeguarding the Countryside from Encroachment: The development is a form of encroachment and will have a direct and significant impact on the site and fulfilment of this purpose. However, the site has strong, defensible boundaries as stated above. There is an opportunity to reinforce these boundaries through additional tree planting to be implemented as part of the proposed landscape strategy. Encroachment will not be ‘unmanaged’ therefore. There is moderate harm.
Purpose 4 – Historic Towns: None of the surrounding settlements are historic towns and so the Green Belt does not perform this purpose. There is no harm.
Purpose 5 – Assist in Urban Regeneration: Whether an area of Green Belt performs this function depends on the circumstances including whether the development needs of the Borough can be met through entirely the development of sites within the urban area. There is a significant quantitative and qualitative need for the large-scale logistics facilities with direct access to the strategic road network in St Helens. There are no non-Green Belt sites that are capable of accommodating this need. The site does not perform a specific function in assisting in urban regeneration. There is no harm within this context.
3.27 The applicant acknowledges that there is a consideration of other harm in the planning balance. The application is supported by an Environmental Statement (ES) that has considered the impact of the development in isolation and cumulatively alongside other relevant developments.
3.28 No or negligible adverse impact will arise with suitable mitigation measures in respect of archaeological value; local air quality; geology, soils and contamination; transport and traffic generation, traffic impact and highway safety; local noise and vibration conditions; and on the water environment, including site and local flood risk.
3.29 The applicant states that the ES identifies two areas where the adverse impact of the development would be greater than negligible.
3.30 There would be a moderate to minor harm to the landscape, during the construction phase and minor adverse impacts during the operational phase, reducing over time as the site landscaping matures. In terms of visual impact, there would be a moderate impact on public views and moderate to minor impact on private views. For the operational phase, the impact on public views would be moderate to low adverse impact and for private views, a moderate adverse impact reducing to minor adverse/negligible over time with maturing landscaping.
3.31 The applicant states that the development would have an adverse impact on wintering bird species, but they will be able to utilise other farmland in the Haydock area for feeding etc. The overall harm will therefore be limited.
P/2017/0254/OUP Planning Committee 24th November 2020
3.32 A total of 22.8 hectares of the site is classed as best and most versatile (BMV) (grade 3a), where the remainder is 3b. The applicant states that this is the lowest grade of BMV and there are a relatively low number of days that the land can be worked by machinery. The applicant states that the resultant harm would be limited.
3.33 Overall, the applicant states that considerations that weigh in favour of the proposed development are as follows:
• Clear strategic level policy compliance at both the national, pan-regional; sub- regional and local level that would respond to a specific growth opportunity which St Helens can benefit from; • Significant direct and indirect local economic and employment benefits; • Meeting the evidenced quantitative and qualitative unmet need for logistics floorspace in the Borough; • Responding to live and current occupier demand and undersupply of strategic logistics sites in the market areas and ability to attract this investment into the Borough; • Enhancement to the overall ecological value of the site; • Improvement to the site’s drainage management and improvement to the water environment and flood risk regime downstream; and • Absence of suitable and viable non-Green Belt sites to meet the identified need for logistics development which has been identified.
3.34 The applicant states that the test presented in paragraph 144 of the National Planning Policy Framework (NPPF) (2019) states that very special circumstances will not exist unless the potential harm to the Green Belt by reason of its inappropriateness, and any other harm, is clearly outweighed by other considerations. It should be noted that the NPPF requires that local planning authorities should give substantial weight to any harm to the Green Belt. The applicant therefore submits that in the absence of any greater harm than that reported in the planning statement, and reflecting the scheme’s significant benefits and the evidenced need, very special circumstances exist to justify development in the Green Belt.
3.35 The applicant states that the development complies with the development plan and the NPPF such that a grant of planning permission is appropriate.
Alternative Site Assessment (ASA)
3.36 The applicant has considered alternative sites across St Helens which may be capable of accommodating a large scale logistics facility as the proposed development. They have used a four-stage methodology as follows:
1. Minimum site requirements (including motorway access, topography & flood risk); 2. Site suitability (including access to public transport, labour market, proximity to sensitive uses and environmental sensitivity);
P/2017/0254/OUP Planning Committee 24th November 2020
3. The extent to which the alternative sites meet purposes 1, 2 and 3 of the Green Belt; and 4. Deliverability assessment (including scale, availability, ownership, access and constraints).
3.37 The applicant has identified sites in accordance with the following criteria:
• Sites of more than 12 hectares (this is much lower that the application site, but enables the scope to include disaggregated delivery of the development); • Any sites that have planning permission for logistics floor space; • Allocated sites in the local plan; • Brownfield land identified in the Allocations Plan Employment Evidence Base Paper; • Sites submitted through previous ‘call in’ exercises; • All sites proposed for application in the St Helens Borough Local Plan Submission Draft (2019), with the exception of allocation 1EA Omega which will meet employment need in Warrington; and • The ASA undertaken as part of the Parkside Phase One planning application.
3.38 The applicant states that no non-Green Belt sites advanced beyond stage 2 of the ASA methodology with a total of seven sites being assessed from stage 3 onwards. When assessed against the purposes of the Green Belt, only 3 sites progress to stage 4: Florida Farm North; Parkside Phase One; and land to the north of Penny Lane. This does not include the application site. However, the applicant argues that this is as a result of the methodology and that the broader Green Belt contribution of the site is overstated, particularly given its containment. The applicant does not agree with the assessment and believes that the site should also move forward to stage 4. It is recognised, however that the Council’s evidence base shown the site scores as ‘red’ and this is accepted.
3.39 The applicant argues that applying the Council’s conservative estimates of employment land need, there is a requirement for 198.17 hectares of employment development to 2035. The three sites stated either have planning permission or a positive resolution and would provide 151.04 hectares of employment development. As there is a shortfall of 47 hectares, the three sites to progress to stage 4 cannot be relied upon alone.
3.40 The applicant states that the assessment presented represents a change to the initial ASA which resulted in sites in excess of 250 hectares progressing to stage 4. On this basis, all seven sites are progressed to stage 4.
3.41 The deliverability assessment is based on the following criteria:
• Site area • Market availability • Access to the strategic road network • Physical and environmental constraints • Ownership
P/2017/0254/OUP Planning Committee 24th November 2020
• Third party constrains • Public access • Policy constraints
3.42 Two of the seven sites are deemed not to be able to accommodate the development and classified as ‘red’. The remaining sites achieve an ‘amber’ score. The applicant submits that the application site performs strongest achieving a ‘green’ score in all but one of the criteria. An amber score was given as a result of the Green Belt location. The next strongest performing sites achieve a ‘green’ score in six of the eight categories (Parkside Phase One and Haydock Green).
3.43 The applicant thus concludes that there are no sequentially preferable alternative sites available that are capable of meeting the identified need for logistics development. The application site performs strongest against the overall assessment framework.
Economic Statement
3.44 The applicant states that the UK logistics market is growing and evolving. Operators require larger premises to accommodate national and regional distribution centre facilities, generally in excess of 500,000 square feet. To optimise efficiency, manufacturing related warehousing needs to be located close to a manufacturing plant. Historically, the ‘golden triangle’ area of the Midlands (between the M1, M6 and M42) has been the preferred location for logistics operators, but this is changing. The north west is positioned favourably to capture a greater share of growth in the sector.
3.45 The concentration of population and businesses in the metropolitan areas of the north west and the planned strong growth, means that the region provides an attractive proposition to logistics operators. There is a need for approximately 5 million square feet of accommodation annually.
3.46 The applicant states that CBRE has examined market evidence of the demand for logistics floor space along the M6 corridor in the North West. Current demand for grade A floor space (for 2019) is at 3.22 million square feet. This highlights the continuing strength of the market.
3.47 The applicant submits that the available supply of grade A floor space at March 2020 can only accommodate 16 months of demand. Supply is lagging behind market demand. Immediately available units of 300,000+ square feet are in short supply with only one unit of 375,000 square feet available in Bolton. The future supply pipeline of grade A space offering in excess of 300,000+ square feet is also diminished, comprising 654,000 square feet in two planned units.
3.48 CBRE concludes that the demand for ‘XXL’ warehouses cannot be met by current stock availability. Haydock Point can provide buildings of this size, filling the gap in the market. There is growing demand in the region for in excess of 500,000 square feet. Haydock Point provides an opportunity to meet market demand for larger premises.
P/2017/0254/OUP Planning Committee 24th November 2020
3.49 CBRE reports that there is limited availability of ‘oven ready’ logistics sites within the M6 corridor. The sites cannot accommodate a building of 1 million square feet. Haydock Point will be able to accommodate a single unit of just under 940,000 square feet.
3.50 Haydock Point can meet the requirements for eaves heights of 15 metres or more. It is close to junction 23 of the M6, providing occupiers with the opportunity to minimise operational costs associated with travel to the strategic highway network.
3.51 There is a clear evidence of the need for new logistics land and floor space within the Liverpool City Region and St Helens Borough, as per the evidence base for the emerging local plan. It is estimated that 632 hectares will be required to accommodate logistics and manufacturing demand for SuperPort, excluding port- based uses.
3.52 The economic evidence base for the Local Plan identifies large scale logistics development as a key opportunity as a result of the strategic location on the M6 and the demand generated by SuperPort.
3.53 The Employment Land Needs Study (ELNS) concludes there is a need for 177-214 hectares of employment land over the local plan period. The largest component of employment land growth is anticipated to be in the B8 Storage and Distribution sector accounting for 60 to 70% of land growth. An expansion of Haydock industrial area is specifically noted as offering the potential to attract logistics operators.
3.54 An Addendum Report to the ELNS dated January 2019 revised the total employment land needs for the borough upwards to a range of 190-239 ha. This revision was made taking into account the latest evidence from the Liverpool City Region Strategic Housing and Employment Land Market Assessment (SHELMA), and other market demand information which highlights the growth potential of demand for large-scale logistics.
3.55 The Local Plan evidence base recognises that there is a positive relationship between investment in the logistics infrastructure of the Borough and the ability to attract manufacturers. There are competitive advantages to be realised by businesses in logistics and manufacturing co-locating or being proximate to one another.
3.56 The baseline conditions in St Helens' economy and labour market demonstrates that there is a need for Haydock Point and the benefits that it will create. For example, economic activity rates are relatively low in the Borough and the unemployment rate is high. Recent events surrounding the Covid-19 pandemic have meant that local economies across the UK, including that of St Helens, are being negatively affected. St Helens is one of the most deprived areas in the country being ranked 26th of 317 local authorities in England, with deprivation a more significant issue now than it was in 2015. Employment and health related matters are significant contributors to deprivation. Haydock Point is located close to areas which are ranked within the 10%
P/2017/0254/OUP Planning Committee 24th November 2020
most deprived neighbourhoods in the country and where employment related deprivation is a principal cause of deprivation.
3.57 The applicant states that Haydock Point will generate a series of social and economic impacts that will positively and significantly address socio economic needs in the Borough. Up to 265 jobs will be created per year over the 5-year construction period. Construction jobs will provide a range of different opportunities by occupation with full time employees typically earning between circa £21,519 and £45,800 every year. A range of apprenticeship opportunities will be available during construction. Businesses in the construction supply chain will also benefit from contracts and associated employment.
3.58 When completed and occupied, the applicant submits that the development will support between 2,286 and 2,758 gross full time equivalent (FTE) jobs on site. The development will provide job opportunities in a range of occupations with average earnings potential between £21,402 and £42,047 per annum. The applicant states that they are committed to ensuring that occupiers prepare local employment strategies to maximise opportunities for local people to access job opportunities.
3.59 The applicant states that the proposed development will generate approximately £3.5 million business rates revenue per annum, of which under current arrangements 50%, or £1.75 million, could be retained by the St Helens Council.
3.60 A Draft Local Employment Strategy (LES) has been prepared that ensures that the benefits for local people and businesses are optimised during each phase of the development. A range of local partners have already been engaged, including the St Helens Chamber and St Helens College who would both be key partners in forming a “Local Employment Partnership (LEP)” for the development. The LES could be secured through a Section 106 agreement.
Environmental Statement
3.61 The content and findings of the submitted Environmental Statement (ES) can be summarised as follows.
Phasing and Delivery A phasing and delivery plan would be prepared as part of a construction environmental management plan (CEMP). The applicant states that the likely phasing will be for the southern plot to de developed first, followed by the northern plot.
The proposed development is expected to be operational in 2025, although an assessment year of 2024 has been used in the assessments. The applicant states that this provides a worst case approach and will support a robust assessment of the proposed development.
Socio-Economics 3.62 The applicant states that the construction phase will generate an annual net additional £23.5 million gross value added (GVA) within the North West region. A
P/2017/0254/OUP Planning Committee 24th November 2020
total of 2,139 gross direct FTE jobs will be supported on-site once operational. A total of 2,407 direct, indirect and induced FTE net additional jobs will be supported by the proposed development once operational. A net additional £110 million GVA will be generated annually within the North West region by the proposed development once operational.
Transport 3.63 The applicant states that the proposed development would be accessible by walking, cycling and public transport. They say that the site is ideally located for a high-quality logistics park, being sited adjacent to the A580 and the M6 motorway.
3.64 The site will assist in enabling the delivery of a wider package of mitigation works at M6 Junction 23. The proposed improvement scheme is being brought forward by Highways England and St Helens Council in consultation with Wigan Council and with the support of consultant WSP. The works require the removal of the northern A49 north arm of the junction to be delivered. The proposal will assist in delivering this aspect of the improvement scheme by providing a new link between the A49 and the A580.
3.65 The applicant states that the accessibility of the site will be enhanced through the provision of a shared footway/cycleway along the northern side of the A580 between the site access and M6 Junction 23, together with controlled crossing facilities at the A580 access junction. A segregated footway cycleway will be provided along the proposed link road through the site, connecting the A49 and A580.
3.66 During construction, the applicant states that the development will have a short-term neutral effect. During the operational phase, the significance of effect on driver delay, public transport users, pedestrian delay, fear and intimidation, accident and highway safety and severance are all classified as long term neutral. The impact of the proposed development on pedestrian delay and pedestrian amenity is concluded to be long term beneficial by virtue of the improvements proposed along the A580 and additional linkages provided by the proposed link road through the site.
3.67 The applicant has considered the inter-project cumulative effects. Whilst there is the potential for the construction phase of committed developments to overlap, any such impact would only be experienced in the short term and would be expected to be short term neutral to minor
3.68 A Construction Environment Management Plan, Delivery Management Plan, and Travel Plan will all be provided to further minimise the impact of the development during the construction and operational phases.
3.69 The applicant states that a delivery management plan will be prepared and implemented by each occupier once known. This will provide the Council with a mechanism to ensure that future occupiers to guide the management of logistics at the units. The plan will need to be prepared by each occupier and tailored to their specific needs, but to be agreed with the Council.
P/2017/0254/OUP Planning Committee 24th November 2020
Ecology 3.70 The applicant states that an updated habitat survey confirms that the site conditions remain broadly the same as reported in the original submission, with the following small changes: • New areas of tall ruderal herb and fly tipping in the westernmost corner of the site. • New area of bare ground and spoil in the centre of the site. • Young oak trees at the margins of the site are now mature enough to map as scattered trees. • Area of marshy grassland in the eastern part of the site has reduced in size and been replaced by tall ruderal herb and modified neutral grassland.
3.71 The site consists of two large arable fields, separated by a ditch which flows from west to east. Neighbouring the site on the eastern boundary is Haydock Park Woods, designated as a local wildlife site (LWS). Lady’s Hill Plantation, also east of the site, is a potential LWS. The nearest Site of Special Scientific Interest (SSSI) is at Highfield Moss 2.7km south east. The nearest European protected site is the Manchester Mosses Special Area of Conservation, 9.5km east.
3.72 The central ditch supports water voles, a species protected by the Wildlife and Countryside Act, 1981. There are no European protected species on site. Trees in the neighbouring LWS have features which support bat roosts and bats forage over the site, particularly along woodland edges and the central ditch corridor.
3.73 The applicant states that the site has little botanical or faunal value, other than for water voles. A boundary hedgerow lining the ditch is a ‘s41 habitat’ for this reason and is given priority under s41 of the Natural Environments and Rural Communities Act (NERC). The site is used by a range of farmland birds, some of which are s41 birds, but a preliminary ornithological assessment suggests that breeding species diversity and population numbers are relatively low. Overwintering bird surveys indicate that the site is regularly used by a flock of lapwing, which are s41 species. The lapwing population is of local significance, but the site is not linked to the Mersey Estuary Special Protection Area lapwing population.
3.74 The adjoining LWS woodlands, the central ditch corridor and parts of the A580 verge are local components of the Liverpool City Region Ecological Framework.
3.75 The applicant states that the development would result in the loss of about 40 ha of farmland, mostly in arable use and of negligible ecological value. Some field margins and areas of permanent neutral grassland would be lost. Some broadleaved trees would be lost at the A580 to form the new site access. There would be two road crossings over the central ditch corridor. A footpath/cycleway would be created in the existing A580 verge grasslands.
3.76 The proposed development includes several habitat-creation measures which are embedded into the scheme design / development parameters, intended to protect and enhance ecological features on the site and adjoining land.
P/2017/0254/OUP Planning Committee 24th November 2020
3.77 The water vole colony would be protected through a mitigation strategy. This includes construction-stage protection works, ditch habitat enhancements and longer-term habitat management and monitoring.
3.78 The overwintering lapwing population would be displaced from the site. In terms of the balance of ornithological interests, other bird species would benefit from the range of new woodland and grassland habitats to be created in the site.
3.79 The applicant states that the net effect of the habitat creation measures, including new woodland, meadow grassland, reedbeds and swales will be to significantly increase the extent and connectivity of habitats of local value, compared to baseline. These measures will also ensure the protection of the adjoining LWS. The net residual effect on ecological features important in the context of the Liverpool City Region, will be positive.
Archaeology 3.80 The applicant states that the baseline historic environment conditions comprise two grade II listed buildings within 1 kilometre of the site; one non-designated heritage asset within the site; and 49 non-designated heritage assets within the buffer of 1km from the site boundary.
3.81 The one non designated heritage asset within the site is Haydock Park. Haydock Park is a former medieval hunting ground. It has low heritage significance because it is not well preserved.
3.82 The site has a low potential for the presence of as yet unknown heritage assets with archaeological interest dating from prehistoric to modern periods.
3.83 The applicant submits that the proposed development would have a negligible impact on the identified heritage assets comprising Haydock Park, part of a former medieval deer park, of low heritage significance. Although there are no surviving elements evident on the ground, construction phase activities do have the potential to affect as yet unknown surviving archaeological evidence, or with other as yet unknown heritage assets, that could be present.
3.84 The applicant therefore states that the asset is of low heritage significance. The predicted magnitude of impact, based on a realistic worst-case scenario, is moderate adverse. The significance of effect is therefore predicted to be low adverse. A programme of archaeological mitigation is proposed that would provide a record of any heritage assets that could be affected by construction. There would be no direct or indirect effects on any designated heritage assets as a result of the proposed development.
Landscape Character/Visual Amenity 3.85 The applicant states that the landscape effects resulting from changes to the physical landscape as a result of a proposed development which may give rise to changes in important characteristics and thus its character, and how this character is experienced. Visual effects relate to the changes that arise in the composition of
P/2017/0254/OUP Planning Committee 24th November 2020
available views as a result of a proposed development, people’s responses to the changes, and the overall effects on visual amenity.
3.86 The applicant states that indicative landscape strategy plans set out the suggested approach that would be taken to detailed planting proposals to deliver effective mitigation within the landscape zone to the site’s edge. The proposal comprises native woodland or woodland edge planting to a minimum depth of 15m to the majority of the site boundary. Part of the boundary with the A580 would be planted with scattered native standard tree planting with some large trees. There would be hedgerow planting adjacent to the acoustic fence and individual parkland trees in the wider area.
3.87 Other parts of the landscape zone, further into the site, would include ponds, species- rich grassland, wet grassland, reed planting, and more trees. There would be semi- mature oak and birch tree planting (up to 7m high) in woodland and woodland edge planting along the northern landscape buffer to assist in providing screening of views from Haydock Racecourse.
3.88 The application site is in the St Helens Council Local Character Area WFE2: Haydock Park. There would be a change to the landscape character as a result of the proposed development. However, the development would be in a wider landscape characterised by manmade elements including the nearby elevated section of the M6, the A580 dual carriageway and built form associated with the racecourse and the settlements of Ashton-in-Makerfield and Golborne. The design and layout of the proposed development, with its planted landscape corridors and benefitting from existing woodlands on adjacent land, would help to create a strong landscaped boundary treatment which would help to integrate the site into the local landscape and enhance woodland connectivity.
3.89 The applicant’s landscape assessment has concluded that there would be no significant residual effects from the proposed development in the wider landscape. The visual assessment shows that there would be no significant residual effects on views. There are no dwellings or public footpaths near to the site and more distant views are limited by existing woodlands. The closest views toward the proposed development would be open and oblique from a section of the A580, experienced whilst travelling, and partially screened views, experienced by visitors to Haydock Park racecourse. All other views toward the site would benefit, in the medium to long term, from the proposed extensive woodland planting along landscape corridors at the site boundaries.
3.90 The applicant has carried out a cumulative assessment, which considered the potential for combined effects from similar development sites within a 3km radius. This concludes that there would not be any significant cumulative effects on landscape or views.
3.91 Overall, the applicant states that the landscape and visual impact assessment has predicted that there will be no significant residual effects arising from the proposed development.
P/2017/0254/OUP Planning Committee 24th November 2020
Air Quality 3.92 The applicant states that dust control measures will be utilised during the construction phase, through a Construction and Environmental Management Plan. The impact of dust associated with the construction phases of the proposed development will not be significant.
3.93 The applicant states that road traffic flows were assessed within a defined study area. The impacts of vehicle emissions associated with both construction and operational road traffic of the proposed development are predicted to be not significant.
Noise 3.94 The applicant states that operational noise impacts are possible, depending on the exact nature of the operations at the site. However, mitigation is available that is capable of reducing these potential impacts to acceptable levels. The exact form of the mitigation will depend on the precise form of development and would be finalised at reserved matters stage.
3.95 Vibration impacts from the construction phase of the proposed development are unlikely. Mitigation should not be required as vibration is unlikely to be perceptible at distances of 200 metres or more.
3.96 The applicant submits that no significant effects are anticipated as a result of development-generated traffic noise, nor from building services plant installed at the site, providing it meets the identified noise limits.
3.97 The applicant states that there would be no significant cumulative effects anticipated as a result of noise from the proposed development combining with other consented schemes in the area.
Geology, Soils & Contamination 3.98 The applicant states that the potential effects of the proposed development to and from ground conditions and contamination has been assessed for both the construction and operational phases.
3.99 The construction process with respect to ground conditions includes two principal elements: site enabling works and provision of foundation structures. Desk based research has not identified any significant on-site sources of contamination associated with historical site activities that may pose a risk to human health, groundwater or surface water. Completion of the enabling works is predicted to have a negligible effect.
