Rainford Action Group (RAG) Representation;
St. Helens Local Plan 2020-2035 Proposed Submission Draft
- Overall Plan
- Comments on site 8HA (Land South of Higher Lane and East of Rookery Lane, Rainford)
- Appendix 1
|SHLP||St. Helens Local Plan 2020 -2035 Proposed Submission Draft|
|SHBC||St Helens Borough Council (“The Council”)|
|RAG||Rainford Action Group|
- This submission is made on behalf of Rainford Action Group (RAG) in consultation with the concerns raised by the local residents and complements the SHGBA submission by Kirkwells.
- RAG was formed in Dec 2016, initially to help Rainford residents to understand what was being proposed by St. Helens Council in the SHLPP, and to help them through the somewhat complicated submission process.
- Many residents were deeply concerned by the scale of development in Rainford proposed by that document. A committee was formed to represent the views of the community and encourage participation in the process.
- Public meetings were held with over 400 attendees, and a Facebook Group was set up which currently has 1,500 members, as well as a Twitter account with over 1,000 followers.
- RAG welcomes the reduction in the number of sites and housing numbers proposed for Rainford in the St.Helens Local Plan 2020-2035 Proposed Submission Draft.
- RAG is not against development per se, and accepts the need for new housing in the right amount and location and where there is a proven need.
- We would also like to see the early adoption of a local Plan. However, we do not believe that this Proposed Submission Draft passes the tests of soundness as set out in paragraph 35 of the National Planning Policy Framework (February 2019) (NPPF ) and there are number of issues we feel need to be addressed which are set out below.
- Overall Plan
In summary our issues with the overall plan are;
- There are no exceptional circumstances to justify not using the standard method to calculate housing need
- The economic analysis is flawed and based on over-optimistic assumptions
- The level of land needed for housing and employment is therefore not as high as set out in the Plan
- There are therefore no exceptional circumstances to change Green belt boundaries
- Other reasonable alternatives have not been fully explored, including lower target figures and using more previously developed land and remedial work to bring back into use land currently classified as contaminated
- The Council have failed to co-operate with other councils and have not published any statement(s) of common ground.
- Traffic & congestion are already a serious issue for Rainford residents, with the village situated at the ‘wrong’ side of the A580 East Lancs Road for access to St Helens. Windle Island has been a severe pinch point for many years and the current works to improve the junction will only give 13% headroom over current levels. This will be swallowed up by additional freight traffic from warehouse and housing developments in the Plan and already approved at Florida Farm, plus increased Superport traffic. This will serve to limit economic growth.
[Note: Points 3.1 to 3.6 are covered in detail in the Kirkwell’s submission on behalf of St Helens Green Belt Association, and by Dr Athey’s submission.]
- Comments on Site 8HA
(Land South of Higher Lane and East of Rookery Lane, Rainford)
- Only 4 sites score 4 negatives* (red) on the Sustainability Appraisal, and the other 3 have all been discarded. SHBC’s own assessment is that 8HA is the least appropriate Green Belt site allocated for housing in Phase 1. It is therefore logical that this should be the first site Green Belt site released from development if the housing need is reduced. We are arguing (3.1 above) that the Council should use the Standard method of 468 rather than the uplifted 486, which over 19 years equates to 342 fewer houses. This comfortably exceeds the 259 houses planned for site 8HA
- This site is next to an Industrial Area and subject to the risks associated with industrial activity such as pollution and even explosions, both of which have been recorded recently. Other sites have been excluded during the site assessment phase due to being next to similar industrial employment land – for example see SHLAA 2016 site assessment ref 16m & 142. (See Appendix 1 for further details)
- The site is Grade 1 Agricultural Land and is some of the most fertile land in the Country. Just 2.7% of the surface area of England is as Grade 1 Agricultural Land. It is actively farmed, providing 2 crops per year and employment in the agricultural sector. These jobs are threatened by the proposed removal of this site from the Green Belt. Housing in close proximity to the Industrial Area will limit future activity and expansion of this site, due to health, safety and amenity concerns. The SHLP is intended to promote employment and economic growth yet this will have the opposite effect.
- Site 8HA is close to two accident blackspots in Rainford at either end of Mill Lane and traffic from this site will inevitably pass through one or other of these junctions on the way to/from St Helens
- The site is reasonably well served by bus, with hourly bus services to St Helens and Ormskirk, but poorly served by rail with the nearest train station located in Rainford Junction over 2 miles away with minimal parking facilities.
- The site promotes biodiversity and sustains wildlife. Building will destroy habitat and reduce biodiversity. Mitigation is not properly addressed in the Plan.
Supporting details for point 4.2
The requirements scheduled for this development in the site profile in Appendix 5 are;
- Safe highway access should be provided from both Rookery Lane and Higher Lane (with any necessary off-site improvements).
- Appropriate noise attenuation measures, should be incorporated to protect new residents from unacceptable noise levels from the adjoining industrial area.
- A flood attenuation feature and habitat creation (similar to existing woodland to the south-east of the site) would be required along the south -western boundary with Rainford Linear Park (minimum 25m).
- Existing protected trees within the site should be given due consideration in line with Policy LPC10. • The design and layout should provide for a range of house types in accordance with Policy LPC01 and LPC02.
There is no indication that either safety or pollution issues have been adequately considered. Smoke and pollution have been observed on a number of occasions extending onto the proposed site.
NEWS REPORT ON EXPLOSION
On 28th May 2018 there was a “huge explosion” at one of the units adjacent to this site, which is an example of the dangers of siting housing so close to industrial activity. See report and photo below from the Liverpool Echo
A “massive explosion” was heard shortly before a fire broke out at a Merseyside industrial estate this evening.Fire crews were called to Rainford Industrial estate, in St Helens , at around 7.40pm to reports of thick black smoke coming from the building on Sandwash Close.People in the area at the time said the bang was so loud it “shook the windows”.
One woman, who lives on Mill Lane, told the ECHO: “We we’re having a barbecue out the back and heard a massive explosion. It startled us all a bit and my husband said it shook the windows in the kitchen.“When we came out to look we could see the black smoke coming out. It looked like it was travelling for miles.”
Another local resident said she was walking her dog on the “dirt track” next the industrial estate when she heard between six and eight bangs and saw thick smoke and big flames shoot into the air.
Crews are still battling the large fire at the site but the smoke has subsided significantly and it appears to be under control.
A road closure is currently in place on Sandwash Close and people are asked to avoid the area.
A Merseyside Police spokesperson said on Twitter: “Please be aware that we have received reports of a large fire at MillLane – RainfordIndustrialEstate.