Wyre Local Plan – Parish Council response
October 25th, 2017
The following constitutes the representation from Inskip-with-Sowerby Parish Council in response to the Wyre Local Plan consultation. Submitted 25th October 2017:
Part A – Personal Details
Personal ID: 0659
Name: Mike Ainsworth, Parish Clerk
Organisation: Inskip-with-Sowerby Parish Council
Email: pc@inskip-with-sowerby.uk
Phone: 07933-485962
I am content for my personal details to be recorded on the council’s Local Plan consultation database
Date of Representation: 25th October 2017
Part B – Legal Compliance and Duty to Cooperate
Q1. Do you consider the Local Plan to be legally compliant: Inskip-with-Sowerby Parish Council are unaware of any legal non-compliance in the production of the Wyre Local Plan.
Q2. Does the Local Plan comply with the Duty to Cooperate: Inskip-with-Sowerby Parish Council are unaware of any failure to comply with the Duty to Cooperate in the production of the Wyre Local Plan.
Part C – “Soundness”
Q3a. Do you consider the Local Plan to be “sound”: No
Inskip-with-Sowerby Parish Council consider the Wyre Local Plan to be unsound on a number of grounds:
(i) The Objectively Assessed Housing Need (OAHN) significantly exceeds the emerging Wyre housing requirement detailed in the Department for Communities and Local Government “Planning for the right homes in the right places: consultation proposals” September 2017;
(ii) The dispersal strategy for spatial distribution of housing is predicated upon highways constraints on access to the main urban settlements located on a peninsula west of the River Wyre. These highways constraints can be resolved allowing development to be focused in more appropriate locations, places where the demand for new housing is stronger;
(iii) Inskip is a small rural settlement in the heart of the Fylde countryside. The Wyre Local Plan elevates Inskip into a Main Rural Settlement despite the fact that it has less infrastructure to support expansion than neighbouring settlements such as St. Michaels and Elswick that remain Small Rural Settlements. The proposed destruction of the essential character of the rural settlement is not reasonable and is not justified;
(iv) The lack of local infrastructure makes the proposed expansion of Inskip unsustainable;
(v) Concerns related to the location of proposed development at Inskip.
Some of the objections appended below are general, others relate specifically to those aspects of the plan directly related to proposals to extend the Inskip settlement.
Section 1: Introduction
Para. 1.2.1 (3)
The Wyre Local Plan states that stakeholders were engaged in the preparation of the Plan. It states that the Council “held meetings with representatives of Parish and Town Councils on a ‘confidential’ and ‘without prejudice’ basis. It was important to keep Parish and Town Councils informed of the ‘direction of travel’ and seek their views where possible”. Wyre officials did meet up on a number of occasions with representatives of Inskip-with-Sowerby Parish Council, on the dates listed in the Statement of Consultation, however Inskip-with-Sowerby Parish Council does not feel that concerns raised by Parish Councillors at these meeting were taken into consideration adequately by Wyre Borough Council in the preparation of the Wyre Local Plan. In addition, the confidential nature of these meetings meant that Inskip-with-Sowerby Parish Council were unable to consult widely within the local community and so adequately reflect public opinion. This concern was raised with Wyre Council on a number of occasions and the lack of open consultation is in direct opposition to national planning policy which states that early and meaningful engagement and collaboration with neighbourhoods is essential.
Unsound: The Plan is not consistent with national planning policy with regard to meaningful engagement and collaboration with neighbourhoods.
Proposed modifications: The Wyre Local Plan should acknowledge that the lack of open consultation is considered unacceptable by the local community.
Section 2: Spatial Portrait and Key Issues
Para. 2.8 – Key evidence base listed: Lancashire County Council Highways Evidence – Implications for housing developments within the proposed Wyre Local Plan February 2017
The highways evidence supports a limit to the additional number of dwellings at Inskip and St. Michaels of 200 based on highways constraints, specifically the additional highways load at local motorway junctions. No consideration however is made as to the highways load on the rural lanes generated by the additional dwellings. In the case of Inskip specific consideration should be given to the main route out of Inskip towards the north, which is Pinfold Lane, a narrow “moss lane” with deep ditches and sharp right-angled turns totally unsuited to heavy vehicles or to high volumes of traffic. There are regular accidents currently and doubling the size of the village can only make the risk of serious road traffic accidents significantly worse.
Unsound: The Plan is not justified as the highways evidence does not encompass constraints on rural lanes.