3.100 The provision of a piled foundation, if required, is unlikely to pose a significant risk to controlled waters and the provision of foundation structures are therefore likely to have a negligible effect.
P/2017/0254/OUP Planning Committee 24th November 2020
3.101 A Construction Environment Management Plan will be implemented through the construction process which will contain a range of environmental protection safeguards. Construction in accordance with the plan will result in the proposed development having no effects to surface water and underlying principal aquifer.
3.102 As the proposed development will largely comprise hard standing and buildings, the potential for contamination of the surface water and underlying aquifer will similarly be negligible.
3.103 The desk study report prepared by the applicant has identified that ground gas may be present and that this may pose a risk to the proposed development. Further investigations will be completed and appropriate mitigation measures will be designed into the development during the detailed design stage, as necessary.
Water Environment 3.104 The applicant states that during construction and operation, there is the potential for the water quality of the on-site watercourse to be adversely affected. The principle means of mitigating this is through the implementation of standard best practice construction methods and pollution prevention techniques.
3.105 The surface water strategy incorporates sustainable urban drainage techniques and as a result, surface water run- off from the site will be restricted to greenfield rates. This means the impact downstream will be negligible.
3.106 Development of the proposed site will result in a loss of area which may have previously flooded in 1 in 100 year events. Therefore, a proposed flood compensation basin will be located within the site to compensate for the loss in flood water storage.
3.107 The applicant submits that United Utilities has stated that the existing sewer network has sufficient capacity for the potential increase in foul water effluent.
3.108 The applicant states that through the mitigation measures which are embedded into the scheme design, and the implementation of measures contained within a Construction Environment Management Plan, the effect of the proposed development during construction and operation will be neutral.
Consideration of Alternatives 3.109 The applicant has given consideration to the availability of alternative sites. This is reported in the planning statement. Consideration has also been given to alternative, on site configurations where two illustrative masterplans have been submitted to show how the site could be developed. In particular, the area to the south is shown to accommodate two units as per the floorspace set out in paragraph 3.5Whilst buildings with a smaller footprint are shown on the second plan, this is as a result of a cross-docking arrangement, rather that additional landscaping. The parameter plan does show vertical ‘no build’ zones, parameters for landscape design and ecology, the incorporation of a principal access form the A580 and the strengthening of the landscape boundary around the periphery of the site, particularly along the A580 frontage.
P/2017/0254/OUP Planning Committee 24th November 2020
Cumulative Impacts 3.110 The applicant has set out the cumulative effects of the development at the end of each section. An assessment of intra-project effects (between the relevant sections) and inter-project effects (with other identified projects) is set out.
4. CONSULTATIONS
4.1 Consultation has been undertaken on a number of occasions through the life of the development. An appropriate summary of consultation responses as they relate to relevant issues in the ES is set out below. The full responses can be viewed on the Council’s website.
Environmental Impact Assessment
4.2 Merseyside Environmental Advisory Service (MEAS) – The EIA and addendum reports satisfy the requirements of the regulations and can be used as a basis for determination of the application.
Transport
4.3 Highways England – Recommend that conditions should be attached to any planning permission that may be granted. The conditions concern the following:
• Details of the design and construction of highways improvement to M6 Junction 23 be submitted and agreed. • That the development is not brought into use until the highway improvement above has been implemented subject to a stage 3 safety audit.
4.4 Local Highway Authority (LHA) – Comments from the LHA are made by Mott MacDonald.
4.5 Merseytravel – Comments are on the original submission. Additional consultation has taken place, but no comments received.
It is to be ensured that traffic and car parking provision can be accommodated within the existing highway network without resulting in congestion that could impede bus services in the area.
The inclusion of a travel plan is welcomed, and the developer is encouraged to promote sustainable modes of travel. This should be subject to regular audit that should be fully funded by the developer and operator.
The majority of the development is more than 400 metres from existing bus stops on Lodge Lane. The developer should fund a bus service into the site for a period no less than 5 years. Three sets of bus stop pairs should be located within the site. Bus stops on Lodge Lane should be upgraded.
Appropriate access for the Merseytravel Merseylink dial-a-ride should be made.
Ecology
4.6 Natural England – No objection. Attention is drawn to the loss of 22.8 hectares of best and most versatile agricultural land.
P/2017/0254/OUP Planning Committee 24th November 2020
4.7 Countryside Development and Woodlands Officer - Further evidence is required that the development can achieve biodiversity net gain as required by the NPPF (2019). Further enhancement is required of the landscape along the diverted A49 corridor.
4.8 MEAS – A habitats regulations assessment of likely significant effects using source- pathway- receptor model has been undertaken. It concludes that there are no likely significant effects.
The updated ecological information is acceptable.
The Green Infrastructure Mitigation Plan (Michael Sparks Associates, January 2017, 30926-FE-027E) should be adopted as an approved document. Two Landscape Strategy Option drawings have been submitted (TEP, 14 June 2019). Either option is acceptable from an ecological perspective.
Whilst the Council’s Countryside Development and Woodlands Officer refers to amending the landscaping to include tree planting along the ditch corridor, from an ecological perspective, it is preferable for any tree planting within 5m of the ditch banks is avoided to prevent any potential overshading of the ditch channel. This would be detrimental to water voles.
A full landscape and habitat management plan should include complete details of management of the central ditch post-development. Undertaking the water vole mitigation strategy should be secured by condition.
Conditions in relation to the following should the attached:
• Design of proposed culverts so as not to impede the movement of water vole along the ditch. • Measures to protect water voles and their habitat from pollution should be incorporated into the proposed surface water drainage scheme. • Details of a lighting scheme to ensure that the boundary habitat and central ditch corridor remain unlit during the operational phase to protect bats and their habitat. Reference should be made to Bats and Lighting in the UK, Bats and the Built Environment Series, Bat Conservation Trust and Institute for Lighting Engineers. • A pre-commencement inspection for badgers should be undertaken as a precaution. • Mitigation measures submitted in the Common Toad Mitigation Strategy (TEP, April 2018, 5843.0108, version 1) should be accepted as an approved document. • No works to vegetation should take place between the 1st March and 31st August in the interests of protecting breeding birds. • The Landscape and Habitat Management Plans and proposed management and maintenance operations should be accepted and supplemented by the submission of a long term (25 year) management plan, habitat creation methodologies; planting schedules and species lists; and details of the management company responsible.
P/2017/0254/OUP Planning Committee 24th November 2020
• A construction environmental management plan (CEMP) should be submitted and agreed to manage and mitigate the environmental effects of the construction process.
The applicant should confirm the preferred option for a wintering bird compensation scheme to ensure that enough is provided.
Archaeology
4.9 MEAS advises that the proposed archaeological mitigation as outlined in Table 15.1 of the Environmental Statement and updated in 3.31 of ES addendum 2 vol. 1, is agreed and can be secured by condition.
Landscape & Visual Impact
4.10 Countryside Development and Woodlands Officer – The proposed development is of too large a scale to fit into the landscape. It should be reduced in scale and set further away from the A580 and Haydock Racecourse. The scale of the proposed development leaves insufficient space for the landscape design to mitigate for impacts on landscape character and openness.
Any development on site must include the cross-docking design principle to maintain greater distance between the landscape perimeter and any buildings constructed on site.
The proposed development will do lasting damage to the landscape character of the area. The proposed development will have significant visual impact with particular harm to Haydock Park Farm and Cottages and the setting of Haydock Park Racecourse. The impact on the latter could potentially have implications for the racecourse business.
It is not stated in the response, but it is worth noting that the floor space proposed here is in the region of 20% larger that the development at Florida Farm North and 55% larger than Parkside).
From a perspective of the Borough’s landscape character, north of the A580, development should not extend eastwards of the M6. In addition, the development would fundamentally change approximately. 9% of the Haydock Park Character Area.
Air Quality
4.11 Environmental Health Officer – No objections raised. The effects of the proposed development on air quality overall are classed as not significant. The mitigation measures remain the same as in the original ES. Paragraph 11.112 outlines the proposed mitigation. This includes provision of electric charging points. There is also mitigation within the proposed scheme such as cycling and walking and car share provision.
Conditions are recommended as follows:
P/2017/0254/OUP Planning Committee 24th November 2020
• Provision of electric charging points in accordance with guidance i.e. provision of at least one electric vehicle ‘rapid charge’ points and one priority parking space for hybrid and electric vehicles for ever 2000m3 of commercial floor space.
• The proposed travel plan is implemented as outlined.
• Recommendations in Table 11.22 of the ES are implemented and remain in place for the duration of the demolition/construction phase.
• On commencement of development, fleet vehicles operating out of the development should be Electric/Hybrid or Euro class VI as a minimum.
Noise
4.12 Environmental Health Officer – From a noise perspective the dominant features of the existing ambient noise environment consist of the road traffic noise associated with the operation of the A580 and the M6 motorway. There is no objection in principal to this proposal as the site is located in an area that is already significantly affected by road traffic noise. The nature of the activity to be carried out in commercial buildings is not yet fully known as they are being built speculatively and as such further detailed assessment of plant and equipment servicing the site will be required as part of the reserved matters application.
Construction phase
Noise levels from the potential construction activity have been assessed in accordance with the relevant BS5228 to indicate if any significant effect is likely to occur at noise sensitive premises. The March 2017 Environmental Statement adopted a criterion of 65dB for construction noise levels, based on the guidance in British Standard 5228. This criterion has been retained in this addendum. From the output provided in Table 12.2 the 65 dB criterion is unlikely to be exceeded at the receptors, even when construction activities are undertaken close to the site boundary without mitigation. The exception to this is levels at the racetrack at Haydock Park Racecourse, approximately 55 metres from the northern boundary of the proposed development site. However, the adopted 65dB criterion relates to the effects of construction noise on human receptors which are not present in at this location.
Overall, the output of the assessment details that construction noise associated with the development is primarily below the relevant threshold value and the impact is not considered to be significant during the daytime working hours. In order to ensure that works are only carried out within the assessed period and construction hours of operation condition is suggested.
A construction vibration assessment has been carried out with the inclusion of the additional receptors. It assesses the potential for vibration from both construction phase of the development and determines perceptible levels of vibration are unlikely. This would result in a negligible magnitude of impact and a minor to no adverse effect. However due to the reprofiling works during the construction phase, a vibration monitoring plan has been suggested to ensure no adverse levels are encountered at the nearest properties. A condition requiring full details of the vibration monitoring
P/2017/0254/OUP Planning Committee 24th November 2020 assessment has been suggested to be submitted as part of the reserved matters application.
Operational Phase
The rating level at the hotel is predicted to be 9dB above the background sound level at night, which would be considered as a moderate magnitude of impact.
At Haydock Park Gardens and the care home, the rating level at night is predicted to exceed the background sound level by 7dB, which would be a moderate magnitude of impact.
At Ashton Heath Farm, the rating level at night is predicted to be 5dB above the background sound level. This would be classed as a low to moderate magnitude of impact.
At Park House Farm, Park Cottages, White Lodge and Ashton Heath, rating levels at night would be between 2 and 4 dB above the background sound level, which would be a low impact.
All the above are residential premises but in addition the rating levels at Haydock Park Racecourse have also been considered, although the BS4142 assessment methodology does not strictly apply to this type of non-residential setting. Only the daytime period has been considered, as the racecourse does not operate at night. The Racecourse Grandstand, the rating level is predicted to be 1dB above the background sound level however at the racetrack, the rating level is 9dB above the background sound level, which would be a moderate impact if considering human/residential receptors.
The maximum noise levels associated with the proposed use are likely to relate to HGV tractor unit or shunter picking up a trailer or slamming car doors. The highest maximum noise levels associated with these events are likely to be in the region of 92dB for a shunter picking up a trailer, 86dB for an HGV tractor unit picking up a trailer, and 72dB for a car door slam, all at a distance of 10 metres.
In order to mitigate for the noise levels associated with the proposed use a variety of noise mitigation measures are included in the Environmental Statement submission and the associated parameter plan. The primary means of mitigating and controlling the noise output is the provision of acoustic barriers shown on the revised parameter plan. These barriers are proposed for the northern boundary of the site and partial barriers to the southern boundary, with both barriers at a height of 5 metres. The effectiveness of any barrier arrangement will be dependent on the ability to block the line of sight from the source of the noise to the receiver. Therefore, the layout of the site as well as the positioning of yard activities, plant and equipment will be significant in determining where a barrier needs to be positioned to be most effective. The effectiveness of any acoustic barrier will have to be reassessed if there are any layout changes at the reserved matters stage. One point of concern which will need to be addressed is the partial barrier to the southern boundary which from the information submitted suggests that the 60dB criterion will be exceeded at nearby sensitive receptors if shunters are used in the area marked out as Service Yard of Unit 2 in the two current illustrative layouts.
P/2017/0254/OUP Planning Committee 24th November 2020
Other mitigation in the form of practical noise management measures are also suggested and full details of any such measures and a demonstration of the mitigation they provide should be included with any reserved matters submission. Therefore, due to the further assessment of all the mitigation put forward a condition requiring an updated noise assessment has been requested with any reserved matters submission.
A road traffic noise assessment is also contained within the report assessing the traffic noise output associated with the alterations to the A49 as well as the addition of the estate road. The noise levels associated with the operation of the development as predicted forward to 2041 is considered negligible.
On balance and given all the information provided regards the noise impact of the development, subject to comprehensive proposed mitigation being put in place, the proposal would not give rise to levels that would indicate significant observed adverse effects such that the application is supported, provided that conditions relating to the following are attached:
• Hours of construction • No temporary power plant to be used outside permitted hours unless otherwise agreed • No external plan or equipment shall be permitted and no additional openings formed without the consent of the local planning authority • Submission of an updated noise assessment to specify the noise emanating from the site and the required mitigation measures, in line with the conclusions of the Environmental Statement • Submission and implementation of an operational noise management strategy • Submission and implementation of a vibration monitoring strategy
Water Environment
4.13 Environment Agency – No objection raised. The removal of the existing failing culvert and its replacement with a suitably sized culvert is acceptable in principle. The development is acceptable if planning permission is subject to conditions requiring following:
• The submission, agreement and implementation of a scheme for the management of an 8-metre buffer zone along the water course; and • The submission, agreement and implementation of a scheme to protect water voles.
4.14 Lead Local Flood Authority (LLFA) – Following the submission of further information ‘2018.04.13 Summary Changes to Haydock Point FRA and DS’, the holding objection is withdrawn, and no objection is raised. Requirements for Suds should be met as part of any future application.
4.15 United Utilities – a large pressurised trunk main crosses the proposed development. United Utilities will not allow any building over with within close proximity to this pipeline. There must be no additional load placed on the strategic water asset and
P/2017/0254/OUP Planning Committee 24th November 2020
associated access during or after construction. United Utilities must have reasonable access.
The applicant should comply with standard conditions as follows:
• A construction risk assessment method statement should be submitted and agreed. • Foul and surface water should be drained on separate system • A surface water drainage scheme based on the hierarchy of drainage options shall be submitted and agreed. • Any sustainable drainage system should be accompanied by an appropriate management and maintenance system.
Contaminated Land & Stability
4.16 Contaminated Land Officer - No objection subject to conditions to secure a phase 2 site investigation, development and implementation of an agreed remediation strategy if required, and submission of a site completion/validation report.
4.17 Coal Authority – no objection.
Sustainability and Low Carbon Energy
4.18 MEAS states that the Sustainability and Energy Report Update (Turley ref: PEEM3055 dated May 2020) indicates that the development will meet BREEAM very good standards with the aim of achieving excellent. This is welcomed.
The Energy Strategy for the development prioritises investment in airtight and energy efficient buildings aiming to reduce carbon emissions by 10%. Provision will be made for solar thermal cells for heating office hot water and photovoltaic cells for electricity meeting 10% of the site’s requirements. Overall the combined energy strategy should result in at least 15% carbon savings. This information is sufficient to comply with part 4 of policy CP1 of the St Helens Core Strategy Local Plan 2012. This can be secured by condition.
Waste
4.19 MEAS advises that condition be attached to secure information on both construction and operational waste management.
Pipeline
4.20 Shell – The proposed works will not affect the Shell pipeline.
Wigan Council
4.21 Wigan Council confirms that there is no objection in principle to the development, and the need for employment land provision. However, matters in respect of highways considerations, the impact of noise from the development and the local plan process. These are summarised below.
P/2017/0254/OUP Planning Committee 24th November 2020
Highway Considerations – Trip generation and forecasting are robust and acceptable, but they show an increase along the A580 which is above the accepted thresholds and require junction assessment. The A573 Warrington Road and A580 East Lancashire Road, Golborne roundabout will be the most significantly impacted junctions.
The 'with development' capacity assessment for the A580 / Warrington Road / Bridge Street junction appears to be reasonable, however, factors such as turning flows may provide optimistic results. For example, a high proportion of vehicles turning right to Warrington Road in the PM peak would reduce queuing on the left / ahead lane and minimise impact of development traffic. The TA does not provide this level of detail where the focus of the capacity assessment is on network peak periods rather than developments. This is at odds with a development generating significant volumes of traffic throughout the day.
The traffic which is generated by the proposed development is considered in the context of the level of traffic which already passes through the respective junctions. This process is flawed as it may conceal significant changes in capacity as a result of the development traffic. The junctions of interest located to the east of the site along the A580 East Lancashire Road corridor require further investigation.
Wigan Council has previously requested an additional sensitivity test to examine the impact of light vehicle development traffic arriving and departing the site from the east. The 'journey to work' information derived from the 2011 Census advocates this assumption. However, B2/B8 developments generate heavy volumes of heavy vehicle traffic and it is unclear what proportion of heavy vehicle development traffic travels east along the A580 East Lancashire Road. The TA does not sufficiently address this.
Previous concerns around the assessment of Golborne Roundabout remain.
There are also concerns in respect of the wider M6 J23 improvement study, which recommended progression of the 'diverging diamond' option, alongside the diversion of the A49 north and south. It is unclear as to how the development proposes to retain access to the M6 J23. An objection is maintained due to the potential to restrict potential capacity improvements.
There are no traffic figures showing “development flows “and “opening year with development” scenarios. Any change to current forecalls flows cannot be verified. These concerns have also been raised by Transport for Greater Manchester.
Wigan Council maintains a highway objection due to the absence of sufficient robust information to demonstrate that the proposed development will not adversely affect the highway network.
Noise – There is insufficient information to determine the noise impact of the development and there is the potential to negatively impact nearby existing noise receptors. This includes background noise receptors, including further monitoring. It
P/2017/0254/OUP Planning Committee 24th November 2020
is acknowledged that the scheme is in outline, and further surveys can be secured by condition. However, the information submitted in respect of the proposals is insufficient to determine the application.
Local Plan Submission Draft – There are concerns regarding policy LPA06: Safeguarded Land North East of Junction 23 M6 (South of Haydock Racecourse), Haydock (ref 2ES). Representations made to the local plan process state that improved highways infrastructure is required and should be in place before any development on the site is operational. If the A49 is required to be diverted in order to secure the strategic improvement needed to Junction 23, accessibility between Ashton-in-Makerfield and Newton-le-Willows should be maintained and improved, particularly for bus services, cycling and walking, for which there is a strong case for enhancement of provision for all three particularly the opportunity to strengthen links with the railway station. If the A49 is required to be diverted, the approach to Wigan Borough from the south, and Ashton-in-Makerfield in particular needs appropriate consideration befitting such a gateway route, with particular emphasis on the environmental quality of that route.
5. REPRESENTATIONS
5.1 The application has been publicised three times as a result of the submission of substantive submissions by the applicant was publicised by press notice, site notice and neighbour notification letters. A total of 67 objection letters, including from the MP for Makerfield, Croft Parish Council and Culceth & Glazebury Parish Council were received raising the following concerns:
5.2 Green Belt & Loss of Green Space
• The Green Belt status of the site contributes to the divide between our neighbouring communities, it is important that this should be maintained because without it the communities of Ashton and Haydock will see urban sprawl that denies them the green open space, clean air and wildlife that they currently enjoy. • The removal of Green Belt for employment development would have the potential to undermine regeneration of brown field sites elsewhere because developers will opt for less complex developments that have a greater return. • The proposal is inappropriate development in the Green Belt and there are no special circumstances that would justify its approval. • There will be urban sprawl with the spaces between existing small and fairly rural communities being eroded. • Most development in the Green Belt is inappropriate and should be approved only in very special circumstances. In this case the developers' circumstances do not outweigh the harm caused. • The combined warehouses of Florida Farm, Haydock Point and Parkside means that the area will have its green spaces decimated and replaced by warehouses, this poor use of agricultural land means that all employment is in the area of logistics rather than spreading the risk of downturn across several industries. • Planning permission should not be granted for Green Belt changes across St Helens until the completion of the local plan process in 2018. • An application to drill for methane gas (P/2017/0254) was refused because it was development unsuitable for the Green Belt. The same should apply to these proposals.
P/2017/0254/OUP Planning Committee 24th November 2020
• The development will spoil the openness of the area resulting in urban sprawl between settlements. It should not be built on Green Belt land which is against the NPPF and the development plan. • There will be loss of precious, irreplaceable Green Belt land in an area which has already experienced significant loss of green spaces due to industrialisation • The aim of Green Belt is to keep the land open and to stop urban sprawl, this development is against the NPPF and the Council’s development plan. • This is Green Belt land protected from ugly developments, once it's gone it's gone and the developers won’t have to look at it. • Saddened that a Labour Council like St Helens would grant planning permission which could reduce the quality of life and destroy valuable Green Belt in local communities. • Is St Helens proposing to dig up its Green Belt and become the logistics outpost of Merseyside or can we attract a more diverse aspirational type of job? • The proposed development would be contrary to the purposes of including land in the Green Belt, it would affect its openness and its permanence. This would all be contrary to NPPF paragraph 79. • The NLUD states that there are 210 hectares of brownfield land in St Helens (plus the two recently come forward – the location of which is secret) and this should be used in preference to Green Belt land. • The revision of a Green Belt boundary should only be allowed in exceptional circumstances. • The proposed development is contrary to Policy CSS1 because there is no evidence that a strategic review of Green Belt at the sub-regional level has occurred. • The Inspector who reviewed the Core Strategy stated that in the short-medium term the general extent of the Green Belt will be maintained, and that it is appropriate to build only as many such developments that are needed rather than build as many as possible particularly where Green Belt land is concerned. • The increased traffic means that there is greater potential for accidents, looking at the data on line there are already a number of incidents. • The development will lead to towns merging and this is the very reason that Green Belts were set up in the first place. The merging will be added to by the local plan which identifies other land around Haydock Island • Green Belt acts as a green lung and processes CO2 and other pollutants by converting the CO2 to oxygen. This has a protective effect on local people. • The entire area around the site is rural arable Green Belt and this development should simply not be built • The Employment Land Needs Study identifies that there are over 30 empty units in Haydock. Surely the Council should be looking to use them before considering developing the Green Belt. • Policy CSS1 and SAS4 seek to focus development within Haydock Industrial Estate. It is noted that existing industrial areas are constrained from further development due to being surrounded by development and the Green Belt. • This area of Green Belt is a public amenity of not only a pleasant visual nature but also a nice place to walk and breathe clean air. It is a green barrier that separates Aston and Golborne from the M6 and A580. • The Council seems to want to get rid of as much Green Belt land as possible and replace it with warehousing. Does Wigan Council also have an opinion as it will affect people of Golborne and Ashton mainly • The St Helens Employment Land Needs Study states that businesses are moving into premises based upon availability not suitability. Based on this evidence, the planning policies protecting Green Belt land are doing their jobs assisting in the recycling of vacant urban land.
