WIGAN STRATEGIC HOUSING LAND AVAILABILITY ASSESSMENT 2016 Update

Consultation Report

December 2016

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Consultation Report

Wigan Council consulted on its draft 2016 Strategic Housing Land Availability Assessment (SHLAA) Update for a 4-week period from 28 June to 26 July 2016. It was a targeted consultation which invited representations from a variety of key stakeholders, including major housebuilders, key landowners, planning consultants and other key figures in the development industry. Neighbouring districts and other Greater Manchester districts were also consulted. A list of all the organisations that were consulted is set out in Appendix A.

During the consultation period, representations were received from the following 8 stakeholders:

 Hargest Ltd  Morris Homes and Persimmon Homes  Lilford 2005 Ltd  Canal and River Trust  HIMOR  Persimmon Homes  Tarleton Estates Ltd  United Utilities

All representations received have been taken into account in the preparation of the final SHLAA update. A summary of these representations and the council’s response is set out at Appendix B. The final 2016 SHLAA Update can be viewed on the Wigan Council website.

To inform the SHLAA and the borough’s housing supply position, the council has also invited stakeholders to submit site suggestions for new housing development as part of a “Call for Sites” exercise since 31 January 2014. In response, 86 sites have been suggested and assessed by the council, including 18 as part of the consultation on the 2016 SHLAA. The council’s assessment of these 18 sites is set out in Appendix F of the final 2016 SHLAA Update.

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Appendix A: Organisations consulted on the draft 2016 SHLAA

AGMA CBRE Mansell Group Bolton Council Clark Planning McDyre Associates Bury Council Cockwill Planning MCK Associates Chorley Council Cornell Group Lancashire County Council Millers Property Services Manchester Council CPRE Lancashire Morris Homes Oldham Council Cunningham Planning Mosaic Town Planning Rochdale Council Dickman Associates Neame Sutton Salford Council Dorbcrest Homes Neighbourhood Investor St. Helens Council DWH NJL Consulting Stockport Council Emerson Group NLP Planning Tameside Council Emery Planning Peel Holdings Trafford Council England-Lyle Persimmon Homes Warrington Council Environment Agency Peter Brett Associates West Lancashire Council EPP Planning Peter Gilkes Abbott Associates Eric Wright Plan It Wright Acland Bracewell Five Star Homes Plan-it Adactus Housing Frank Marshall Prospect GB Ainscough Strategic Land Gemstone Ltd PWA Planning Ancer Homes Great Places Redrow Homes Arena Housing Greenbank Partnerships Redwaters Argon Properties GVA Riverside Arup Helena Partnerships Russell Homes Axiom Regenerate HIMOR Group Seddon Homes Aylward Planning Holliss Vincent Simply Housing Barratt Homes Story Homes Barton Willmore Homes and Communities Agency BCP Ltd HOW Planning Turley Homes Hughes Brothers United Utilities Bloor Homes Hurstwood Group Wainhomes Blue Sphere ID 4 Living Walsingham Planning Bovis Homes ID Planning Wigan and Leigh Homes Bramall NW Indigo Planning Your Housing Group British Waterways JASP Planning Brookhouse Group Longport

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Appendix B: Summary of representations received and Council response

Ref: Site / topic Summary of comment Council response: Hargest Ltd. (Mosaic Town Planning) 1.1 Greenbank No reference to Greenbank Industrial Estate, which The reasons for excluding the site from the Industrial Estate, was previously listed (ref: 27). Previous assessment are set out in Appendix F. Hindley Green representations were submitted in July 2015. The lack of reference to the site is contrary to paragraph Inclusion of a site in a previous iteration of the 011 (Ref ID: 3-011-20140306) of the national Planning assessment does not guarantee its continued Practice Guidance which states that “sites which have inclusion. particular policy constraints, should be included in the assessment for the sake of comprehensiveness but these constraints must be set out clearly”.

