West Lancs. Borough CouncilPlanning Departmentvia E mail to:plan.apps@westlancs.gov.uk

147a Blaguegate LaneLATHOMSkelmersdaleLancsWN8 8TX 31st October 2016

Planning Application 2016/1027 - Land

at Firswood Road/Blaguegate Lane, Lathom

This reply refers in detail to the major plans (Transport Assessment, Planning Obligations Statement, Planning Statement, Planning Layout, Design and Access Statement and Economic Benefits Statement) submitted by the applicants. There is much common material that is shared by some of the other documents but repetition under those titles would not be helpful. Less detailed comments for other than those in the major documents are made about some of the other plans.

Concern among residents is very strongly focused on the impact of this development on the whole of Firswood Road in respect of road safety, residential amenity and its rural character. The increase in traffic movements that would flow from this development has been related to the number of houses to be built and Bellway representatives have admitted that their objective is to build the maximum number of homes that falls within 60 forecast vehicle movements, on site completion. It follows that, almost as soon as growth has an impact, that limit would be breached.

In addition, what has not been taken into account is the provision for future development of land belonging to three properties on Blaguegate Lane, which would also add to traffic movements from the site. That could contribute another 30 houses, generating 20 peak hour vehicle movements, which ought to be taken into account, since this future development is what the Development Brief envisages. These movements could only be made to and from Firswood Road under the Bellway plans.

Transport Assessment (including Travel Plan)

Although a revised transport assessment was published on 20th October, it is provisional (one statement being subject to confirmation) and it still contains fundamental errors.

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SOUTH LATHOM RESIDENTS’ ASSOCIATION

“4.9 metres within the vicinity of the site…”

The actual carriageway width is between 4.6 and 4.9 metres, between the railway bridge and Blaguegate Lane.

“2.2.1 Firswood Road which bounds the site to the west has an approximate carriageway of 4.9m within the vicinity of the site and is subject to a 30mph speed limit.”

This statement has been revised since discussion with LCC. The report submitted to LCC indicated Firswood Road width as 5.9m. The revised Transport Assessment needs to be resubmitted to LCC for further evaluation, therefore. The 30mph limit along the southerly section of Firswood Road changes to the national (60 mph) limit close to Slate Lane.

The actual carriageway width is between 4.6 and 4.9 metres between the railway bridge and Blaguegate Lane but narrows at various points northwards of the proposed new site entrance (junction).

The whole document focuses on the section of road between that junction and Blaguegate Lane, which takes attention away from conditions north of that entrance.

“2.2.2 The A577 Blaguegate Lane runs in an approximate east-west alignment, it is subject to a 40 mph speed limit …”

This is incorrect. The actual speed limit along Blaguegate Lane is 30 mph, although higher speeds are common.

“3.2.2 The geometric parameters used for the junction would meet with current design guidance. They include a carriageway width of at least 5.5 metres, footways of 2 metres in width will also be provided on either side of the carriageway and the required junction radii of 10 metres at the junction with Firswood Road as well as Manual for Streets compliant visibility splays of at least 2.4 metres by 43 metres…”

This statement is extremely misleading, since it refers only to roads to be constructed within the development site. On entering Firswood Road, there is only one footpath of 600 to 800 mm. width (see photograph 2 and 3) and the carriageway, which cannot be widened, is only 4.6 metres to 4.9 metres wide for the length up to Blaguegate Lane.

There is no mention of the short distance of this junction, or the steep incline, to the crest of the old railway bridge (3 metres above – see photograph 1 below) or of road conditions north of the bridge where the road narrows more in places and the pavement disappears completely.

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Photograph 1

Please note the ‘Slow’ sign and the positions of the lamp posts, which confirm the very narrow footpath (0.38m) over the bridge.

“3.4.1 Pedestrian and cycle access into the site will be afforded via the proposed vehicular access point into the development site from Firswood Road which will link with existing pedestrian infrastructure located within the vicinity of the site.”

This access refers to the junction with Firswood Road only. No direct access from within the site to the east, north or south is proposed. We consider this to be a major weakness of the plans.

“3.5.1 The site layout has been designed with Manual for Streets (MfS) documents in mind to ensure maximum permeability as well as reduced vehicular speeds allowing for walking and cycling provision to be central to the development site.”

