LPA.AKN.1 CHARTERED TOWN PLANNER ST HELENS BOROUGH COUNCIL PROPOSED DEVELOPMENT ON LAND KNOWN AS HAYDOCK POINT PROOF OF EVIDENCE OF ALYN NICHOLLS PLANNING MATTERS ON BEHALF OF THE LOCAL PLANNING AUTHORITY JANUARY 2020 PINS Reference: APP/H4315/V/20/3256871 140 Denby Lane T: 01484 860000 Upper Denby www.alynnicholls.com Huddersfield HD8 8UN [email protected] 140 Denby Lane 01484 860000 Upper Denby www.alynnicholls.com Huddersfield [email protected] HD8 8UN CHARTERED TOWN PLANNER CONTENTS Page Number STATEMENT OF EXPERIENCE 1. INTRODUCTION 3 2. CONTEXT 6 3. THE DEVELOPMENT PLAN 10 Policy for Economic Regeneration 11 Policies Relating to Green Belt 16 Policies to Protect Landscape Character 17 Summary on the Development Plan 17 4. NATIONAL POLICY 19 Building a Strong and Competitive Economy 19 Green Belt 20 Summary on National Policy 27 5. LANDSCAPE AND VISUAL IMPACT 29 Summary of Landscape and Visual Impact 33 6. OTHER MATTERS 35 Noise 35 Air Quality 36 Loss of Best and Most Versatile Agricultural Land 36 Residential Amenity 36 Traffic and Transport 37 Summary of Other Matters 37 7. THE PLANNING BALANCE 39 Landscape and Visual Impact 41 Whether there are Very Special Circumstances to Justify Development within Green Belt 42 8. SUMMARY AND CONCLUSIONS 44 Overall Assessment and Conclusion 48 ALYN NICHOLLS BA (HONS) MRTPI Land to the North East of the A580 East Lancashire Road / A49 Lodge Lane, 1 Haydock, St Helens (Haydock Point) STATEMENT OF EXPERIENCE OF ALYN NICHOLLS BA (HONS) MRTPI I hold a Bachelor of Arts Honours Degree in Urban and Regional Planning and I am a Member of the Royal Town Planning Institute. I have 40 years’ experience practising as a Chartered Town Planner and for the last 30 years this has been as Principal of my own practice. My clients include landowners, developers, local planning authorities and others. My experience has included development proposals located within the Green Belt in the North West and elsewhere. It has encompassed proposals for appropriate Green Belt uses and developments that by definition were inappropriate. I am familiar with addressing the issue of the impact of development on the openness of the Green Belt, in respect of the purposes of including land within the Green Belt, and, assessing whether very special circumstances arise to justify development. I have also dealt with Green Belt issues in a plan making context. I also have experience of development for employment uses. Over my career I have dealt developments raising employment land issues in the North West and within St Helens. I have worked through a time when the St Helens economy was in decline, and when an excess of employment land and an absence of demand were characteristics of the Borough. I was initially instructed by St Helens Council in September 2020 to provide evidence on their behalf in respect of “call-in” public inquiries relating to development at Parkside. I therefore followed the processing and putative determination of the Haydock Point application, but I did not have any involvement in the preparation of the Officer Report to Planning Committee or the consideration of the merits of the application within that report. Having regard to all of the material, which is currently available to me, including the evidence of Ms Xanthe Quayle, Mr Anthony Meulmann and Mr Edward Mellor, I support the Council’s resolution that it would have refused planning permission if it had been in a position to do so. That position has not changed in the light of the amendments which have subsequently been made by the Appellant to the proposed development. For the avoidance of doubt, there has not been time for the amended scheme to be reported back to the LPA. I am familiar with the site and the surrounding area and I have visited it for the purposes of this inquiry. I have provided written and oral evidence to the Parkside Phase 1 (PP1) and Parkside Link Road (PLR) inquiry. I consider the evidence submitted on behalf of these 3 schemes by the Local Planning Authority to be consistent Proof of Evidence on behalf of St Helens Borough Council January 2021 ALYNNICHOLLS CHARTERED TOWN PLANNER Land to the North East of the A580 East Lancashire Road / A49 Lodge Lane, 2 Haydock, St Helens (Haydock Point) Endorsement My evidence for this appeal has been prepared in accordance with the guidance of the Royal Town Planning Institute. I confirm that the views expressed within my evidence are my true and professional opinions. ALYN NICHOLLS BA(HONS) MRTPI 25 January 2021 Proof of Evidence on behalf of St Helens Borough Council January 2021 ALYNNICHOLLS CHARTERED TOWN PLANNER Land to the North East of the A580 East Lancashire Road / A49 Lodge Lane, 3 Haydock, St Helens (Haydock Point) 1. INTRODUCTION 1.1. My evidence