P/2017/0254/OUP Planning Committee 24th November 2020
• When the Core Strategy was being considered, the following comments were made by the Council: “This area is generally unsuitable for development due to its strong intact character and varied number of well-established land uses. There may be opportunities for limited small scale development reflecting the existing small scale patterns of development, which would avoid further fragmentation of the landscape and which would not interrupt the existing interplay of open to enclosed space. The developed industrial edge to the east of Haydock reinforced by the elevated line of the M6 should pose a constraint to further development eastwards. The contemporary raw immature edges to the south of Haydock and north of Newton-Le-Willows should be strengthened using an appropriate large scale landscape structure which reflects the typical scale and grandeur of the woodland structure elsewhere in the estate. Within this narrow undeveloped corridor the landscape structure should be reinforced to improve the strength of character and maintain a contrast between the urban and rural landscapes.” • Ashton in Makerfield is used as a by-pass to avoid congestion, this development will make it worse. • There are a number of vacant warehouses in this area and all brownfield sites should be exhausted first. • The application site offers an attractive green entrance to the township of Ashton and the Borough of St Helens, it is farmland supporting nature and wildlife providing natural drainage for the area. The openness of the area adds to the enjoyment of visitors to the racecourse and nearby hotels • Visitors to our Borough would find it very odd to destroy such greenery close to Haydock Park Racecourse. • In the Applicant's Economic Statement, they acknowledge that there are alternative sites in the North West but operators want the M6 corridor because sites further away from it are less efficient and therefore less profitable. Developers are not considering the harm to the environment or the well-being of communities who live with the consequences of development.
5.3 Transport
• Levels of traffic at Junction 23 are already unsustainable throughout Ashton and Golborne, most mornings there are long queues on the A49 through Ashton Town Centre in both directions linked to congestion on the M6, traffic is also bad on race days and to add the development into this would make a bad situation intolerable. • Any development linked to an already overburdened M6, generating thousands of additional lorry movements every year should only be considered in areas that have the capacity to absorb them. • There is a danger that HGVs may take routes through residential areas. • At the presentation that before the application was submitted, Peel assured us that their plan included improvements to Haydock Island to alleviate the problems of congestion. What is their magic solution? • A traffic pollution monitoring station was set up by a Council employee at 12:00, why didn’t they put it up at peak times? Was it to manipulate the true readings to mislead the public and planning committee? • If all of the developments proposed in this area go ahead then the effect on Haydock Island will be catastrophic, already residents of Haydock travelling to Manchester have to add another 30 minutes to negotiate Haydock Island just to get to work at 6:30am. • Even outside peak hours, Haydock Island is still busy and I get caught in a backlog of traffic which can add 20minutes to my journey. The junction and surrounding roads are not suitable for any more traffic.
P/2017/0254/OUP Planning Committee 24th November 2020
• It seems like not a day goes by without an accident at Haydock Island, the traffic lights have no continuity and insufficient timing which do not allow for the volume of traffic coming from all directions. This new layout has not been thought through. • The traffic and number of events at the Racecourse has increased over the years and is horrendous without adding further traffic from logistics developments. • The access junction to the development is a traffic light junction onto the A580, this will mean that there are three bottlenecks in the space of 1 mile • Is it not being considered how much traffic will be caused by employees? • The A49/A58/A580/M6 are inadequate to support the approximate increase of 17,500 vehicle movements per day on these roads in and around the development. • This development and others are a disaster waiting to happen in terms of the environment, air pollution, air quality, traffic and congestion. • Traffic and congestion at Haydock Island is worse now than before the improvements • The construction phase of the development will cause traffic chaos • The Local Travel Plan for Merseyside states that the overall aim of the strategy is to develop and maintain a sustainable freight system that seeks to maximise opportunities for the movement of goods by rail and manages the highway network to keep traffic moving. This development does not comply with that strategy, although Parkside does. • More and more school leavers will need to travel further afield anyway if they want to secure a decent well paid job which will mean more traffic. • The AQMA along the M6 should be extended to cover the whole of the A580/A49/M6 J23 because of all of the idling traffic. • The Council freely admitted at the 17th January 2017 Planning Committee meeting that there will be problems with traffic and they would have to deal with it in the future. Further openly advising everyone to lobby Government in order to get diesel engines off the roads. The3 High Court recently stated that NO2 is a real and persisting danger and that on average 64 people per day die prematurely. • Children will find it difficult to get to the schools in close proximity to the site due to traffic congestion which will be caused by the development. • There is frequently a long queue from the A49 towards J23 often blocking the A599, not just during rush hour. • Haydock Island has some of the worst traffic problems in the UK and is described by Highways England as the most notorious traffic pinch point in the North West. A solution to this problem can only be achieved by using adjacent land – including the application site. • There is a danger that HGVs and other traffic will take diversions through residential areas, this may be worsened by traffic taking other routes to avoid paying tolls on the Runcorn Bridges. • The traffic for Haydock Island reaches beyond Springfield Park and a further increase in traffic is hard to contemplate. • The conclusion of the Air Quality Assessment is not a true representation of the possible impacts of traffic generated by the development and I request that the methodology and results are thoroughly checked and verified. • The impacts on traffic and congestion will be severe, whatever figures Transport Assessments put on paper they do not reflect the experience of drivers and commuters. • The latest solution to the traffic and environmental issues, by diverting the A49, will not solve the problems and will exacerbate ethe situation. • Existing congestion will only be worsened by the installation of such an island and add to the serious backing up of traffic, from all directions, from the M6 and A580.
P/2017/0254/OUP Planning Committee 24th November 2020
• Approximately 10 to 15% of traffic travelling south on the A49 currently turn left at the M6 island onto the A580 heading towards Manchester. This means that 85 to 90% of the diverted through the proposed industrial estate, will have to cross the A580 and turn right at the proposed new traffic lights to return to the M6 they have been diverted from. It is inconceivable that anyone can suggest this as a ‘solution’ to the existing traffic problems. • Additional pollution would be generated by such a proposal. • The volume of traffic having to cross the A580 will create havoc to the A580 in both directions and can only exacerbate the existing and very serious congestion problems. • The new arrangement will create a problem along the road to Lodge Lane and Golborne. The pollution will still increase along with volume of heavy goods traffic on and off the new road that will still head towards junction 23. • Haydock Island has had a lot of money spent on ‘improvement works’ and has done very little to ease traffic flow and there have been many accidents and near misses happen on a daily basis. • Even though the A580 is busy it is an area used by pedestrians, runners and cyclists. • The site should be in an accessible location, but it is not within 400m of a rail link and is surrounded by roads that are already heavily congested. • The catchment area of the Port of Liverpool is defined by the rules governing HGV driving (4.5 hours without a break), thus defining the maximum day trip achievable. Ships once docked are unloaded onto HGVs who then get as far as possible within 4.5 hours. Therefore there is no justification to bring large warehousing and logistics to St Helens as that would only be 1 hour away from the Port. Similarly, freight arriving from the North would use the M58 and from the south would use the new Mersey crossing thus bypassing St Helens. • Seaforth Dock has a direct rail link to the West Coast Main Line so can take loads north or south and freight could also go to the Potter Rail Freight Terminal (Knowsley) in a similar fashion. • The designated distribution hub for the Port of Liverpool is in Ditton and it has direct access to the River Mersey, The Manchester Ship Canal, the M56 and all other infrastructure. There is also 2.5m sqft of distribution space (rising to 3.5m sqft if needed). • Rail is better for the economy and the environment so why would St Helens allow a development that does not aim at the best means of transporting goods? • It is no good saying that Haydock Island is not the responsibility of St Helens Council and we will say it ok because Highways England say so. You do not walk off a cliff if someone says it is ok. • The access onto the A49 is dangerous • Ashton in Makerfield is becoming gridlocked with plans to develop at Pewfall and Brynn as well • Road based travel is not environmentally sustainable as the effects of climate change require mitigation and immediate action to reduce exhaust emissions. • There is a layby to the north of Springfield Park which is used by HGVs which cause noise and often drivers relieve themselves at the side of the road. • Can there be sufficient car parking spaces for staff as the Parks office development use Haydock Park Garden as parking when there are insufficient spaces available. The residents have suffered verbal abuse from staff who double park, and park across residents driveways.
5.4 Air Quality
• Air pollution is a cause for concern as tens of thousands of people die early every year because of air pollution and the UK regularly exceeds the legal levels for
P/2017/0254/OUP Planning Committee 24th November 2020
pollution. The logistics/warehousing proposed will exacerbate existing pollution levels in the area together with the traffic from Florida Farm and the other areas identified in the local plan. • Until the Health and Wellbeing board agree the Local Air Quality Management Strategy and can be confident that other major developments will not contribute to other unnecessary deaths then planning permission should be refused. A specific air quality management plan should be put in place for the A580/M6 area in Haydock, given the concerns of local residents the Council could leave itself open to a class action lawsuit from our children in the future should the concerns about poisoning prove to be true. • This development, and other in the locality will worsen air quality in the two Air Quality Management Areas in the Borough (M6 and High Street, Newton) where residential properties are exposed to Nitrogen Dioxide (NO2) emissions above the 2005 UK limits. • There are two schools in close proximity to the site and the air quality of the area will suffer due to increased HGV movements, it will harm the health of the children. • There will be an increased risk of flooding downstream of the proposed development in an area which is already prone to flooding. • There can be no feeling of wellbeing as you approach any area covered in concrete buildings and the deterioration of air quality from all of the vehicles especially when they are backed up in long queues with their engines running. • Air quality in the area is already breaking legal limits • There has been no consideration of air quality impacts on the High Street Air Quality Management Area in Newton le Willows. • The development is located in an Air Quality Management Area, when AQMAs are declared the Council must prepare an Air Quality Action Plan to set out the measures it intends to put in place in pursuit of the objectives. The Action Plans to mitigate the effects of air pollutants in the vicinity of the M6 AQMAs have yet to be implemented. • Question why automatic air quality monitor AN2 has not been selected as a receptor in the air quality modelling given that it records 53 micrograms per cubic metre in 2015. Diffusion tubes on the motorway have also marginally exceeded objectives and have not been included in the Air Quality Assessment. • The background pollutant levels in the Air Quality Assessment decrease from 2015 to 2022, there is no explanation given why this happens, there is also uncertainty over the emission factors and in general they are reported to under report emissions. Even with adjustment I cannot see how it would be possible for air quality to improve with development. To put this in context, committed developments would put around 20,000 – 25,000 additional vehicle trips each day onto the road network. • The air quality is getting worse, along with continuous traffic noise all day and all night. The development will add to these problems, with the loss of much valuable green space and precious wildlife. • Haydock ward has a legacy of poor health due to its industrial past and those with respiratory disease will be particularly susceptible to the pollution caused by new vehicles. • Sitting idling in traffic under the bridge of Haydock Island is very dangerous to health, diesel fumes have been reclassified as a grade 1 carcinogen meaning they are a definite cause of cancer, people exposed to these fumes were 40% likely to develop lung cancer. • Air pollution, including particulate matter has been linked with Alzheimer’s disease.
P/2017/0254/OUP Planning Committee 24th November 2020
5.5 Pollution
• Added pollution will affect the psychological and physiological wellbeing of myself and the residents of St Helens • There will be noise and light pollution • Due regard has not been given to the impacts of vibration • Light pollution, traffic noise and operational noise will affect residential properties throughout the night-time.
5.5 Ecology
• The proposal would have an adverse impact on wildlife habitats, woodland and water courses near to the development. • Wildlife does not need improving on, it is fine as it is without interference, it is very likely that the wildlife will suffer. • The local plan says that the Council should make sure that the up keep of recognised habitats is maintained and not damaged from development. Haydock Point is a former medieval hunting ground and likely one time deer park, it houses woodland birds including waders which are on the Red List. One of the birds, Lapwing, is a qualifying feature of European Importance, the population is local to Haydock and are not likely to be part of the Mersey Estuary SPA but are material to the planning process. • There is a population of Water Voles on the site which is fully protected under the Wildlife and Countryside Act and is a S41 priority conservation species. The woodland edge is also a viable habitat for badgers and there a colonies of bats and many veteran trees.
5.6 Design & Appearance/Impact on the Landscape
• Just because there may not appear to be a better place to build the development is not a good enough reason. Haydock residential areas will be dwarfed by it. The Employment Needs Land Study actively promotes this as a good thing. • The landscape character assessment for Haydock Industrial Estate identifies that the farmland adjacent provides separation between the Haydock and Ashton in Makerfield residential areas. • The warehouses are too big to be built here, they will dominate the landscape and not blend in with the nearby Haydock Racecourse. • The size of the buildings up to 25m high will dominate the rural landscape • The St Helens Landscape Character Assessment identifies that the area should be conserved and enhanced, stating that it has a strong intact character with trees and hedges being an important part of the local landscape character. • The built up commercial area is very clearly divided by the M6 from the rural landscape where the logistics development is proposed. • The St Helens Landscape Character Assessment states that the developed industrial edge to the east of Haydock reinforced by the elevated M6 should pose a constraint to further development eastwards. • Attempts by the developer to disguise these enormous, towering mega structures and mitigate the impact on the landscape with planting schemes around the periphery will fail to blend this incongruous development with the wider rural environment. The worst case would be loading bays adjacent to the A580. • Disagree with the reasons given in the Planning Statement that this development would cause moderate harm to the Green Belt and the purposes of including land within it and moderate level harm to the local landscape from a limited number of viewpoints.
P/2017/0254/OUP Planning Committee 24th November 2020
• Haydock Park Racecourse will be affected because the current open views seen on television will be replaced by industrial views which will damage the wider opinion of our region. • The applicant is attempting to downgrade the significance of the open parkland setting and agricultural character of the proposed development site by disregarding positive elements. The area currently provides an impressive and beautiful green gateway to St Helens and Haydock Park Racecourse which plays a significant role in promoting St Helens nationally. • It would make more of an industrial area which would be devastating. • Should this be built, it could be left vacant as has happened elsewhere, it will just end up being an eyesore and derelict. • It appears that the local environment is not high on the list of priorities for the Council. • Access is vital to Haydock Park Racecourse which is one of the towns major sporting venues.
5.7 Economic Development/Employment
• The City Growth Strategy seeks to grow, strengthen and diversify the business base, but the proposed development fails to do that for the following reasons: St Helens already has the largest proportion of logistics workers in the North West and double the national average. The environment will be completely ruined and there will be a presence which will be detrimental to the whole area and impinge on other areas. The business base is not diversifying – we are putting all of our eggs in one basket. • St Helens is a no man’s land between Liverpool and St Helens in relation to Liverpool SuperPort and Port Salford. Haydock would just scrape into the timeframe to be able to claim as being in the SuperPort area and is realistically unlikely to be able to exploit any of the port’s assets and capabilities. • The only reason to destroy this open area is to provide jobs, but actually is it necessary? We need permanent jobs, not short term jobs of erecting warehouses which will stand empty. Why not try to fill the existing empty units such as Sankey Valley Industrial Estate? • The development is speculative and therefore there is no guarantee of jobs in the Borough, the developer is quoting figures based on other speculative developments that are not operational yet. • Jobs may be created here but lost elsewhere due to people not getting to work on time • Lots of the new jobs will be from existing factories and not really new jobs, most of them will also be automated and once the novelty of the warehouses wears off they will just be a blot on the landscape. • Haydock has lower than average joblessness. Having already given planning permission for 2 other developments which would deliver 3,117 jobs it is unclear where all of the employees will come from. This will not reduce the number of journey made by private car in order to reduce Nitrogen Dioxide as required by the new plan. • In respect of Peel’s rhetoric of 2,758 jobs with priority given to local people is speculation and contravenes the Equal Opportunities Act. • The over provision of warehousing hubs does not sit with the Green Paper on ‘New Modern Industrial Strategy’ which will support businesses to grow and to create more high skilled and paid jobs for local people. Our Borough will not share in this prosperity because the Council is looking at stop gap measures like this. • The job market locally will be saturated by warehouse jobs unless the job estimates are inflated. A recent study at Omega estimates that from 1.7m sqft of
P/2017/0254/OUP Planning Committee 24th November 2020
floor space only 60 new jobs have been created as companies just relocated their workforce. • The Council should look at brownfield sites away from busy junctions and far away from residential properties if this is the kind of employment they wish to bring to St Helens. • The job figures quoted are the magical 2,500 but who would want to work in a low paid job in a warehouse that may soon become automated? • The need for buildings of this size has been over estimated and unproven. In the February 2017 issue of Business Insider the latest thinking is that smaller warehousing hubs are needed, not a large one because several smaller warehouses aids delivery times. • In the current economic climate we should be trying to champion local producers and the local economy. It is a fact that 40% of UK food is imported, we should be looking to buy from British farms and in return our farmers should be looking after the countryside.
5.8 Flooding & Drainage
• There is frequent flooding on the A580 close to areas of warehousing, the nearside carriageway partially floods kerbside during periods of heavy rainfall and there is a danger of vehicles aquaplaning at speed, this will increase if more warehouses are allowed. • Extreme weather events are becoming more common and fields act as sponges holding on to water and releasing it at a more manageable rate.
5.9 Local Plan
• The application is premature and developers are pre-empting the plan assuming that it will go through without scrutiny and amendment from the Planning Inspector • The Core Strategy states that there are 261 hectares of previously developed land in the Borough which is a far cry from special circumstances. • It must be noted that the new local plan is designed to fulfil the economic strategy of the borough over the period 2018-2033. This is based entirely on B8/B2 warehousing and the quantum of logistics development in Haydock/Newton is not being phased in over the 15 years of the plan. This will have a catastrophic impact on the Green Belt, traffic, air quality and infrastructure. The Council have no plans to monitor the cumulative impacts or take action to mitigate adverse impacts from multiple developments. There will be no time to adapt to changes in the economy and markets, or rapid changes in technology. • At the Core Strategy Examination in Public in 2012, Peel stated that they were in dialogue with Aimia Foods about relocating to the Haydock Point site. Aimia Foods are located in Haydock, if the company does relocate to a larger unit it will not create new jobs and will leave an empty unit. • The Draft Local Plan 2018-2033 is at a very early stage, it would appear that the developers are citing it as a material planning consideration. However, the plan has not been finalised and there have been a significant number of representations made. Peel are pre-empting the local plan. It is also noted that there is no Transport and Infrastructure Strategy to underpin the plan nor does St Helens have a regional Air Quality Strategy.
5.10 Other Matters
• Concerns that a lack of joined up working in relation to the plans of neighbouring authorities and the cumulative impact of proposed development in adjoining constituencies are not adequately considered. There are two large developments
P/2017/0254/OUP Planning Committee 24th November 2020
proposed on land a short distance from this site in Wigan’s area. Have the cumulative impacts on air quality and traffic of the proposed developments around this stretch of the M6 in St Helens and Wigan been considered? • At the Florida Farm committee I was shocked at the standard of members and lack of knowledge and expertise and obvious impartiality. There were no regards to the real issues regarding health and pollution, food banks in Parr should not be a relevant consideration. • Our homes will be devalued if the proposed development goes ahead. • Understand that local authorities want to maximise business rates to minimise the impact that the new localisation of business rates will have on them but this action should go hand in hand with maintaining quality of life for local communities. • Article’s 1 and 8 of my Human Rights are being disregarded, due regard to both has not been given. They relate to a right to enjoy the surrounding community and a right to a peaceful home life. • The residents of St Helens have not adequately been informed of this development and the adverse impacts it will have on them. • The area does need some investment, but this should be in shops, parks and the countryside. Not creating more infrastructure which is not beneficial and impacts massively on local residents. • The balance between private corporate profits and Borough finances seem to far outweigh consideration for the green environment, quality of life and the objections of local residents affected by the approval of these planning applications. • Where will this end? Will there be a long line of warehouses along the East Lancs Road? • The area has only just recovered from mining and now you want to subject us to an unnecessary eyesore • The application is contrary to national and local policy, there is a new plan being prepared but this does not mean that there is a policy vacuum • It is an abomination that the Florida Farm application has been approved by a reckless council who don’t want to listen to the local voices who do not want this kind of wanton destruction. • With the uncertainty of Brexit and the likely cost of importing foodstuffs, agricultural land should be kept for the purpose of feeding the nation’s people. In the past 20 years, the amount of arable land in the UK has decreased by 30% and food imports have increased by 47%. However, the combined pressures of increasing volatility in world food production prices, problems arising from climate change and the need to reduce the nation’s carbon footprint means that the next 20 years in agriculture will be very different from the last. • Connor McGinn MP has concerns about the safety of Haydock Island and the new improved junction seems to have made things worse. • There is a potential further cumulative impact from all of the housing being proposed in the local plan. • The Council hasn’t yet produced a Brownfield Register and I do not believe that there are no brownfield sites available for this kind of development. It was deeply disappointing to hear that additional brownfield sites had been found following the public outcry about the new local plan and to Florida Farm. • Peel have other land that they intend to build on near to the site • This application should not proceed without sight and knowledge of the Parkside proposals. • Whilst employment land is considered as a cumulative impact, housing allocations in the Draft Local Plan aren’t, they should be assessed. • There has been a lack of detailed plans and consultation, do not feel fully informed about the development and there is an attempt to push this under the radar which is disrespectful to tax paying residents • Is there a need for a development at Florida Farm, Parkside and Haydock Point?
P/2017/0254/OUP Planning Committee 24th November 2020
6. SITE HISTORY
6.1 None relevant.
7 POLICY CONTEXT
National Planning Policy Framework 7.1 Paragraph 9 of the National Planning Policy Framework (NPPF) states that planning decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account to reflect the character, needs and opportunities of each area. Paragraph 11 states that planning decisions should apply a presumption in favour of sustainable development. This means approving development proposals that accord with an up-to-date development plan without delay; or where the development plan is absent, silent or out of date planning permission should be granted unless the application of policies in the NPPF that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF taken as a whole.
7.2 Paragraph 12 of the NPPF clarifies that the presumption in favour of sustainable development does not change the statutory status of the development plan as the starting point for decision making. Where a planning application conflicts with an up- to-date development plan, permission should not normally be granted. Local planning authorities may take decisions that depart from an up-to-date development plan, but only if material considerations in a particular case indicate that the plan should not be followed.
Development Plan 7.3 The adopted development plan for St Helens is the St Helens Local Plan Core Strategy (adopted 2012); saved policies in the St Helens Unitary Development Plan (adopted 1998); and the Joint Merseyside and Halton Waste Local Plan (adopted 2013).