MfS documents “in mind” or observed? Provision for walking and cycling within the site is acceptable but in both cases it is the impact upon Firswood Road, and new and existing residents’ use of it, that is unsatisfactory. Firswood Road is used by local communities for a wide variety of recreational activities which include cycling, horse riding, jogging and walking, including dog walking. An increase in traffic can only increase the risk posed as no footpaths exist for 50% of the length of Firswood Road.

From 4.2.1 ‘…paragraph 30 which states when making decisions, local authorities should:-

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“Support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport” ’

But these plans do not facilitate the use of walking and cycling, which are the most sustainable modes of transport. They enforce unnecessarily long and precarious routes to local facilities and thereby encourage people to use their cars. No account has been taken of the needs of disabled people, young families or elderly residents who have most need of safe routes.

“4.2.2 In addition, paragraph 35 states that to further enhance the opportunities for sustainable development any future developments should be located and designed where practical to:-

• To accommodate the efficient delivery of goods and supplies.

• Give priority to pedestrian and cycle movements, and have access to high quality

public transport facilities.”

The plans give no priority to pedestrian and cycle movements.

“4.2.3 As will be demonstrated within this Transport Assessment, the proposed development accords with the policy test contained within paragraph 32 of the framework which states that:-

'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment and that any plans or decisions should take into account the following;

• the opportunities for sustainable transport modes have been taken up depending

on the nature and location of the site, to reduce the need for major transport

infrastructure;

• safe and suitable access to the site can be achieved for all people; and

• improvements can be undertaken within the transport network that cost

effectively limit the significant impacts of the development. Development should

only be prevented or refused on transport grounds where the residual cumulative

impacts of development are severe.' “

Safe and suitable access to the site cannot be achieved for all people, using the plans submitted. Residual cumulative impacts would be severe, both for the residents of Firswood Road and those of the new development.

‘4.2.4 The location of the proposed development adjacent to a number of local amenities is in accordance with the guidance contained within paragraph 38 which states that:-

“Key facilities such as primary schools and local shops should be located within walking distance of most properties” ’

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Whilst we could not argue about these facilities being within walking distance for an adult in good weather conditions along a suitable route, the proposed route is along Firswood Road and the A577, and the single pavement along Firswood Road is unsuitable for a parent walking young children to school in any weather conditions. An alternative route to school along Old Engine Lane would involve a very unsafe route over the old railway bridge, where the single pavement is extremely narrow (0.38m) and visibility is very restricted. (See also Accessibility section which follows later).

“4.2.6 The site has been allocated for residential development in the West Lancashire Local Plan (2012-2027) and has therefore been deemed a suitable and accessible location for residential development by West Lancashire Borough Council and an independent Local Plan Inspector.

The Local Plan Inspector released the whole site as a single development site, with direct routes to Neverstitch Road. The problem with this site is it is being “creamed off” and so those routes would be cut off, with all routes directed to Firswood Road.

From “4.3.8 The West Lancashire Borough Council – Firswood Road Development Brief (August 2014)…

…4.3.11 The Vision for the Firswood Road site is set out as follows;

The Vision for the Firswood Road site is to develop the land in such a way as to complement the existing residential areas and to diversify the choice and range of housing to meet local needs, whilst helping to create a linear park to provide multifunctional recreation spaces, and improve opportunities for walking and cycling.”

Instead of complementing the existing residential areas, the proposed development would impose itself upon them and it would do nothing towards creating a linear park; in fact, it would hinder access.

Also from 4.3.11 “ ‘Road designs should include permeable surfaces and service infrastructure should go into green space corridors or service ducts’. “

To date there have been no plans for service infrastructure, other than drainage, provided. We are concerned, however, that so far all indications have been that such infrastructure would be provided entirely from Firswood Road.

From 4.3.12 “…Advice received from the highways authority (Lancashire County Council) is that the number of residential units served by an access onto Firswood Road should be limited such that no more than 60 extra trips at peak times be generated by the new housing. This could equate to approximately 100 3-bedroom dwellings, subject to detailed transport assessments demonstrating that the 2-way trip generation on Firswood Road does not exceed 60 vehicles per hour at peak travel times in order to maintain the rural nature of the lane.”

