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Local Plan - frequently asked questions

What stage of preparation has the emerging Local Plan reached?

The Local Plan Submission Draft (2019) was submitted to the Secretary of State in October 2020 for independent Examination. Two Planning Inspectors were appointed to undertake the Examination and public hearing sessions were held throughout May and June 2021.

After considering all of the evidence presented by all parties, the Inspectors advised the Council of the main modifications required to make the Plan "sound" in accordance with national policy. A public consultation on these proposed main modifications was then held between November 2021 and January 2022.

Following consideration of the consultation responses, the Inspectors issued their Final Report into the Local Plan Examination, accompanied by the final main modifications that the Inspectors required to be made to the Plan. In doing so, the Local Plan Examination process was complete.

The Local Plan was then presented to Members at Cabinet, before being officially adopted with approval by members at a meeting of the Full Council in July 2022.

Do the Inspectors require changes to be made to the Plan? If so, what are they?

Yes, the Inspectors identified a number of main modifications that need to be made to the Plan to ensure it can be considered "sound" as required by national policy. The full details of these can be found in a table appended to the Inspectors' Report. The headline changes can be summarised as:

  • Extending the timeframe of the Plan to ensure a 15-year period post-adoption (i.e., the end date of the Plan will change from 2035 to 2037);
  • Taking into account the Council's climate change emergency declaration;
  • Ensuring that Green Belt policy relating to safeguarded land and compensatory improvements is positively prepared and consistent with national policy;
  • Clearly articulating the exceptional circumstances for Green Belt release at strategic and site levels;
  • Modifying Policies LPA01 and LPA04 so that the Plan promotes the effective use of land;
  • Ensuring that the site profiles for allocated and safeguarded sites are site-specific and not generic;
  • The inclusion of bespoke policies for the Bold Forest Garden Suburb and Parkside West;
  • Revising the boundaries for allocated sites 7HA and 9EA and safeguarded site 4HS so that they are positively prepared, justified and effective;
  • Modifying housing mix, affordable housing, and housing standards policies so that they are effective and consistent with national policy (most notably, changing the "requirement" to deliver bungalows to an "encouragement" in policy to do so);
  • Ensuring that the housing and employment land supply position is up to date so the Plan is effective (using the supply position as of 31 March 2021);
  • Amending the Monitoring Framework to make sure it is effective; and
  • A number of other modifications to ensure that the plan is positively prepared, justified, effective and consistent with national policy.

Could the Plan be adopted without making the proposed main modifications?

No, the main modifications are a requirement of national policy to make the Plan "sound". Paragraph 385 of the Inspectors' Report makes clear that the Inspectors would recommend non-adoption of the Plan as submitted to them due to identified soundness issues set out in their Report. However, in paragraph 386, the Inspectors conclude that with the recommended main modifications being made to the Plan as set out in the Appendix to their Report, the Plan satisfies the legislative requirements and is sound, and is therefore capable of adoption.

If the Council does not make the required main modifications to the Plan, it would not be sound, and therefore the Council would need to withdraw the Plan. It is also worth noting that the identification of main modifications is an entirely normal and common part of the Examination process.

Has the Local Plan been subject to appropriate public consultation?

Yes, the Plan has been through various stages in its evolution and has been publicly consulted on at each stage, as follows:

  • Local Plan Scoping Consultation - 20 January 2016 to 2 March 2016
  • Local Plan Preferred Options - 5 December 2016 to 30 January 2017
  • Local Plan Submission Draft - 17 January 2019 to 13 May 2019
  • Local Plan Main Modifications - 18 November 2021 to 13 January 2022

At all stages consultation has been undertaken in accordance with the Council's Statement of Community Involvement (SCI) and the full details of how the consultation was undertaken up to Submission Draft stage is set out within the Council's Consultation Statement prepared for the Local Plan Examination (document reference SD004 in the Examination Library).

The Inspectors considered the consultation undertaken by the Council during the preparation of the Plan, and concluded in paragraph 33 of their Report, "the consultation and engagement methods which included drop-in sessions, appear to have been effective .... Consultation has exceeded the requirements of the regulations."

What does the Plan mean for the provision of housing in the Borough?

The Plan sets out a housing requirement over the Plan period (2016-2037) of 10,206 dwellings.

