I agree with this objection to the planning application P/2021/1070/OUP-Land off Elton Head Road

This representation is submitted on behalf of Waterside Village Action Group (the group) in response to planning application P/2021/1070/OUP – Land of Elton Head Road.

The representation is supported by a petition containing XXX signatures from local residents in support and agreement of the representation made.


This representation is set out in three parts…

A. Comments on the supporting planning statement undertaken by Cassidy & Ashton dated 14/12/2021.

B. General comments linked to the local plan submission draft and the schedule of main modifications.

C. Overall conclusions of the representation.


Abbreviations list

LA Local Authority

LPA Local planning authority

LPSD Local plan submission draft

MM Main modification

SHLAA Strategic housing land availability assessment

NPPF National planning policy framework

A) Comments on the supporting planning statement


2.4 The site is not partially enclosed; it has only lost a small percentage of its boundary to open space to the east and continues to fully serve the purposes of the green belt.


2.8 The sites listed here at all brownfield sites and as such have rightly been developed to provide housing in line with Saint Helens councils brownfield first policy. these developments have improved the aspects of the earlier and enabled regeneration of former industrial sites. this proposed application is currently designated as green belt and as such a comparison to the previous sites being granted planning permission hold no weight. previous developments on neighbouring brownfield sites do not add to a case for redesignation of green belt land.



Page 166 green belt stage review 2b


3.1 The use of the entire site would be contrary to MM037 and LPD04 criterion 2. The two large 5 bed properties proposed on the extreme edge of the eastern wedge would impact directly on residents occupying numbers 50, 52 and 57 of Ansdale Wood Drive. These properties would be overlooked and results in a reduction of daylight to habitable rooms. this could be accommodated in the plan as the initial developable capacity assessed at stage 2B of the green belt assessment was 84 units.


4.4 This speculative application does not accord with the development plan as the site is safeguarded until beyond the local plan period.


4.5 The LPA have approached the proposed site in a positive way by safeguarding for developments beyond the plan period.


4.6 There is no requirements for a boost of supply. The LPA have produced the LPSD so ensure sufficient housing supply is in place to satisfy the housing projections during the plan period. As set out in appendix one of the updated employment and housing land supply position statements May 2021.


4.8 The LPA have a clear understanding of the availability of land as set out in the SHLAA and green belt review which have informed the LPSD and the allocations within. This parcel has been assessed at all stages of the LPSD process and suitably allocated against housing requirement.


4.9 This site is not required to fulfil housing requirements of the borough until after the plan period.


4.11 a) The needs for different types of housing have already been or being satisfied by existing or planned developments within a stone’s throw of the application site.

b) Local market conditions are tending towards over supply considering the current planned developments…


Eccleston park golf club – 989 Dwellings

Linkway (former Suttons dc) - 294 Dwellings

Waterside village extension - 109 Dwellings

Land South of Sutton High school 180 Dwellings

1572 Total


c) These have been assessed and suitably planned as paths of the LPSD.

d) This speculative application would change the character of the earlier by removing 3.7 hectares of green belt land. At green belt review stage 2b the document states that this parcel of land scores medium to high for landscape and visual sensitivity. This site would not promote regeneration as seen in point 2.8. It can be seen in the indices of deprivation that Lee green falls within the lowest 12% for health deprivation. The destruction of 3.7 hectares of green belt land will in no way contribute to improving the health of local residents.


4.12 There is no anticipated shortage of suitable land for housing developments as can be seen in the LPSD and the identified 15-year supply.


4.13 Destruction of green belt land cannot be seen to positively add to the overall quality of the area. the visual aspects of the area will be fundamentally changed forever. the site cannot support a green public space suitable for new residents to enjoy - the site is fully utilised for housing.


4.15 this site has been subject to the local plan process and a suitably being assessed considering all points highlighted in section 4.15 of the supporting planning document. the result has been to safeguard this land until beyond the plan period.