St Helens Local Plan Core Strategy (2012) • CSS1 Overall Spatial Strategy • CIN1 Meeting St. Helens' Infrastructure Needs • CSD1 National Planning Policy Framework - Presumption in Favour of Sustainable Development • CAS4 Haydock and Blackbrook Strategy • CAS5 Rural St Helens • CP1 Ensuring Quality Development in St. Helens • CP2 Creating an Accessible St. Helens • CE1 A Strong and Sustainable Economy • CQL2 Trees and Woodlands • CQL3 Biodiversity and Geological Conservation • CQL4 Heritage and Landscape
P/2017/0254/OUP Planning Committee 24th November 2020
Saved Policies of the adopted St Helens Unitary Development Plan (1998) • S1 Green Belt • GEN12 Lighting and Security Apparatus • GB1 General Criteria for Development Control in the Green Belt • GB2 General Criteria for Development Control in the Green Belt • ENV4 Statutory Site Protection • ENV5 Sites of Community Wildlife Interest and Local Nature Reserves • ENV12 Development Affecting Trees • ENV13 New Tree Planting on Development Sites • ENV21 Environmental Improvements Within Transport Corridors • ENV23 Archaeology • ENV26 Contaminated Land • ENV30 Drainage
Waste Local Plan (2013) • WM8 Waste Prevention and Resource Management • WM9 Sustainable Waste Management Design and Layout of New Development
Supplementary Planning Documents • Local Economy • Ensuring a Choice of Travel • Biodiversity
Local Plan Preferred Options 7.4 The Submission Draft of the St Helens Borough Local Plan 2020-2035 was published on 17th January 2019. The plan proposes to allocate 265.3 hectares of land for employment up to 2035, with an additional 85.88 hectares of land safeguarded for employment use beyond the plan period.
7.5 The Plan proposes to remove the application site from the Green Belt and safeguard it for employment purposes but for beyond the plan period. The site proposed to be safeguarded is larger than the application site at 55.9 hectares. This is as a result of the need to ensure that the new Green Belt boundary uses physical features that are recognisable and are likely to be permanent, rather than simply relating to ownership.
7.6 The reasoned justification states that the timing, form and extent of any development that may be acceptable in the future on these sites is likely to be influenced by the need to ensure a phased approach to meeting overall employment needs and the extent to which constraints affecting these sites have been overcome. This is likely to be influenced by the interrelationship with Junction 23 of the M6, where a need for substantial improvements to enhance junction capacity within the plan period has been identified.
P/2017/0254/OUP Planning Committee 24th November 2020
Other Documents 7.7 The following documents form part of the Council’s evidence base and will be discussed below:
• Economic Evidence Base Paper, Aecom, September 2015 (EEBP) • Employment Land Needs Study, BE Group, October 2015 (ELNS) • Draft Strategic Housing and Employment Land Market Assessment, GL Hearn, January 2017 (SHELMA) • Addendum Report to the ELNS, BE Group, October 2017 – Amended January 2019 (ARELNS)
Other Considerations 7.8 The application has been considered having regard to Article 1 of the First Protocol of the Human Rights Act 1998, which sets out a person’s rights to the peaceful enjoyment of property and Article 8 of the Convention of the same Act which sets out his/her rights in respect for private and family life and for the home. Officers consider that the proposed development would not be contrary to the provisions of the above Articles in respect of the human rights of surrounding residents/occupiers, for the reasons set out further below.
7.9 This application has been considered in relation to Section 17 of The Crime and Disorder Act. The Police Crime Prevention Officer has been afforded the opportunity to comment on this scheme, but no comments have been received.
7.10 The application has been considered in accordance with the St Helens Council’s Comprehensive Equality Policy, which seeks to prevent unlawful discrimination, promote equality of opportunity and good relations between people in a diverse community. In this case the proposed development is not anticipated to have any potential impact from an equality perspective.
8 ASSESSMENT
8.1 Paragraph 7 of the National Planning Policy Framework (NPPF) states the purpose of the planning system is to contribute to the achievement of sustainable development.
8.2 For decision taking this means approving development proposals that accord with an up to date development plan without delay; or where there are no relevant development plan policies, or the policies which are most important for determining the application are out of date, granting planning permission unless (i) the application of policies that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or (ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits when assessed against the NPPF taken as a whole.
8.3 Paragraph 12 notes that the presumption in favour of sustainable development does not change the statutory status of the development plan as the starting point for decision making. Where a planning application conflicts with an up to date development plan, permission should not normally be granted. Local planning
P/2017/0254/OUP Planning Committee 24th November 2020
authorities may take decisions that depart from an up to date development plan, but only if material considerations in a particular case indicate that the plan should not be followed. Paragraph 38 states that local planning authorities should approach decisions on proposed developments in a positive and creative way; decision makers at every level should seek to approve applications for sustainable development where possible.
8.4 The application relates to an area of land in the Green Belt, it is also greenfield. This application proposes a logistics development with some manufacturing, with access from the A49 and A580. This report will therefore assess the application, where the starting point is compliance with Green Belt policy.
Principle of the development
8.5 Saved Policy GB1 in the Unitary Development Plan is relevant. This policy states that new buildings within the Green Belt will not be permitted, except in very special circumstances, unless it is for one of four identified purposes.
8.6 Paragraph 145 of the NPPF sets out the policy for assessing proposals that involve the erection of new buildings within the Green Belt. It states that a local planning authority should regard the construction of new buildings in the Green Belt as inappropriate development unless one of eight identified exceptions apply.
8.7 Paragraph 143 of the NPPF states that inappropriate development is by definition harmful to the Green Belt and should not be approved except in very special circumstances. Paragraph 144 states that when considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt and ‘very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal is clearly outweighed by other considerations.
8.8 Although there are some differences between the policies, they are broadly consistent and therefore significant weight should be given to saved policy GB1 (applying NPPF Paragraph 213).
8.9 This application proposes the erection of up to 167,225 square metres of employment floor space. It is therefore inappropriate development because it does not meet any of the exceptions identified in Green Belt policy. Given that the application proposes inappropriate development, it is necessary to consider whether there are very special circumstances to justify granting planning permission for the proposed development (in terms of NPPF Paragraphs 143 and 144).
8.10 This section of the report will assess the applicant’s case of very special circumstances as set out in Section 3; it will then evaluate the harm caused to the Green Belt, and any ‘other harm’, before coming to a conclusion whether the harm is clearly outweighed by other considerations.
P/2017/0254/OUP Planning Committee 24th November 2020
Very Special Circumstances 8.11 The applicant has set out a number of benefits of the scheme that, in their view, constitute very special circumstances. The advantages focus on the economic benefits that the scheme will bring and that it will meet the quantitative and qualitative need for logistics floorspace in St Helens Borough. The development will respond to occupier demand and undersupply of strategic logistics sites in the market areas and the ability to attract this investment into the Borough. In addition, the proposed development would enhance the ecological value of the site and improve drainage.
8.12 In this regard there are clear parallels with the decisions in Florida Farm, Parkside, Omega West and the Eddie Stobart site, to which Members should have regard in order to be consistent in decision making. However, there are also site specific issues, such as the impact on openness and purposes of the Green Belt, landscape and visual impact, noise, traffic ecology etc which mean that each balance will need to be taken on the basis of the individual land use planning impacts.
8.13 As discussed in Section 7 of this report, the development plan comprises the St Helens Core Strategy (2012), the saved policies of the St Helens UDP (1998) and the Joint Waste Local Plan (2013). The Council has issued the Submission Draft of the St Helens Borough Local Plan 2020-2035, which has been informed by a substantial evidence base. In accordance with Paragraph 48 of the NPPF, the Local Plan 2020- 35 should only be given limited weight due to its early stage of preparation. However, the evidence that has been used to prepare the plan is a material consideration to which weight can be attached.
8.14 Paragraph 80 of the NPPF states that planning policies and decisions should create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges for the future. Paragraph 82 states that planning policies and decisions should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters of networks of knowledge and data driven, creative or high technology industries; and for storage and distribution operations at a variety of scales and in suitably accessible locations.
Whether there is policy support and a need for new employment land in St Helens
The applicant’s case 8.15 The applicant sets out that national policy requires significant weight to be put on the need to support economic growth. They say that there is a significant and growing need for additional high-quality large-scale logistics development in St Helens and that there are no urban sites or sequentially preferable Green Belt sites that meet the needs and requirements of operators. There are no other sites able to accommodate the development, and meet the identified need, in a complete or disaggregated form. They say that demand has increased over the period of determination of the application and is reflected in the updated evidence published in preparation of the
P/2017/0254/OUP Planning Committee 24th November 2020
new local plan. The applicant states that this reinforces the need for the development to come forward now.
The Council’s assessment 8.16 This application falls to be determined in accordance with the development plan unless material considerations indicate otherwise (Section 38(6) of the Planning & Compulsory Purchase Act 2004 and Section 70 of the Town & Country Planning Act 1990).
The Development Plan 8.17 Policy CSS1 identifies previously developed land in sustainable locations, including Haydock Industrial Estate as the main focus of economic development. The justification for the policy states that the spatial distribution for employment land is likely to broadly follow the distribution of existing employment areas and notes that they are constrained from further development outwards due to being surrounded by Green Belt. Policy CSS1 states that development will be restricted to within existing settlement boundaries, unless it complies with Green Belt policy.
8.18 Policy CAS4 sets the strategy for Haydock and Blackbrook. It states that economic development will continue to be focused on Haydock Industrial Estate through the development of remaining sites in the Economic Land Supply. The policy also states that support will be given for developments that maintain the effectiveness of the Freight Route Network including Junction 23 of the M6, and initiatives to improve access to employment opportunities such as those at Haydock Industrial Estate.
8.19 The justification for the policy states that Haydock Industrial Estate is the largest in the Borough covering 126 hectares and is well located in relation to the M6 motorway. At the time, 9 hectares of land were identified as available for development, mostly at the former colliery at Old Boston, although this has or is in the process of being developed. The following key issues are identified: safeguarding industrial uses; improving accessibility by sustainable means; ensuring that development does not adversely affect Junction 23 of the M6 motorway and if appropriate through the use of demand management measures; and securing additional development opportunities..
8.20 Policy CE1 states that sufficient land and premises will be provided to strengthen and diversify the Borough’s economic base and support the City Growth Strategy and other economic regeneration initiatives by providing at least 37 hectares of land to meet local needs to 2027. It is anticipated that 32 hectares of this demand would come from B8 logistics, 5 hectares would come from B1 offices and demand for B2 manufacturing would reduce by 18 hectares.
8.21 The justification for the policy identifies that the need for employment land would be met through the identification of a range of sites within an Allocations Development Plan Document (DPD) and supporting the reuse of previously developed land. The policy also states that economic development will be focused to those sites that are either within, in close proximity to, or have easy access to public transport to the most deprived areas of the Borough. Where this is not possible, developments will be
P/2017/0254/OUP Planning Committee 24th November 2020
expected to contribute to improving such links. The policy identifies an employment land supply of 86.12 hectares and an additional 32 hectares of windfall land which could come forward.
8.22 Following the adoption of the Core Strategy in 2012, the Council began work on an Allocations Local Plan Development Plan Document (ALPDPD) to identify sites for development in the Borough. As part of that process, the Council undertook research to update the evidence base which underpinned the Core Strategy, prepared between 2009 and 2011. The updated evidence base identified that there was a significant material change in the employment land market which meant that there was a need for considerably more employment land than identified in Policy CE1. This was one of the factors which led to the Council preparing a new local plan for the Borough (rather than progressing the ALPDPD).
8.23 The St Helens Borough Local Plan 2020 – 2035 has recently been submitted for examination. There are a number of objections to key policies which, in accordance with paragraph 48 of the NPPF, means that it can only be given limited weight at this point. However, it is relevant to note that it identifies a need for a minimum of 215.4 hectares of employment land between 2018 and 2035, consistent with the Council’s employment land evidence base.
8.24 This evidence base is a material consideration when determining this planning application. As noted above, it is clear that the need for employment land to 2035 is significantly greater than that identified in Policy CE1 of the Core Strategy. The Council’s evidence on the need for employment land is set out below.
Economic Evidence Base Paper (EEBP) 8.25 In September 2015, the Council published the Economic Evidence Base Paper (EEBP). The EEBP set the context for the demands of the employment land market and it noted that in 2015 there was an acute shortage of available, quality, industrial accommodation across all size parameters in the North West. The paper highlighted that the region had the lowest availability in the country of B8 logistics buildings in excess of 9,000 square metres and less than 8 months of theoretical supply in September 2014.
8.26 The EEBP noted that there was significant occupier demand for large scale logistics buildings with over 4,500 square metres of floor space in the North West, evidenced by transactions of floor space taking place between 2011-2015. The EEBP noted that the amount of floor space taken up in the region in the first half of 2015 was the largest of all UK regions.
8.27 The EEBP states that the strong demand is set to continue due to the North West Region’s location, the strength of Manchester and Liverpool, infrastructure projects such as Superport and Airport City, and the continued rise of internet shopping whose retailers are deliberately developing logistics strategies to be near to customers.
P/2017/0254/OUP Planning Committee 24th November 2020
8.28 Sub-regionally, the EEBP reflects on political change and investments in infrastructure in the Liverpool City Region (LCR) since 2012. The LCR Growth Deal was signed in 2014 and the creation of a freight and logistics hub is one of the five strategic projects at its heart. The Growth Plan for the LCR has a strong emphasis on logistics and freight as a means of supporting and enhancing the economic output of the region.
8.29 The EEBP notes the growing needs of the Liverpool Superport. It refers to the study ‘Liverpool City Region Superport: An Analysis of the supply of, and demand for, distribution space within the Liverpool City Region (2014)’. The Study defines the Superport area as one hour’s drive time from the Port of Liverpool and includes the Borough of St Helens. The Study examines the factors that will drive demand for port related employment land and premises and states that there is an overall requirement of 783-808 hectares in the Superport area over the next 20 years.
8.30 In this context of regional and sub-regional need, the EEBP identifies that the Council commissioned an Employment Land Needs Study (ELNS) to identify the objectively assessed need (OAN) for employment land within the Borough up to 2037. The ELNS was published in October 2015.
Employment Land Need Study (ELNS) 8.31 The ELNS states that the demand for warehousing space (which includes demands for manufacturing and logistics operations) has changed significantly since the development of the Core Strategy, with the commercial property market in the region being driven by an increasing demand for large scale logistics operations (greater than 10,000 square metres). Consequently, the demand side factors which influence the calculated number of years’ supply of land in the Core Strategy are now too low for projections of need.
8.32 The ELNS notes that large flat sites with excellent motorway access and proximity to market/supply chains are highly sought after, the Borough of St Helens’ key location on the M6 and M62 motorways mean that it is ideally positioned in the North West to provide a critical role in the logistics sector.
8.33 The ELNS identifies an employment land objectively assessed need or OAN baseline of 147 - 174 hectares up to 2037. This OAN is based upon previous take up of floor space. However, there are additional factors which would increase demand for large scale logistics employment in the Borough, such as the development of a strategic rail freight interchange at Parkside and Superport, which would translate into an additional 30-40 hectares of employment land.
8.34 With these additional factors being taken into account, the ELNS identifies that the actual OAN for the Borough is 177-214 hectares of land with around 100-130 hectares being for B8 storage and logistics.
8.35 As the ELNS was published in October 2015 an Addendum Report to the ELNS (ARELNS) was published in January 2019 to update it and to support the Submission
P/2017/0254/OUP Planning Committee 24th November 2020
Draft of the Local Plan. The ARELNS reviews the ELNS’s estimate of the OAN for employment to give the most up to date evidence and market conditions.
Addendum Report to the Employment Land Needs Study (ARELNS) 8.36 The ARELNS notes that the logistics market continues to be the most in demand commercial market in the North West, with demand focussed on the motorway corridors. It reports that discussions with commercial agents in the region show a general belief that there is substantial demand for large logistics space in the coming years and that the logistics market is the most likely sector to drive growth in the Borough of St Helens and the broader North West Region for years to come. The Report identifies that the market is constrained by lack of space and that high quality, large (greater than 5 hectares), flat sites with excellent access to the motorway network and planning support are in short supply.
8.37 The ARELNS states that there has recently been strong developer interest in the Borough of St Helens (in particular Haydock) which is consistent with the highlighted demand and the conclusions drawn in the ELNS. It also notes that with Omega in Warrington built out, there is a need for further large scale logistics sites to be provided near the intersection of the M6 and M62 (a key hub).
8.38 The ARELNS identifies that employment land take up has been supressed in the Borough of St Helens for a number of years because of an inadequate supply of market attractive sites. It notes that the Boroughs of Halton, Liverpool, Knowsley, Wirral and Warrington have all experienced a significantly greater take up of employment land than St Helens between 2005 and 2015. Furthermore, it notes that the sustained strength of the market and the growing momentum around sites in the Borough of St Helens (in particular Haydock) suggests that the increased need for employment land may be more than anticipated in 2015.
8.39 As a result of these factors, the ARELNS identifies that the revised OAN for the Borough is between 190 – 239 hectares of employment land between 2012 and 2037. It states that between 110 – 155 hectares of this land would be for B8 logistics.
Strategic Housing and Employment Land Market Assessment (SHELMA) 8.40 Sub-regionally, the Liverpool City Region (LCR) published a draft Strategic Housing and Employment Land Market Assessment (SHELMA) in January 2017. The purpose of the SHELMA is to provide an evidence base to inform the preparation of a City Region Spatial Framework and support the preparation of local plans by local planning authorities in the LCR & West Lancashire.
8.41 The draft SHELMA identifies that across the LCR and West Lancashire there would be a need of between 308 – 397 hectares of land to accommodate large B8 floor space (units of over 9,300m2) between 2012 and 2037. However, it does not break this figure down by local authority area.
Liverpool City Region Assessment of the Supply of Large Scale B8 Sites (LCRB8) 8.42 Following on from the SHELMA, the LCR produced the above study in June 2018. The purposes of the LCRB8 is to review sites in the LCR that are capable of
P/2017/0254/OUP Planning Committee 24th November 2020
supporting the growth in large scale B8 developments over 10,000m2. The study assessed sites to identify whether they are realistically marketable and likely to come forward for a large scale B8 use by 2037.
8.43 The former Parkside Colliery site was assessed as part of the LCRB8 which found that its location close to both the M62 and M6 motorways makes it well located for regional and national distribution markets. The study states that Parkside is a prime site in the City Region providing the potential for 63.65 hectares of strategic B2 and B8 development at a location which provides excellent access to the strategic road and rail networks.
Liverpool City Region Assessment of the Supply of Large-Scale B8 sites (ASLCB8) June 2018 and Addendum Sheet, November 2019
8.44 The Liverpool City Region published an Areas of Search Assessment (ASA) document in August 2019, intended to build on the work previously undertaken in the LCRB8 by assessing a number of areas that were considered to provide further development potential for strategic B8 warehousing and distribution requirements.
8.45 The ASA identifies a committed supply of 182.75 hectares which is likely to come forward to meet the large-scale B8 demand. The ASA then goes on to show that if the supply of land likely to support strategic B8 development is extended to include sites as set out, then the total supply increases to 342.68 hectares (previously 295.6ha in the ACLCB8), including Green Belt sites.
8.46 Overall, the ASA established that there is a residual over supply of 3.68 hectares for the ‘do minimum’ scenario and a residual requirement of 94.32 hectares for the do something’ scenario.
Recent developments 8.47 The evidence outlined above covers the period between 2012 and 2037. Since 2012, planning permission has been granted for employment developments in the Borough including around 30 hectares at Florida Farm, 11 hectares at Haydock Green and 3.5 hectares at Kilbuck Lane. Applications for the development of 63.75 hectares at Parkside and a Parkside Link Road are subject to consideration by the Secretary of State. The Council has resolved to grant planning permission for 75 hectares at Omega adjacent to the M62. This application is currently with the Secretary of State. However, even allowing for these developments there is still a significant need for employment land in the Borough As stated above, it is worth noting that the Secretary of State has recently refused planning permission for the redevelopment and expansion of the Eddie Stobart facility in Warrington.
National Planning Policy 8.48 The need for employment development should also be considered in the context of national planning policy. Paragraph 8 of the NPPF sets out that one of the three overarching objectives of the planning system is an economic one. It states that to help build a strong, responsive and competitive economy, the planning system should ensure that sufficient land of the right type is available in the right places and at the right time to support growth, innovation and improved productivity.
P/2017/0254/OUP Planning Committee 24th November 2020
8.49 Paragraph 80 of the NPPF states that planning decisions should help to create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future.
8.50 Paragraph 82 of the NPPF states that planning decisions should recognise and address the specific locational requirements of different sectors; including making provision for storage and distribution operations at a variety of scales and in suitably accessible locations.
Summary of the evidence 8.51 There is clear and compelling evidence that there is a significant need for new employment land in the Borough of St Helens, including large scale logistics. It is also clear that the market for employment land has changed significantly since the adoption of the Core Strategy in 2012 and the more modest requirements of 37 hectares of land up until 2027. The extent of change outlined effectively renders policies CSS1 and CE1 in the Core Strategy out of date. and means that they should only be given limited weight when considering this application. By contrast the evidence outlined above is up to date and has been prepared in accordance with National Planning Practice Guidance (NPPG). This means that that in the context of the NPPF, it should be given significant weight when assessing this application.
The Council’s assessment 8.52 If the site can be shown to be deliverable and attractive to the market, it follows that it would help meet the significant need for employment land as set out above and ensure that there is an appropriate pipeline of industrial buildings to enable the growth of the Borough’s economy.
8.53 The EEBP states that large scale logistics is the most active market in the region and a particular opportunity for the Borough of St Helens. It considers specific criteria to determine where distribution development should be located and takes into account issues identified in the Core Strategy and criteria of critical importance to occupiers and developers. The criteria established to meet the needs of large-scale employment development are summarised as follows:
• Minimum site area of 5 hectares. • 10 minutes or less drive time to motorway junction • Availability of HGV access. • Access from A570/A580/M6/M62 via the strategic and/or primary freight network as identified in the Core Strategy, avoiding roads used to access main urban residential areas • Good public transport access. • Separation from sensitive uses, including identified outdoor recreation and leisure facilities.
P/2017/0254/OUP Planning Committee 24th November 2020
8.54 In order to determine whether a site is likely to be deliverable and attractive to the market the EEBP criteria is a relevant consideration.
8.55 The application site is just over 42 hectares, located in close proximity to junction 23 of the M6. It is also in close to a labour market however it is not well served by public transport. The A580 provides a direct link from the site to the primary freight network. There are sensitive uses in the area, specifically Haydock Park Racecourse. However, in broad terms, the site meets the EEBP criteria and is considered to be deliverable and attractive to the market.
8.56 The application proposes a speculative development, but the EEBP states that this is not uncommon. Indeed, three out of four logistics buildings at Florida Farm and Haydock Green (originally granted outline permission and thus speculative) have now been constructed and are occupied. The applicant states that the site is immediately deliverable and will satisfy the high demand for additional, high quality large logistics floor space in the North West.
8.57 In summary, based upon the evidence, the proposed development can be considered deliverable and attractive to the market. It would assist in meeting the significant need for large scale logistics sites in the Borough.