Between 1 Apr 2016 and 31 Mar 2021 there have been 3,074 additional dwellings made available in the Borough. This number takes account of any demolitions or loss of properties during the time and therefore the number is referred to as 3,074 Net Completions.

Taking these additional properties into account means that the residual housing requirement for the remaining Plan period (1 Apr 2021 to 31 Mar 2037) is 7,132 dwellings. This is the number of homes that need to be built up to the end of the Plan period.

In terms of the supply of land to meet the residual housing requirement over the remaining Plan period (7,132 dwellings), the Plan anticipates it will comprise:

  • 5,670 homes on non-Green Belt land (land in the urban areas and in brownfield sites), and
  • 2,114 homes on Green Belt land

This equates to a supply of 7,784 dwellings over the remaining Plan period up to 2037 to meet and slightly exceed the residual requirement of 7,132 dwellings. This slightly increased number provides some flexibility in the housing supply over the entire Plan period which reflects the need to provide a positively prepared Plan, as set out in national policy.

This overall Plan period supply position was also considered through the Examination, with the Inspectors noting that the evidence showed some 10,858 dwellings are capable of being delivered in the Plan period (comprised of 5,670 in the urban area and 2,114 to be released from the Green Belt and 3,074 completions between 1 Apr 2016 and 3 Mar 2021) against the Plan period requirement of 10,206, providing headroom of 652 dwellings over the Plan period. 

In paragraph 290 of their Report, the Inspectors concluded that "... potential supply exceeds the requirement by around 6%.  Therefore, there is some flexibility built into the supply."  They found the proposed housing supply in the Plan to be appropriate.

Approximately 80% of the residual housing requirement up to 2037 is anticipated to be delivered on non-Green Belt sites, i.e., those in the urban areas and on brownfield sites.

The average annual housing requirement in the Plan has remained unchanged through the Examination process, and the Inspectors have concluded that the proposed allocations to meet housing need are appropriate, including those sites to be released from the Green Belt.

It is noted that the latest standard method figure for local housing need in the Borough is less than the housing requirement set out in the Local Plan. What are the implications of this for the Plan?

The latest standard method figure for local housing need is based on the 2014-based household projections for the period 2022 to 2032 and the 2021 affordability ratios published in April 2022. As noted in the Inspectors' Report (paragraph 51), this has been taken into account in their considerations on the housing requirement in the Plan, and in paragraph 59, the Inspectors concluded "Taking into account the LHN and the economic and other factors referred to above, the uplift and 486 dwellings per annum (dpa) as a minimum housing need figure is justified."

It remains the case that the 486dpa housing requirement is justified to align with the economic growth and job aspirations in the Borough over the Plan period, therefore, the latest standard housing need figure does not justify any change to the housing requirement in the Plan.

How will affordable housing be delivered?

Policy LPC02 Affordable Housing in the Plan provides the policy mechanism to ensure affordable housing will be delivered in the Borough. It takes a zonal approach to the delivery of affordable housing, splitting the Borough into three distinct zones based on viability evidence. Proposals for new open market housing developments of 10 or more dwellings will be required to provide at least 30% affordable housing on greenfield sites in the two most viable zones, and then 10% affordable housing on brownfield site in the middle viability zone.

There is therefore a clear and deliverable approach to the provision of affordable housing in the Borough. The Council will also continue to work with registered providers to consider other proposed schemes for affordable housing in the Borough.

What does the Plan mean for the provision of employment land in the Borough?

The Plan has an overall employment need between 2012 and 2037 of 239 hectares (ha).

Take up of employment land between 1 Apr 2012 and 31 Mar 2021 has been 60.77ha.

Existing supply of employment land (sites with permission and under construction) = 4.99ha.

Total residual employment land requirement between 2021 and 2037 = 173.24ha.

The proposed supply from allocations in the plan to meet the residual need of 173.24ha between 2021 and 2037 totals 182.31ha. This does not include site allocation 1EA, the Omega South Western Extension, as this is allocated to meet employment needs arising in Warrington.

Through the Examination, the Inspectors scrutinised the employment evidence informing the employment land requirement and found it to be justified. The detailed employment figures have been updated (as above) since the Plan was submitted to reflect the latest supply position as of 31 March 2021, and to reflect the additional two years of the Plan period. The employment allocations in the Plan have all been retained, with the exception of those which have been built out or where construction is well underway since the Submission Draft was published in 2019, as the allocation status is no longer needed.

