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CPRE Lancashire, Liverpool City Region and Greater Manchester Comments Matter 4 –Green Belt, Green Infrastructure and Open

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CPRE Lancashire, Liverpool City Region and Greater Manchester Comments Matter 4 –Green Belt, Green Infrastructure and Open CPRE Lancashire, Liverpool City Region and Greater Manchester comments Matter 4 –Green Belt, green infrastructure and open spaces Issue 1: Is the approach to Green Belt in the Plan justified and consistent with national policy? Are there exceptional circumstances to alter the Green Belt boundary in Liverpool as part of this Local Plan? No, the approach to Green Belt in the Plan is not justified and is not consistent with national policy. The fundamental aim of Green Belt to keep land permanently open, and the five purposes should be specified in the local plan policy. It is considered that the local plan as written, wrongly promotes development in the Green Belt. The Local Plan will indeed benefit from a development management policy on Green Belt to be consistent with the NPPF, 2012. The Local Plan policy should make clear that the presumption in favour of sustainable development does not apply. Development in the Green Belt is inappropriate, by definition harmful. Although exceptions, and very special circumstances may apply, the general principle of Green Belt is of a no build zone that should be fully communicated to discourage applications. The policy ought to reiterate the NPPF, 2012 policy wording. In March 2018 CPRE highlighted the exceptional circumstances required to release Green Belt land for development had not been justified. If exceptional circumstances were evidenced, then CPRE would have expected that a strategic review of the Green Belt would should be conducted by suitably qualified planners, in accordance with policy within the NPPF and planning practice guidance. With regards to proposals for further expansion at Liverpool John Lennon Airport, exceptional circumstances are yet to be proven and the ramifications of the Heathrow Ruling must be fully considered [2019]EWHC 1070 (Admin). Q4.1 In LCC01a (in response to initial question Q51 in EX2b) the Council explains why a Green Belt Review has not been undertaken in Liverpool. Is the Council’s approach justified? 1 For local plan purposes the Council set out a demonstrable five year housing land supply, plus buffer on previously developed land. CPRE is pleased that the Council is seeking a high proportion of new housing on brownfield land. However, the Council reasoning is challenged, because to release Green Belt there must be a strategic review to ensure the land being released is done on the basis of sustainable development and assessing sites in an objective manner to understand land most suitable for development. Otherwise, speculative development, which is based on land owning and developer interests come forward on sites not intended for development. Trust in the planning system is eroded when planners say they have enough land not to need Green Belt release for the local plan, yet cannot demonstrate an adequate supply in situations of appeals leading to controversial consents. To illustrate the point, in recent times there have been a number of applications for housing development on non-allocated sites, including land in the Green Belt and Green Wedge. The Planning Inspectorate decided in favour of the appeals, because it accepted the arguments promoted by developers that the Council did not have an adequate supply. CPRE recommends there should be more accountability and transparency to better understand the housing land situation. CPRE supports H1 recognising the local plan should enable enough housing to be delivered; and that Liverpool has a key contribution to make, and as set out in our response to Matter 3, the housing requirement must be justified and we advocate using the latest Office of National Statistic based data to inform the housing requirement. Even though the local plan is being tested against the NPPF, 2012, the inspector needs to be alert to the consequence of failing the Housing Delivery Test leading to further loss of land in the countryside. People tell us they would much prefer their local greenspaces to be improved https://www.cpre.org.uk/news/we-want-richer-green-spaces/. For sustainable development, the use of wasted land resources in more centrally located areas, which have a much lower greenhouse gas impact, in advance of building on greenfields is advantageous. The Government revised the NPPF in July 2018 to dedicate Section 11, on ‘making effective use of land’, and previously NPPF, 2012 Paragraphs 17 and 111, set out that local plans should, “encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.” 2 Q4.2 Where the Green Belt in Liverpool borders Knowsley and Halton has there been a consistent plan-led approach to the Green Belt to ensure a contiguous and coherent cross-boundary designation? Knowsley adopted its Local Plan Core Strategy in January 2016. Local communities defended against ‘needless’ Green Belt loss, however some Green Belt was released to form ‘sustainable urban extensions’ to amply accommodate the planned growth over the local plan period. In February 2017 the Government then announced support for proposals to develop Halsnead Garden Village. The plan for the village includes over 1,500 homes, the biggest residential developments on Merseyside on agricultural land in the Green Belt at the junction of the M62 Motorway. Clearly, Green Belt was not protected by the adoption of the local plan. There is also a large application for the Omega 8 site, which squeezes the Green Belt to the east end at the Warrington Boundary on the M62 whilst Halsnead erodes land at the west end in Knowsley. In addition to these Green Belt incursions, there has been numerous large scale warehouse and distribution developments consented in the Green Belt along the motorway corridors. In our view this rampant speculative development has caused significant and substantial cumulative harm to the Green Belt. The planning policy designation intends to keep land permanently open and serves five important purposes and it is nationally significant. Despite local MPs raising the matter with the Secretary of State, call in powers have not used, for example with Florida Farm in St Helens on the grounds it was a local matter. The Parkside road access development applications recently minded to approve by both St Helens and Warrington Councils have been called in by the Secretary of State. Q4.3 The Council’s justification in LCC01a for not reviewing the Green Belt is in the context that there is no need to do so in order to release land for development (excepting the airport). Paragraph 85 of NPPF2012 lists the other circumstances to take into account when defining Green Belt boundaries. Is the Council assured that the Green Belt boundaries in the submitted plan are justified and that no alterations are needed to: (i) include additional land that serves the purposes of Green Belt; and/or (ii) any ‘tidying-up’ to ensure boundaries follow physical features? CPRE accepts that there may be some minor boundary revisions required as a result of digital polygon errors, but where land in Green Belt designation is being released for future development, this necessitates a full strategic review. Exceptional circumstances to release Green Belt have not been justified. 3 CPRE believes the Policies Map should not be altered to remove Green Belt at the following locations a) Land east and south of Old Lodge Close b) Land south of Holt Lane and east of Caldway Drive c) Land west of Parkview Drive, and d) Land east of Ribble Road. For the avoidance of doubt, the boundary to the Green Belt should be delineated on the Policies Map by means of a solid green line, to complement the currently proposed delineation by means of vertical green line hatching. Q4.4 Should criterion (a) of Policy GI1 be separated to provide distinction between Green Belt (which has very specific national planning policy status) and SPAs/Ramsar sites (which have particular separate legal protection)? Yes, CPRE agrees that criterion (a) of Policy GI1 should be separate to provide distinction between Green Belt (which has very specific national planning policy status), and the different purpose of the SPAs/Ramsar sites, which are protected under environmental designations, which afford separate legal protection. GI1 should protect all the different types of Green infrastructure, which is defined in NPPF, 2012 as being a network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities. Green Wedges, Green Corridors and the Green Web are local names for the different elements of Green Infrastructure. Issue 2: Is the Plan’s policy framework for, and designation of, Green Wedges, Green Corridors and the Green Web (Policies GI2 and GI9) justified, effective and consistent with national policy? In Liverpool local people have a strong association with the purpose of planning policy designation for the different elements of Green Infrastructure: Green Wedges, Green Corridors and the Green Web (Policies GI2 and GI9) and this cultural distinctiveness ought to be celebrated and supported. Local people tell us they want the designation to be retained. The Localism Act 2011 was intended to give local communities a voice. Local opinion matters. NPPF 2012 paragraph 10 states: 4 “Plans and decisions need to take local circumstances into account, so that they respond
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