Councillor Andrea Wall – Representation submitted 02.04.2020
I am writing to formally object to any of the Green Space known as Widnes Golf
Club being developed for housing. This land is designated as Green Space in
the UDP and in the Local Plan, it is on the already heavily congested Liverpool
Road and the addition of the cars that go with 255 properties would make the
congestion and resultant pollution worse in this area. There are hundreds of
school children that pass by this on school days and the increased traffic would
bring increased risk to their safety. Already Leigh Avenue, Highfield Road,
Lower House Lane and Liverpool Road are regularly backed up with traffic, to
add more traffic would simply make the existing situation worse. The nearby
primary schools and two of the high schools are already hugely oversubscribed,
adding more houses here would push existing residents out of a chance of a
school place at these schools. Due to this Green Space’s location, I believe
any housing development of this land is uniquely placed to impact on existing
residents across the whole of Widnes.
A housing development here would change the character of the area and lose
us Green Space that we can ill afford to lose, alongside this would be the
destruction of trees, hedgerows and habitats for wildlife. I also have concerns
regarding the flooding that regularly occurs on Liverpool Road. People who live
off Liverpool Road and Leigh Avenue, such as in Foxley Heath, Three Crowns,
Heath Road area and around the Ball O’Ditton, the Kingsway Estate area and
the Shakespeare Road area already regularly struggle to leave their roads to
get on to the main roads, which I have personally witnessed. I have also
personally witnessed the difficulties in people leaving the Frank Myler
Pavilion/Ditton Primary School car park.
I have concerns regarding the capacity of vital services in this area, such as
GPs and dentists, the existing facilities in the area are already very busy.
As I work my way through the hundreds of pages of reports, I will be submitting
further objections, but these are my starting points.
1) As a ward councillor I have spoken to hundreds of people in the vicinity and
not one person has said they agree with this application. In the local area there
is universal opposition to this application, the views of the local community
should be given much weight in the decision-making process, as it is the local
community that would have to live with the result should the development be
2) When the Local Plan was out for Public Consultation, with this land
designated as Green Space in it, over 1,000 representations went in to the
council from the local community supporting the Green Space Designation,
therefore it is clear what the local community’s views are.
3) On page 9 of the Design and Access Statement of the application it states:
“There are a large number of schools in the vicinity which have capacity to
accommodate new pupils.”
This is simply not true, two out of the three local high school are hugely over
subscribed and the nearest primary schools, St Bede’s and Ditton Primary are
also over subscribed.
4) On page 13 of the Design and Access Statement of the application it states:
“To provide a mix of dwelling types that will satisfy local need and enhance the
profile of the area as a whole.” The majority of the houses proposed to be built
are 4 bed+ houses there is not a local shortage of 4 bed+ houses in the private
market sector. From local knowledge of other developments of this nature, it
tends to be people moving into the local area that buy this type of housing, not
people that already live here, therefore it is not the case that there is local need.
The local community are clear that this development would not enhance the
area at all, it would make the existing area worse.
5) Page 13 of the Design and Access Statement also states: “To create a well informed attractive neighbourhood, not dominated by car.” Yet the application
includes 200% car parking and a garage for houses – meaning at least two cars
per property, a huge addition to the already congested roads in the area.
6) I note that nearly a quarter of the 25% ‘affordable’ housing would be in the
form of 1 bedroom flats and none of the properties for market sale are flats it
would appear that the ‘affordable’ housing is being squashed into the smallest
land space possible to maximise the space for full market houses, it is therefore
difficult to understand how nearly a quarter of the proposed ‘affordable’ housing
are indistinguishable from the other housing, as quite clearly a block of flats is
very distinguishable from houses.
7) I do not accept that the golf club have done their best to drive up membership
or to encourage none members to pay to play golf there, I have seen no
evidence of this whatsoever. Indeed, I believe the opposite to be true and this
is in fact an attempt to ‘cash in’ on the land. Recent local press reports state
that the Golf Club are saying for them to continue in their present form they
would have to reduce down to members volunteering to run the course,
therefore there is clearly an option for them to continue.
8) The municipal golf course will be re-opening as a nine-hole golf course with
club house facilities, therefore the proposed 9 hole golf course will not even be
unique in the town of Widnes and is not an enhancement to this borough.
9) This application constitutes a loss of Designated Green Space in this borough
with no replacement Green Space on offer whatsoever and indeed only the
enhancement of another borough’s Greenspace on offer, this is unacceptable
and in my view against the UDP and Local Plan.
I will be writing and submitting further objections in the near future.
Cllr Andrea Wall – Kingsway
Councillor Andrea Wall – Representation submitted 03.04.2020
Following the submission of my first formal objection to this application I will
now turn to the application’s Planning Statement document, Halton’s Core
Strategy, Halton’s Unitary Development Plan and Halton’s Local Plan.