And from 6.6.2 “As agreed with the highways officers at Lancashire County Council, the trip generation for the proposed development has been based on the approved vehicle trip rates that were applied to the Haydock Grange residential development in Preston in order to maintain a consistent approach for residential development proposals in this area of Lancashire.”

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These plans provide for 319 bedrooms and 235 parking spaces, rather than the 300 bedrooms and 200 parking spaces indicated by the above advice. Such guidelines might be appropriate if walking and cycling provision were not so meagre but in the situation here the site should reduce the numbers of bedrooms and parking spaces from the guideline figures, not increase them. The document demonstrates in figure 10 that 74 vehicles would access the site in the afternoon busy period within five years and that figure is based upon a questionable exercise based on trip rates agreed for the Haydock Grange development in Preston, which was approved in 2012. It seems that the Haydock Grange Development consisted of 450 homes of different proportions of house sizes and different provision of affordable homes. We do not believe that the assumptions made for the Haydock Grange development are applicable for Firswood Road because the two developments are substantially different. Moreover, no evidence has been produced of actual trip generation rates being experienced at Haydock Grange, compared with forecasts.

“5.2.2 A pedestrian footway is located along the eastern side of the Firswood Road carriageway along the frontage of the site. The existing footway has an approximate width of 1 metre along the frontage of the site, whilst to the south it has an minimum width of 1.5 metres..”

This statement is completely untrue. The minimum width of pavement to the south is 600mm, which is on the blind junction with Blaguegate Lane. Otherwise the width reduces to as little as 760mm and rises to about 900mm in front of the site (see photographs 2 and 3). To the north, the pavement is extremely narrow (about 380mm –see photograph 1) over the bridge and disappears altogether within the length up to Spa Lane, including around the dangerous bend near to Woodley and Newhaven. The northern area leads to public footpaths at Old Engine Lane and, on both sides, at Slate Lane. The road itself is a favourite area for leisure pursuits such as horse riding, cycling and walking. Any significant increase in traffic would endanger people (including children) and animals involved in these pursuits

Photograph 2 showing the measurement being taken

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Photograph 3 showing the measurement on the stick at that point.

Accessibility

“Table 5.1 Local Amenity Distance (metres)

Bus stops on Blaguegate Lane 450

Spar Convenience Store 1190

Rowlands Pharmacy 1290

Skelmersdale social club 1390

St Richards Catholic Primary School 1520

Co-operative food store 1550

Kingsbury Special Needs Primary School 1580

Sandy Lane Health Centre 1660

West Lancashire Community High school 1680

Liverpool Road Hall Community Centre 1760

Warbreck Garden Centre 1900”

The distance to Rowlands Pharmacy should be around 1570 metres, as it is located at the opposite end of the Sandy Lane Centre from the Co-operative food store.

Skelmersdale Social Club has had an uncertain future for a long time and has been closed for much of the year (and is still closed) for major building works. The sign over the building is now “jynx bar”, which might well prove to be a prophetic name.

The two primary schools quoted do not serve the whole population. One is for Catholic children and the other is a Special Needs school.

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The distances quoted are not conducive to walking because the pavement along Firswood Road is so poor.

Apart from bus stops, all of these facilities could be reached much more easily by walking and cycling if there were a direct and safe route in an easterly direction from the site.

From Appendix 1 table G“Accessibility to other basic services Post Office, Library, Bank and Pub : At least 3 within 1.5 km Score: 1Accessibility to Play Area or Park less than 400m Score: 3 Cycling distance to secondary school less than 600m Score :2”

From 5.6.2 ‘Following the completion of the accessibility questionnaire the proposed developmentaccumulated a score of 20 which places the development within the “Medium Accessibility” bracket.’The score shown (20) is the lowest possible score to be classed as medium. However, certain component scores have been inflated. The Post Office is about 1.57 kilometres from the site, using the document’s own figures (allowing for the mistake about the distance to Rowlands’ shop). Of the four facilities listed there is only a pub within 1.5 km (the Victoria – the Railway Inn has closed), so the score should be zero. No play area or park is less than 500 metres from the middle of (or even the entrance to) the site, so that score should be zero. We do not regard the proposed public open space, which is designed to be used by older children, adults and dogs to be a play area or park but even if it were, the score could only reach 1. The secondary school within the shortest cycling distance of the site is West Lancashire Community High School (a Special Needs school), which is shown earlier to be (when walking) about 1680 metres from the site, score 0. The combined effect of these changes would reduce the total score to 14 or possibly 15, which significantly reduces the accessibility assessment from medium to low.