Whether other sites could meet the need
Applicant’s case 8.58 The applicant has submitted an Alternative Sites Assessment (ASA) which states that there are no sequentially preferable sites to the application site capable of meeting the identified need for logistics development. It is worth noting that the applicant is of the view that there are no urban, brownfield or non-Green Belt sites of sufficient size that can provide the locational characteristics to accommodate large scale logistics to meet the current market need. No non-green belt sites progressed past stage 2 of the 4 stage assessment.
The Council’s assessment 8.59 The application proposes the delivery of 167,225 square metres of floor space on a site of 42.3 hectares. In the draft SHELMA and other planning applications submitted to the Council, it is generally accepted that the floor space of a B8 logistics building would take up around 40% of the area of a plot. It is therefore appropriate to apply this ratio when assessing whether other sites could accommodate the proposed development. Based upon a 40% building to site ratio, a 42 hectare site would be sufficient to physically deliver the proposed development (around the size of the application site). This is not, however, a ratio which is relevant to an assessment of the landscape or visual impact of a proposal or to impact on the openness and purposes of the Green Belt, which require a more sophisticated and nuanced assessment. On this simple basis for the purposes of an alternative sites assessment, however, there are no available sites of this size in the urban area or with planning permission to meet the identified need. Therefore, it is accepted that the proposed development could only be delivered in the Green Belt.
P/2017/0254/OUP Planning Committee 24th November 2020
8.60 For robustness, it is important to consider if the development could be disaggregated i.e. whether the floor space proposed for each of the development parcel shown on the parameters plan could be provided on other sites within the urban area or on sites in the Green Belt with planning permission. The applicant has submitted two illustrative masterplans. The smallest unit size proposed is 29,096 square metres, although the footprint is 22,298 square metres, as it includes provision for a mezzanine. Using the 40% calculation as outlined above it is relevant to assess whether sites of 5.6 hectares or above are available and suitable for large scale logistics buildings. This is lower than the applicant’s minimum site criteria of 12 hectares.
8.61 The EEBP assesses sites over 5 hectares that are identified in the Council’s employment land supply and considers them against the EEBP criteria to determine whether they would be available and suitable for a large-scale logistics development. The EEBP concludes that there are no available and deliverable sites in the urban area greater than 5 hectares that could accommodate a large-scale logistics building.
8.62 Planning permission has been granted for two units to the north of Penny Lane. One unit, the largest, has been constructed and occupied. The second site has a site area of 6.2 hectares and remains vacant. At least one of the smallest units (units 2 and 3 on both options 1 and 2 of the submitted illustrative masterplan) could be accommodated on this site
8.63 In summary, there are no sites within the urban area or with planning permission which could accommodate the proposed development in full. There are no sites in the urban area that could deliver the individual buildings. There is, however, one site with planning permission that could accommodate either unit 2 or 3 on both illustrative layouts. However, units 1 and one of 2 and 3 on either layout could only be accommodated within the Green Belt.
8.64 The applicant states that this site is considered to be sequentially preferable to other Green Belt sites within the Borough. Development of the application site would be harmful by definition. It is not therefore considered that other Green Belt sites are sequentially preferable alternatives or that this is site is sequentially preferable to other Green Belt sites. To demonstrate such a proposition, large parts of the Green Belt would have to be comprehensively assessed in terms of their specific balance of land use impacts (in accordance with the test of very special circumstances). This is not a helpful or relevant analysis to undertake. However, this does not detract from the applicant’s central contention that a site in the Green Belt is required to meet the identified need.
8.65 Paragraph 80 of the NPPF states that planning decisions should help to create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth taking into account both local business needs and wider opportunities for development.
8.66 The Council’s evidence, and the evidence submitted by the applicant shows that there is a significant demand for new employment land in the Borough. It also
P/2017/0254/OUP Planning Committee 24th November 2020
demonstrates that there is a lack of suitable employment land and premises available that could accommodate the large-scale logistics buildings proposed which would be attractive to the market.
8.67 It has been demonstrated that the proposed development would be deliverable and attractive to the market. It would make a significant contribution to the need for employment land in the Borough and this should carry significant weight in favour of the proposed development.
Whether there are economic benefits
Applicant’s case 8.68 The applicant’s case of very special circumstances identifies that the proposed development would have a significant positive economic benefit for the Borough of St Helens. These can be summarised as follows:
Construction phase • Generate up to £165 million investment; • Support up to 265 FTE jobs (gross) per annum on average during the 5 year construction period; • 80 direct net additional FTE jobs created in St Helens; • 20 FTE indirect and/or induced jobs generated within the construction chain in St Helens; and • Generate an uplift of £6.5 million gross value added (GVA) in St Helens; and £27 million GVA for the north west annually.
Operational Phase • Up to 2286 to 2758 gross FTE jobs when the development is completed and occupied; • Up to 1,035 indirect /induced net additional jobs; and • £6.2 million GVA for St Helens; and £159 million GVA for the north west annually.
The Council’s assessment 8.69 The benefits set out above are reported in the applicant’s economic statement and ES. In terms of investment into the local economy, it is difficult to assess the precise level of investment that would be brought about by the proposed development, however, on the basis of previous similar developments, it is likely to be significant.
8.70 The development is speculative and so there is no certainty over the level of jobs that would be created. The figures suggested by the applicant are based upon the Homes and Communities Agency (2015) Employment Densities Guide, 3rd Edition. This is an appropriate means of calculating the number of people that could be employed on the site and consistent with how other similar applications have been assessed. The conclusions reached on this basis are also considered to be reasonable.
8.71 The proposed development would result in a significant investment into the local economy and would create/support a number of jobs during the construction and
P/2017/0254/OUP Planning Committee 24th November 2020
operational phases. This should be given significant weight in favour of the proposed development.
Whether there are social benefits
Applicant’s case 8.72 The applicant states that economic activity rates and the employment rate are relatively low in St Helens where the unemployment rate is high. The Borough is one of the most deprived in the country being ranked 26th of 317 local authorities in the Indices of Deprivation 2019. St Helens is relatively more deprived now than it was in 2015. Employment and health related matters are significant contributors to deprivation, which highlights the importance of providing access to employment opportunities. Further, the application site is located close to a large number of localised areas which are ranked within the 10% most deprived neighbourhoods in the country.
8.73 The applicant thus submits that the proposed development has the potential to positively and significantly address the socio-economic needs in the Borough, both now and in future. The development will provide job opportunities in a range of occupations with average earnings between £21,402 and £42,047 per annum. They say that this will help to provide opportunities for people currently seeking a job.
8.74 The applicant states that enhancing local labour and supplier uptake of local employment and contract opportunities is an important priority for the Council. A Draft Local Employment Strategy (LES) that ensures that the benefits for local people and business are occupied during each phase of the development. The LES can be secured through a planning obligation.
The Council’s assessment 8.75 The social benefits outlined above are considered to be a reasonable reflection of the benefits of the development. There is no guarantee that the development would give jobs to those in the highest areas of deprivation, but jobs would be created. The site would be accessible and a planning obligation or condition could secure a detailed LES that will require that recruitment is directed towards local people in deprived areas. In particular, the applicant has said that funding will be made available to enable access to opportunities for apprentices in particular. The applicant also proposes to provide funding for a bus service to increase accessibility to the site more generally. There is therefore a reasonable prospect of the development making a small contribution to tackling deprivation in the Borough (through either direct, or indirect impacts). This should be given modest weight in favour of the proposals.
Whether there are environmental benefits
Applicant’s case 8.76 The applicant states that the development will enhance the overall ecological value of the site and improve drainage management and improve the water environment and flood risk regime downstream.
The Council’s assessment
P/2017/0254/OUP Planning Committee 24th November 2020
8.77 The purpose of ecological enhancement and drainage improvements are to accommodate the proposed development and mitigate and compensate for the harm caused. It is therefore not appropriate to consider these matters as material benefits of the scheme, when they essentially mitigate and compensate for the impact of the proposal.
Conclusion on Very Special Circumstances 8.78 Paragraph 80 of the NPPF states that planning decisions should help to create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth, taking into account both local business needs and wider opportunities for development.
8.79 The evidence shows that there is a significant need to deliver employment land in the Borough of St Helens. The proposed development would make a significant contribution to the employment land supply in accordance with the increased requirement in the OAN. The site is of a scale and in a location that is attractive to the market. There are no other sites in the urban area that could accommodate this type and scale of development. There is one site with planning permission that could accommodate the smaller units shown on the illustrative masterplans.
8.80 The proposed development is immediately deliverable and attractive to the market. Notwithstanding this, the quantitative need is such that if planning permission were to be granted, it would not necessarily preclude other sites being promoted inside or outside the Green Belt provided that the relevant statutory and planning policy tests could be met. Granting planning permission would not set a precedent either, as each site would have to be judged on its own merits. There is no potential “floodgates” argument and no identifiable precedent site.
8.81 The applicant has also shown that the proposed development would deliver significant economic benefits during the construction and operational phases, in terms of investment into the Borough and direct and indirect jobs created. Some modest social benefits would also be delivered because there is a reasonable prospect of the development making a small contribution to tackling deprivation in the Borough.
8.82 Thus the applicant has demonstrated that the proposed development will deliver benefits that should be given significant weight in favour of the development. This must be weighed against the substantial harm caused to the Green Belt and any other harm.
Harm to openness 8.83 Paragraph 133 in the NPPF states that 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; their essential characteristics are their openness and permanence.
8.84 Saved Policy GB2 in the Unitary Development Plan states that development in the Green Belt will be judged against: whether it is appropriate in terms of its siting,
P/2017/0254/OUP Planning Committee 24th November 2020
scale, design, materials and landscaping and does not detract from the openness of the Green Belt.
8.85 The applicant states that the impact of the proposed development on the openness of the wider area of Green Belt is not considered insignificant, but the site’s physical context reduces its visibility and perceived impact on the openness of the wider area from publicly accessible areas. Thus, the development will have limited direct impact on the ability of the wider Green Belt function in this area to be permanently retained.
8.86 The site is a flat open area of fields mainly in agriculture. Development of 167,225 square metres of employment floor space up to 21.5 metres high would have a significant adverse impact on the openness of the Green Belt in this location as a matter of fact, contrary to saved policy GB2 of the UDP. The applicant’s view that the physical context reduces visibility and thus the perceived impact on openness, is not accepted. There would be a loss of visual openness and an area of open countryside between the defensive edge of Haydock, formed by the M6 motorway, and Golborne that would result in significant harm contrary to saved policy GB2. Whilst the impact of the Parkside Phase One development was also considered to be significant it was within the context of a site that was previously a deep coal mine, partly previously developed land and a ‘man made’ landscape including spoil heaps. This is a flat, relatively open landscape that has not previously accommodated built development or any man-made features. The harm to openness is significant and weighs against the development in the planning balance.
Whether there is harm to the purposes of including land within the Green Belt 8.87 Saved Policy GB2 states that development in the Green Belt will be judged against criteria including whether it conflicts with the purposes of including land within the Green Belt.
8.88 Paragraph 134 of the NPPF and Saved Policy S1 in the St Helens UDP identify the purposes of including land in the Green Belt as: • To check the unrestricted sprawl of large built up areas • To prevent neighbouring towns from merging into each other • To assist in safeguarding the countryside from encroachment • To preserve the setting and special character of historic towns and, • To assist in urban regeneration by encouraging the recycling of derelict and other urban land.
8.89 The applicant has assessed the development in relation to the purposes of including land in the Green Belt. They conclude the following:
• Unrestricted sprawl – moderate harm • Neighbouring towns merging – low harm • Encroachment into the countryside – moderate harm • Historic towns – no harm • Assist urban regeneration – no harm
P/2017/0254/OUP Planning Committee 24th November 2020
To check the unrestricted sprawl of large built up areas 8.90 This application proposes development outside of the defined urban area and would expand the built-up area. It is acknowledged that there are definitive boundaries to the south and west of the site (the A580 and the A49). However, the proposed development clearly conflicts with this purpose.
To prevent neighbouring towns from merging into each other 8.91 The development would bring the existing urban area of Haydock closer to Golborne to the east. There would be a gap of approximately 770 metres between the two urban areas. The areas of Haydock and Ashton are in relatively close proximity. The development would not necessarily bring those settlements closer together. The development would not cause the settlements to physically merge but there would be an increased perception of the built up areas coming together in the landscape as the boundaries will be much closer.
To assist in safeguarding the countryside from encroachment 8.92 The site is open land that lies outside the urban area and reads as part of the countryside. Allowing the development would result in encroachment into the countryside, the scale of which would be significant. The proposed development would conflict with clearly with this purpose.
To preserve the setting and special character of historic towns 8.93 None of the settlements in the surrounding area are identified as historic towns and so there is no conflict with this purpose.
To assist in urban regeneration by encouraging the recycling of derelict and other urban land 8.94 The proposal does not assist in urban regeneration by encouraging the recycling of derelict and other urban land. There is conflict with this purpose. However, there are no sites in the urban area which could be recycled to deliver this development.
Summary of Impacts on the Green Belt 8.95 The application proposes inappropriate development in the Green Belt and would be contrary to three of the five purposes. It would have a significant impact on openness, contrary to saved policy GB2. Substantial weight should be given to the harm by way of inappropriateness, together with significant weight to the conflict with purposes and harm to the openness.
Other Harm 8.96 As set out in Paragraph 144 of NPPF, when assessing whether very special circumstances exist, it is also necessary to weigh any ‘other’ harm into the planning balance. This report will now consider the ‘other’ impacts of the development and identify whether they cause harm.
Transport 8.97 Paragraph 111 of the NPPF states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment.
P/2017/0254/OUP Planning Committee 24th November 2020
8.98 Paragraph 109 of the NPPF states that development should only be prevented or refused on highway grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.
8.99 Paragraph 103 of the NPPF states that significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions and improve air quality and public health.
8.100 Paragraph 108 states that in assessing applications for development it should be ensured that appropriate opportunities to promote sustainable travel modes can be – or have been – taken up given the type of development and its location, safe and suitable access to the site can be achieved for all users and any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree.
8.101 Paragraph 106 states that maximum parking standards should only be set where there is a clear and compelling justification that they are necessary for managing the local road network, or optimising the density of development in a location that is well served by public transport.
8.102 Policy CP2 states that new developments will be expected to: provide safe and adequate vehicular, cycle and pedestrian access to and from and circulation within a site, provide adequate on-site parking that does not exceed the Council's maximum standards, only take direct access from the primary route network where it does not restrict the capacity of the road or its intended purpose and where a reasonable alternative exists direct access will not be permitted.
8.103 It goes on to state that new developments are expected to locate to sites where there is the potential for users to walk or cycle to the site and/or the provision of cycle and walking facilities within the site, and/or the improvement of routes or facilities which serve the site and, locate to sites where there is good access to the public transport network and/or the provision of public transport facilities within the site and/or the improvement of public transport facilities which serve the site.
8.104 The Policy further states that significant generators of traffic should be: located within 800m or 400m of safe and convenient walking distance of stations and bus stops serving a high frequency route respectively, located on sites which are served by rail or where rail facilities can be provided as part of the development or where this option is not available locating where there is a good access to a road designated as a Freight Priority Route.
8.105 Policy CSS1 in the Core Strategy states that the main focus for economic development will be previously developed land in sustainable locations within the M62 link corridor and Haydock Industrial Estate because of their proximity to the primary and strategic road network. The policy also states that the following regeneration activity will be supported: better links between areas of deprivation and economic development by promoting activity on sites within or in close proximity to
P/2017/0254/OUP Planning Committee 24th November 2020
areas of deprivation or those with good public transport access, and measures for improving links between employment and residential areas.
Impact on the Highway Network 8.106 A Transport Assessment (TA) has been submitted with the application which assesses the impacts of the development on the strategic and local highway networks. The TA assesses the impact of the proposed development during typical traffic conditions, it cannot be expected to take into consideration traffic flows during exceptional circumstances (e.g. road traffic collisions or road closures). It is also unnecessary unless off-peak and inter-peak flows are noted to be close or higher to the peak hour network flows. They are not in this case.
8.107 The scope and inputs into the TA have been reviewed by Mott Macdonald, on behalf of the Council, and Highways England. It is considered to be acceptable.
8.108 The following junctions have been assessed in St Helens:
• M6 J23 • A580 / Proposed Site Access • A49 / Proposed Site Access • A49 Lodge Lane / A599 Penny Lane • A580 Haydock Lane
8.109 A number of submissions have been made, but the junctions have ultimately been assessed on the basis of 2024 (opening year, with and without the development and mitigation) and 2027 (future year with the existing layout and mitigation layout).
8.110 Mott MacDonald state that the scope of the junctions included is sufficient to determine the impact arising from the development on the surrounding network.
8.111 The operation of the M6 J23 Haydock Island with the development and proposed mitigation improves when compared to the current situation. Mitigation involves widening the A580 east and west approaches to enable extended queueing for the dedicated left-turn lanes, to reduce blocking of the ahead lanes. The scheme also includes widening of the A580 eastbound and westbound ahead lanes through the middle of the at-grade hamburger below the M6. In terms of the A49 arm, the A49 approach to the junction would be removed but still allow traffic to exit Junction 23 northbound. The proposed scheme, including part closure of the A49 arm, mitigates the impact of the traffic from the development in both 2024 and 2027.
8.112 The proposed site access on to the A580 comprises the formation of a new three-arm signalised junction. It includes the minor realignment of the A580 eastbound carriageway to enable widening of the westbound carriageway into the central reservation to provide a segregated right turn lane. The scheme also includes the provision of a crossing facility as the junction will connect a proposed share-use path with an existing footway to the south of the A580.
P/2017/0254/OUP Planning Committee 24th November 2020
8.113 The junction will operate within practical capacity (90%) in both 2024 and 2027. Mott MacDonald has confirmed that the design of the scheme is therefore suitable.
8.114 The site access from the A49 is proposed to be a three-arm roundabout. The roundabout will enable access from J23 via a northbound approach. No traffic would be permitted to join J23 from the roundabout, so no corresponding exist arm is proposed.
8.115 The road safety audits highlighted some minor issues in the designs which have been addressed by the applicant. As such, Mott MacDonald has confirmed that the proposed mitigation and site access schemes are suitable in design and forecast operation.
8.116 A mitigation scheme to signalise the junction of the A49 Lodge Lane/A599 Penny Lane was developed in support of the development at Haydock Green (north of Penny Lane). The scheme has been implemented and has been in operation for around 12 months. The junction will continue to operate within capacity and is suitable to accommodate the traffic generated by the development.
8.117 The A580/Haydock Lane will operate within capacity and is suitable to accommodate the traffic generated by the development.
8.118 Overall, the modelling undertaken to determine the impact of development traffic at the junctions within the St Helens highway network shows that there would not be a severe impact in terms of capacity, subject to implementation of mitigation. The modelling is valid and acceptable.
Internal Spine Road and Access Roundabout 8.119 The developer proposes to realign the A49 through the site. This is based on partial closure of the A49 approach to Junction 23, with full closure a possibility in the future. As a result, the site spine road/realigned A49 carriageway will need to be delivered prior to the A49 approach to Junction 23 being closed-off. This will mean that the site access junctions, spine road and internal roundabout junction will need to be completed prior to closing the A49 approach to Junction 23. The infrastructure proposed needs to take account of this and ensure that this primary local route can be accommodated based in the proposed infrastructure.
8.120 The new route will form the access road into a major logistics development and as well as part of the primary road network in St Helens Borough. The route forms part of the reserved matters section of the application so Mott MacDonald has recommended a specific condition with respect to the proposed realignment of the A49. The applicant has submitted the application with access to be considered but limited to the physical points of access with the highway network only.
8.121 Article 5 of the Town and Country (Development Management) (England) Order 2015 states that where access is a reserved matter, an application for outline planning permission must state the area or areas where access points to the development proposed will be situated. Access is defined in article 2 and states that it means the
P/2017/0254/OUP Planning Committee 24th November 2020
accessibility to and within the site, for vehicles, cycles and pedestrians in terms of the positioning and treatment of access and circulation routes and how these fit into the surrounding access network. The realigned A49 proposed by the development here falls within the definition of access.
8.122 It is accepted that the scheme will need to go through a design review and road safety audit as it is developed. However, the alignment of the A49 and internal site infrastructure as shown on the parameter plan can and should be secured by condition.
Compliance with Policy CP2 8.123 The development would provide for safe and adequate vehicular access to the public highway. However, policy CP2 requires that developments that generate significant movements of freight be located on sites which are served by rail or where rail facilities can be provided as part of the development, or where these options are not available, locating where there is good access to a road designated as a Freight Priority Route. The proposed development would not be served by rail, but would have access to the freight network. There is therefore compliance with CP2 in this regard.
Sustainable Travel 8.124 The applicant has applied the accessibility standard assessment required by the Ensuring Choice of Travel Supplementary Planning Document (SPD). The assessment shows that the site does not comply with the location criteria that encourages development to be located in areas with the best levels of access, such as town or local centres. However, the applicant explains that given the proposed use for B8/B2 uses, the location will ensure that HGV traffic is not routed through residential areas and local roads that would give rise to unacceptable impacts. Development of the site will primarily give rise to local trips from employees travelling to and from work. The assessment demonstrates that there are suitable facilities for walking and cycling to and from the site. There are existing bus stops that can be accessed on Lodge Lane within 400 metres of the proposed A49 site access roundabout. However, this distance is increased significantly for access to the proposed buildings on the site. The stops are served by a single service that does not connect at interchange point for inward rail or bus journeys.
8.125 It is acknowledged that a B8/B2 development is best located away from local roads as far as possible and is close to the strategic road network. However, the development does not comply with the Core Strategy in terms of accessibility. Mott MacDonald has recommended the operation of a shuttle bus service between the site and the recently upgraded Newton-le-Willows Railway Station.
8.126 The applicant has submitted a framework travel plan. It includes the description of the role of a travel plan co-ordinator; measures to be set out in detail in a full travel plan; targets, including a 10% reduction in single occupancy vehicle trips; as well as monitoring measures and surveys. The applicant has also committed to the provision of a subsidised bus service, including a financial contribution of £1 million, where linkages with rail and bus stations in the Borough and the site would be facilitated.
P/2017/0254/OUP Planning Committee 24th November 2020
8.127 A full travel plan will need to be prepared that builds on the commitments in the submitted framework, but that is aligned with the needs and operation of the occupiers of the site. This should include for the provision of a shuttle bus service from Newton-le-Willows Railway Station; contain details of the level and nature of cycle parking; and on-site facilities such as showers and lockers. Perhaps most importantly, there should be specific measures to promote and monitor sustainable travel to and from the site relating to the workforce. Information such as staff postcode data, travel patterns and shift times should be used to formulate and demonstrate the appropriateness of proposed travel plan targets, commitments and measures. All of the above can be secured by appropriately worded condition and/or planning obligation.
Accommodating HGV parking facilities 8.128 Paragraph 107 of the NPPF states that planning decisions should recognise the importance of providing adequate overnight HGV parking facilities, taking into account any local shortages to reduce the risk of parking in locations that lack proper facilities or could cause a nuisance. It states that proposals for new or expanded distribution centres should make provision for sufficient HGV parking to cater for their anticipated use.