The site has been put forward to be considered and should not be ruled out without assessment due to future policies which may or may not come into place. Morris and Persimmon Homes (Mosaic Town Planning) 2.1 Land at Rectory The SHLAA does not include the residual The residual land safeguarded for future Lane, Standish Morris/Persimmon Land at Rectory Lane which is development to the east of Standish town centre subject to current representations to the Allocations has been removed from the SHLAA to reflect the Plan. However it does include the land to the south proposals in the draft Greater Manchester (0274) which has the same planning status. Spatial Framework (GMSF), which proposes this land to be included on the Green Belt. This site, together with SHLAA sites 0272, 0274 and 0276 have been removed from the SHLAA on this basis. Lilford 2005 Ltd (Acland Bracewell Surveyors) 3.1 SHLAA 0265:  Support the density and delivery rate. Support welcomed. Hindley’s Farm,  Object to reduction of site area to 0.6ha and Atherton consider there to be no grounds for this change. The SHLAA identifies a reduced site to:  No evidence presented by Council in the SHLAA to justify this reduction. (a) Reduce the impact on highway capacity at  It is a deliverable site in a single ownership willing the site access with Schofield Lane, given the site would be accessed close to the

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Ref: Site / topic Summary of comment Council response: to develop in short term. Schofield Lane / A577 traffic signal junction.

(b) Reflect the longstanding arrangements that the landowner has with neighbouring residents who rent out garden space and garages.

3.2 SHLAA 0239; Land  Support the density and delivery rate Support welcomed. at Parsonage Farm  Whilst detailed assessments and surveys have not and Garage, Leigh been undertaken, support that the site is not subject to any significant constraints that may unduly affect/delay development.  It is a deliverable site in single ownership willing to develop in short term. Canal and River Trust 4.1 SHLAA 0043 - Land The Trust own the tree lined embankment adjacent to Noted. The site proforma in Appendix G has between the canal forming part of the site. Any work in the been amended to reflect this. Crankwood Road vicinity of the embankment, would be required to and Leeds Liverpool safeguard the structural integrity of the waterway Canal infrastructure and the safety of its users and neighbours, particularly in respect of digging foundations and any loading placed on the embankment. HIMOR (Emery Planning) 5.1 Inclusion of sites in At the 2015 public inquiry for the sites at Lurdin Lane In accordance with footnote 11 of the NPPF, all the 5 year supply and Rectory Lane, the evidence questioned the sites in the SHLAA, including those with that are in existing inclusion of sites in the five year supply that are in planning permission, have been thoroughly use or where there existing use, where there is a history of renewals, or assessed in terms of their availability, suitability are a history of there appears to be no developer interest. We are and deliverability. renewals concerned that the evidence has not been taken into account in the 2016 SHLAA, despite the Inspector As part of the preparation of the SHLAA update, clearly having concerns over elements of the supply. the Brownfield Land Register and/or the Wigan Allocations and Development Management Local Plan in 2015/16, the council attempted to

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Ref: Site / topic Summary of comment Council response: contact the applicant/landowner (or their agent) of all unimplemented sites with planning permission to assess the likelihood of implementation and delivery timescales.

Only those deemed to have a reasonable prospect of delivery within the next 5 years have been included within the 5 year supply. 5.2 Sites without Concerned that approximately 2,000 units are Only sites which have a reasonable prospect of planning permission included in the 5 year supply without planning delivery in the next 5 years, are shown to make in 5 year supply permission. a contribution to the 5 year supply.

Whilst such sites can be included, in our view they Following reassessment, there has been a should only be included where they have made reduced contribution from sites without planning sufficient progress through the planning system and permission to the 5 year supply in the final can be shown to be viable. The implication of the SHLAA. As a result, sites without permission Wainhomes judgment1 is that sites without planning now represent only 30% of the five year supply, permission should only be included where there is with 50% of these on sites where housing is robust evidence to justify their inclusion. proposed and awaiting determination.

The remaining supply is on sites that are either: a) subject to pre-application discussions; b) in council ownership and being marketed or intended for disposal in the short term; or c) have a willing landowner and developer interest. 5.3 Build rates and lead Concern at the council’s optimism where custom build Custom-build rates and lead-in times have been in times rates or lead-in times have been applied as a result of applied as a result of site intelligence, including site intelligence. Whilst intelligence from developers information provided by the developer. We is useful, this must also be qualified by actual closely monitor housing completions on a real- evidence especially in terms of the performance on time basis and patterns of delivery on similar the ground from similar sites. and/or proximate sites are considered.