sets out an assessment of the overall planning balance for the proposed employment development on open greenfield land located to the northeast of Junction 23 of the M6 Motorway, to the north of the East Lancashire Road (A580) and east of the M6 and Lodge Lane, Haydock. The site is known as Haydock Point. The appeal site is located within Green Belt. It is agreed to be inappropriate development in the Green Belt. 1.2. The appeal proposal seeks outline planning permission, with all matters reserved other than access, for the development of the site for up to 167,225 sq m of B8/B2 (up to 20% B2 floorspace) ancillary office and associated site facilities floorspace, car parking, landscaping, site profiling and transport, drainage, and utilities infrastructure. The application was submitted on 21 March 2017. Agreements were reached between the Council and the appellant on a timescale for determination up until the 21 June 2020, where time extensions were requested and agreed. The time taken to deal with the application to that point was due to a number of issues, but primarily because highway issues had not been resolved. The appeal against the failure of the Council to determine the application was made on 27 July 2020, at which point the Local Planning Authority was still awaiting responses from consultees on additional environmental information which had been the subject of statutory consultation. The responses had been delayed by the coronavirus pandemic and the associated lockdown. 1.3. I note that the appeal against non-determination took place because the Appellant wanted this proposal considered by the Secretary of State at the same time as PP1, the PLR, and schemes for employment development within the Green Belt in Wigan and Bolton. The appeal does not (apparently) imply any dissatisfaction with the processing of the application by the Local Planning Authority. There is certainly no reasonable basis for any such dissatisfaction. 1.4. The appeal proposes the development of up to 167,225 square metres1 of B8/B2 floorspace, including up to 20% B2 floorspace. The appellant asserts that the parameters of the development would allow a single unit of 1 million square feet (92,903 square metres). This would be a larger unit than proposed by any other site before the Secretary of State. The scheme is speculative and there is no named end user. 1.5. The proposal falls within the scope of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. An Environmental Statement (“ES”) was submitted for the development. At the time of the appeal, the applicant had recently submitted a substantial amount of information, revising the Environmental Statement, the parameter 1 1,800,000 square feet Proof of Evidence on behalf of St Helens Borough Council January 2021 ALYNNICHOLLS CHARTERED TOWN PLANNER Land to the North East of the A580 East Lancashire Road / A49 Lodge Lane, 4 Haydock, St Helens (Haydock Point) 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. Whilst not all of the technical consultee responses were received at the time of the appeal, they have now been received. 1.6. The appeal was recovered by the Secretary of State, such that the Haydock Point proposal could be considered together with employment proposals at Parkside in St Helens, the Parkside Link Road (the “PLR”) proposal predominantly in St Helens, but also partially in Warrington, employment proposals at Symmetry Park within Wigan Borough, and at Wingates Industrial Estate within Bolton which had all been “called-in” by the Secretary of State. 1.7. The Council considered the Haydock Point application on 24 November 2020. The Planning Officer’s Report to Committee recommended that had the Council remained as the determining authority, to grant permission subject to conditions and the applicant entering into a Section 106 Obligation. The Officer considered that the relevant planning balanced was "finely balanced". This recommendation is not binding on the Council, which took a different planning judgment and the Council resolved that it would have refused to grant permission for the following reason: “There would be landscape and visual harm caused to the character and appearance of the area that outweighs the economic benefits including jobs and investment in the planning balance. Very special circumstances do not exist to outweigh the harm to the Green Belt. The development would be contrary to saved policy GB1 of the St Helens Unitary Development Plan and paragraphs 143 and 144 of the National Planning Policy Framework which states that when considering any planning application, local planning authorities should ensure substantial weight is given to any harm to the Green Belt. ‘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.” 1.8.