Page 5 of the Planning Statement states that there are four high schools
within a half mile radius of the site, while technically this is true, one of these
high schools, Ashley High School is a specialist education provision, specifically
only for pupils with a SEN/Autistic Spectrum Condition. Ormiston Chadwick has
been over subscribed for the past two years and for the coming year was full
by the time the distance from the school reached 1,231 metres. Wade Deacon
has been over subscribed for many years and for the coming year was full by
the time the distance from the school reached 1,605 metres.
Below my comments are in bold after each policy.
2) Core Strategy Policy CS1: Halton’s Spatial Strategy states:
“Brownfield Focus (beneficial and efficient use of existing sites) Outside of the
Key Areas of Change, the re-use of previously developed land will be
prioritised, notably where regenerating or bringing sites back into use will bring
wider benefits to the Borough. Important green infrastructure within the urban
area will be protected from detrimental development to ensure its value, both
individually and as part of a network, is retained.”
The Designated Green Space known as Widnes Golf Club is not one of
the Key Areas of Change. It is important green infrastructure within an
urban area and must be protected to ensure its value, both individually
and as part of the green network that runs through Spike Island, through
Leigh Rec, through King George Playing Fields and onto the Golf Club is
retained. It is intrinsic to the green network within Widnes.
3) Core Strategy Policy CS3: Housing Supply and Locational Priorities
Housing Requirement states:
“A minimum of 9,930 net additional homes should be provided between 2010
and 2028 at an average rate of 552 dwellings per annum.”
These figures have changed in the Local Plan (DALP) that was unanimously
passed by full Council in August 2019 and is currently with the Planning
Inspectorate the new figures are below:
“During the period 2014 to 2037 provision will be made for the development of at least 8,050 (net) additional dwellings a. At an average of 350 dwellings (net) each year”
Enough housing supply land has been allocated in Halton to achieve
these housing figures, without building on this Green Space. The
Government’s standard methodology calculation of Housing Need gives
a minimum requirement for Halton of 296 net new dwellings per annum,
therefore Halton’s plan exceeds the Government’s minimum requirement
4) Core Strategy Policy CS7: Infrastructure Provision states:
“Development should be located to maximise the benefit of existing
infrastructure and to minimise the need for new provision. Where new
development creates or exacerbates deficiencies in infrastructure it will be
required to ensure those deficiencies or losses are compensated for,
adequately mitigated or substituted before development is begun or occupied.”
This Designated Green Space is bound by residential housing, a railway
line and the very busy Liverpool Road (B5178), for a B road this road
already has huge volumes of traffic and is a main route across the town
of Widnes. When it was partially closed for a number of weeks, there was
chaos on the surrounding road network. Two further roads and three
further openings on to this road, with the addition of approximately
another 500+ cars will detrimentally impact on the infrastructure and will
exacerbate the deficiency that already exists. There is nothing that can be
done to change the B5178 in this location due to its proximity to existing
housing and no amount of Section 106 funds could mitigate the
detrimental impact on local residents.
5) Core Strategy Policy CS12: Housing Mix states:
“On sites of 10 or more dwellings, the mix of new property types delivered
should contribute to addressing identified needs as quantified in the most up to
date Strategic Housing Market Assessment, unless precluded by site specific
constraints, economic viability or prevailing neighbourhood characteristics.”
The Local Plan states the below:
“The Mid-Mersey SHMA 2016 sets out the demographic need for different sizes
of homes, identifying that the majority of market homes need to provide two or
three bedrooms, with more than 50% of homes being three bedroomed.”
The UDP states the below:
“The housing type profile in Halton currently differs from the national pattern
with higher proportions of medium/large terraced houses and bungalows than
elsewhere in the country. Consequently, there is under provision of other
dwelling types, namely small terraced and detached homes and also to a
certain extent, flatted homes. Surveys demonstrate that the variety of bed
spaces provided in homes across the Borough is comparable to other areas in
the country, but that residents’ aspirations are mostly for two and three
bedroomed terraced and semi-detached properties.”
The majority of houses that this application proposes are 4 bedroom
detached houses, yet the need and aspiration in Halton is identified as
being for 2 and 3 bedroom properties. There have already been many 4
bedroom detached houses built in Widnes in the last decade or so, there
is no local need for further properties of this type. I have checked on this
developer’s other sites and the minimum starting price for their 4
bedroom detached houses is £251,000 and they range up to over
£300,000. The average annual income of Halton residents is £28,000, even
in dual income families this would be a mortgage multiplier of a minimum
of 4.4. It is more social housing that we need to meet local people’s
needs, built on brownfield sites, not more 4 bedroom detached houses,
taking away Green Space.