8.129 The applicant has stated that a delivery management plan would be in place for the site such that issues arising from HGV’s are unlikely to arise. The plan also includes provision of a £25,000 contribution to the Council as a ‘safety net’ for provision of facilities including a traffic regulation order if considered to be appropriate. The latter has only just been put before the Council and is subject to consultation with the LHA. However, the proposed parameters plan and the two illustrative masterplans do not identify any areas that could be used for overnight lorry parking. However, a condition is recommended that requires reserved matters applications to provide these facilities and demonstrate that the level of provision is adequate. Subject to this condition, it is considered that the proposed development accords with Paragraph 107 of the NPPF.
Summary of transport impacts
8.130 The site is well located relative to the strategic road network and subject to conditions securing the mitigation stated, the proposed development would not have a severe impact on the highway network such that it and complies with the provisions of the NPPF. There would be some queueing and delay at some junctions which should weigh against the proposed development in the planning balance. The site lies in close proximity to a local labour, although access to public transport needs to be improved. Provision of lorry parking should be included in reserved matters proposals. Conditions to secure appropriate forms of sustainable transport can be used to access the development site. Such that the proposed development complies with the relevant parts of NPPF and policies CSS1 and CP2.
Ecology
8.131 Paragraph 170 of NPPF states that planning decisions should contribute to and enhance the natural and local environment by minimising impacts on and providing net gains for biodiversity. Paragraph 175 states that when determining applications, local planning authorities should refuse permission if significant harm to biodiversity
P/2017/0254/OUP Planning Committee 24th November 2020
cannot be avoided or adequately mitigated; and opportunities to incorporate biodiversity improvements in and around developments should be encouraged – especially where this can secure measurable net gains in biodiversity.
8.132 Policy CQL3 reflects this, but also requires that all development proposals are based on ecological assessments where appropriate and that developments affecting protected species will only be acceptable if there is clear evidence that the development outweighs the nature conservation interest.
8.133 Policy CQL2 states that the multipurpose value of tree, woodlands and hedgerows will be protected and enhanced by:
• requiring developers to plant new trees, woodlands and hedgerows on appropriate sites; • to conserve, enhance and manage existing trees, woodlands and hedgerows; • ensuring that development does not damage or destroy any tree subject to a TPO or any tree of value unless there is a clearly demonstrated public benefit, and where trees are justifiably lost they should be replaced on at least a 2:1 ratio; and • supporting proposals which assist in the positive use of woodlands for green infrastructure purposes including recreation, education, health, biodiversity and economic regeneration.
8.134 The application site consists of a central watercourse that divides the site into two arable fields. Haydock Park Woods lies on the eastern boundary and is a designated local wildlife site (LWS). Lady’s Hill Plantation s also to the east. Highfield Moss is the closes site of special scientific interest (SSSI) and is 2.7 kilometres to the south east.
8.135 The nearest European Protected site is the Manchester Mosses Special Area of Conservation. It if 9.5 kilometres east. A habitats regulations assessment of likely significant effects using source-pathway- receptor model has been undertaken and concludes that there are no likely significant effects. MEAS agrees with this assessment.
8.136 The central watercourse or ditch supports water voles, a protected species. Trees in the LWS support bat roosts and bats forage over the site. The applicant states that there is little other botanical or faunal value. A boundary hedgerow lining the ditch is given priority under section 41 of the Natural Environmental and Rural Communities Act (NERC).
8.137 The site is used by a range of farmland birds. Surveys carried out by the applicant indicate that that the site is regularly used by a flock of lapwing, also protected under section 41 of the NERC Act. It is a species of local significance and not linked to the Mersey Estuary Special Protection Area lapwing population.
8.138 The development would result in the loss of around 40 hectares of farmland that the applicant says is of negligible ecological value.
P/2017/0254/OUP Planning Committee 24th November 2020
8.139 The applicant has included several habitat creation measures embedded into the design of the scheme. Water vole would be protected by measures implemented through the construction phase as well as enhancements to the ditch and provision for long term habitat management and monitoring.
8.140 The applicant accepts that the lapwing would be displaced from the site. However, other bird species would benefit from the provision of new woodland and grassland created within the site.
8.141 Overall, the applicant states that the net effect of habitat creation will be positive. Mitigation for wintering birds will be provided and there will be 10% biodiversity net gain by measures on site and increasing the area available for wintering birds on the applicant’s land. This would be secured by a s106 agreement.
8.142 MEAS has raised no objection to the proposals and state that the submitted Green Infrastructure Mitigation Plan should be adopted as an approved document. Two landscape strategy option drawings have been submitted to accord with the two illustrative masterplans. MEAS agrees that either option is acceptable from an ecological perspective.
8.143 MEAS has advised that a full landscape and habitat management plan should include completed details of management of the central ditch post-development. Undertaking the water vole mitigation strategy should be secured by condition. Similarly, conditions set out in paragraph 4.8 above should be attached.
8.144 The proposed development would not have an unacceptable impact on protected species or their habitat, subject to conditions securing the implementation of mitigation measures. Further, although the proposed development would cause a loss of habitat, sufficient mitigation and compensation, including 10% biodiversity net gain.. The proposed development would therefore accord with the requirements of policies CQL2, CQL3 and the NPPF. Whilst the proposals would mitigate and compensate for the loss of habitat and biodiversity, there would be harm in the planning balance.
Archaeology
8.145 Saved Policy ENV23 in the Unitary Development Plan states that in considering development proposals affecting archaeological sites or remains the Council will require developers to take full account of known or anticipated archaeological remains in their proposals and normally refuse planning permission if in the opinion of the Council, insufficient information is provided to determine the archaeological impact of development; the development would prejudice the preservation of archaeological features where they are found; in those situations where preservation is not feasible, adequate provision has not been made for the excavation and recording of the site.
8.146 The applicant states that the main impact of the development is during the construction phase. There are no designated heritage assets either within or in the vicinity of the site and so there would be no impact during operation of the
P/2017/0254/OUP Planning Committee 24th November 2020
development. Any impact would only arise were the development to be decommissioned.
8.147 There is a single non-designated heritage asset, Haydock Park, directly affected by the development. It is a former medieval deer park. The applicant states that the magnitude of the impact is moderate adverse, the significance of the effect is low adverse and so the overall effect is not significant, mainly because the majority of features are no longer present. This is a reasonable assessment of the position.
8.148 In terms of remaining interest, the applicant states that the potential for and location of any surviving archaeological evidence is not clear, and that that it would be of moderate to negligible heritage significance in any case. The applicant proposes to undertake a geophysical survey followed by targeted archaeological investigation of any areas shown to have high archaeological potential as a result of that survey. The applicant has proposed a scheme of archaeological mitigation in the environmental statement. MEAS has advised that this is acceptable and should be secured by condition. There is compliance with ENV23 as a result.
Landscape, Design and Visual Impact
8.149 Paragraph 170 in the NPPF states that the planning decisions should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan). Further, the decision should recognise the intrinsic character and beauty of the countryside as per paragraph 170(b). Paragraph 171 states that distinctions should be made between the hierarchy of internationally, nationally and locally designated sites so that protection is commensurate with their status and gives appropriate weight to their importance.
8.150 Policy CQL4 states that landscape character will be protected, preserved and enhanced by ensuring all new development respects the significance and distinctive quality of landscape character and that it is of a high standard of design reinforcing the Borough of St Helens’ local distinctiveness.
8.151 The St Helens Landscape Character Assessment states that the area is generally unsuitable for development due to its strong intact character and varied of well- established land uses. It states that there may be limited opportunities for small scale development to reflect existing patterns of development, avoiding fragmentation of the landscape. This is not a small-scale development.
8.152 The applicant states that during the construction phase, there would be a short-term impact on the immediate surrounding landscape because the retention of landscape features around the site would help to reduce the impact. It is considered that there would be a moderate impact during this phase. Notwithstanding that the activities would be temporary, significant earthworks would be undertaken within the site that would impact upon the surroundings..
P/2017/0254/OUP Planning Committee 24th November 2020
8.153 There would be a significant and permanent change to the landscape during the operational phase. It is accepted that from distant viewpoints in particular, it would perhaps read as part of the urban area. However, the Countryside Development and Woodlands Officer has stated that the development is of such a scale that it does not fit into the landscape. In particular, there is a fundamental issue of the impact of the scale of the development on the wider landscape and the narrowness of the proposed landscape buffer zones, which has a limited impact on mitigating the impact of buildings of very substantial primary mass, together with the proposed road and ancillary development and activity..
Re-routing of the A49 Lodge Lane 8.154 The proposal is to divert a key highway through the site. However, the Countryside Development and Woodlands Officer is concerned that the landscaping being provided along this new corridor is of relatively poor quality. This is exacerbated by the need to retain a relatively open grassy embankment down to the watercourse, as a result of the need to protect water voles, along which the road would be located. More space should be available for landscaping along the diverted A49 route including a formal avenue of trees. MEAS has expressed concern about planting along the watercourse. However, the Countryside Development and Woodlands Officer has said that an avenue of trees planted along the upper slopes of the habitat, away from the water may be appropriate. This would not compromise the water vole habitat but would provide some positive visual features that help to break up the internal, industrial landscape along what will be a heavily used, key highway route. The existing A49 lies within a green corridor with wide grass verges, hedges and trees along its length. It would be appropriate to request that the diverted the route should have similar positive landscape features.
8.155 Illustrative master plan option 2 plans shows cross docking of buildings, which is welcomed, as this will pull the buildings away from the perimeter. However, the plan is illustrative and option 1 shows the buildings close to the boundary. Whilst cross docking is highly likely, it is an operational issue and not something that the Council can require.
Wider Landscape Impact 8.156 In terms of the site as a whole, there needs to be sufficient space to create landscaping that will allow adequate screening and enable the development to be integrated into the wider landscape. There also needs to be space to create a variety of habitats and provide opportunities for biodiversity.
8.157 The parameter plan shows a landscape zone with a minimum depth of 15 metres for woodland planting, grassland, meadow, scrub and reed beds along the northern, eastern and western boundaries. The Countryside Development and Woodlands Officer states that a 15-metre landscape strip is relatively narrow. It would not facilitate the development of a woodland and would accommodate two overlapping trees at best . As a result, the ability to screen and integrate the buildings into the landscape is highly limited, especially given the proposed primary scale of these buildings.
P/2017/0254/OUP Planning Committee 24th November 2020
8.158 The parameters plan shows a 15-metre strip of trees with a narrow no build zone identified to the rear at the junction of Lodge Lane and the East Lancashire Road. The parameter plan and the illustrative masterplans also show the provision of a SUDs features in this location. This is a key focal point of the scheme where design and landscaping are critical. Whilst a condition to ensure the features of the parameter plan are implemented can be attached, including the no build zone, there would still be development in this location, such that car parking would essentially form a key view of the scheme.
8.159 The Countryside Development and Woodlands Officer agrees that the landscaping proposals along the East Lancashire Road have been improved, but the landscape buffer remains inadequate. The scheme also fails to deliver locally distinctive design where there is an opportunity to do so. For example, the existing units located at Omega fronting the M62 are sited between 90 and 100 metres from the carriageway. In this case, the distance would be in the region of 40 metres. In addition, the parameter plan shows the location of a 5-metre high acoustic fence along the site frontage. The requirement for this is discussed below, but the applicant’s assessment actually shows that the fence is required along the majority of the frontage (see paragraph 187) The buildings and the acoustic fence would be imposing features within the landscape and overall, would appear as incongruous features in this context.
8.160 There is a similar issue at the site access, where a narrow no build zone and landscaping strip is identified immediately adjacent to the development parcel. Ideally, there would be a grassland buffer to ensure mature landscaping provides a context within which the building would site. However, it is too close to the junction and again, the building would appear out of place.
8.161 In the north of the site, the development parcel shown on the parameter plan is in close proximity to the boundary with Haydock Park Racecourse. Ideally, the distance here would be wider to accommodate grassland and woodland planting. The Countryside Development and Woodlands Officer states that there are buildings adjacent the northern boundary of the site that have been used by barn owls for roosting and nesting. A grassland strip here would allow such species to above to hunt along the boundary and link to suitable habitat in the locality. Notwithstanding this, it is good practice that when designing a woodland edge, not only are marginal woodland species used to create a woodland belt, but marginal woodland rough grassland is also created, as this helps to protect the buffer of the woodland and allow woodland birds / mammals to continue to still forage along a key area which is the woodland edge.
8.162 The north eastern boundary of the site does have a wider woodland buffer. It appears to primarily be focused around the no build zone that would primarily accommodate car parking. This feature appears to be as a result of the land ownership boundaries and again, would appear out of character with the landscape and the remainder of the development.
8.163 Whilst the applicant believes that the effect on landscape character would be moderate to minor adverse, the scale of the development within the landscape and
P/2017/0254/OUP Planning Committee 24th November 2020
landscaping scheme proposed means that there would be a significant adverse impact. The development would be an incongruous addition, where insufficient mitigation and integration into the landscape has been proposed. The development would be contrary to policy CQL4 and the harm caused would weigh significantly against the development.
Visual Impact 8.164 Policy CP1 requires that new developments are sympathetic to surrounding land uses and occupiers, avoiding detrimental impacts on the amenities of the local area, in particular residential amenities. The policy also requires that new developments minimise and mitigate the effects of pollution.
8.165 The applicant has identified a number of visual receptors including public rights of way, highways and residential locations (including a rehabilitation facility and hotel) and has undertaken an assessment of the likely significance of the impact.
8.166 The applicant states that the greatest visual effects as a result of the construction phase are where low-level views are possible and where there is no screening. The applicant states that the public views (public rights of way and highways) would result in a moderate adverse to negligible. For private views (primarily from residential sites), there would be a significant amount of change, but it would result in a moderate adverse to negligible effect during construction. This conclusion is accepted as the impact would be temporary.
8.167 During the operational phase, the greatest adverse impacts are experienced by those closest to the site. In terms of private views, whilst the applicant states that there are a number of urban features present, the development would increase the urban area, resulting in a significant change. It is accepted, though, that the significance of the change reduces the more distant the receptor or more oblique the view. The applicant states that the effect of the development is mitigated by the proposed landscaping.
8.168 It is accepted by the applicant that the greatest adverse visual effects are on private views again for those closest to the site, primarily as a result of the replacement of open views across farmland with prominent and permanent built structures.
8.169 The views available to the south are relatively open and so views from Haydock Park Farm and Haydock Park Farm Cottages would result in a moderate adverse impact, with relatively open views from upper storeys at these properties.
8.170 The buildings would be visible from Haydock Park Racecourse above the existing trees, particularly as there are a number of elevated positions within the Racecourse site. The existing view does contain some manmade elements, but the development be in close proximity to the boundary and out of character with the landscape. The impact would be moderately adverse.
8.171 The development would also be a prominent feature from the Holiday Inn to the north off Lodge Lane, similar to the Racecourse. However, the impact would be minor adverse because of the nature of the business.
P/2017/0254/OUP Planning Committee 24th November 2020
8.172 The distance of the other private views from the site, including Haydock Park Gardens, would be minor adverse. There would be no overshadowing for example or direct impact on residential amenity in this regard. The applicant states that this would reduce to negligible over time, but given the nature of the landscape scheme and the height of the buildings, this is considered to be unlikely.
8.173 There would be limited harm to longer range views private and public views of the site, with most harm caused to private views in the vicinity of the site, as per policy CP1. Accordingly, this harm should be given moderate weight against the proposed development in the planning balance.
Conclusion on Landscape and Visual Amenity 8.174 The landscape and visual assessment carried out by the applicant has not been fully reasoned and appears to significantly underassess the residual effects in both landscape and visual terms. To allow the development would be contrary to policy CP1 of the Core Strategy. This must be given significant weight against the proposed development in the planning balance.
Air Quality
8.175 Paragraph 181 of the NPPF states that planning policies and decisions should sustain compliance with and contribute towards relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas (AQMAs) and the cumulative impacts of air quality from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management and green infrastructure provision and enhancement.
8.176 The NPPG advises that the Ambient Air Quality Directive 2008 sets legally binding limits for concentrations in outdoor air of major air pollutants (EU limit values) that
impact public health such as particulate matter (PM10 and PM2.5) and Nitrogen
Dioxide (NO2). As well as having direct effects, these pollutants can combine in the atmosphere to form ozone. Dust can also be a planning concern, for example, because of the effect on local amenity.
8.177 Poor air quality can have health impacts, and this is reflected in the EU Limit Values referred to above. The Limit Values are annual mean concentrations of 25µg/m3 3 (micrograms per cubic metre) for PM2.5 and 40µg/m for both PM10 and NO2. The annual mean should be applied at locations where members of the public might regularly be exposed to, such as the building facades of residential properties, schools, hospitals etc. If the pollutant level is below the EU Limit Values then it is largely regarded that there is an acceptable impact on health.
8.178 The NPPG states that air quality may be relevant to a decision if the development is likely to have an adverse effect on air quality in areas where it is already known to be poor, particularly if it could affect the implementation of air quality strategies and action plans and/or breach legal obligations (including those relating to the conservation of habitats and species).
P/2017/0254/OUP Planning Committee 24th November 2020
8.179 Policy CP1 states that all proposals will be expected to manage and mitigate against the effects of pollution caused by developments, and that development which would impact on AQMAs will require special consideration with regard to their impacts on air quality.
Construction Phase 8.180 During the construction phase, the main impacts on air quality would be from dust and construction traffic.
8.181 Dust would be a risk to users of the surrounding highway network, including the A580 and other sensitive receptors, including housing, in the vicinity. The applicant states
that there will be increases of nitrogen dioxide (NO2 ) and particulate matter (PM10) but that it will be negligible. In addition, the standards set out in the relevant DEFRA guidance would not be exceeded. The impact would not be significant, therefore.
8.182 For construction traffic, the applicant predicts that there would be an increase in NO2
and PM10 at all but one location, but there would generally be a negligible impact. There would be a moderate increase at a property at the junction on Ashton Road, close to the junction with Crow Lane East (1.3 kilometres directly south of the site). However, the relevant DEFRA guidance standards are unlikely to be exceeded. Overall, the applicant states that the impact is not significant. The impact would also be temporary and short term.
8.183 On the basis of advice from the Council’s Environmental Health Officer, the applicant’s assessment can be accepted.
Operational Phase 8.184 The main impact of the operational phase on air quality is from an increase in road
traffic. Again, there would be increases of NO2 and PM10 at receptors, but the applicant states that it would be negligible. Exceedance of the relevant DEFRA
guidance is unlikely. The applicant states that the predicted increase in levels of NO2
and PM10 would not be significant.
8.185 The applicant’s assessment is appropriate. There is no objection from the Council’s Environmental Health Officer subject to attaching conditions concerning he provision of electric charging points, implementation of a travel plan and implementation of the mitigation measures set out in the environmental statement. These measures include
Conclusion of Air Quality
8.186 In summary, the proposed development would result in an increase NO2 and PM10 in some locations but there would be no exceedance of levels set out in DEFRA guidance, nor would there be a significant impact overall. Accordingly, the proposed development would comply with the relevant sections of policy CP1 and the NPPF.
Noise & Vibration
8.187 Policy CP1 requires that new developments are sympathetic to surrounding land uses and occupiers, avoiding detrimental impacts on the amenities of the local area,
P/2017/0254/OUP Planning Committee 24th November 2020
in particular residential amenities. The policy also requires that new developments minimise and mitigate the effects of pollution.
8.188 Paragraph 180 in the NPPF states that planning decisions should ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. In doing so they should mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life as set out in the Noise Policy Statement for England.
8.189 The NPPG states that local planning authorities’ decision taking should take account of the acoustic environment and in doing so consider: whether or not a significant adverse effect is occurring or likely to occur; whether or not an adverse effect is occurring or likely to occur; and whether or not a good standard of amenity can be achieved.
8.190 The dominant noise source in the locality of the site is from road traffic. The applicant has assessed both the construction and operational phases of the development within this context.
Construction Phase 8.191 The applicant has assessed the impact of construction activities on a number of nearby receptors. They say that the level set out in the relevant British Standard is unlikely to be exceeded in the majority of locations even when there is activity close to the boundary with no mitigation. The exception is Haydock Park Racecourse, located around 55 metres from the northern boundary of the site. The applicant states that the impact would be on horses rather than people (there is no relevant British Standard for the former), but that due consideration should be given to the potential impact as part of the construction management process. Overall, the applicant states that the overall significance of the effect would be minor to no adverse effect. The impact would also be temporary and short term.
8.192 As per the response from the Environmental Health Officer, the output of the assessment details that construction noise associated with the development is primarily below the relevant threshold value and the impact is not considered to be significant during the daytime working hours. The applicant has suggested that activities be appropriately controlled through the adoption and implementation of a construction environmental management plan. However, it is recommended that a condition be attached to secure it, including a restriction on the hours of operation during the construction phase.
8.193 The applicant states that perceptible levels of vibration are unlikely as a result of construction activities, resulting in a negligible magnitude of impact and a minor to no adverse effect. However, a vibration monitoring plan has been suggested to ensure no adverse levels are encountered at the nearest properties due to the reprofiling works. It is recommended that a condition requiring the implementation of a vibration monitoring assessment be attached as part of any reserved matters application.
P/2017/0254/OUP Planning Committee 24th November 2020
Operational Phase 8.194 The maximum noise levels associated with the development are likely to relate to HGV tractor units, shunters picking up a trailer and slamming car doors.
8.195 The applicant has assessed the noise impacts in a number of locations, where the following are of note:
• Holiday Inn Hotel – there would be a moderate magnitude of impact. It is of medium sensitivity, so there would be a moderate adverse impact that would be significant. • Haydock Park Gardens – there would be a moderate magnitude of impact but as the sensitivity is high, there impact would be major adverse. • Ashton Heath Farm – there would be a low impact but as the sensitivity is high the impact is moderate to major significant. • Park House Farm, Park Cottages, White Lodge and Ashton Heath – there would be a low impact, but the sensitivity is high so there would be a moderate adverse impact which is significant. • Park Road, Dean Dam Farm and Thistle Hotel – the impact would be negligible that would not be significant.
8.196 The impact on Haydock Racecourse has been assessed, but there is no standard against which the impact of development can be assessed on horses. The applicant states that the range of the impact could be none to major.
8.197 As a result, the applicant has made an assessment if a number of mitigation measures were introduced. These include orientating buildings at reserved matters stage to screen service yard activities from the closest receptors; installation of an insulated built-up system; level access doors that do not open onto noisy spaces or the doors could be kept closed at night; if refrigerated trailers are used at the site, electrical hook-up points could be installed, allowing the use of quieter electrically- powered units rather than diesel-powered units; and installation of acoustic barriers to reduce maximum noise levels.
8.198 The parameter plan shows the indicative line of a potential acoustic fence to the northern perimeter of the site described as defining the northern service yard of unit 1; and the southern service yard of unit 3 (located in the south west of the site). It would have a maximum height of 5 metres and would be visible along the site frontage common with the A580.