Proposed modifications: The Highways Evidence needs to be re-visited taking into account the poor state of the rural lanes, and the number of additional dwellings allocated at Inskip and St. Michaels needs to be re-visited accordingly.
Section 3: Vision and Objectives
Para. 3.4.1
The objectives listed bear little resemblance to the Strategic Objectives presented in the earlier “Wyre Local Plan Issues and Options” in June 2015 other than that both offer 12 objectives. In particular Strategic Objective No. 12 from the earlier June 2015 document, namely “to ensure the sustainability of rural communities and ensure a diverse and resilient rural community” has been eliminated entirely. The Inskip-with-Sowerby Parish Council proposal at the time was that this objective should be enhanced by appending an additional clause reading “whilst maintaining the essential character of rural settlements” – but this was apparently rejected.
Unsound: The Plan is not positively prepared as it does not take into account the need to ensure the sustainability of rural communities.
Proposed modifications: The objective “to ensure the sustainability of rural communities and ensure a diverse and resilient rural community whilst maintaining the essential character of rural settlements” should be re-instated at Para. 3.4.1 as an objective of the Wyre Local Plan.
Section 4: Local Plan Strategy
Para. 4.1.6
Objectively Assessed Housing Need (OAHN) is stated to be an annual figure of 479 dwellings or 9580 dwellings over the local plan period 2011-2031 – however the Department for Communities and Local Government “Planning for the right homes in the right places: consultation proposals” September 2017 identifies the Wyre indicative assessment of housing need at 313 dwellings per annum, a significantly lower value than either the OAHN or the number of dwelling declared within the Local Plan (411).
Unsound: The Plan is not justified and not consistent with national planning policy as it is based on an inappropriate and excessive Objectively Assessed Housing Need (OAHN).
Proposed modifications: It is recommended that the Local Plan is amended to reflect the lower figure emerging from government of 313 dwelling per annum as a revised OAHN.
Para. 4.1.11
The strategy in the Local Plan for spatial distribution of housing is described as one of dispersal. In reality however the demand for additional dwellings is to be found in the main population centres close to employment opportunities rather than in small rural communities. The dispersal strategy is predicated upon highways constraints on access to the main urban settlements located on a peninsula west of the River Wyre. These highways constraints can be resolved through investment in highways upgrades such as those proposed for the A585 trunk road, the Mains Lane by-pass for example, allowing development to be focused in more appropriate locations, places where the demand for new housing is stronger. The evidence supporting the highways constraints needs to be challenged and solutions found. As a result the spatial distribution presented in the Local Plan is fundamentally unsound.
Resolution of the highways constraints allows more effective exploitation of brownfield sites on the Wyre Peninsula that would otherwise be under utilised, allow more development closer to employment opportunities, and, in conjunction with the emerging reduced housing needs requirements (see comments on Para. 4.1.16, above), alleviate the requirement to dump housing development in the rural areas where there is in reality little demand for additional housing.
Unsound: The Plan is not positively prepared, not justified, and not effective as highways constraints within the main population centres need to be challenged and overcome.
Proposed modifications: Detail needs to be provided to justify the Highways evidence prepared by LCC and Highways England and how this leads to the recommended dispersal strategy to housing development. This evidence needs to be challenged and solutions found that allow development to be focused in more appropriate locations, including existing brownfield sites, places where the demand for new housing is stronger.
Para. 4.1.15
“The Local Plan establishes a settlement hierarchy which denotes the role of places within the Borough reflecting the concentration of services and facilities and their accessibility”. In the Wyre Local Plan Evidence Base document Settlement Study, August 2016 Inskip, the largest of five settlements within the Parish of Inskip-with-Sowerby (population 455), is defined in Table 2 as a Small Rural Settlement – as also is St. Michaels (population 405), which appears to be grouped with Inskip in the Local Plan. Likewise the nearest neighbouring village to Inskip, Elswick in the Borough of Fylde (population approx. 1000), though somewhat larger than Inskip and with more infrastructure facilities, is treated as a Small Rural Settlement in the Fylde Local Plan.
The Wyre Local Plan now treats Inskip as a Main Rural Settlement rather than as Small Rural Settlement. There is no consistency between the treatment of the neighbouring villages of Inskip, St. Michaels, and Elswick, to the severe detriment of Inskip. The basis for treating Inskip as a Main Rural Settlement is not made clear in the Settlement Study or elsewhere in the Local Plan or evidence base.
