Proposed development of M61 Corridor near Horwich, Westhoughton & Blackrod

Matter 8: Additional
site allocations
Statement by Peel
Holdings (Land and
Property) Ltd
March 2014
Stephen Harris
Bolton Allocations Plan
Contents:
1. Introduction 1
2. Question 1 1
3. Land south east of Junction 4, M61 2
4. Land to the south of Chequerbent,
Westhoughton 4
5. Horwich Golf Club, Horwich 7
6. Question 4 8
7. Appendices 8

Project
Client
: HS6-9334-SH-jc
: Peel Holdings (Land and
Property) Ltd
This report has been prepared for the
client by Emery Planning with all
reasonable skill, care and diligence.
Version : 1.0
Date : March 2014
Author : Stephen Harris
No part of this document may be
reproduced without the prior written
approval of Emery Planning.
Emery Planning Partnership Limited trading
as Emery Planning.

Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
1. Introduction
1.1 This statement has been prepared in answer to the questions set out by the Inspector.
1.2 Peel’s overall position is that whilst the Allocations Plan accords with the Core Strategy, the Core
Strategy itself fails to provide for the full, objectively assessed development needs of the borough.
It is therefore no longer up-to-date and fails to take account of the NPPF, which was published after
the Core Strategy was adopted. Peel considers that a review of the strategic policies is required.
As a minimum, the Allocations Plan should programme an immediate review of the strategic
policies of the Local Plan. Alternatively and due to the concerns we raise, the Allocations Plan
should be immediately subsumed into a wider review of the Core Strategy in the format of a new
Local Plan.
2. Question 1
Are additional allocations required to meet development needs or otherwise
make the Plan sound?
2.3 Yes. As we have set out in other hearing statements, in particular matter 3, there is a shortfall in the
overall housing supply and also the 5 year supply. Additional sites are required to meet the housing
requirement, and also to provide the plan with the inbuilt flexibility to deal with potential nondelivery
of sites.
2.4 Peel owns the following sites which it consider could be brought forward to help meet the
development needs of the Borough:
· Land south east of Junction 4, M61
· Land to the south of Chequerbent, Westhoughton
· Horwich Golf Club, Horwich
2.5 Matter 8: questions 2 and 3 are answered below in having regard to each site.
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Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
3. Land south east of Junction 4, M61
3.6 Peel owns the land south east of Junction 4 of the M61, which is immediately to the north of the
draft Cutacre allocation. A site location plan is appended at EP1. The site comprises 9.1 hectares.
The site provides an excellent opportunity for a commercial and/or gateway leisure development.
3.7 Planning permission was recently granted for the Logistics North development, which forms part of
the broad location in the Core Strategy. The Council is proposing to amend the Green Belt
boundaries in accordance with the boundaries of the planning permission. However this creates
an illogical Green Belt boundary, with a strip of Green Belt separating the site in the middle, and a
residual parcel of Green Belt between the site and the M61 (i.e. the land owned by Peel). The M61
is a permanent physical feature which we consider forms the logical Green Belt boundary in this
location.
3.8 Peel’s site forms part of the M61 corridor and the Broad Location, as shown at figure 5.5 of the CS
(page 73). We consider that Peel’s site should be included within the land released from the Green
Belt and allocated for development, for the following reasons:
· The Green Belt boundary can only be changed through the Local Plan process. There are
exceptional circumstances already established for the release of Green Belt at Cutacre. The
question is what is the appropriate boundary having regard to NPPF paragraph 85.
· The addition of the Peel site would provide a longer term Green Belt boundary and greater
economic flexibility and potential within the Plan period (not the first few years only), which
would be consistent with national planning policy.
· Logistics North is due to be completed within 10 years (see Appendix EP2 Harworth letter) so
the proposed additional land would provide for further development within the plan period.
· The Peel site would be suitable and developable as either future expansion or gateway
leisure/service facilities for the wider development – it would be consistent with meeting
sustainable development needs.
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Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
· The inclusion of the site within the Allocation would bring Logistics North to a strong and
permanent boundary of the M61, giving the wider development more prominence to the
motorway. This could assist in attracting and retaining businesses and maximising the
economic benefits of the scheme as a whole. Such ‘frontage’ situations can be seen at most
comparable employment parks. In that sense, the site would complement and support the
consented site.
· If the site is not released from the Green Belt, it requires ‘very special circumstances’ to clearly
outweigh harm caused by development in the Green Belt, to which substantial weight is
attached. If the Council wanted to see development on the site at some point, this would
require Peel (or whoever brought forward such a proposal) to establish such a case and take
a significant risk on a planning application in the Green Belt. This is contrary to a plan-led
approach. The Allocations Plan is the right forum to look holistically at the Green Belt
boundary in this area. Once defined, the Green Belt boundaries need to be capable of
enduring beyond the plan period.
3.9 We recognise that the Core Strategy’s approach to Green Belt release at Cutacre was based on
the now-consented site but in light of the above factors the Allocations Plan would be made sound
by bringing the additional land into the employment Allocation. Indeed the M61 economic
corridor is prominent within the Core Strategy hence any ‘departure’, if it exists, is one of detail.
3.10 Furthermore, we would also draw attention to our representations on employment land as set out in
response to Matter 2. It is apparent that even if the Council’s supply of employment land is taken
on face value, the Council has opted for the very lowest end of the requirement range (145ha).
We consider that this is contrary to the NPPF’s objectives for economic growth, and fails the test of
being ‘positively prepared’ particularly when there are deliverable sites available. It also appears
from the supply that the Council is not allocating sufficient sites in order to actually meet the CS
minimum requirement. Therefore additional sites are required. Our client’s site, which is located
within the M61 corridor and the established broad location for employment development,
represents a logical and deliverable solution to increasing the supply of employment land.
3

Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
3.11 Peel’s proposal to include their site within the Cutacre Broad location is supported by Harworth
Estates, the owner and developer of the consented ‘Logistics North’ scheme at Cutacre (i.e. the
site currently proposed for release from the Green Belt). A letter from Harworth Estates confirming
their support is appended at EP2.
3.12 In conclusion, we consider that this land should be released from the Green Belt and added to the
Cutacre allocation. A plan showing how we consider that the Green Belt boundary should be
amended is attached at Appendix EP3.
4. Land to the south of Chequerbent, Westhoughton
4.13 Peel control and are promoting the land to the south of Chequerbent, Westhoughton. A site
location plan is appended at EP4. The site is currently designated as Protected Open Land on the
adopted Proposals Map. We consider that it would comprise a sustainable urban extension of
Westhoughton for residential or mixed use development. The site was not specifically promoted at
the Publication stage because Peel acknowledged in their representations that the CS does not
provide a policy mechanism for the release of Protected Open Land and it had been clear
throughout the Allocations Plan process that POL was effectively beyond the scope of the plan.
4.14 Peel’s duly made representations stated “As part of Peel’s previous representations seeking a wider
plan review, a number of sites were put forward for development. These are located within
Protected Open Land or the Green Belt and hence given the focus of the Allocations Plan on
implementing the Core Strategy (which protects those designations) it would not appear to within
the scope of the Allocations Plan to allocated those sites. We therefore do not include detailed
objections proposing those sites but await the opportunity to promote those sites at plan review
stage”. However in light of the Inspector’s questions and the housing supply shortfall, which
suggests that a more flexible approach to development of Protected Open Land is needed to
boost supply in both the short and long term, it is now appropriate for those sites to be considered.
4.15 In any event, if additional land is to be released to meet development needs, there will inevitably
need to be a process of considering reasonable alternatives (as required by Sustainability
Appraisal) and finding a sustainable and achievable approach in line with national policy. Relying
4

Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
only on sites that developers have speculated representations upon, outwith the defined scope of
a formal consultation process, would clearly fail to meet those requirements. We therefore provide
information on this site to ensure that the Council and the Inspector are aware of the opportunity,
and to inform the aforementioned process of identifying what land should be brought forward for
development.
4.16 A document has been prepared by Randall Thorp with contributions from Emery Planning and i-
Transport setting out an appraisal of site constraints and opportunities, with a conceptual
masterplan outlining a potential broad form of development. This is appended at EP5. This
demonstrates that the site has the potential to deliver approximately 1,700 new homes at an
average net density of 30 dwellings per hectare, education and community facilities and new
green infrastructure proposals. The vision document demonstrates that there is a deliverable option
for addressing the housing supply shortfall.
4.17 The site is located on the edge of the Westhoughton in a highly sustainable location. It is close to
the town centre where there is a range of local facilities and services within walking distance. As
well as strategic road connections, there are two rail stations in close proximity as well as a range of
bus services. The site is well contained by permanent physical features, namely existing housing to
the north and west, the railway to the south and the dismantled railway to the east. The railway
line and former railway line embankments are tree lined and would provide a logical, well defined
settlement boundary.
4.18 The site is deliverable and can commence promptly within the next 5 years. It is a greenfield site
and has no known constraints. Highways and access matters have been considered by I-Transport
consultants, and their findings are set out in the vision document. Importantly, the site could help
bring forward longstanding aspirations for a link road connecting the M61 and M6, passing through
settlements between Bolton and Wigan, and Wigan itself.
4.19 The site could realistically be brought forward as follows:
· 2014 – Submission of outline planning application; granting of outline planning permission;
submission of reserved matters planning application.
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Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
· 2015 – granting of reserved matters planning permission; completion of legal agreement;
discharging of conditions.
4.20 It is therefore anticipated that development could start on site in approximately early 2016, with the
first dwellings being delivered in 2016/17. From a site of this size Peel would expect an average
delivery rate of 80-100 dwellings per annum (assuming 2 main housebuilders plus a Registered
Provider) thereafter. Therefore we propose that the following rates of delivery could be achieved
on the site:
16/17 17/18 18/19onward
s
25 75 100 per
annum
therefafter
Total to 2026
900 (remaining balance post
2026 = 800)
4.21 The proposed development of the land is considered viable and attractive to the housing market
with high levels of market demand. There are no known significant cost factors that would prohibit
or delay development from commencing immediately, subject to planning permission being
granted.
4.22 In conclusion, the site represents a suitable, deliverable option for addressing the housing supply
shortfall. Therefore if the Inspector is minded to agree that additional housing land is required over
the plan period and/or in the next 5 years, the site could be allocated in the Allocations Plan
through further work and assessment post these Examination sessions. Whilst we recognise that this
would not accord with the approach to Protected Open Land of the CS, the delivery of housing is
imperative and as we have set out in our response to Matters 2 and 3, there is an urgent need to a
need to review the CS due to an out of date requirement and shortfall in supply. Therefore the
Allocations Plan could allocate Protected Open Land now, or as a minimum introduce flexibility
into the plan to allow for sites to come forward to address the shortfall. The alternative is that the
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Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
Allocations Plan is found unsound because it fails to provide for an adequate supply of housing
land.
5. Horwich Golf Club, Horwich
5.23 The site comprises Horwich Golf Club, which is located off Victoria Road, Horwich. A site location
plan is appended at EP6. The site is currently designated as Protected Open Land on the adopted
Proposals Map. Horwich Golf Club was not specifically promoted to the Publication consultation
although Peel did confirm that they controlled sites designed as Protected Open Land and Green
Belt. Therefore the Council has been aware of this source of land. However the site is put forward
now for the same reasons we have put forward for the Chequerbent site.
5.24 A vision document has been prepared by Randall Thorp with contributions from Emery Planning
and i-Transport setting out an appraisal of site constraints and opportunities, with a conceptual
masterplan outlining a potential broad form of development. This is appended at EP7. This
demonstrates that the site has the potential to deliver approximately 240 new homes at an
average net density of 30 dwellings per hectare. The vision document demonstrates that there is a
developable option for addressing the housing supply shortfall.
5.25 The site comprises an existing golf club in a highly sustainable location. It is surrounded by residential
development on three sides and represents a logical rounding off of Horwich. We consider that it
would comprise a sustainable urban extension of Horwich for residential or mixed use development.
5.26 The site has easy access to a range of destinations including Bolton to the east, Greater
Manchester, Chorley, Preston, the East Lancashire towns and to the west towards Wigan and the
M6. Thus the site is therefore accessible to a range of larger destinations but is also close to Horwich
town centre where there is a range of local facilities and services within walking distance. The site
benefits from easy and close connections to the strategic road network but is also close to Horwich
Parkway railway station, which provides direct services to Bolton, Salford, Manchester, Chorley and
Preston. The site is also close to a range of bus services in Horwich. Thus the site has excellent
transport connectivity to the main highway and public transport networks, with a range of local
and regional destinations within easy reach.
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Matter 8: Additional site allocations
Peel Holdings (Land and Property) Ltd
March 2014
5.27 The site is owned by Peel and is developable. It is currently a 9-hole golf course. It has no known
insurmountable constraints. Highways and access matters have been considered by I-Transport
consultants, and their findings are set out in the vision document. It is anticipated that the site
could be developed over a 5-7 year build period following grant of planning permission.
5.28 The proposed development of the land is viable and has been subject to internal development
appraisal by Peel. Horwich is an attractive housing market with high levels of market demand.
There are no known significant cost factors that would prohibit or delay development, subject to
planning permission being granted.
5.29 In conclusion, the site represents a suitable, deliverable option for addressing the housing supply
shortfall.
6. Question 4
What would be the practical and procedural implications?
6.30 The Allocations Plan would need to be amended, resulting in the need for further site assessment
work and additional public consultation and Sustainability Appraisal. However in our view the
changes are required in order to make the plan sound. Alternatively the Inspector could direct the
council to withdraw the Allocations Plan and prepare a comprehensive Local Plan including a
review of the Core Strategy immediately.
7. Appendices
EP1. Site location plan - Land south east of Junction 4, M61
EP2. Letter from Harworth Estates
EP3. Proposed amendment to Green Belt boundary at Cutacre
EP4. Site location plan - Land to the south of Chequerbent, Westhoughton
EP5. Vision document - Land to the south of Chequerbent, Westhoughton
EP6. Site location plan - Horwich Golf Club
EP7. Vision document - Horwich Golf Club
8

EP1

Drain
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Moss Hall
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Moss Hall Farm
Farm Cottages
Track
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A 6
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PH
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SALFORD ROAD
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Path (um)
Subway
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BACK LANE
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Cutacre
Gas Gov
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South East of J4 M61
22.48 acres, 9.10 ha
WB
112.2m
651
Scale: 1:2500
@ A3
Date: 27:01:12
113.7mThis material has been reproduced from
Ordnance Survey digital map data with
the permission of the Controller of
Her Majesty's Stationary Office.
© Crown copyright.
Licence Number 100018033
Ref: AH / RK
Def
659
650
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EP2

EP3

Proposed Green Belt Boundary
Proposed Green Belt Boundary
BDS: RK/ Proposed Greenbelt Boundary
This material has been reproduced from
Ordnance Survey digital map data with
the permission of the Controller of
Her Majesty's Stationary Office.
© Crown copyright.
Licence Number 100018033
Ref: RP/ RK
Date: 20:03:14 Scale: 1:10000
@ A3

EP4

EP6