8.199 However, the applicant states that based on the two current illustrative layouts, the noise assessment would also mean there is a need for a barrier to screen the remainder of the service yard of Unit 2. This extent is not shown on the parameter or illustrative masterplans. The applicant further states that with respect to potential B2 uses, the recommended measures to minimise openings in the building fabric should be employed at reserved matters stage. On this basis, it is recommended that notwithstanding the details shown on the parameter plan, that the 5 metre high
P/2017/0254/OUP Planning Committee 24th November 2020
acoustic barrier along be extended along the frontage in accordance with the recommendations in the applicant’s assessment.
8.200 The applicant states that in order to secure an appropriate level of mitigation a planning condition should be attached requires further noise assessment of the detailed proposals and the requirement for necessary mitigation to be delivered as part of the implementation of the development or phase of development. This is agreed.
8.201 The applicant has also assessed off site road traffic impacts. The partial closure of the A49 would result in a negligible impact during the daytime. The reduction in road traffic noise on Lodge Lane at Junction 23 as a result of closing the southbound carriageway would be classed as a low beneficial impact. For the night time, the reduction in road traffic noise on Lodge Lane at Junction 23 would be classed as a moderate beneficial impact, over the long-term. The applicant concludes that there would be no significant adverse effects predicted during either the day or night-time.
8.202 On balance and on the basis of the information submitted, the noise impact of the development would not result in a significant adverse impact, subject to the implementation of mitigation measures. The conditions stated in paragraph 4.12 recommended by the Environmental Health Officer are proposed to be attached.
Geology, Soils & Contamination
8.203 Paragraph 170 of the NPPF states that planning decisions should contribute to and enhance the natural environment by preventing new development from contributing to, being put at unacceptable risk from or adversely affected by unacceptable levels of soil pollution or land instability; and remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land where appropriate.
8.204 Paragraph 178 of the NPPF states that planning decisions should ensure that a site is suitable for its proposed use taking account of ground conditions and any risks arising from land instability and contamination. This includes risks arising from natural hazards or former activities such as mining and any proposals for mitigation including land remediation (as well as potential impacts on the natural environment arising from that remediation). Paragraph 179 states that where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner.
8.205 Policy CP1 states that new developments should ensure that the site of the proposed development is not contaminated and/or unstable or that provision can be made for its remediation to an appropriate standard, taking into account its intended use and making use of sustainable remediation technologies.
8.206 The site does not have any past industrial use. The only potential sources of contamination appear to be restricted to historical drainage ditches that might represent localised sources of filled ground and hence contamination and ground gas. However, the applicant makes recommendations that an intrusive phase two
P/2017/0254/OUP Planning Committee 24th November 2020
investigation is undertaken to confirm the ground conditions and establish whether any contamination constraints are present. The contaminated land officer raises no objections and agrees that conditions relating to undertaking a phase 2 site investigation, as well as development, agreement and implementation of an agreed remediation strategy and subsequent validation be attached.
8.207 Subject to the conditions recommended, the proposed development could be delivered in a safe manner in accordance with the requirements of Policy CP1 and the NPPF.
8.208 As stated above, the generation of dust during the construction phase needs to be minimised when moving and stockpiling material on the site. However, mitigation measures have been identified that would minimise the impact such that policy CP1 is complied with.
8.209 Paragraph 112 of the NPPF states that local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. Policy CP1 states that new developments should avoid loss or damage to high quality soils where possible and minimise loss or damage where this can be shown to be unavoidable.
8.210 The detailed soil and Agricultural Land Classification (ALC) identifies land as being either grade 1, 2 or 3. Land which is classified as grade 1, 2 and 3a in the ALC system is defined as best and most versatile agricultural land (BMV). The applicant’s Agricultural Land Classification and Soil Resources Report states that there would be a loss of 22.8 hectares of grade 3a land as a result of the development .
8.211 There will be a direct, permanent, long-term effect on BMV agricultural land, but it is not considered to be significant. Natural England has reviewed the proposals and have raised no objections, although draws attention to the loss. It is not considered that the proposed development would cause significant harm to high quality soils. Nonetheless, the loss of agricultural land is still an adverse impact to weigh in the balance.
Water Environment
8.212 Policy CP1 and paragraph 163 of the NPPF state that when determining planning applications, local planning authorities should ensure that flood risk is not increased elsewhere and only consider development appropriate in areas of flooding where informed by a site specific flood risk assessment.
8.213 Saved Policy ENV30 states that planning permission will not be granted for development that: are in areas of liable to flooding, cause loss of access to watercourses for future maintenance, cause loss of natural flood plain except in exceptional circumstances and where compensatory measures are provided as agreed with the Environment Agency, and give rise to substantial changes in the
P/2017/0254/OUP Planning Committee 24th November 2020
characteristics of surface water run off unless adequate off site works can be provided.
8.214 Paragraph 165 of the NPPF states that major developments should incorporate Sustainable Urban Drainage Systems (SUDS) unless there is clear evidence that this would be inappropriate. SUDS should a) take account of advice from the Lead Local Flood Authority, b) have appropriate proposed minimum operational standards, c) have maintenance arrangements in place to ensure an acceptable standard of operation for the lifetime of the development and d) where possible provide multifunctional benefits.
8.215 The application site lies entirely within flood zone one which means it is at very low risk of flooding. There is a single watercourse that runs east-west through the centre of the site. Second watercourse, Dean Brook could also be impacted by the development.
Construction Phase 8.216 During the construction phase, the applicant states that a number of construction activities have the potential to result in contamination of the waterbodies. In relation to water quality, earthworks, creation of stockpiles and excavation and transportation of material, amongst other things, could impact on water quality. The introduction of permeable surfaces would potentially increase rainfall run off rates and increase flood risk both on the site and downstream. Waste water is a potential source of pollution.
8.217 The applicant has therefore set out a series of mitigation measures including the following:
• Drainage management plan to control silted or contaminated entering a waterbody or drainage system. • No water from foundation excavations to be discharges directly to a watercourse. • Water that is discoloured or has an unusual odour will be removed and taken to a licensed waste disposal site. • A bunded area will be provided to accommodate activities around plant and vehicles. • Provision of spill absorbent material to eb retained on site. • Designated area for washing and cleaning aware from the surface water drainage system. • Appropriate provision of facilities for waste water. • Provision of a wheel wash to mitigate the transport of mud from the site onto the highway. • Damping down during dry weather to prevent dust. • Appropriate areas for storage of construction materials, including impervious bases. • Storage of excavated materials in accordance with DEFRA good practice. • Installation of coffer dams to keep water out of working areas.
P/2017/0254/OUP Planning Committee 24th November 2020
8.218 The LLFA and the Environment Agency have reviewed the information and have raised no objections subject to conditions being attached.
Operational Phase 8.219 During the operational phase, the applicant states that the flood risk effects will be mitigated through measures embedded within the design of the scheme and in particular through a SUDs surface water drainage system. Measures to protect water quality would also be introduced.
8.220 As above, the LLFA and Environment Agency have reviewed the information and have raised no objection to the proposals, subject to implementation of a SUDs scheme and appropriately worded conditions as stated at conditions 4.14 to 4.15 be attached.
Conclusion on Water Environment 8.221 The applicant has demonstrated that the proposed development has been designed to be an appropriate use within flood zone 1, and that it would not increase flood risk elsewhere. Measure to minimise the risk of pollution events have also been set out. The development would thus accord with the requirements of the NPPF and Policy CP1.
8.222 As stated, conditions are recommended to deliver the drainage strategy and secure the implementation of the management and maintenance plan. The proposed development would thus comply with the relevant sections of NPPF and Policies CP1 and ENV30.
Cumulative Impacts & Environmental Management
8.223 The applicant has assessed the cumulative impacts of the development under each topic area be looking at the following:
• Intra project – the potential effects between environmental topic areas of the development; and • Inter project – the potential effects arising when combined and interacting with the effects of other major developments.
The major developments include the Haydock Green, Penny Lane (Moviato); Canmoor off Haydock Lane; Parkside; and Florida Farm North.
8.224 The likely significant cumulative effects will be considered against the predicted baseline conditions for the construction and operational phases. This approach is accepted.
Socio-Economics 8.225 The applicant states that the intra-project effects primarily relate to the increase in traffic, but this has been taken into account in formulating the TA. In terms of inter- project impacts, there would be a major cumulative effect on employment, productivity and business rate revenue during both the construction and operational phases of the development. The impact on unemployment, deprivation and the skills
P/2017/0254/OUP Planning Committee 24th November 2020
profile of the area would be of major beneficial significance. This is a reasonable assessment of the position.
Transport 8.226 The intra-project impacts relate to the noise and air quality. The impacts have been assessed under the relevant sections and as above and the impact is acceptable.
8.227 In terms of inter-project effects, the applicant has derived future baseline traffic flows by including the other identified developments. The applicant states that there are no material impacts at the junctions and the impact is not severe, notwithstanding any overlap during the construction phase. This is agreed.
Ecology 8.228 The intra-project impacts relate primarily to transport, water environment and geology, soils and contamination. In particular, transport features within the site and provision of the cycle track will result in the removal of mature trees, grassland and verge habitat, in addition to an impact on the central watercourse and water voles. However, mitigation is proposed in the form of a 15 metres buffer and protection areas that will mitigate the impact. The new SUDs basins and swales will not affect existing habitat and will potentially create new wildlife habitat. There is no inter- project impacts. This is a reasonable assessment of the position.
8.229 In terms of inter-project impacts, none of the other developments have ecological receptors that have a range and depend upon them. The impact is as per the ecology chapter and is accepted.
Archaeology 8.230 There are no intra-project or inter-project cumulative impacts during the construction or operational phases.
Landscape and Visual Impacts 8.231 The applicant has identified intra-project impacts with transport, ecology, drainage and noise. They say that in the medium to long term, there would be no significant impacts arising from the interaction. The landscape effects have been assessed.
8.232 The main inter-project impact is as a result of the Haydock Green development to the north of Penny Lane. The applicant states that this is not expected to have a greater adverse significance over and above that already identified. Again, this is agreed.
Air Quality 8.233 The applicant states that the main intra-project impact concern traffic and has been assessed. Inter-project impacts may result during the construction phase, but it is not considered to be significant.
Noise and Vibration 8.234 As with air quality, the main intra-project impact is traffic, and has been assessed. Inter-project, the applicant states that there are no additive noise effects likely to
P/2017/0254/OUP Planning Committee 24th November 2020
occur with the exception of Haydock Green, Penny Lane. However, given the distance, it is agreed that a cumulative operational impact is unlikely to arise.
Geology, Soils and Contamination 8.235 The intra-project impacts relate to dust (air quality) and noise during the construction phase. This has been assessed and found to be acceptable. It is agreed that there is no inter-project cumulative impact.
Water Environment 8.236 The main intra-project impact relates to ecology and the creation of SUDs basins and swales. Water quality may be affected, but will be protected through the implementation of a construction environmental management plan. The features created will have an impact on the landscape and visual impact assessment.
8.237 No cumulative inter-project impacts are identified.
Conclusion on Cumulative Impacts 8.238 The applicant’s assessment of inter-project and inter-project cumulative impacts is reasonable and meets the requirement of the relevant regulations. The conclusions reached are logical in the circumstances.
St Helens Borough Local Plan Submission Draft 2020 – 2035
8.239 The Council is currently preparing a new local plan. The local plan is currently at submission draft stage. It was submitted for examination on the 29th October 2020.
8.240 Paragraph 48 of the NPPF states that local planning authorities may give weight to relevant policies in emerging plans according to:
a) the stage of preparation of the emerging plan (the more advanced its preparation, the greater weight may be given); b) the extent to which there are unresolved objections (the less significant, the greater the weight that may be given); and c) the degree of consistency of the relevant policies in the emerging plan to the NPPF (the closer the policies in the emerging plan to the policies in the NPPF, the greater the weight that may be given)
The policies in the plan that are the most relevant to the determination of this application are LPA02 and LPA06.
8.241 Policy LPA02 ‘Spatial Strategy’ states that the plan releases land from the Green Belt to enable the needs for housing and employment development to be met over the plan period in the most sustainable locations. It also identifies land to be safeguarded for development where planning permission for permanent development should only be granted after the plan period. It states that within the remaining areas of Green Belt, new development shall be regarded as inappropriate unless it falls within one of the exceptions set out in the NPPF. The policy goes on to state that substantial new employment development will take place on large sites that are capable of
P/2017/0254/OUP Planning Committee 24th November 2020
accommodating large employment buildings (over 9,000 square metres) and are close to the M6 and M62.
8.242 Policy LPA06 ‘Safeguarded Land’ states that sites identified as safeguarded land are to be removed from the Green Belt in order to meet longer term development needs well beyond the plan period. Safeguarded land is not allocated for development in the plan period. Planning permission for development will only be granted following a local plan review, where applications will otherwise be refused. The application site forms part of a site identified to be safeguarded for employment.
8.243 Paragraph 4.24.2 of the reasoned justification states that the case for developing safeguarded sites is likely to be informed by the level of need for housing and employment development compared to supply, infrastructure capacity and any other factors that may affect the delivery of sites at the time. Paragraph 4.24.3 states that in the case of the application site, the form and extent of any development that may be acceptable in the future is likely to be influenced by its interrelationship with junction 23 of the M6, where a need for substantial improvements to enhance junction capacity within the plan period has been identified.
8.244 Following publication of the plan, a significant number of representations have been received by the Council regarding the removal of sites from the Green Belt. In particular, comments question whether the need for employment land justifies the ‘exceptional circumstances’ required to remove the land from the Green Belt. These objections are considered to be unresolved and therefore in accordance with paragraph 48 of the NPPF only very limited weight can be given to the policies.
Prematurity
8.245 The NPPG sets out the circumstances when it might be justifiable to refuse planning permission on the grounds of prematurity. Paragraphs 48 to 50 of the NPPF explain how weight may be given to policies in emerging plans. However in the context of the Framework and in particular the presumption in favour of sustainable development, arguments that an application is premature are unlikely to justify a refusal of planning permission other than where it is clear that the adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, taking the policies in the Framework and any other material considerations into account. Such circumstances are likely, but not exclusively, to be limited to situations where both:
a) the development proposed is so substantial, or its cumulative effect would be so significant, that to grant permission would undermine the plan-making process by predetermining decisions about the scale, location or phasing of new development that are central to an emerging Local Plan; and
b) the emerging plan is at an advanced stage but is not yet formally part of the development plan for the area.
8.246 Refusal of planning permission on grounds of prematurity will seldom be justified where a draft local plan has yet to be submitted for examination. Where planning
P/2017/0254/OUP Planning Committee 24th November 2020
permission is refused on grounds of prematurity, the local planning authority will need to indicate clearly how the grant of permission for the development concerned would prejudice the outcome of the plan-making process.
8.246 Given the considerable need for employment land in the Borough, it is not considered that the development proposed (whilst substantial) is so substantial, or its cumulative effects would be so significant, that to grant permission would undermine the plan- making process by pre determining decisions about the scale, location or phasing of new development that are central to an emerging Local Plan.
8.247 Although the plan has been submitted, it is at a very early stage of examination. Accordingly, it is not considered that the determination of this application would be premature.
Planning Obligation 8.248 There is reference throughout the report as to the heads of terms of a planning obligation or section 106 agreement. The applicant submitted a comprehensive document setting out heads of terms, some of which had not been put before the Council previously, just prior to publication of the agenda. It is useful, therefore to set out the proposed heads of terms in full here:
Highways • The requirement to complete the proposed improvement works at Junction 23 M6 or, entirely at the Council’s discretion and as an alternative, make a £1.4m contribution to the Council to be used for purposes of improvements to Junction 23; • The transfer of land within the application site to the Council, on request, for the purposes of developing a new link from the new spine road/new A49 to the existing A49 so as to remove the need for the western roundabout (should this be viable in the future); and • Submission, approval and implementation of a sustainable transport plan including the provision of a sustainable transport fund of £1 million to fund the establishment and operation of a shuttle bus service that will link to Newton, Earlestown and St Helens railway stations as well as St Helens bus station. • Submission, approval, implementation and monitoring of a delivery management strategy for each building to deal with site operations; routing of HGV’s, signage; parking provision, including avoiding parking on the public highway; establishment of a working group including local community groups and residents; and overall management of the strategy. • A HGV amenity measures contribution of £25,000 to be used by the Council to mitigate the impacts on residents resulting from the use and parking of HGV’s including making appropriate traffic regulation orders.
The matters relating to the provision of improvement to Junction 23 M6 is subject to consultation with the LHA and Highways England. A condition is suggested below, but the provision would by one means or the other, not both.
P/2017/0254/OUP Planning Committee 24th November 2020
Ecology • Delivery of a scheme for replacement wintering bird habitat on land owned by the applicant located within the vicinity of the site; • The requirement to submit for approval and subsequently implement a strategy to achieve a 10% net gain in biodiversity against the site’s baseline through on or off site measures, or a combination of both
Local Employment • Submission, agreement, implementation and review of a local employment scheme to maximise opportunities for access to employment on the site by local people; and • Provision of an apprentice support fund of £100,000 to be used for the support, management and mentoring of apprentices. The fund would support the appointment of an apprentice support co-ordinator if considered appropriate, with 30% of the contribution being available for the provision of bursaries, loans or financial support to apprentices to assist with the provision of equipment, protective clothing, additional training and transport costs amongst other things.
9. CONCLUSION
9.1 Section 38 (6) of the Planning and Compulsory Purchase Act 2004 states that if regard is to be had to the development plan for the purpose of any determination to be made under the Planning Acts the determination must be made in accordance with the development plan unless material considerations indicate otherwise. This is also emphasised in Paragraphs 11 to 12 and 47 of the NPPF.
9.2 Saved Policy GB1(a) in the Unitary Development Plan does not permit the erection of new buildings in the Green Belt unless it is for certain purposes (as was previously set out under PPG2). A new industrial development such as this is considered inappropriate development in the Green Belt and does not meet any of the exceptions in the policy. Saved Policy GB1(a) therefore states that such inappropriate development should not be permitted except in very special circumstances.
9.3 Saved Policy GB2 states that subject to the provisions of Saved Policy GB1, development in the Green Belt will be judged against (i) whether it is appropriate in terms of its siting, scale, design, materials and landscaping and does not detract from the appearance and openness of the Green Belt, (ii) it will not generate so much traffic as to cause nuisance or danger nor require any major improvements to rural roads, (iii) it does not conflict with the purposes of including land within the Green Belt and (iv) it will not conflict with other objectives for the use of land in the Green Belt, and wherever appropriate, will make a positive contribution to their achievement.
9.4 Paragraph 144 of the NPPF states that when considering any planning application, the Council should ensure that substantial weight is given to any harm caused to the Green Belt and that ‘very special circumstances’ will not exist unless the potential
P/2017/0254/OUP Planning Committee 24th November 2020
harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.
9.5 Paragraph 144 of the NPPF is considered to be consistent with both Saved Policy GB1(a) and Saved Policy GB2.
9.6 The proposed development would cause harm to the Green Belt by reason of its inappropriateness, it would have a significant impact on the openness of the Green Belt and would be contrary to at least three of the five purposes. This makes the proposed development contrary to certain aspects of saved policy GB2. In accordance with saved policy GB1(a) and paragraph 144 of the NPPF, this harm should (individually and collectively) be given substantial weight against the proposed development.
9.7 The proposed development would increase traffic flows along surrounding highways, resulting in some additional queuing at junctions. However, both the local and strategic highway network has sufficient capacity such that the impact would not be severe. Transport links to the site at present are poor but can be made acceptable through the imposition of conditions.
9.8 The impact on ecology is acceptable. There would be a loss of habitat, but sufficient mitigation is being proposed such that there is compliance with policy CQL3. There is harm however, but it should be given very limited weight in the planning balance.
9.9 There would be no unacceptable impact on archaeology, although a significant portion of the medieval deer park would be lost resulting in harm. There is compliance with policy EVN23, where the harm should be given very limited weight.
9.10 The proposed development would have a significant adverse impact on landscape character and visual amenity, contrary to policies CP1 and CQL4. The landscape proposals are not sufficient to mitigate the impacts, in addition to the provision of a 5 metre high fence along the site boundaries, especially along the frontage common with the East Lancashire Road. The proposal would result in significant harm that should weigh against the proposed development.
9.11 The proposed development would cause some harm to air quality in certain locations, which must be weighed against the proposed development. However, the proposed development would not cause any exceedances of standards set out in DEFRA guidance or have a significant effect overall. There would be no conflict with policy CP1 or paragraph 181 of the NPPF because impacts have been minimised and mitigated. However, the harm caused should be given very limited weight against the proposed development.
9.12 The noise effects of the proposed development would not have a significant effect on the amenity of the residents at the nearest residential properties in accordance with Policy CP1 subject to the implementation of mitigation, including a 5 metre high acoustic fence around much of the perimeter of the site. However, it is acknowledged
P/2017/0254/OUP Planning Committee 24th November 2020
that some harm would be caused by additional noise and this should weigh against the proposed development.
9.13 In favour of the proposed development, there is a significant need to deliver employment land in the Borough of St Helens, in particular for large scale logistics developments such as this. The proposed development is deliverable, attractive to the market, and it would make a significant contribution to the employment land supply, in accordance with the requirements of policy CE1 and the increased requirement in the OAN contained in the AELNS, considered to be a robust evidence base for decision taking. There are no sites within the urban area that could accommodate the proposed development, the only possible alternatives are also in the Green Belt. This economic land position should be given significant weight in favour of the proposed development.
9.14 The application also proposes a number of economic benefits, of such a scale that they should be given significant weight in favour of the proposals in accordance with Paragraph 80 of the NPPF. There are also some social benefits and very limited environmental benefits which should weigh in favour of the proposed development.
9.15 In terms of the planning balance, the contribution that the development would make to the Council’s employment land position is significant and of particular importance, given that the need is of such a quantum and character that only Green Belt sites are likely to satisfy it. However, in this case, the assessment to be undertaken to satisfy Green Belt policy is finely balanced and certainly more difficult than for previous decisions such as Parkside. It is nonetheless considered that this and the other significant economic benefits would clearly outweigh the substantial harm caused to the Green Belt and the other harm identified above. Consequently, it is considered that the proposed development complies with GB1 and the NPPF.
9.16 It is therefore concluded that there is conflict with policies CSS1, CE1, CP1, CP2, CQL4, and GB2 so the proposed development does not accord with elements of the development plan. However, there are ‘very special circumstances’ such that the proposed development complies with saved policy GB1 (a), taking on board such policy conflicts, and therefore on balance, it also complies with the development plan as a whole.
9.17 In terms of Green Belt policy, there is no material inconsistency or conflict between the Unitary Development Plan, the Core Strategy and the NPPF. On balance the proposed development constitutes sustainable development in terms of the NPPF because the ‘very special circumstances’ outweigh the substantial harm to the Green Belt and other harm. Furthermore, the public benefits of the proposed development outweigh the heritage harm. The proposed development complies with the development plan, so in accordance with Paragraph 11 of the NPPF, it should be approved without delay. There are no material considerations which would require a determination other than in accordance with the development plan. Rather, the material considerations further support the grant of permission, subject to conditions and a section 106 agreement.