Unsound: The Plan is not positively prepared and the elevation of Inskip into a Main Rural Settlement despite the fact that it has less infrastructure to support expansion than neighbouring settlements such as St. Michaels and Elswick that remain Small Rural Settlements is not justified
Proposed modifications: It is recommended that the Wyre Local Plan is amended to treat Inskip as a small rural settlement.
Para. 4.1.18
The settlement of Inskip, which has a population of 455 (Settlement Study, August 2016 – Appendix 1) amounting to 0.415% of the total population of the Borough (given as 109,749 in Para. 2.3.1 of the Local Plan), is to be allocated 3.4% of all additional housing. This is inequitable in comparison to neighbouring settlements such as Elswick, in Fylde, and St. Michaels – in particular as all of the 200 additional dwellings allocated to St. Michaels and to Inskip within the Local Plan are allocated to Inskip and none to St. Michaels.
The “Wyre Local Plan Issues and Options” in June 2015 proposed three spatial distribution options and for each of these the description as the appropriate level of development at the settlement of Inskip was as follows:
• Option 1: Fylde Coast Peninsula Main Urban Focus – limited development at Inskip
• Option 2: A6 Corridor Focus – limited development at Inskip
• Option 3: Dispersal – moderate development at Inskip
Accepting that the Wyre Local Plan remains based on the “dispersal” option, it is impossible to represent the growth of the core Inskip settlement from 236 dwellings in 2016 up to 518 by the completion of the Wyre Local Plan period in 2031 – a 120% increase – as a moderate scale of development, it can only be described as a massively disproportionate and unsustainable scale of development. Nor can it be represented as equitable when compared with neighbouring settlements.
The “Wyre Local Plan Issues and Options” in June 2015 stated at Para. 6.27 that “the release of site on the edge of all rural settlements would need to be carefully considered to ensure that the expansion of these settlements is not disproportionate and does not have an unacceptable impact on the character of rural areas”. The proposed expansion of Inskip fails these criteria. In response to the earlier “Wyre Local Plan Issues and Options” the Inskip-with-Sowerby Parish Council advised that any expansion of the core Inskip settlement be restricted to approximately 50 additional dwellings.
The moderate expansion of the housing stock at Inskip proposed by the Parish Council reflects the infrastructure deficit at Inskip and reflects public opinion. There are already two unpopular housing estates being developed or in the pipeline at Inskip and the initial results of a survey carried out in response to the publication of the Local Plan indicates that 73% of all households in the Inskip settlement positively oppose any further development (the majority of the remainder of households did not respond either way).
Unsound: The Plan is not positively prepared and not justified as the scale of development proposed at Inskip is massively disproportionate and inequitable. The allocation of the housing quota of 200 new dwellings to be shared between Inskip and St. Michael with Inskip being allocated 200 new dwellings whilst St. Michaels is allocated no new dwellings is inequitable and unjustifiable.
Proposed modifications: It is recommended that the Local Plan is amended to reflect a moderate scale of extension to the core Inskip settlement as proposed in the earlier “Wyre Local Plan Issues and Options” in June 2015, adding no more than 50 additional dwellings to the current and approved housing stock.
Section 5: Strategic Policies
SP1 Development Strategy
SP1 states that “the spatial approach in this Local Plan is one of sustainable extensions to the towns and rural settlements in accordance with the settlement hierarchy below, with settlements higher up the hierarchy, where possible, taking more new development than settlements lower down the hierarchy. New development is required to be of appropriate type and scale to the character of the settlement in the hierarchy unless specifically proposed by other policies in this Local Plan”. The table underneath the text lists Inskip as a Main Rural Settlement as opposed to the designation of Small Rural Community identified in the Settlement Study, August 2016 and there is no indication as to the basis for this ‘promotion’ of Inskip from Small Rural Community to Main Rural Settlement.
The net result is that Inskip take a share of the 19.5% of housing growth allocated to the Main Rural Settlements, and in fact takes the lion share – Inskip is allocated 64% of new housing allocations listed for these 10 settlements (see table at Para. 4.1.18) and this appears both inequitable and unjustifiable.
It appears that, though development opportunities are very limited at St. Michaels owing to its location in the flood plain, Inskip and St. Michaels have been grouped together in order to leverage the excellent highways access to major trunk routes towards Lancaster, Preston, and Blackpool that St. Michaels benefits from in order to artificially uplift the additional housing load that can be allocated to Inskip.
Unsound: The Plan is not positively prepared and not justified as the allocation of housing across the various settlements is inequitable.