Traffic Impact Analysis

“From 6.5.2 …For the purposes of this traffic impact analysis it has been assumed that all traffic will travel to and from the south via the A577 Blaguegate Lane/Firswood Road junction…”

“6.6.4 As can be seen from Table 6.1 the residential development 6.6.4 is forecast to generate a 2-way total of approximately 54 trips in the AM peak hour and 59 trips in the PM peak hour…”

Whilst this method simplifies the presentation of vehicle movements, it diverts attention from the northerly route to Spa Lane, which is a problem junction because of restricted visibility and fast moving traffic along Spa Lane. In the busy periods of the day, traffic movements along Spa Lane are more akin to those of a busy A road but no account has been taken of the effects of traffic generation from the development onto this junction, nor on the amenity of residents in this area of Firswood Road.

(See table 6.2) The p.m. increase in movements is shown as 74 using the site entrance but only 59 at the Blaguegate Lane/Firswood Road junction. This suggests that table 6.2 contains an error, given the assumption that all flows to and from the site will use the junction with Blaguegate Lane. Figure 10 shows 74 at both points and growth would take even the lower figure of 59 above the 60 limit provided by LCC Highways within a short time. There would be little comfort for residents in knowing

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that the immediate effects of development would be acceptable only in the very short term. In any case, the acceptability level relates to the impact on junctions and not on local amenity.

Planning Obligations Statement, Planning Statement and Planning Layout

From Planning Obligations Statement

“2.1 The Council have an adopted Community Infrastructure Levy (CIL) charging schedule, the required CIL contribution for this site as calculated by Bellway Homes Ltd is £820,316 at the current rate.”The leaflet distributed to residents states this figure as £969,750 and the Planning Statement says £945,650. Why are the three figures (underlined) different?

From Planning Statement

“1.2 Bellway has undertaken pre-application consultation with West Lancashire Borough Council and the local Parish Council and residents. The advice received and issues raised during these discussions have informed the final design of the scheme.”

“Pre-application consultation” has been virtually non-existent for both South Lathom Residents’ Association and Lathom South Parish Council. That is, the leaflet that was hand-delivered on 5th September to 300 homes (mostly in Skelmersdale) was sent by post to the Parish Clerk on that same date. South Lathom Residents’ Association had subsequently to send an E mail message to Sebastian Tibenham of Pegasus, to let him know of our existence and ask some initial questions. There has not been any consultation in the true sense of the word, since the plans were more or less fixed by that time. One E mail with a requested plan attached was sent to SLRA and then immediately withdrawn.Since the leaflet was uninformative it is not surprising that people waited for more information before responding to the invitation to respond to Pegasus. In any case, most of the local residents of surrounding properties had already given authority to SLRA to represent their joint interests in respect of this development.

Bellway declined an invitation to send a representative to the September Parish Council meeting. The company did not then answer questions sent by the Parish Council until four of the company’s representatives attended the October (12th) meeting. By that time the application had been validated and residents had been informed by letter, under WLBC’s normal procedure.

While the few contacts with Bellway and Pegasus were outwardly friendly and helpful, the information that we really needed was withheld until after the application had been validated and published on 10th October.

From 1.3 “As such, the principle of residential development on the site has already been established and paragraph 14 of the National Planning Policy Framework (NPPF) is engaged, which confirms that proposals that accord with the adopted development plan should be approved without delay.”

The most relevant question is “does it accord with the adopted development plan?” The report of the Inspector into the current Local Plan makes it clear that the allocation is based upon his belief that the whole site for 400 houses would be developed as a whole, based on co-operation between owners of 95% of the land in question. In addition, The Firswood Road Development Brief sets out important requirements which the applicants have either ignored or rejected.

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From 1.8 • “£945,650 (current rate) in Community Infrastructure Levy contributions to fund strategic transport and highway improvements, strategic green infrastructure and communityfacilities.”

There are three different figures in circulation at the same time (see Planning Obligations Statement comment above).