1 Wainhomes (South West) Holdings Limited v Secretary of State for Communities and Local Government [2013] EWHC 597 7

Ref: Site / topic Summary of comment Council response:

Overall, we are not convinced that sufficient evidence Of the specific sites identified in the is available to support the proposed lead-in times and representation, with the exception of SHLAA build rates, including: 0191, all are justifiable based on information  SHLAA 0191 AG Barr provided by the developer, with some of them  SHLAA 0006 Rothwells Farm under construction.  SHLAA 0007 Stone Cross Lane  SHLAA 0278 Cat I’th Window Farm, Standish The lead-in time at SHLAA 0191 has been  SHLAA 0004 Garrett Hall extended slightly following discussion with the  SHLAA 0010 Rectory Lane, Standish (Phase 1) landowner. Homes are on board and  SHLAA 0273 Land south of Rectory Lane (Phase intend to start delivery this year. 2) Delivery rates of all sites identified in the Core Where the expected delivery rates in the Core Strategy have been reviewed to reflect the latest Strategy are relied upon, these should be reviewed to evidence. For example delivery at North Leigh, reflect the latest evidence. South of Hindley and other key sites have been put back in the trajectory to reflect current circumstances (compared to previous SHLAAs). 5.4 SHLAA 0001: North Challenge delivery of 262 homes at North Leigh within The council is working in active partnership with Leigh next 5 years taking into account the need to market the landowner, North Leigh Park Group, and the the site and find a developer, discharge conditions HCA and has commissioned specialist and remediate the land. consultants to facilitate early delivery of homes and road infrastructure on the site.

An initial phase of the development (at Nel Pan Lane) has reserved matters approval for 162 homes, subject to finalisation of the legal agreement. A developer is on board and there is a high prospect of delivery from 2018 at a rate of 50 homes per annum.

Site remediation is expected to commence for the whole site in Autumn 2017 and is anticipated to take around 18-24 months to complete.

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Ref: Site / topic Summary of comment Council response: Remediation is to be prioritised at the Phase 1 housing site and also at the northern part of the site along and adjacent to the proposed east- west link road. Construction of the road is expected to commence in Autumn 2017 and be completed in Autumn 2019. The landowner intends to release further housing phases, accessed from the new road, with a reasonable prospect of delivery from April 2019 and 50 homes per annum. 5.5 Windfall allowance The windfall allowance of 100 dwellings per annum The windfall allowance of 100 homes per annum conflicts with the Core Strategy housing trajectory is justified in paragraphs 2.25-30 of the SHLAA. which includes a lower allowance of around 45 per It is based on trend data from 2011, and given it annum. only takes into account small sites and not employment sites that have been lost to housing it is a conservative figure. 5.6 Calculating the In accordance with the PPG, which requires the Agree that applying the Sedgefield approach is requirement shortfall to be addressed as soon as possible in order consistent with the appeal decisions and the to significantly boost housing land supply, the guidance in NPPG. Sedgefield approach must apply. This also accords with the Standish appeal decisions. However, the Liverpool approach is a recognised method of calculation, albeit less favoured by Planning Inspectors in recent decisions. Persimmon Homes 6.1 Approach to Object to the approach set out in paragraph 2.26, The land at Swan Lane, Hindley Green is a employment sites / which states that, despite the council currently current planning application for 126 homes that land at Swan Lane, undertaking an Employment Land Review, which may is pending determination. Its inclusion in the Hindley Green lead to the de-designation of substantial parts of SHLAA is dependent on the outcome of this. Primary Employment Areas, the Council cannot identify such sites that are in active use and the owner The approach set out in paragraph 2.26 allows has not made clear that they intend to vacate the site. sites to be included in the SHLAA where there is robust justification that the site is not viable for On this basis those sites allocated for employment, continued employment use.