Proposed modifications: The Local Plan needs to justify that the allocation of housing across the various settlements is equitable, or where the allocation is inequitable then this needs to be justified.
SP2 Sustainable Development
The Wyre Local Plan should reflect the National Planning Policy Framework in delivering sustainable development. There is a lack of local infrastructure and services at Inskip:
• Nearest Health Centre and Dentist are 4 miles away in Great Eccleston;
• Nearest hospital and ambulance station is at Fulwood some 6 miles distant;
• Extended response times for all emergency services;
• Nearest shops are also at Great Eccleston some 4 miles distant;
• Nearest supermarkets are at Kirkham and Fulwood (some 6 miles distant), or Garstang and Poulton (about 8 miles to each);
• No locally based taxi service;
• Very limited bus service (only every two hours and only during the day on weekdays towards Preston and Great Eccleston, but no bus service direct to Poulton, Garstang, or Kirkham);
• Secondary school students are bussed to either Garstang and Broughton (with some bussed to Kirkham or Poulton);
• There are no transport facilities for 16 to 18 year olds attending college.
And the very limited job opportunities:
• Local job opportunities limited to farming and a few local industrial units offering very modest levels of pay;
• Most working age people have to commute out for work;
• Many commute 20, 40, 60, or more miles to work and back each weekday;
• The nearest train station is 6 miles distant at Kirkham, which is on a branch line some way distant from the West Coast Coat Main Line;
• Nearest access to the motorway network is M6 Junction 32 at Fulwood,
As a result the level of development proposed in the Wyre Local Plan is totally unsustainable.
Unsound: The Plan is not justified and not consistent with the National Planning Policy Framework on the basis that the level of development proposed at Inskip is not sustainable.
Proposed modifications: The Wyre Local Plan needs to offer a level of development that is sustainable and is commensurate with the extremely modest infrastructure delivered in this remote rural setting (up to 50 additional dwellings maximum).
Section 7: Housing
HP3 Affordable Housing
HP3 requires 30% of new development should be affordable homes. In the recent past developers have promised to meet this requirement at Inskip so as to obtain planning consent but have subsequently applied for the condition to be lifted owing to their failure to successfully engage with a social housing service provider.
Unsound: The housing policy with regard to Affordable Housing is not effective and needs to be strengthened.
Proposed modifications: It is recommended that successful engagement with a social housing service provider is included in the Wyre Local Plan as a pre-requisite for planning consent for each housing allocation.
Section 9: Site Allocations
SA1 Residential Development
The Wyre Local Plan identifies a single site at Inskip (SA1/13 Inskip Extension) suitable for residential development and allocates a total of 255 dwellings at this location (of which outline planning permission has already been granted for 55). The Site Allocations Background Paper, September 2017 however details 8 sites at Inskip’ of which 4 were ‘short-listed’. It is noted that all four short-listed locations are all in the same ownership. There is no evidence that land holdings put forward by other landowners were given serious consideration, for example, one site was sieved out on the grounds that it is “in a detached or isolated location”. The location is adjacent to two other sites that were short-listed and adjacent to one of the very few village amenities, the Derby Arms public house.
Unsound: The Plan is not justified as the analysis of potential development sites at Inskip is open to challenge.
Proposed modifications: All potential sites should be treated equitably.
Site SA1/13 – Inskip Extension
The Wyre Local Plan states that the design for the proposed Inskip Extension should “provide an ‘organic’ extension to the village. It should utilise important key vistas into the adjoining open countryside and provide a rural transition zone between the development and the wider countryside. Particular attention should be given to the nature and quality of boundary treatments.” The development being proposed does not constitute organic growth but constitutes disproportionate scale of incursion into open countryside along two boundaries of the existing village (both north and west).
The site consists some of the best Grade II agricultural land in the area. The fields to the north of Preston Road and east of Pinfold Lane are laid out as grass and include several ponds supporting pond-life including newts, coots, and moorhen. This grassland has traditionally supported the grazing of a plethora of wildlife including deer, owls, oystercatchers, pheasants, and geese, and in particular supports a number of ground-nesting birds including corncrake, lapwing, and curlew. There is very strong opinion in the local community that developing this particular greenfield site would be significantly detrimental to the local rural ambience. It is recommended that consideration is given to revising the Wyre Local Plan and allocating land for development with lesser agricultural, ecological, and amenity value.
