PARKSIDE LINK ROAD PROOF OF EVIDENCE OF IAN GRIMSHAW BA(Hons) MA(LM) MSc MRTPI TOWN PLANNING CONTENTS 1.0 INTRODUCTION 1 2.0 THE PROPOSED SCHEME 2 3.0 RELEVANT PLANNING POLICY 7 4.0 PLR AND GREEN BELT POLICY 20 5.0 HARM TO GREEN BELT 25 6.0 COMPLIANCE WITH THE DEVELOPMENT PLANS 38 7.0 MATERIAL CONSIDERATIONS SUPPORTING THE PLR 74 8.0 OVERALL CONCLUSION 92 9.0 SUMMARY 95 APPENDICES (PRESENTED SEPARATELY) Appendix 1: Warrington Green Belt Drawings A6354.12.001 and A6354.12.002 Appendix 2: Desk-Based Analysis of Agricultural Land Quality Appendix 3: UK Government Carbon Reduction Announcement 4th December 2020 PLR.IJG. 1- Pg 1 1.0 INTRODUCTION 1.1 My name is Ian Jeffrey Grimshaw. I am a Chartered Member of the Royal Town Planning Institute and a Chartered Member of the Landscape Institute. I am a Director of The Environment Partnership (TEP) Limited which I co-founded over twenty years ago. 1.2 I have worked on a large number of infrastructure and development projects taking the lead on securing planning permission and related consents. TEP has provided a range of services to St Helens Council as applicant in connection with the Parkside Link Road including town planning advice. I have overseen these services on the project since early 2017. 1.3 My evidence addresses the town planning case for the scheme and is structured as follows: In Chapter 2.0 I set out a summary description of the proposed PLR development I set out the planning policy context in Chapter 3.0 I focus on the Green Belt policy context in Chapter 4.0 I consider the harm to Green Belt from the PLR and secondary effects in Chapter 5.0 In Chapter 6.0 I consider other compliance with the development plans I set out material considerations in support of the PLR in Chapter 7.0 Chapter 8.0 presents my overall conclusion Chapter 9.0 comprises my Summary 1.4 The evidence which I have prepared and provide for this public inquiry (References APP/H4315/V/20/3253230 and APP/H4315/V/20/3253232) in this proof of evidence is true and has been prepared and is given in accordance with guidance of my professional institutions and I confirm the opinions expressed are my true and professional opinions. 6354.12.018 PLR.IJG. 1- Pg 2 2.0 THE PROPOSED SCHEME 2.1 The Parkside Link Road (PLR) would comprise a single carriageway road which would link the A49 Winwick Road to the A579 Winwick Lane enabling access to Junction 22 of the M6. Mr Bayliss sets out a full description of the scheme in his evidence. Summary Site Context 2.2 The summary site context is set out in the Statement of Common Ground on planning matters (CD 5.156). The application site is south east of the town of Newton le Willows and part of the scheme is proposed on the site of the former Parkside Colliery. The application site is an irregular shape with a site area of approximately 38 hectares (3.3km in length) and includes areas of land that lie in both the St Helens and Warrington administrative boundaries. The whole of the application site is in the Green Belt. Relevant Planning History 2.3 Mr Littler sets out in his evidence relevant planning history of the former Parkside Colliery. In summary, there have been planning applications for development for B8 uses based on rail freight but these have failed due to economic circumstances. The PLR Applications 2.4 The PLR is subject of two planning applications: one to St Helens Council and one to Warrington Borough Council. The applications were made under The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 and the applicant determined that the proposals fell within the remit of these Regulations without seeking a screening opinion from the local planning authorities. 2.5 A scoping opinion was requested in accordance with Regulation 15 from the two planning authorities accompanied by a scoping report issued in June 2017. A scoping opinion was received on 25th July 2017 from St Helens Council and on 14th August 2017 from Warrington. Following changes to the red line boundary, the scoping report was re-submitted in November 2017 to consider whether the changes affected the scope of the EIA and confirm that the Scoping Opinion remained valid. Confirmation was received from each planning authority. 6354.12.018 PLR.IJG. 1- Pg 3 2.6 In March 2018 a full planning application was submitted to each planning authority. The 2018 applications were accompanied by an Environmental Statement (ES) (‘the 2018 ES’). 2.7 Requests for additional information were received and in addressing some of these the scheme was amended in respect of construction compounds, drainage, minor realignments, removal of works in Cockshot Brook and relocation of the noise barrier on the A579 Winwick Lane. To accommodate these changes, the red line boundary was amended, extending further eastwards along A579 Winwick Lane. The predicted traffic flow data was updated and taken into account. 