“1.10 In light of the numerous benefits delivered as part of the proposals and the limited impacts of the development, the application can be regarded as being in accordance with the Local Plan and NPPF and we advise that it should be approved without delay.”

It can also be regarded as ignoring important parts of both documents. We say that it is important to get the right sort of development on the site and further thought is needed, including genuine local consultation. Repeated reference to approval without delay, when the final proposal has still not been submitted to WLBC is not helpful.

From 3.5 “The combined urban area of Lathom and Skelmersdale has a residential population of approximately10,000 people.”

Careless use of statements such as this does not engender confidence in the whole proposal.

There is no “combined urban area of Lathom and Skelmersdale”. The population of Skelmersdale (without Upholland) is around 34,000.

Planning Layout

As mentioned already, the applicants have set out to maximise the number of properties in the development, consistent with the requirement to confine busy hour traffic movements to 60 and the proposed layout follows this approach. Problems with that approach have been mentioned earlier in this letter. In addition, the planned layout creates difficulties in the area around 32 Firswood Road and there are unacceptable issues relating to accessibility to and from the site.

Number 32 Firswood Road has a fairly short back garden, in the corner of which is a septic tank. Access to empty that tank from the site would be cut off. Also, surrounding properties would restrict the light levels from the north and east into the rear living area and, as we have already highlighted, there is a complete absence of bungalows planned for the site. We recommend that the layout should be reconsidered to provide small bungalows around this property and to give access to the septic tank. This could be consistent with protection for the outflows from septic tanks all along the southern section of Firswood Road via the field behind them.

No effort has been made to link the site to the rest of the development and no provision has been made for a more direct link to Railway Roundabout/Neverstitch Road. No details have been given for provision of services, (other than drainage, plans for which are questionable) and no plans have been produced for access for construction vehicles and delivery of materials to the construction site. Access for the best line of the proposed linear park past Firtree has been compromised by the position of the foul water pumping station.

There are also properties planned which would not benefit significantly from sunlight and the energy savings that sunlight offers.

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Further bungalows of differing sizes would better reflect the character of the area and all properties should have storage areas for bins at the rear (this is not covered by the plans). We have no objections to some terraced housing being provided, so long as the access to them (and to the rear gardens) is carefully thought out.

Design and Access Statement

Section 1 Introduction to Site

1.1 Vision

“The redevelopment of this site for residential use will tie in with a predominantlyresidential area.”

It is far from being a predominantly residential area. There is ribbon development all along Blaguegate Lane and at the southern end of Firswood Road. The immediate area around two sides of the site is that ribbon development. Heading northwards, the rural setting continues up to Slate Lane. Rural Green Belt land lies to the west of Firswood Road and to the south of Blaguegate Lane. There is open land adjoining the site to the east.

1.2 Site Context Summary

“Location in the wider area

The site is in close proximity to severalschools covering a range of agegroups including Brookfield Park andSt Richard’s Catholic Primary School which are approx 10 mins walk from thesite. Glenburn Sports College, LathomHigh School Technology College andOur Lady Queen of Peace EngineeringCollege are also in close proximity.

Using the only walking route mentioned, the journey to Brookfield Park Primary School on School Lane is considerably longer than the walk to St Richards Catholic Junior School on Sandy Lane, which is around 1.5 kilometres from the centre of the development site. This shorter journey would take a young child about 25 to 30 minutes to walk. How many parents would walk their children to either school in anything but ideal conditions?

Glenburn Sports College has been closed and the journeys to the two other secondary schools mentioned would take longer than 30 minutes to walk, with no pavements to walk along Neverstitch Road and dangerous roads to negotiate, via Spa Lane, otherwise.

“The site is located a short distance (approx 2km) to the town centre of Skelmersdale”

The Transport Assessment states 2.7 km. However the journey by road follows a semi-circle which extends the distance considerably.

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There are also regular bus services to this train station on the no 385 that runs approx every 20 minutes”

The 385 bus service runs every 30 minutes but is supplemented to Ormskirk by the 310/311 service, giving an overall frequency of approximately 20 minutes in the daytime, Monday to Friday. Services in the evenings and through the weekend are much less frequent.