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Ref: Site / topic Summary of comment Council response: but where the landowner has provided sufficient evidence that such uses are no longer viable, should As stated above, the site will be included in the be considered in the SHLAA. This is the case on land SHLAA if the current planning application is at Swan Lane, Hindley Green. approved. 6.2 SHLAA 0130: Support inclusion and delivery assumptions. The site Noted and support welcomed. Walmsley Farm, has commenced with an application for reserved Higher Folds matters for the remainder of the site (300 units) being prepared and expected in 2016. 6.3 SHLAA 0266: Land Support inclusion. The site can deliver in the short Noted and support welcomed. east of Pocket Nook term. A build rate above the 25 dwellings per annum Farm, Lowton assumed by the Council is achievable at this location. 6.4 SHLAA 0010 and Support the assessment of the two sites and the build Noted. SHLAA 0273: Sites rate assumptions applied, which are achievable. at Rectory Lane, Standish 6.5 SHLAA 0270: Land Support the assessment of the site. Whilst Noted. In response, the capacity of the site has to the rear of 43- acknowledging the Council expect the site to come been reduced from 135 to 85 homes. 99a Pepper Lane, forward from 2026 given its safeguarded land Standish designation, there are no known site constraints and therefore housing could be delivered in the short term, if required. The site could accommodate in the region of 85 homes. Tarleton Estates (Turley) 7.1 Para 2.9 Generally accept 30 dwellings per hectare as an As stated in paragraph 2.10, alternative density average density across sites. However, due estimates have been applied to some sites consideration should be given to size, design where this can be justified. Examples include considerations and accessibility benefits in respect of conversions (e.g. redevelopment of former mill each site, which will result in some sites delivering a buildings); areas where higher densities are higher or lower yield. An appraisal of each site would prevalent in an area; and at town centre sites improve the accuracy of the projected housing with good accessibility by a choice of means of delivery. transport. 7.2 Para 2.15 The SHLAA should have regard to the latest available Noted. As set out in paragraph 2.14, alternative information in projecting annual build rates on sites delivery rates have been applied where the and particular how the prevailing economic context council has specific site intelligence. This can

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Ref: Site / topic Summary of comment Council response: and strength of the local housing market affects this. include intelligence of higher build rates on In this respect, a build rate of 25 units per annum per comparable sites. developer is a conservative estimate. Higher build rates, including of 30+ units per year per developer is achievable on sites in strong market areas where demand is high. 7.3 The reference to 4 developers per site on larger sites Noted. The highest delivery rate assumed in the is considered appropriate. It is noted that up to 6 SHLAA is 100 per annum, which assumes up to developers per large site was assumed in the 2013 4 developers per site on larger sites. which my clients do not consider to be realistic as a general rule. 7.4 Appendix D Information on the position of sites with planning Noted. The council monitors progress on permission is provided in some instances and is development sites on an ongoing basis. welcomed (permission date or whether under construction). This should be kept under review by officers throughout the year and the SHLAA period should such information be requested by members of the public/ development industry. 7.5 Slippage No allowance has been made for slippage in the Agree that an allowance should be applied to delivery rates of sites with planning permission. This take into account potential lapses in planning is not consistent with evidence of past completions on permission. As such, a 10% lapse rate has sites with planning permission in the Borough. Given been applied to all unimplemented sites with the past low delivery rates, and the slow progress, in planning permission. This has not been applied some cases, of sites from outline permission to to sites that are under construction. reserved matters stage, the full delivery of sites with planning permission is highly unlikely. An allowance The application of a 10% lapse for sites with should therefore be considered. A minimum slippage planning permission was considered reasonable provision of 10% should be adopted. in the Cotswold DC v SoS CLG judgement (Nov 2013) (paragraph 71). 7.6 Delivery rates of Further explanation of the claimed supply from a Delivery rates applied at the broad locations, broad locations range of ‘broad location’ sites is requested, having and other significant sites, have generally been regard to the assumptions in Table 1 for lead-in approved by the landowner / developer, periods and the number of developers possible on including Turley at East of Atherton and South of sites. For example ‘land at Stone Cross, Lowton’ is Atherton.

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Ref: Site / topic Summary of comment Council response: assumed to deliver 200 units in the period 2016-21 having only received full planning permission in March Preliminary works at the Stone Cross Lane site 2016. have started and housing delivery is anticipated this year (2016/17). Given the strength of the housing market, the delivery of 200 homes by April 2021 is considered realistic. Housing completions will however be monitored and will inform future SHLAA updates accordingly.