Is there still a need for safeguarded land in the Borough?

Yes, the principle of safeguarding land and the quantum of safeguarded land to be provided were both considered through the Local Plan Examination. The basis for providing safeguarded land is clearly set out in the National Planning Policy Framework (paragraph 143 c and d). Based on all the representations received, and the evidence provided, the Inspectors concluded, in paragraph 107, that "the Plan achieves an appropriate quantum of safeguarded land and demonstrates exceptional circumstances in this respect."

Therefore, there is clearly a need for safeguarded land in the Borough, and the Plan identifies a sufficient quantity of such land.

How does the Plan address environmental issues in the Borough?

The Plan includes a number of environmentally focussed policies designed to ensure that environmental matters are taken full account of in the future development of the Borough and that development can mitigate environmental harms and deliver the greatest environmental benefits, both in terms of site design as well as off-site environmental improvements. Such policies include:

  • LPA08: Green Infrastructure
  • LPC05: Open Space
  • LPC06: Biodiversity and Geological Conservation
  • LPC07: Greenways
  • LPC08: Ecological Network
  • LPC09: Landscape Protection and Enhancement
  • LPC10: Trees and Woodland
  • LPC13: Renewable and Low Carbon Energy Development
  • LPD09: Air Quality

Taking Policy LPC05 Open Space as an example, there are over 1,700 hectares of accessible open spaces and outdoor sports and recreation facilities in the Borough. These include different types of open spaces such as parks and gardens, natural and semi-natural greenspaces, amenity greenspaces, provision for children and young people (including equipped play areas), allotments, cemeteries and churchyards, outdoor sports and recreation facilities (including playing fields, golf courses, bowling greens, tennis courts and sailing spaces.

The policy sets out that the Borough's network of open spaces, is protected, managed, enhanced and where appropriate expanded, development proposals resulting in the loss of open space will only be permitted in limited circumstances, and new residential development will be required to contribute to the provision, expansion and enhancement of open space to meet needs in accordance with the policies of the Plan.

Policy LPC10 Trees and Woodland also makes clear contributions to delivering environmental improvements, particularly with respect to the requirement that where a tree is justifiably lost, its replacement will normally be required on at least a 2 for 1 ratio.

The Local Plan also references the need to provide compensatory mitigation measures in terms of the release of some Green Belt land to meet identified development needs. Such mitigation measures will improve areas of remaining Green Belt land, delivering environmental improvements.

The Council will work with partners, including the Mersey Forest Partnership, to deliver various environmental improvements across the Borough in tandem with delivering growth. An example of this being the £180,000 secured by the Council as a result of the planning permission for the Omega south west extension which will be used to improve green spaces within the Bold Forest Park.

The Policy framework in the Plan complements national policy and legislation in respect of environmental matters, particularly with respect to Biodiversity Net Gain, and will enable the Council to not only protect the existing environmental assets in the Borough, but also improve them.

How does the Local Plan address flood risk?

The Local Plan has a dedicated flood risk policy, LPC12. Reflecting national policy, it states that new development should be located in accordance with the sequential approach, and that major developments should incorporate sustainable urban drainage systems unless there is clear evidence this would be inappropriate. In this respect, a hierarchy is set out for the management of surface water, with the preferred option being the provision of an adequate soakaway or other form of filtration system.

The Plan covers flood risk and water management in significant detail, and flood risk and drainage issues will be considered in full detail through the planning application process for all sites.

How does the Plan address the Borough's declared climate change emergency?

The main modifications to be made to the Plan provide increased reference to how the policies of the Plan will assist the Council in respect of the declared climate change emergency. The main modifications also strengthen the Council's position with respect to providing compensatory measures in the remaining Green Belt to mitigate Green Belt release elsewhere.

Together, these policies provide a strong framework to ensure environmental matters are taken into account along with the delivery of development in the Borough over the Plan period.

How does the Plan ensure the protection of heritage?

The Local Plan has a policy dedicated the historic environment (LPC11) stating that the Council will promote the conservation and enhancement of the Borough's heritage assets and their settings in a manner appropriate to the significance of each asset. The policy sets out the approach to be taken to proposed development affecting heritage assets and areas of archaeological interest. In doing so, there is a clear framework for how planning applications will be considered in this respect, and the heritage of the Borough given the appropriate protections, in accordance with national policy.