When Inskip-with-Sowerby Parish Council has met with Wyre planning officials in the past it was acknowledged that development to the south of Preston Road was the preferred option from a planning perspective, all other matters being equal, principally for the following reasons:
(i) further development to the south of Preston Road would “round-off” the core village, preserving a compact area of settlement at Inskip. This is in line with the Wyre Local Plan policy for clear settlement boundaries;
(ii) it would be less disruptive to a larger proportion of the residents of the existing settlement. Few residents overlook this location and fewer residents will feel that their amenity has been blighted by development here than if the main development is to the north of Preston Road. Indeed the main impact of further development to the south of Preston Road, other than the tenant at Hodgkinson Farm, would be residents of the new builds (the 27 currently under construction and the 55 proposed new builds); and
(iii) further development to the north of Preston Road would result in an unbalanced settlement profile, would adversely impact on a larger proportion of the residents of the existing settlement.
It is understood that the land to the north of Preston Road was favoured over that to the south on the basis that the landowner was unwilling to ‘buy-out’ the farm tenancy in the short term. The reality is, of course, that the landowner will still wish to develop the land to the south of Preston Road in due course, it is just a matter of timing. It is recommended that land be allocated in this Plan to the south of Preston Road as this is the most appropriate location for any further development.
Unsound: The location of the proposed Inskip Extension in the Local Plan is not justified and its scale is disproportionate.
Proposed modifications: It is recommended that any proposed Inskip Extension be located to the south of Preston Road.
Part D – Sustainability Appraisal
Q4. If you wish to comment on the Sustainability Appraisal, please make your representation below:
Para. 5.2.1.4
Main rural settlements
The Sustainability Appraisal highlights that “all allocations, other than those located in Bowgreave, are located over 4km away from existing health care facilities potentially resulting in negative effects on health and wellbeing in this area. The lack of health care facilities in these areas may result in the nearest facilities being put under pressure and unable to deal with demand. Furthermore, the large number of residential dwellings proposed in the area could result in a pressure being placed on local educational facilities as well as basic amenities and services. It is recommended that further facilities are included in development in order to mitigate any potential negative effects that development may bring about. It is recommended that sustainable transport provisions to the nearest facilities are strengthened and consideration should be given to new health care facilities which are included in the development”.
In the case of Inskip the existing crisis in provision of primary health will be significantly exacerbated not only by the proposed Inskip-Extension but also as a result of the large developments proposed at Great Eccleston, where the local Health Centre is located.
Until the Wyre Local Plan includes proposals for enhanced Primary Health Care to meet the needs of the communities of Great Eccleston, Elswick, Inskip, St. Michaels, and rest of rural Wyre and Fylde that are currently supported from the small and struggling Health Centre in Great Eccleston it cannot be seen as Sustainable.
Proposed modifications: It is recommended that at Para. 5.3.3 the Sustainability Appraisal is amended to include a Health Policy Recommendation to this effect.
Para. 5.2.2
Rejected alternative sites
Other than stating that the rump of the field to the north of Site SA1/13 – Inskip Extension and sites at Hodkinson’s Farm, to the south of Preston Road, Dead Dam Bridge, Preston Road, and Higham Side Road, Preston Road were rejected owing to highways constraints there is no indication as to why these sites were considered sequentially less preferable to the proposed Inskip-Extension.
Proposed modifications: It is recommended that justification is given for the preference hierarchy of sites at Inskip in order to demonstrate the objectivity of the preference order.
Comparison of Sustainability Appraisal of proposed Inskip-Extension (detailed at Appendix F, Para. 4.4) and rejected sites (Appendix G, Para. 4.5)
The disparity between the scoring of Site SA1/13 – Inskip Extension and of the rejected site at Hodkinson’s Farm is unjustified and unacceptable as there is no evidence presented that differentiates the two sites.
Proposed modifications: It is recommended that evidence is presented that differentiates between the proposed Inskip Extension site and the rejected Hodkinson’s Farm site.
Part E – Next Steps
Q5a. Do you wish to participate at the oral part of the examination: Yes
Q5b. If you wish to participate at the3 oral part of the examination it would be useful if you can explain why you think this is necessary.
Inskip-with-Sowerby Parish Council object to the proposed Inskip Extension on the basis that there is no local demand for this level of development, that the proposed level of development is disproportionate, discriminatory, and is not sustainable, and that the site selection cannot be justified.
There is a lack of confidence within the local community that issues raised will be addressed by Wyre Council in a satisfactory manner and as a result Inskip-with-Sowerby Parish Council feel duty bound to represent local opinion through the public examination process.