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Lancashire - Campaign to Protect Rural England

St Helens Local Plan: CPRE's response

Wednesday, 23 January 2019 11:27

St Helens Local Plan: CPRE's response

CPRE Lancashire hopes that the St Helens Local Plan will progress towards adoption without delay, as in our experience, greenfield land in the countryside, particularly Green Belt, is more vulnerable to development without the protection of an up to date, and adopted local plan, steering development to the most sustainable locations. However, we do have a number of comments, and encourage our members to read CPRE’s response to inform their own if not already submitted.

St.Helens Borough Local Plan 2020-2035: Submission Draft
Town and Country Planning (Local Planning) (England) Regulations 2012
As stated above, CPRE Lancashire hopes that the St Helens Local Plan will progress towards adoption without delay, to protect Green Belt and greenfield land.
That said, in our response to the Submission Draft Local Plan we did point out that some policy areas, fail to meet the tests of soundness as set out in paragraph 35 of the National Planning Policy Framework (February 2019) (NPPF):
a) Positively prepared – on the whole yes, in fact too positive, leading to over-planning for jobs and housing;
b) Justified – jobs and housing need is over estimated, combined with more brownfield land focus, it erodes the case that ‘exceptional circumstances to release Green Belt exists;
c) Effective – the Local Plan would be more effective if the site allocations were genuinely reliant on a  brownfield preference; and
d) Consistent with national policy – there is conflict with the NPPF, such as Section 11 as currently the Local Plan does not make the most effective use of land.
We make comments against the following policies, see document to download below with more comprehensive commentary.
LPA01: Presumption in Favour of Sustainable Development – strongly support, but some policies in the local plan do not support;
LPA02: Spatial Strategy – strongly support “As a priority, the Council will continue to work to support the redevelopment of brownfield sites in the urban area,”  but we think too much Green Belt is identified for release.
Policy LPA03: Development Principles -  generally supports, as we agree places should be inclusive, and that deprivation should be alleviated in the future.
Policy LPA04: Strategic Employment Sites – support, but 215.4 hectares of new employment land is unjustly excessive.  Our view is supported by the expert opinion of economist Dr. Glenn Athey.  It would be grossly negligent for the Council to allocate too much farmland for development, which is important for future food security, and is currently protected by Green Belt designation on the basis of economic analysis that is flawed and consequently not fully justified.
LPA04.1: Strategic Employment Sites – we opposed needless release of Green Belt land for employment uses.
LPA05: Meeting St.Helens Borough’s Housing Needs – agree, particularly low cost housing in rural areas, but stringent Housing Delivery Tests, introduced by Government means if the Council fails, it results in yet more countryside land being approved for development.  So, now it is even more incumbent on the Council not to plan for one single house too many.  Expert demographer Mr Piers Elias, demonstrates that the 2016-based data would yield a much reduced figure of 360 dwellings per year.
LPA05.1: Strategic Housing Sites - CPRE Lancashire is opposed to needless release of Green Belt land for housing, we reserve the right to comment on all the housing sites included in LPA05.1 at the examination.
LPA06: Safeguarded Land – too excessive, St Helens Council is really going for a “slash and burn” approach to the Green Belt.
LPA07: Transport and Travel – generally supportive, but the local plan should meet the housing and travel needs of all people.
CPRE Lancashire wishes to represent the views of its members at the examination of the local plan in due course.
As the leading countryside charity, CPRE can give guidance to local residents and other interests groups to engage positively with the examination. We can also provide an alternative viewpoint to developer representations to make sure the process is fully balanced.

For more information on how to respond, please see our earlier article:


To focus more effort on important rural campaigns CPRE Lancashire has closed the Springfield Office in Leyland.  To get in touch with us, please contact or phone 01772 378831. Post can be sent to CPRE Lancashire, c/o Acres Brook, Sabden Road, Higham, BB12 9BL

Registered charity number: 1107376, registered company number: 05291461