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 Unitary Development Plan (UDP) and in the Local Plan, it is on the already heavily congested Liverpool Road and the addition of the cars that go with 233 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 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 granted permission.
- 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 community supporting the Green Space Designation, therefore it is clear what the local community’s views are.
- 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. 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 at least a quarter of the proposed ‘affordable’ housing is 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 proposed 9 hole golf course is not an enhancement to this borough, it is a downgrading and a detriment 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 Green Space on offer, this is unacceptable and in my view against the UDP and the Local Plan.
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.
- 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 last 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 last year was full by the time the distance from the school reached 1,605 metres.
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 for Halton.
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 road 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 states:
“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 future generations.
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. There is also a proven link between green space and trees helping with mental health.
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.
11. UDP Policy GE6 PROTECTION OF DESIGNATED GREENSPACE states:
“ 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 adequately compensated.”
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.
- The developer is not providing suitable replacement Green Space of at least equal size or amenity value.
- 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.
- 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 GREENSPACE states:
“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 properties.
13. UDP Policy GE10 PROTECTION OF LINKAGES IN GREENSPACE SYSTEMS states:
“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 inter-connecting 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 species 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 being lost.”
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.