Rainford Parish Council
Submission to St Helens Council regarding the Local Plan Preferred Options
This document is Rainford Parish Council’s submission to the St Helens Council Local Plan Preferred Options Consultation
The current preferred options include the proposal to build 1100 dwellings within the Parish of Rainford on Green Belt land. While the Parish Council recognises the need to provide new housing and employment across the Borough, it wishes to make the following comments and observations in relation to the existing document:
The Proposed Housing Allocation Sites HA14 & HA 15 included in Phase 1 of the plan
It is understood that the current proposals would see up to 300 dwellings being built on these Green Belt sites. The existing Village does not have the infrastructure and services to provide for such a sudden high percentage increase in the population:
v Rainford has 2 Doctors surgeries and 2 Dental practices. Anecdotal evidence suggests that waiting a week or more for an appointment with a doctor is commonplace. Neither of the dental practices presently accepts NHS patients.
v Although no estimate for the number of new residents is given, it is reasonable to assume that many of the occupants of the proposed housing would be less than 18 years of age. While the CE Primary School is currently undersubscribed by 26 places, 15 of these are in one year group. Although Corpus Christi and Brook Lodge Primary schools may both currently have the capacity for extra pupils, this is not on a scale to accommodate the number of children requiring places. All three of the primary schools in the Village have little or no room for expansion. This would mean that a substantial proportion of children residing within Rainford could not be educated within the Village, or that a new primary school would have to be built.
No site is identified within the plan for this purpose.
Rainford High School was oversubscribed by in excess of 100 places for the September 2016 intake. The Parish Council understands that the school has increased its PAN by 20 to 290, with 10 entry classes, which was approved by St Helens Council. Rainford High has ambitions to increase 6th Form pupil numbers as part of its academisation plans, the fulfilment of which will bring the infrastructure of the school to capacity.
There is no provision for the secondary education of an increased number of resident 11 – 18 year olds within the plan.
v The current limited retail offering within the Village would not be able to support the requirements of an additional 3000 residents and there is no provision within the plan for additional retail outlets.
v It is commonly estimated that for every new home built, the occupiers will have 2 cars. The roads in and around Rainford were not designed or built to accommodate the volume of traffic the first phase of building would create and it is impossible to envisage how the traffic generated by an additional 800 dwellings would be managed. Indeed, many of the roads in the Village, (for example Mossborough Road), struggle to cope with the prevailing vehicular movement. Furthermore, there are frequent accidents, some of a serious nature, at the junction of Mill Lane and Higher Lane and the junction of Mill Lane and the Rainford by-pass (A570). Building houses at site HA15 would further aggravate this dangerous situation. Additionally, much of the extra traffic would wish to travel through Windle Island during the rush hour period. It is the understanding of the Parish Council that the works shortly to commence at this busy junction are expected to be a solution to the existing traffic problems at this location, not to alleviate the anticipated increases due to the implementation of the Local Plan.
The lack of available parking in the Village centre is also an existing issue and further development on such a large scale would only exacerbate this problem. The roads accessing sites HA14 & HA15 are in the main too narrow for the high number of HGVs that would be required during development.
No provision has been made in the plan to cope with the extra traffic generated either in or around Rainford or for improving the access roads to the Village.
v The high volume of cars travelling in, out and through Rainford is partly due to the very poor public transport services. The bus services that are available do not connect with the meagre rail services, and it is impossible to get to and from either Liverpool or Manchester by train in the evening from Rainford.
Other General Observations regarding the content of the Plan
Much of the land within Rainford is prone to flooding and remains such despite remedial works. This is particularly true of sites HA14, HA15, HS18, HS19, HS20 & HS21. Development on these sites would cause even greater problems in adjacent areas and it is difficult to see how the stipulation in the plan that the water flow rate must remain the same post development as it was before, is achievable.
All the Green Belt sites identified for development within Rainford in the Preferred Options consist of Grade 1 agricultural land. People need to be fed as well as housed and there is no provision in the plan for the recovery of this lost farming land in other areas of the Borough. Agriculture and its associated industries are major commercial activities and the highest source of employment within the Parish. No consideration is given to the amount of land locally (and nationally) that is required for growing food or more importantly perhaps, the effect on the local economy of building on farmer’s fields. The Parish Council would question the morality of building on land which produces 2 and sometimes 3 crops per annum.
Rainford Parish Council does not accept the premise made in the plan that 570 new homes per year will be required and queries whether the ‘Brexit’ referendum decision has been factored into the population figures the Council has used to predict housing requirements. It is not unrealistic to assume that EU migration into St Helens will decline over the timescale of the Development Plan. The population of the Borough is currently decreasing with the greatest exodus in the 25 - 44 age group: the very people that developers wishing to build on Rainford’s Green Belt would want to target. The overall effect is a further reduction in population numbers and this calls into question the Council’s statistics in predicting housing requirements in the Borough over the stated 15 years and beyond. Furthermore, there are newly built houses within the Borough that have still not been sold, despite being available for some time. Rainford Parish Council would suggest there is insufficient evidence to support the perceived need for the number of houses required. Therefore the case for using Green Belt land constituting the exceptional circumstances required to release the land for development is invalid.
It is the understanding of the Parish Council that there are a sufficient number of Brown Field sites within the Borough to fulfil the perceived housing and industry requirement. Although more costly to develop, building on these sites would provide affordable housing within walking distance of St Helens Town Centre. This would provide employment and thus stimulate and boost the economy of a town currently struggling to attract both business and residents. Leaving ugly Brown Field contaminated sites as they are is not going to alleviate this situation. Building dwellings on the Green Belt in Rainford will not alleviate this situation. Building affordable homes close to the town centre will.
In recent years, a number of dwellings have been built in Rainford on small plots of land and the Parish Council have supported these initiatives which have put unused land to good use. The Parish Council wish to propose that in order to maintain the rural and Village nature of Rainford, smaller plots of land are identified where minor developments could take place which would not damage the infrastructure of the Village. It would be possible to integrate and absorb the resultant additional number of dwellings and residents, which would not be the case if the many hectares of Green Belt land the plan proposes are developed.
In conclusion, Rainford Parish Council maintains that Rainford does not have the infrastructure to support the large scale development proposed on Green Belt sites within the Village. The current preferred options for Rainford are completely disproportionate given the current size and rural nature of the Village and the limited facilities and services available. Flooding of the sites and/or of adjacent land should be a great cause for concern and St Helens Council should be mindful of the wider effects of releasing Grade 1 agricultural land from the Green Belt for the building of houses.
The Parish Council does not consider that St Helens Council has successfully made the argument for the ‘exceptional circumstances’ required for releasing Green Belt land for development as it questions the validity of the assumptions made regarding the increase of the population and need for housing within the Borough during the time frame of the plan.
Rainford Parish Council suggests that Brown Field sites within the Borough, even if they are more problematic, would be more appropriate for development as this would have the added advantage of assisting in the rejuvenation of St Helens Town Centre. The Parish Council would support small scale developments within the Parish.