6) Core Strategy Policy CS13: Affordable Housing states:
“Affordable housing units will be provided, in perpetuity, on schemes including
10 or more dwellings (net gain) or 0.33 hectares or greater for residential
purposes. Affordable housing provision will be sought at 25% of the total
residential units proposed. The Council will seek to secure 50% of new
provision as social and affordable rented tenures and 50% intermediate
housing tenures across the Borough.”
The minimum requirement of 25% ‘affordable’ housing is in the
application, however, nearly a quarter of the ‘affordable’ dwellings are in
the form of 1 bedroomed flats, there are no market rate flats in the
application, therefore a quarter of the affordable dwellings would be
distinguishable from the rest. In addition, I note that it is often the case
that developers return once they have received planning permission to
state that they can no longer build the ‘affordable’ dwellings promised as
the scheme is would not be viable (profitable) if they have to build them.
7) Core Strategy Policy CS20: NATURAL AND HISTORIC ENVIRONMENT
“Halton’s natural and historic environments provide the Borough with a range
of biological, geological and heritage assets which are not only of environmental
value but provide a social and economic resource and ultimately contribute to
the character of the Borough’s landscapes. These assets should therefore be
conserved and where possible enhanced for current and future generations and
to ensure a strong sense of place and improve local distinctiveness.”
This designated Green Space is part of Halton’s natural and historic
environment, it is located within the Mersey Community Forest and is the
site of a Deciduous Woodland. Quite clearly this development would
result in the loss of natural/heritage assets of landscape character, as the
proposal is to build on it. Once done this could never be reversed and it
is certainly not enhancing it for future generations, it is destroying it for
8) Core Strategy Policy CS21: Green Infrastructure states:
“Halton’s green infrastructure network will be protected, enhanced and
expanded, where appropriate. Halton Borough Council working alongside other
partners and agencies responsible for the delivery and maintenance of green
infrastructure will achieve this through: Ensuring that new development
maximises opportunities to make provision for high quality and multifunctional
green infrastructure taking account of deficiencies and the standards for green
space provision. Resisting the loss of green infrastructure where there are
identified deficiencies in provision.”
This application goes against this policy to protect, enhance and expand
the green infrastructure. This application would result in a substantial
loss of green infrastructure. This Local Green Space is special to the
local community as is demonstrated by the huge numbers that put in
representations supporting it retaining Green Space Designation when
the Local Plan went out to public consultation.
9) Core Strategy Policy CS22: HEALTH AND WELL-BEING states:
“Ensuring the Borough’s communities have good health and well-being is a
major priority for Halton. Statistics show that health standards in Halton are
amongst the worst in the country and highlight that this is an aspect of life in the
Borough in need of urgent improvement. It is essential that policies are put in
place that tackle the underlying causes of health problems in the Borough, and
facilitate the provision of healthy lifestyles and healthy environments for all.”
This application goes against this policy to facilitate healthy lifestyles and
healthy environments for all. The loss of such a huge amount of
Designated Green Space would have a negative impact on the healthy
environment. In addition the number of additional people would put a
strain on already stretched health care resources in the vicinity, making
it harder for existing residents to get things like GP appointments.
10) Core Strategy Policy CS23: MANAGING POLLUTION AND RISK states:
“Halton is affected by risk to its population, environment and buildings from a
variety of sources from both within and outside of the Borough. The domination
of Halton’s past and current economy by industry has left a legacy of pollution,
particularly ground contamination which presents a physical and financial
barrier for development to overcome. Today, industrial processes in the
Borough are carefully controlled through environmental legislation and permits
to ensure that pollution is managed. In addition to these statutory processes it
is important that the mechanisms available through planning processes are also
used to minimise the effects of pollution on health and the environment.”
The addition of at least another 500 + cars in this area would increase the
pollution levels. Due to the legacy left by the chemical industry in Halton,
it is all the more important to retain Designated Green Space in this area,
this land was originally owned by a chemical company, it is only right that
it is retained as Designated Green Space for the local population, many
of whom have had family members that have suffered ill health due to the
legacy of the chemical industry.
1 UDP Policy GE6 PROTECTION OF DESIGNATED GREENSPACE
“ Development within designated and proposed greenspace, as defined on the
Proposals Map, will not be permitted unless it is ancillary to the enjoyment of
the greenspace or, in the case of designated greenspace in educational use, it
is specifically required for educational purposes, in compliance with Policy GE8.