Section 2.1 Constraints and Opportunities

“The opportunities can be summarisedas;- Creating a linear park(our emphasis)- The site sits in a wider development area.- Meeting the aspirations of the LocalAuthority and aid housing provision in thearea by creating a diverse mix of houses.- Utilising existing landscapingto assist with the character and placemaking of the scheme.”

The opportunity to create a linear park is not enhanced by these proposals. The position of the proposed foul water pumping station is so close to “Firtree” (which is on the old railway track) that it makes a minor southerly re-alignment of the park unlikely. A northerly re-alignment would either be more prejudicial to the amenity of “Firtree” or longer and more expensive to provide.

From 3.1

- The council confirmed that the development brief was written at a differenttime and on the basis that the whole site would come forward collectively.- The density of the scheme is less than the 30% target statedin the local plan but the council noted that this was an edge ofsettlement site to Skemersdale where they are seeking to attractmore aspirational housing so therefore there is flexibility.

It is quite clear from the Development Brief that it was not written on the basis that the whole site would be developed collectively, since there is a section dedicated to separate development of the south west corner. However, the whole site for 400 houses was allocated in the Local Plan because the Inspector accepted that it would be deliverable on the basis that it would be developed collectively. This is made very clear in his report.

From 4.1 Design, Proposed Layout

“To provide new and improveexisting pedestrian links.”

The existing inadequate pedestrian links along Firswood Road (the only outlet from the site) will not be improved at all by these plans and yet the increase in pedestrian and vehicular movements would make them more unsafe.

From 4.4 Design, Movement, links and street hierarchy.

“Principle [sic] access for the neighbourhood

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will be taken via Firswood Roadwhich will form an attractivepedestrian friendly avenue”.

See also our comments about the Transport Assessment.

It is perfectly clear from the development brief that only a minor secondary access may be joined into Firswood Road.

How anyone could describe the result of development as being the formation of a pedestrian-friendly avenue is a mystery to us. The single narrow pavement is inadequate for current pedestrian movements and the road is too narrow for safe both-way movements of vehicles. No improvements are planned or easy to envisage. This development would have pedestrians competing for road space with much more frequent movements of vehicles, especially (but not exclusively) at peak times.

From 4.7:

“The dwellings are two storey withdetached garages being single storey.Figure 14 shows the proposed scheme.The scale of the developmentresponses [sic] to the local area andis in keeping with the existingproperties surrounding the site.”

Around 50% of the properties along Firswood Road (up to the bridge) are bungalows and 50% of those along the north side of Blaguegate Lane (from Firswood Road) are also bungalows but not one of the examples used is a bungalow and, more importantly, not one of the proposed 94 houses is a bungalow. How can this be regarded as responding to the local area and being in keeping with the local area? We do not regard detached garages as affecting that situation, especially as we have not referred to existing detached garages as contributing to local character.

4.9 Affordable Housing

The comments in this section say nothing about affordable housing. Only ten per cent affordable housing is proposed, with no housing for the elderly. This compares with 30% and 20% respectively for the whole site. If only 10 of 94 houses are to be built on a quarter of the number (400) planned for the whole site, 110 (37%) will have to be built on the remaining three quarters. On the same basis if no homes are provided for the elderly on this part of the overall site, 80 homes for the elderly (26%) will be required on the remaining areas. Given that the highest prices are likely to be achieved on the application site, it seems highly improbable that these percentages could be achieved over the remaining area, especially in view of the development risks that it poses. Thus, the developers’ and land owners’ targets are completely at variance with the development brief. This points to one or more of the following factors being wrong: proposed land price; proposed profit margins; proposed selling prices.

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From 4.10 Design

“The predominant architectural features in the local area that have informed the proposed elevational treatments are; Tile hanging, brick heads/cills, pediment detailing, porch detailing, render and band coursing.”

The property that has been chosen is the only one in the area that carries such ornate details. It can hardly be described as typical.

Section 4.12 Design Access and Inclusivity

“The proposed schemeoffers choice and variety for all groupswithin the community and aimsto appeal to a multitude of peoplewith differing lifestyles”

With four bedroomed houses making up 50% of the proposed development, only 10% affordable housing and no provision for the elderly, this development would not meet the description given. Given the objective of providing “aspirational” housing, it would be surprising if it did. Whilst we would not like to see a cramped development, such as many of those found in Skelmersdale, we do have a good mixture of housing and people of differing ages who live in the area. The introduction of so many people in the 35 to 50 age range (the group most likely to be attracted to the proposed development, in our view) could destroy the current balance. The area does need some re-distribution of ages but not to this degree. People in this age range tend to be car commuters, which would be most detrimental to the traffic situation along Firswood Road.