The assumed housing delivery and lead-in time applied within the Standish and Golborne and Lowton broad location reflect information provided by the housebuilders. Many of these sites are also under construction.

The lead-in time and delivery rates applied at Garrett Hall, Landgate and South of Hindley are consistent with Table 1.

Most, if not all, of these sites are at a more advanced stage than your client’s site at East of Atherton, where a higher level of delivery is suggested in the short term. 7.7 South of Atherton The trajectory for the site is broadly acceptable. Noted. The trajectory has been amended However, it is considered a conservative estimate of accordingly. It now assumes the delivery of 25 delivery given the landowner’s intention to progress homes in 2018/19 and 75 homes per annum the site through detailed planning permission in the thereafter. short term. It is highly likely the site will be capable of delivering some units earlier in the period 2016-21. 7.8 Land at Bee Fold A reserved matters application for 85 dwellings has Noted. The SHLAA trajectory has been Lane, Atherton recently been submitted by Bellway Homes. This will amended accordingly. be delivered within the period 2016-21. The SHLAA should be updated to reflect this. 7.9 East of Atherton Consistent with the Development Framework (2012), The Development Framework assumes the site

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Ref: Site / topic Summary of comment Council response: previously shared with the Council, the developable to be residential only, whereas the site is area should be increased to 19 hectares and the identified in the Core Strategy for both housing capacity increased to 665 homes. and employment uses. The capacity of 600 homes is therefore retained in the SHLAA. This was relied upon in designating the site as a Broad Location in the Core Strategy and has therefore been subject to independent examination. Exceptional justification for deviating from the provisions and conclusions of the Development Framework are needed. 7.10 East of Atherton Reference to part of the site being covered by a More clarification is provided in Appendix G nominated landfill is potentially misleading. This is a relating to the landfill site. historic landfill which has been subject to restoration by the previous owner and consequently does not represent a significant constraint to the development of the site. This should be clarified in the SHLAA. 7.11 East of Atherton To correspond with information within the submitted The delivery rates proposed are considered Development Framework, the site will deliver 100 optimistic given that previous discussions with units in the period 2016-2021, 325 in 2021-26 and the landowner have suggested that a planning 240 in 2026-31. application is not anticipated in the short term. United Utilities 8.1 Site allocations The Council should be aware that a fuller Noted. understanding of the impact on water and wastewater infrastructure can only be achieved once more details are known, such as the timescales for development, the approach to surface water management and the chosen points of connection. 8.2 Fragmented If ownership is fragmented, we would strongly Noted ownership encourage the Council to establish, prior to publication of the local plan, how the landowners intend to work together to ensure the co-ordinated delivery of infrastructure in the most sustainable fashion. Co- ordinated delivery of infrastructure can only be secured on strategic sites in fragmented ownership

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Ref: Site / topic Summary of comment Council response: where there is a clear legal agreement between the landowners.

8.3 Groundwater New development sites are more appropriately Noted. Appendix G of the SHLAA has been protection located away from locations which are identified as amended accordingly. Ground Source Protection Zones (SPZ1). Without adequate mitigation measures, development in SPZ1 could pose a threat to groundwater quality.

Sites at Pocket Nook, Lowton are within SPZ1 (SHLAA sites 0008, 0266 and 0326).

The following sites fall within SPZ2 areas: 0006 Rothwells Farm; 0015 Lincoln Drive, Ashton; 0204 Bungalow, Pocket Nook Lane; 0240 Barn Lane, Golborne; 0289 Land north of Haydock park racecourse. 31 Proximity of sites to Land north of Bickershaw Lane (SHLAA 0051) and Noted. The site proformas in Appendix G have Wastewater Westwood Park (SHLAA 0134) are located close to been amended accordingly. Treatment Works wastewater treatment works. Sites proximate to such works should be considered with your Environmental Health colleagues, due to potential noise and odour emissions. Future masterplanning of the above sites should be informed by an odour impact assessment and a noise assessment.

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