Exceptions may be made where the loss of the amenity value, which led to the
designation of the site as greenspace, is adequately compensated for. Loss of
amenity value may be compensated for where either of the following criteria
can be satisfied:
a Development on part of the site would fund improvements that raise the
overall amenity value of the greenspace, as measured against the criteria for
designation of greenspace set out in the justification to this policy. In assessing
whether a proposal would raise the overall amenity value of the site,
consideration will also be given to the extent to which accessibility to and
through the site, including linkages with other greenspaces, would be improved.
b The developer provides a suitable replacement greenspace of at least equal
size and amenity value, or significantly enhances the amenity value of nearby
greenspace. In assessing whether a proposal would significantly improve the
amenity value of a nearby greenspace, consideration will be given to the extent
to which the quality and accessibility of the space would be enhanced.
c No proposal should result in a loss of amenity for local residents by forcing
them to travel to a less convenient location.
d In all exceptional cases there would have to be clear and convincing reasons
why development should be permitted or that loss of amenity value could be
a) This application goes against this policy. Building houses is not
ancillary to the enjoyment of the Green Space. The proposal does not
raise the overall amenity value of this Designated Green Space, it severely
reduces the size of the Green Space and the justifications for the policy
clearly state that quantity of Green Space is a consideration. This land is
part of a series of pieces of land that has a target of 30% Woodland Cover
set by the Mersey Forest.
Our environment faces serious challenges, ranging from climate change
to habitat fragmentation, this application goes against the work being
done to improve our environment to ensure Halton plays its part in
tackling the climate emergency.
b) The developer is not providing suitable replacement Green Space of
at least equal size or amenity value.
c) This application seeks to remove an 18 hole course from this
borough, replace it with a 9 hole golf course and invest in an existing 18
hole golf course over the borough boundary. This is a loss of amenity for
local residents, who will have to travel further and by car, increasing
pollution to their nearest 18 hole golf course.
d) There are no clear and convincing reasons that this is an
exceptional case or that it should be permitted, the loss of amenity value
and Designated Green Space cannot be adequately compensated.
12) UDP Policy GE8 DEVELOPMENT WITHIN DESIGNATED
“New buildings required for recreation and interpretative uses will be permitted
within designated greenspace if their function is directly related and ancillary to
the use and enjoyment of the greenspace.”
I have no objection to the Golf Club building a new club house, subject to
it not interfering with the peaceable enjoyment of their neighbour’s
13) UDP Policy GE10 PROTECTION OF LINKAGES IN GREENSPACE
“Greenspace systems, as defined on the Proposals Map, are networks of
interconnecting greenspaces, providing important visual, physical, functional
and structural linkages. Development affecting a “greenspace system” will not
be permitted in the following circumstances:
a It would sever or unacceptably affect visual, physical, functional or structural
linkages within the system.
b It would have an unacceptable effect on any part of the system, to the
detriment of the overall amenity of the system, measured in terms of visual
impact, impact on the landscape, impact on wildlife, and impact on the
recreational value of the system.
c It would be detrimental to the objective of creating a network of interconnecting greenspaces.
d It would break visual or cultural links with the historic use of the landscape.
e It would impair the movement of people on foot, cycle or horse-back.
f It would impair the colonisation or movement of flora or fauna.
g It would cause a material reduction in a habitat whose characteristics are of
demonstrable value to the Greenspace System.
h It would cause demonstrable harm to any protected speciees known to be
dependent on the use of the affected part of the system for migration, breeding,
feeding or shelter.”
This application should not be permitted as it would create each of the
circumstances set out in A through to H, apart from E.
14) UDP Policy GE12 PROTECTION OF OUTDOOR PLAYING SPACE FOR
FORMAL SPORT AND RECREATION states:
“Development that would result in the loss of outdoor playing space for formal
sport and recreation, such as pitches, courts, greens and athletics tracks,
whether in public, private or educational use, will not be permitted unless one
or more of the following criteria can be satisfied:
a A carefully quantified documented assessment of current and future needs
for the school/ educational establishment or local community, has
demonstrated that there is an excess of playing field provision and the site has
no special significance to the interests of sport.
b The existing facilities are of a poor quality and are underused and
development on a small part of the playing space would fund improvements
that significantly enhance the quality of these facilities and enhance the
potential for the increased usage of the site for outdoor sports and recreation,
provided that the development will not affect land forming part of a playing pitch,
bowling green or tennis court, (outside a residential curtilage) including any
safety margins or the loss of any other sporting/ancillary facility on the site nor
reduce the size of the site to an extent which restricted its reasonable use,
taking into account longer-term needs of the local community.
c The developer provides a suitable replacement facility, at least equivalent in
terms of quantity and quality, and which is in place prior to the existing site
None of these criteria have been met, therefore this application should
not be permitted.
15) UDP Policy GE26 PROTECTION OF HEDGEROWS states:
“Development will not be permitted if it is likely to damage or destroy an existing
hedgerow, either directly or indirectly, unless the importance of the proposed
development can be shown to clearly outweigh both the amenity value and
nature conservation value of the hedgerow.”
This application states that existing hedgerow will be destroyed, the
proposed development’s importance does not clearly outweigh the
amenity value and nature conservation value of hedgerow.