Section 4.12 Elderly Housing

The entry about HAPPI is irrelevant, since no housing for the elderly is proposed.

Section 5.1 Sustainability

The following statement is made but the text says nothing overt to support it:

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“ One of the major contributing factors to heat loss has beenshown to be the lack of airtightness in buildings.”

Also, the layout of the site does not contribute significantly to solar gain or electricity generation.

Section 6.1 Summary Conclusion

The development will provide 94new homes which will provide arange of house types to create abalanced mixed community

Design and mix have been compromised by the aspirational aspect. 50% four-bedroomed homes, no bungalows, no provision for the elderly and only 10% affordable housing is not representative of the local character.

The development will create a well Informed attractive neighbourhood,not overly dominated by the car.

This is debatable. There would be 235 car parking spaces provided and walking and cycling to replace short car journeys would not be encouraged by the development. Domination by car movements is highly likely, so it remains open to opinion whether this would constitute over-domination or not. Our view is that it would.

The development will create asensitive and robust solution tothe relationship between existingand proposed dwellings.

This is a meaningless statement. How can overlooking, with no respect for people’s basic needs to retain their current treated water disposal arrangements (drainage into the site) and to empty a septic tank be regarded as sensitive? What is meant by the word ‘robust’, in the context of these proposals? It appears that the applicants have taken no notice of our 2014 comments in respect of the development brief and have designed the scheme from a desktop, without really getting to know the site, its history and its surroundings. Proper pre-application consultation with the local community could have made a huge difference.

“The development will create asense of place which includeshouse types that reference thelocal architectural language”.

The proposed house types are typical of the standard ranges of modern housebuilders, with slight tweaks. The sense of place would be similar to that of any modern estate, largely separate from the existing community. What we want is to integrate the new community with the existing one and the rest of the development site, once that has been completed. Four hundred houses will more than double the population of the southern part of Lathom.

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Economic Benefits

The claims made are open to serious debate. Some of the figures refer to West Lancashire Borough and Lancashire County councils, whereas others relate to the North West or the rest of the country.No allowance appears to have been made for economic losses resulting from the development, or to leakage outside the local economy. Certain claimed benefits are merely substitution: for example Government payments to local authorities, such as the New Homes Bonus, are merely a transfer of funds from national taxation and give no net benefit to the country. The permanent loss of agricultural employment and output from high grade soils should not be overlooked.

Transport costs will be inflated by the need for upwardly mobile people to commute over long distances, which represents wasted money and environmental degradation.

Food and drinks, entertainment, clothing and footwear and household goods are commonly bought by some households in different parts of the regional economy, on out of town retail parks. Unless the regeneration of Skelmersdale Town Centre goes ahead very quickly and changes are made to the current state of Ormskirk Town Centre, not much of the additional expenditure will flow to the local area.

To some extent, the total figures have been under-estimated, because of the nature of housing proposed. Three and four bedroomed housing on the site would be beyond the financial reach of people on average incomes. Therefore, the financial success or otherwise of this development will rely on attracting families which have combined earnings of at least twice the average income for a single person. 94 houses would need to attract in the order of 150 people employed in occupations which generate this level of income, we suggest, and commuting to that type of employment would impact substantially on the number of traffic movements onto Firswood Road.

We also draw attention to the economic impact of the proposed foul water pumping station. Although small in overall financial terms, this pumping station will increase the consumption of energy for the developed site by comparison with a more straightforward and consistent gravity system, leading to higher maintenance and running costs. This plan will thereby unnecessarily increase annual household costs for residents through higher site maintenance charges and will impact negatively on their annual levels of disposable income.

Ecological Assessment

We are disappointed to note that this assessment has been based upon two short daytime field visits in the Springtime, when the field will have been prepared recently for planting. Any search for faeces will have been frustrated by farming operations and no proper assessment of nocturnal wildlife will have been possible, ruling out bats, badgers and barn owls- all of which are protected species.

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