4.16 The group absolutely agree with the wording highlighted from the NPPF in this paragraph. It is clear that there is a distinct principle within the NPPF for supporting the delivery of homes where required. The main issue for the applicant is that the LPA have demonstrated throughout the local plan process that there is no requirement for developing this site until beyond the plan period.


5.26 Paragraph 5.26 does not take into consideration the cumulative development cycle within walking distance of this site. the documents only identifies 294 dwellings when the actual figure is over 1500 dwellings as can be seen in point 4.11/b.


5.28 The group absolutely disagree that the application is supported on development management grounds by local and national planning policy. the LPA has clearly demonstrated that there is no requirement for the site to be developed within the local plan period. Failure to retain this site as ‘safeguarded’ would amount to admission on behalf of the LPA that the local plan process and housing trajectory calculations are fundamentally flawed.



6.12 Would Cassidy & Ashton be able to supply the evidence to justify their conclusion that they do not believe the five-year housing supply identified in the LPSD will be delivered? This report calls into question the significant work performed by the LPA with no evidence to back up their conclusions. The group absolutely disagree with the conclusions of Cassidy & Ashton and fully support the conclusions of the LPA and government inspector.


6.17 The group strongly disagree with the conclusion that very special circumstances exist to justify consent for this development to be granted. the group have demonstrated that there is sufficient supply identified within the El PSD which has been confirmed by the government inspector at the public inquiry and throughout the main modifications process.


8.4 This is an erroneous statement. the updated employment and housing land supply statement dated May 2021 clearly shows that there is sufficient supply to satisfy housing requirements for the next five years and through the entire plan period. Page 15 of the above-mentioned documents clearly states the shortfall spread over the next five years as zero.








B) General comments


1. Early release of parcel GBP_085_C Would be contrary to St. Helens council’s climate change emergency declaration by releasing safeguarded green belt land before the absolute need is demonstrated.


2. The entire sub parcel lies within a proposed coal and claim mineral safeguarding area. how does this application conform with policy LPC14?


3. Policy LPA02 and MM006 states…


“This Plan releases land from the Green Belt to enable the needs for housing and employment development to be met in full over the Plan period from 1 April 2020 until up to 31 March 2037, in the most sustainable locations. Other land is removed from the Green Belt and safeguarded to allow for longer term housing and / or employment needs to be met after 31 March 2037. Such Safeguarded Land is not allocated for development in the Plan period and planning permission for permanent development should only be granted following an update full review of this Plan. 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 National Planning Policy Framework (or any successor document). Inappropriate development in the Green Belt shall not be approved except in very special circumstances.”


No review of the plan has yet taken place and very special circumstances do not exist to justify early release of this parcel. This is also backed up by policy LPA06 - Safeguarded Land.


4. The proposed application is in direct conflict with policy LPC01. Developments of 25 or more dwellings on greenfield sites require at least 20% to be constructed to adaptable standards and at least 5% designed to ‘wheelchair user’ acceptable standards.









C) Conclusions


The applicants has demonstrated a very weak argument for the early release of this parcel of land from safeguarding status. The argument of lack of housing supply clearly holds no grounds as demonstrated by the local authorities meticulous planning of the local plan submission draft backed up by the findings of the government inspector at the planning inquiry and throughout the main modifications process.


Arguments considering the success of neighbouring developments and deliverability of this site again hold no grounds as neighbouring sites have served to regenerate the area from a past industrial landscape by using brownfield land. These factors are not suitable grounds for greenbelt release are set out in the national planning policy framework.


The supporting document accompanying this application concludes that the five-year housing land supply will not be delivered without supplying any evidence to back up this statement. The supporting document has also grossly underestimated the cumulative effects of proposed and current neighbouring developments and the effects these will have on the local area.


For the reasons stated above, the group requests that planning permission is refused for this application and the safeguarded status of the parcel is retained.

Waterside Village Action Group    Contact the author of the petition