P/2017/0254/OUP Planning Committee 24th November 2020
9. RECOMMENDATION
9.1 That had the Council remained as the determining authority, grant planning permission subject to conditions and a s106 agreement as per paragraph 8.248.
9.2 Proposed conditions are stated below. It is proposed that the detail be delegated to the Service Manager – Development & Building Control for agreement with the applicant through the appeal process.
General Conditions
1. All applications for reserved matters must be made within three years of the date of this decision notice and development must be commenced before the expiration of two years from the final approval of the reserved matters or, in the case of approval on different dates, the final approval of the last such matter to be approved.
2. Prior to the submission of any reserved matters application, a phasing plan shall be submitted to and agreed in writing with the local planning authority. The development shall be implemented in accordance with the agreed phasing plan.
3. As part of the first reserved matters application, precise details of proposed site levels shall be agreed with the local planning authority. The levels plan must include specifications. The development shall be implemented in accordance with those details
4. No development shall take place on any one phase until details of the following reserved matters relevant to that phase have been submitted to and approved in writing by the Council as Local Planning Authority: (i) appearance, (ii) landscaping, (iii) scale and (iv) layout. The development shall be carried out in accordance with the reserved matters as approved.
5. Reserved matters applications for layout, scale and appearance shall include full details of facing materials for that phase. The proposed facing materials shall be selected to minimise the visual bulk of the buildings and their effectiveness shall be demonstrated through a written justification and a series of photomontages. The development shall be implemented in accordance with these details.
6. The alignment of the main estate road shall be in accordance with drawing 30926-FE- 008A1 Parameters Plan.
7. The development hereby approved permits a total of 167,225 square metres of employment floor space within use classes B8 and B2. Up to 20% of the floor space will be provided for occupation within class B2 only as per Environmental Statement Addendum 2 Volume 2 Main Report May 2020 paragraph 3.13.
8. The gross external floor area of any building shall not be less than 22,298 square metres.
9. Reserved matters applications shall include a lighting strategy for that phase, which includes details of light columns, lighting specifications, a light spillage plan showing the LUX levels in relation to the closest nearby properties/highways and details of baffels. The lighting scheme shall be designed to maintain the amenity of neighbouring residents, ensure highway safety and protect ecology, including bats, by preventing excessive light spill onto sensitive habitats. There should be reference to the document
P/2017/0254/OUP Planning Committee 24th November 2020
‘Bats and Lighting in the UK, Bats and the Built Environment Series, Bat Conservation Trust and Institute for Lighting Engineers’. The development shall be implemented in accordance with the agreed details.
10. No development shall take place on any phase of the development until a Construction Environmental Management Plan (CEMP) for that phase has been submitted to and agreed in writing with the local planning authority. The CEMP should address and propose measures to minimise the main construction effects of the development and amongst other things, should include details of ecological mitigation, construction and demolition waste management, pollution prevention and soil resource management. It shall include but not be limited to:
• Details of phasing; • A dust management plan which includes details of the proposed dust monitoring programme, both before and during construction, with proposed locations and duration of monitoring; • Details of how retained habitats within and adjacent the site will be protected during construction, including the central watercourse and its banks; • Reasonable avoidance measures (RAMs) for protected and notable species; • Pollution prevention control measures including the measures stated in section 14.93 of the Environmental Statement Volume 2 (March 2017); • Soil resource management; • Site waste management; • Construction traffic routes; • The location and numbers of parking spaces for contractors; • Temporary roads/areas of hard standing; • A schedule for large vehicles delivering/exporting materials to and from site; • A scheme of street sweeping/street cleansing; • Details of lighting which is designed to minimise impacts on the surrounding highway network, residential amenity and ecology; • A surface water management plan, including a drainage management plan ; • Contact details of the principal contractor; • Confirmation that the principles of Best Practicable Means for the control of noise and vibration will be employed, as defined within the Control of Pollution Act 1975; • Confirmation that the good practice noise mitigation measures detailed within BS5228-1: 2009+A1:2014 shall be employed; and • Confirmation of inclusion of noise mitigation measures detailed within paragraph 12.153 of the Environmental Statement Volume 2: Main Text (March 2017) and paragraph A12.55 of the Environmental Assessment Addendum Volume 2 – Main Report (December 2017).
The development shall be carried out in accordance with the agreed CEMP.
11. No development shall take place in any phase until a construction risk assessment method statement (RAMS) for construction of the proposed development for that phase has been submitted to and approved by the Council as local planning authority. The statement shall outline the potential impacts from all construction activities, including vibration, on water infrastructure that crosses the site and identify mitigation measures to protect and prevent any damage to this infrastructure both during and after construction. The development shall be undertaken in accordance with the approved RAMS.
12. Reserved Matters applications shall be in accordance with the following plans:
P/2017/0254/OUP Planning Committee 24th November 2020
• 30926-FE-008A1 Parameters Plan • 30929-FE-027H Green Infrastructure Mitigation Plan • VN60647/P-08 Proposed A580 highway improvements NMY proposals • VN60647/PL-001 Proposed development access off A49 Lodge Lane • VN60647/PL-002 Proposed A580 Highway Improvements: Development Access
Local Contractors 13. No development shall take place on any phase until a scheme to promote the use of local suppliers of goods and services during the construction of that phase has been submitted to and agreed in writing with the Council local planning authority. The development shall be implemented in accordance with the agreed scheme.
Ground Conditions
14. No development shall take place until a scope of works for phase two site investigation has been prepared to include analysis suite and risk assessment methodologies. The scope of works shall be submitted to and agreed in writing with the council as local planning authority, prior to any site investigations being carried out.
Should the phase 2 investigation identify any requirements for remediation then a remedial strategy, including a validation methodology, shall be submitted to and agreed in writing with the Council as local planning authority.
The scope of works and the phase 2 investigation shall be completed by a competent person in accordance with government and Environment Agency guidance, namely “Land Contamination: Risk Management” (https://www.gov.uk/guidance/land- contamination-how-to-manage-the-risks).
15. No development shall take place until the agreed remedial strategy (if required by the information submitted under condition 15) has been implemented and a site validation/completion report for that phase has been submitted to and approved in writing with the Council as local planning authority.
For the avoidance of doubt, the site validation/completion report shall include, but will not necessarily be limited to; i) full details of all remediation works undertaken; ii) validation (in accordance with the validation methodology detailed within the agreed remedial strategy) of the adequacy of the remediation; iii) sampling, testing and assessment of the suitability of any imported or site won soils; iv) the fate of any excavated material removed from site. The site validation/ completion report(s) shall be completed by a competent person in accordance with government and Environment Agency guidance, namely “Land Contamination: Risk Management” (https://www.gov.uk/guidance/land-contamination-how-to-manage-the-risks).
Landscape and Ecology
16. All tree work must be to British Standard: BS3998 (2010).
17. No grassland clearance or tree or hedgerow felling, lopping or pruning shall take place from 1st March to 31st August inclusive, unless a survey for breeding birds has been undertaken and the results, together with a scheme of mitigation and protection measures has been submitted to and approved in writing by the Council as Local Planning Authority. Should grassland clearance, tree or hedgerow felling take place between the dates stated above, the agreed mitigation and protection measures shall be implemented in full and retained through the duration of the relevant works.
P/2017/0254/OUP Planning Committee 24th November 2020
18. No development shall take place on any phase until details of the temporary measures to provide physical protection of all trees, hedges and shrubs shown to be affected within that phase have been submitted to and agreed in writing with the local planning authority. These details must specify tree protection measures which will be put in place to not only protect the existing retained trees, hedges and woodlands but also any new tree planting and landscaping delivered as part of any development on site. All tree protection measures must be to at least BS 5837 (2012) standard. Method statements must also be included; particularly where there are impacts to root protection areas and ground protection or special no dig surfacing is required. All measures must be in place prior to any demolition or development taking place on any phase. The provision of total exclusion zones so defined shall be kept free of machinery, stored materials of all kinds and any form of ground disturbance not specifically catered for in the agreed measures, for the duration of all site and building works (including works that may be carried out within the any adjacent area of the site).
19. No development shall take place an any phase until a scheme of arboricultural supervision in relation to that phase is submitted to and agreed in writing with the Council as local planning authority. The scheme shall set out to ensure that all tree work and tree protection measures, including supervision of no dig surfacing construction, is both delivered and maintained in accordance with the agreed details. The scheme shall include the level of supervision, reporting mechanisms to the Council and frequency of site visits and reporting, as well as provision for a meeting on site prior to works taking place on site between the, developer, developer’s relevant contractors and arboricultural consultant as well as the local planning authority.
20. Reserved matters applications must include fully specified landscape plans for that phase which must (where appropriate):-
• Be in accordance with the species recommendations, principles and standards detailed in paragraph 8.142 of the Environmental Statement Volume 2 (March 2017) and paragraph A8.149 of the Environmental Assessment Addendum Volume 2 (December 2017). • The development shall be implemented in accordance with the submitted details and any trees, shrubs and plants and meadow areas planted / sown, which within a period of 5 years from the date of planting / sowing die, are removed or become seriously damaged or diseased, shall be replaced in the next planting season with others of a similar size, species and quality unless the Local Planning Authority gives written consent to the variation.
21. A detailed landscape and management plan based on the information set out in Appendix 8.7 of the Environmental Statement Volume 4 (March 2017) shall be submitted to and approved in writing by the Council as Local Planning Authority. The plan shall include but not be limited to the followings:
• Details of long-term management over a minimum period of 25 years; • Habitat creation methodologies; • Planting schedule and species lists; and • Details of the management company responsible for the works, including maintenance.
22. No development shall take place until a scheme for the provision and management of an 8 metre wide buffer zone alongside the central watercourse has been submitted to and agreed in writing by the Council as local planning authority. The development shall be carried out in accordance with the approved scheme. The buffer zone scheme shall
P/2017/0254/OUP Planning Committee 24th November 2020
be free from built development including lighting, domestic and formal landscaping. The scheme shall include:
• Plans showing the extent and layout of the buffer zone; • Details of any proposed planting scheme (for example, native species); • Details demonstrating how the buffer zone will be protected during development and managed/maintained over the longer term including adequate financial provision and named body responsible for management plus production of detailed management plan; and • Details of any proposed footpaths, fencing, lighting.
23. Water vole mitigation shall be carried out in accordance with the strategy set out in Appendix A8.6 Water Vole Mitigation Strategy (TEP Ltd, 25th October 2017, 5843.010 version 3). Details of the management of the central watercourse during the operational phase shall be included in the full landscape and habitat management plan required by condition 23. Measures to ensure that the movement of water vole along the ditch is not impeded shall also be included.
24. The measures outlined in the Common Toad Mitigation Strategy (TEP, April 2018, 5843.0108 version) shall be implemented and retained thereafter
25. No development shall take place until a pre-commencement inspection for badgers is undertaken. The results of the inspection shall be submitted to and agreed in writing with the Council as local planning authority prior to any site works.
Water Environment
26. Foul and surface water shall be drained on separate systems.
28 No development shall take place in a phase until a surface water drainage scheme that includes a management and maintenance plan for that phase has been submitted to and agreed in writing with the Council as local planning authority. The scheme shall be based upon the principles set out in the preliminary drainage strategy (Environmental Statement Volume 4: Appendix 14.1 Section 7 (March 2017) and Environmental Assessment Addendum Volume 3: Appendix A14.1 Section 7 (December 2017)). The agreed scheme shall be implemented before the first use of any building hereby permitted in that phase and managed/maintained as agreed thereafter.
Highways
To be dealt with be condition or planning obligation 29 No part of the development shall be occupied until the highway improvement works have been implemented. For the avoidance of doubt, the works shall include:
• The closure of the A49 southbound approach to M6 Junction 23 as illustrated on Vectos Drawing VN60647/P-09 Revision G • The provision of the A580 eastbound carriageway widening scheme on approach to and through Junction 23 as illustrated on Vectos Drawing VN60647/P-09 Revision G • The provision of the A580 westbound carriageway widening scheme on approach to, through and departing from Junction 23 as illustrated in Vectos Drawing VN60647/P-09 Revision G
P/2017/0254/OUP Planning Committee 24th November 2020
To be dealt with by condition or planning obligation 30 No development shall take place, except for site clearance and remediation, until the full design and construction details of the required highway improvements to the M6 Junction 23 with the A580 and A49 as shown in outline on Vectos drawing number VN60647/P-09 revision H dated November 2017, have been submitted to and approved in writing by the Council as local planning authority. The details to be submitted shall include:
• Final details of how the scheme interfaces with the existing highway alignment; • Final traffic signal operating parameters; • Full signing and carriageway marking details; • Full construction details; • Confirmation of compliance with current departmental standards (as set out in the Design Manual for Roads and Bridges) and policies (or approved relaxations/departures from standards); and • An independent Stage 2 Road Safety Audit carried out in accordance with current departmental standards and current advice notes.
No part of the development shall be occupied until the agreed details have been implemented, including the satisfactory completion of a stage 3 road safety audit.
31 No development shall take place, except site clearance and remediation, until a scheme for the design of the site accesses has been submitted to and approved in writing by the Council as local planning authority. The accesses shall be designed in accordance with the principles set out in the approved drawings, as follows:
• A49 site access as illustrated on Vectos Drawing VN60647/PL-001 (December 2019) • A580 site access as illustrated on Vectos Drawing VN60647/TR121 Revision B (dated 17 July 2020)
The approved scheme shall subsequently be constructed to surfacing level and completed prior to the closure of the A49 southbound approach to Junction 23 and prior to first occupation. The access shall be kept available for use at all times.
32 The first reserved matters application shall include the route and design of the main estate road/realigned A49 link road through the site in accordance with condition 6.
33. No development shall take place, except site clearance and remediation, until a scheme for the design of the re-direction of traffic along the A49 through the application site in accordance with Plan Masterplan Drawing 30926-FE-042K, has been submitted to and approved in writing by the Council as local planning authority.
The site spine road / realigned A49 will form part of the adopted highway network. The approved scheme shall subsequently be constructed to surfacing level and completed prior to first closure of the A49 southbound approach to Junction 23 and prior to first occupation. The spine road shall be kept available for use at all times.
33 No development shall take place, except site clearance and remediation, until a scheme for the design of highway improvement works has been submitted to, and approved in writing by, the Council as Local Planning Authority. For the avoidance of doubt, the works shall include:
• Construction of a shared-use footway/cycleway along the northern side of the A580 carriageway between the eastern side of the A49 arm at M6 Junction 23 to
P/2017/0254/OUP Planning Committee 24th November 2020
the proposed A580 site access junction as illustrated in Vectos Drawing VN60647/P-08 Revision A (March 2017).
The approved scheme shall subsequently be implemented prior to first occupation.
34 Reserved Matters applications shall include precise details of car, motorbike and cycle parking for that phase, either in accordance with the Council’s adopted standards or there is justification provided for the level of parking provided of the Council’s adopted standards are not met.
The details shall include the provision of 1no electric charging point and 1no priority parking space for hybrid and electric vehicles for every 2000m3 of commercial floor space.
No building proposed in any phase of development shall be brought into use until the agreed details that are associated with it have been provided. Specifically, until the areas identified have been surfaced, drained and permanently marked out or demarcated in accordance with the details agreed. The parking and servicing areas shall be retained as such thereafter and shall not be used in a manner that would prevent the parking of vehicles.
34 The development shall not be occupied until the owners and occupiers of the site have appointed a Travel Plan Coordinator. The Travel Plan Coordinator shall be responsible for the implementation, delivery, monitoring and promotion of the Travel Plan, including the day-to-day management of the steps identified to secure the sustainable transport initiatives. The details (name, address, telephone number and email address) of the Travel Plan Coordinator shall be notified to the Council as Local Planning Authority upon appointment and immediately upon any change.
35 The development shall not be occupied until a travel plan has been submitted to and approved in writing by the Council as local planning authority for each occupier. The plan shall include immediate, continuing and long-term measures to promote and encourage alternative modes of transport to the single occupancy car. For the avoidance of doubt, the travel plan shall include but not be limited to:
• Operational details of a shuttle bus service; • Involvement of employees; • Information on existing transport policies, services and facilities, travel behaviour and attitudes; • Updated information on access by all modes of transport; • Resource allocation including Travel Plan Coordinator and budget; • A parking management strategy; • A marketing and communications strategy; • An action plan including a timetable for the implementation of each such element of the above; • and • Mechanisms for monitoring, reviewing and implementing the travel plan.
The approved travel plan shall be implemented in accordance with the timetable contained therein and shall continue to be implemented as long as any part of the development is occupied and in use.
An annual report shall be submitted to the Council no later than 1 month following the anniversary of the first occupation of the development for a period of 5 years. The
P/2017/0254/OUP Planning Committee 24th November 2020
annual report shall include a review of the travel plan measures, monitoring data and an updated action plan.
36 An enhancement scheme for bus stops on Lodge Lane shall be submitted to and agreed in writing with the Council as local planning authority. The enhancement scheme shall include access kerbs, shelters, new bus stop information and signage and road markings. The agreed works shall be implemented prior to the first use of any building on the site.
37 Prior to first use any building on the site, a scheme for the provision of no less than three sets of bus stop pairs to be sited within the development shall be submitted to and agreed in writing by the Council as local planning authority. The scheme shall be implemented in accordance with a phasing plan that shall be included in the submission and retained as such thereafter.
38 Reserved matters applications shall include provision for overnight lorry accommodation and shall include evidence to demonstrate that the level of provision is adequate for that phase of the development. The development shall be implemented in accordance with the agreed details and those areas shall be retained as such thereafter.
Archaeology
39 No development shall take place until a written scheme of archaeological investigation has been submitted to an agreed in writing by the Council as local planning authority. The scheme shall include geophysical surveys and targeted archaeological investigations if shown to be necessary, as set out in table 15.1 of the Environmental Statement Addendum 2: Volume 2 (May 2020). The scheme shall be carried out as agreed.
Noise
40 Construction works shall not take place outside of the following hours:
• Monday to Friday 08:00 – 18:00 hrs; • Saturday 08:00 – 13:00 hrs; and • Not at all on Sundays or Public/Bank Holidays
41. No temporary power plant shall be used outside the permitted hours of construction unless the details have been submitted to an approved in writing by the Council as local planning authority, prior to its use on site. Any such plant shall only be operated in accordance with the approved details.
42 Any reserved matters application shall be accompanied by an updated noise assessment which specifies the provisions to be made to control noise emanating from activities at the site.
The mitigation scheme shall be based on the results of the noise assessment and build on the findings of earlier assessment which suitably characterises the noise climate at the residential dwellings, both prior to and following the operation of the development permitted, namely;
• Haydock Point – Environmental Statement – Chapter 12 Noise and Vibration March 2017 and
P/2017/0254/OUP Planning Committee 24th November 2020
• Haydock Point - Environmental Statement Addendum 2: Volume 2 Main Report Haydock Point, St Helens Prepared by Turley on behalf of Peel L & P Investments (North) Ltd, May 2020;
The following noise levels shall be met after implementation of the scheme:
For fixed plant, the rating level of noise emitted from the site, measured at the closest boundary of the nearest residential dwellings shall be at least 5dB (A) below the existing background level.
For other operations on site the rating level of noise shall not exceed the existing background level at the positions assessed. Measurement and assessment shall be made according to British Standard BS 4142:2014 + A1:2019.
The assessment shall be carried out by a suitably qualified acoustic consultant/engineer and can be done so by calculation or measurement.
All works that form part of the agreed mitigation scheme shall be implemented in full prior to that phase of the development being brought into use.
43. No additional external plant or equipment or any additional openings be formed in the elevations or roof of the buildings hereby permitted which directly ventilate the building or which discharge from any internal plant or equipment.
44. No part of the development shall be occupied until full details of the acoustic barriers/bunds identified on 30926-FE-008A1Parameters Plan have been submitted and approved in writing with the Council as the local planning authority.
Any timber/acoustic fencing used in the boundary treatment shall be treated to give a minimum design service life of 15 years in accordance with the requirements for fencing timber in BS5589.
45. Reserved matters applications for scale and layout shall be accompanied by an operational noise management strategy. The approved strategy shall be implemented and retained as such thereafter.
46. Reserved matters applications shall include full details of a vibration monitoring strategy for the construction phase of the development. The agreed strategy shall be implemented and retained through the during of the works.
47. Within three months of the occupation of each phase, a verification assessment report which demonstrates that sound levels from the development comply with the requirements of condition 42 shall be submitted to the Council as local planning authority. Should the report reveal sound levels in excess of the requirements of condition 42, a scheme of additional mitigation, including a timetable for implementation shall be submitted to and agreed with the Council as local planning authority. Any additional mitigation shall be installed in accordance with the timetable for implementation.
Air Quality 48. The measures set out in the Environmental Statement Volume 2 Table 11.22 (March 2017) shall be implemented and remain in place for the duration of the construction phase.
49. On commencement of development, fleet vehicles operating out of the development should be Electric/Hybrid or Euro class VI as a minimum.
P/2017/0254/OUP Planning Committee 24th November 2020
P/2017/0254/OUP Planning Committee 24th November 2020
Notification of Appeal
P/2017/0254/OUP Planning Committee 24th November 2020
P/2017/0254/OUP Planning Committee 24th November 2020
PARAMETER PLAN
P/2017/0254/OUP Planning Committee 24th November 2020
GREEN INFRASTRUCTURE MITIGATION PLAN
P/2017/0254/OUP Planning Committee 24th November 2020
ILLUSTRATIVE MASTERPLAN OPTION 1
P/2017/0254/OUP Planning Committee 24th November 2020
ILLUSTRATIVE MASTERPLAN OPTION TWO
P/2017/0254/OUP Planning Committee 24th November 2020
Landscape Strategy Option One
P/2017/0254/OUP Planning Committee 24th November 2020
Landscape Strategy Option Two
P/2017/0254/OUP Planning Committee 24th November 2020
Illustrative Northern Elevations – Units 1 & 3
P/2017/0254/OUP Planning Committee 24th November 2020
Illustrative Site Sections – Option One
P/2017/0254/OUP Planning Committee 24th November 2020
Illustrative Site Sections – Option Two
P/2017/0254/OUP Planning Committee 24th November 2020
Junction 23 M6 Proposed Highway Improvement
P/2017/0254/OUP Planning Committee 24th November 2020
Proposed Cycling and Walking Improvement
P/2017/0254/OUP Planning Committee 24th November 2020
Proposed Site Access
P/2017/0254/OUP Planning Committee 24th November 2020
Proposed A49 Lodge Lane Access
P/2017/0254/OUP Planning Committee 24th November 2020
Artists Impression – A580 Westbound
P/2017/0254/OUP Planning Committee 24th November 2020
Artists Impression – Junction 23 M6
P/2017/0254/OUP Planning Committee 24th November 2020
Artists Impression – Site Access
P/2017/0254/OUP Planning Committee 24th November 2020
Artists Impression – M6 Carriageway
P/2017/0254/OUP Planning Committee 24th November 2020
P/2017/0254/OUP