How will the Plan ensure that the necessary infrastructure is delivered?

There are various different types of infrastructure to be delivered along with new development and the Plan has a series of policies to facilitate and shape this infrastructure.

For example:

  • In relation to Green Infrastructure and open spaces, the Plan sets out expectations through Policies LPA08, LPC05 and LPD03.
  • In terms of transport and travel, the expectations are set out in Policy LPA06, and
  • In terms of providing affordable housing, the requirements are set out in Policy LPC02.

The site profiles for the allocated and safeguarded sites in Appendices 5 & 7 of the Plan also set out identified specific infrastructure requirements beyond the general requirements that are applicable to all sites.

Supporting the various individual policies with requirements, including those referred to above, is the overarching Policy LPA07, which sets out that the Council will seek to ensure the satisfactory provision of all forms of infrastructure to serve the local community, including through the use of developer contributions. In doing so, a hierarchy of developer contributions has also been set out. This policy provides the mechanism to deliver infrastructure required to mitigate the impacts of new development, including social infrastructure, such as health and education, where it is shown to be necessary.

Education

The Council will be able to secure new schools and / or the expansion of additional classroom space at existing schools through developer contributions in support of new development coming forward, where there is an evidenced need to do so. The policy framework provided in the Plan, as above, enables this to happen.

Health

The Council will be able to secure new health centres and / or extensions to existing health facilities through developer contributions in support of new development coming forward, where there is an evidenced need to do so. This is facilitated by the policy framework set out in the Local Plan. It should be noted that health workers are provided through central government funding based on population numbers.

Transport

The Local Plan contains a policy framework to ensure that development proposals, including Policy LPA06 Transport and Travel, which focusses not only on the need to provide necessary improvements to the road network (local roads and the Strategic Road Network), but also highlights the need to secure the delivery of new or improved bus, cycling and public transport infrastructure, where required.

The Local Plan provides the policy framework to deliver such improvements, where there is an evidenced need for such improvements to support new development. A recent example of this was securing a £750,000 public transport contribution as part of the planning permission granted for the southwest extension of the Omega employment site to be spent on bus service enhancements to link the development into the St Helens bus network to ensure there are links between destinations in south St Helens and Omega.

This is complemented by the opportunity to secure funds from other sources (such as via the Combined Authority) to deliver transport infrastructure improvements in the Borough, such as the St Helens Southern Gateway project, which is currently being delivered, and includes the delivery of new footpath / cycleways, upgrades to Lea Green train station and the nearby Bull and Dog roundabout junction.

How will the Local Plan contribute to delivering social value outcomes?

Policy LPA03 - A Strong and Sustainable Economy states that the Council will support the use of local suppliers of goods and services and the creation of apprenticeships and training opportunities for local people in accordance with the requirements of the Local Economy SPD.

Policy LPA03.1 states that detailed development proposals within a Strategic Employment Site must be accompanied by comprehensive package of training schemes and / or other measures to enable local residents (including unemployed and disadvantaged people) to access and benefit fully from the employment opportunities provided at the site.

Therefore, the implementation of the Local Plan will deliver social value outcomes, and the Council will work pro-actively to maximise such opportunities.

What happens next?

The Local Plan Examination has now closed following the receipt of the Inspectors' Report into the Examination. The Plan will be updated to make the necessary main modifications as identified by the Planning Inspectors, along with any further small, additional modifications needed to tidy the Plan up. The definitive version of the Plan was taken to Cabinet on 30 June 2022 and Full Council on 12 July 2022 for adoption.

Does the recent Queen's Speech and associated Levelling Up and Regeneration Bill have any implications for progressing the Plan to adoption?

The Levelling Up and Regeneration Bill is at the very earliest stages of its progress towards enactment. This being the case, it will likely undergo change to its content as it progresses and it will be some time before it comes into force. Notwithstanding this, there is nothing in the content of the Bill at this time that suggests conflict with progressing the Local Plan towards adoption. Indeed, the Government remains of the view that Councils should continue to progress Plans in preparation towards adoption without delay. 

While the Bill progresses, it remains critical that the Council has an up-to-date planning policy framework in place, in the form of a new Local Plan. This will ensure the Council is in the best possible position to deliver and shape the identified growth needs of the Borough in the most sustainable way, whilst protecting against inappropriate development.