2.8 Updated planning application drawings and an updated Transport Assessment were prepared and submitted to support the planning application. An Addendum Environmental Statement (‘the 2019 Addendum ES’) was prepared to support these amendments. The updated information was submitted in March 2019. 2.9 The applications comprise the documents listed as Core Documents 5.1 – 5.44. 2.10 The planning authorities have advertised and consulted on the applications in accordance with the 2011 EIA Regulations. The applications were considered at planning committee meetings held on 17th December 2019 (St Helens Council) and 18th December 2019 (Warrington Borough Council). In each case the decision was taken to approve the applications subject to the Secretary of State not wishing to intervene (and, in the case of the application to Warrington Borough Council, subject to completion of an agreement under section 106 of the Town and Country Planning Act 1990). 2.11 The Secretary of State informed the Councils and applicant by a letter dated 21st May 2020 that he had decided to ‘call-in’ the applications along with others in northwest England. 2.12 It has been decided that the two applications relating to the PLR will be heard at a single public inquiry along with the called-in application by Parkside Regeneration for development of ‘Parkside Phase 1’. This application is for outline planning permission with all matters reserved other than means of access for ‘the construction of up to 92,900 m2 of employment floorspace (Use Class B8 with ancillary B1(a)) and 6354.12.018 PLR.IJG. 1- Pg 4 associated servicing and infrastructure including car parking; vehicle and pedestrian circulation space; alteration of existing access road including works to existing A49 junction; noise mitigation; earthworks to create development platforms and bunds; landscaping including buffers; works to existing spoil heap; creation of drainage features; substations and ecological works’. 2.13 The application was made to St Helens Council (P/2018/0048/OUP) and the Council made a decision to approve the application, subject to the Secretary of State not wishing to intervene and completion of a s106 agreement, at the same meeting at which the PLR decision was taken. 2.14 Although being heard at the same public inquiry, the application for the PLR and for Parkside Phase 1 are independent and have been pursued separately throughout. It is clearly acknowledged that development of Parkside Phase 1 does not require the PLR. Further Information 2.15 Following the decision to call-in the PLR applications, Wigan Council confirmed an Order imposing a weight limit on part of the A579 Winwick Lane as explained in the Transport Assessment October 2020 (CD 5.48). It was acknowledged that this would affect the results of traffic modelling used in the PLR applications, as Mr Roberts explains in his evidence. The call-in of the applications means that the anticipated opening date of the PLR will be later than that used in the traffic modelling for the applications. To address these changes, the model was re-run and consideration given to whether any of the environmental impact assessment would be affected by changes that resulted. 2.16 The Applicant identified possible changes to the results of assessments of air quality, noise and effects on climate change. Since the applications were made, the Design Manual for Roads and Bridges (DMRB) guidance on environmental assessment has been updated. The majority of these updates have been consolidation and re- presentation of guidance that has evolved over time. Considering the output of the revised traffic model meant that there also was an opportunity to consider if any of the updated DMRB guidance needed to be taken into account in assessments. 6354.12.018 PLR.IJG. 1- Pg 5 2.17 Notice of these assessments was given at the first Case Management Conference regarding the PLR applications on 1st October 2020. The updated information, titled ‘Further Environmental Information’ was circulated to PINS, the two planning authorities and the Rule 6 party Parkside Action Group on 16th October 2020. 2.18 PINS has subsequently advised on 6th November 2020 that although there is not a requirement to publicise the production of the Further Environmental Information under the 2011 EIA Regulations, that publicity should be undertaken. St Helens Council and Warrington Borough Council have publicised the production of the Further Environmental Information and made it available on their websites. 2.19 In my evidence, I use the following references to the environmental information which has been produced: Documents Reference in Proof Environmental Statement Statement (March 2018) 2018 ES Environmental Statement Addendum (March 2019) 2019 Addendum ES PLR Further Environmental Information (October 2020 Further Environmental 2020) Information 2.20 Following the second Case Management Conference held on 13th November 2020, it was confirmed that the likely main issues to be addressed at the inquiry into the PLR comprise the matters in Box 1 below.