Letter to Derek McKenzie – DC/2025/01178 Land at West Lane Formby discharge of Condition 6 CEMP.

21st January 2026

Derek McKenzie

Head of Planning

Sefton MBC

DC/2025/01178 Land at West Lane Formby discharge of Condition 6 CEMP.

Dear Derek

During the Public Forum at January’s Full Parish Council meeting residents raised concerns regarding construction activity at West Lane Formby.

Chief amongst their concerns was the prospect of the use of concrete driven piles as proposed in Redrow’s geotechnical report by Betts Geo Consulting Engineers.

Today the Parish Council received the report by EnviroSolution’s who were commissioned to review Redrow’s geotechnical submissions. EnviroSolution’s technical note concludes that the ground conditions at West Lane do not justify Betts Geo Ltd.’s dismissal of CFA piling. The site investigation data, including SPT results and successful cable percussion drilling through the peat, show that CFA piles are technically viable and, in several respects, preferable, this is before considering the wider environmental benefits they provide. Driven displacement piles, by contrast, pose significant risks in these soils leading to ‘vibration transmission, excess pore pressure generation, potential artesian effects, and increased likelihood of long-term negative skin friction as peat consolidates’. EnviroSolution also points out that these issues were not adequately addressed in Betts Geo Ltd.’s response.

The note emphasises that CFA piles offer better control of vibration, reduced disturbance to saturated soils, and the ability to ‘design a reliable socket into dense sands below 12 m bgl’ something driven piles cannot achieve with the same certainty. It also highlights that Betts Geo Ltd provided no pile design details and ‘relied instead on unsubstantiated claims about CFA unsuitability’. While driven piles may be cheaper and quicker, EnviroSolution concludes that they present unacceptable environmental and geotechnical risks for this site, and that CFA piling represents the more appropriate and defensible foundation solution.

Considering the above, claims by Betts Geo on behalf of Redrow seem completely undermined.

CFA piling is typically 20-40 dB quieter than driven concrete piles, making it several times less intrusive to nearby receptors. Because CFA rigs generate steady engine and auger noise rather than the high impact hammer blows associated with driven piles, they avoid the impulsive peaks that travel efficiently through loose sands and peat. This distinction is directly relevant to BS 52282 (BPM Best Practicable Means), which requires developers to adopt the method that minimises noise and vibration were reasonably practicable. In the West Lane context, CFA piling clearly represents the BPM compliant option.

Given that the determination of BPM regarding foundation/piling, relies heavily on the ability to challenge geotechnical data, and that Environmental Health Officers do not provide comments in relation to geotechnical engineering considerations, it is impossible for they alone to determine if condition 6 has been satisfied.

Furthermore, from a quick examination of previous major housing developments in Formby, it seems that the process of determining BPM with regards to piling justification has simply involved accepting without requisite scrutiny the method proposed by the developer and then seeking to mitigate noise and vibrations. If so, this is procedurally flawed. Under BPM, a method with inherently high impact cannot be elevated above lower impact alternatives simply through mitigation.

The Parish Council and residents need to be reassured that at least regarding West Lane, Planning Officers will seek the necessary expertise to be able to challenge Betts Geo’s questionable assertions and review the merits of the Parish Council’s Geotechnical Consultants’ report.

Further concerns were expressed about activity on the construction site, hours of work and noise and vibration.  This activity is usually governed by the Construction Environmental Management Plan (CEMP).  However, planning consent has never been granted for Redrow’s CEMP.  Indeed, it is the discharge of Condition 6 that Formby Parish Council is challenging in our Geotechnical review.

Condition 6 states quite clearly that:

No development shall commence (including demolition) until a Construction Environmental Management Plan has been submitted to, and approved in writing by, the local planning authority to cover activities associated with demolition, site clearance and construction hereby approved. The approved statement shall be adhered to throughout the construction period and shall include but not be limited to:

  • measures for the control of noise, vibration and dust during demolition of buildings and structures
  • measures for the control of noise, vibration and dust during site clearance
  • measures for the control of noise, vibration and dust during construction
  • the justification for (to demonstrate best practicable means) and details of the
  •  chosen method of any piling and/or ground compaction.

Reason: To safeguard the living conditions of neighbouring occupiers, land users and the features of the Sefton Coast SAC during both the demolition, site clearance and construction phases of the development.

Demolition and site clearance activities are being carried out prior to the discharge of condition 6. How is this being monitored and against what parameters, when condition 6 has not yet been discharged? Both residents and the Parish Council would welcome a comprehensive explanation as to how this has been allowed.

I enclose a copy of the EnviroSolution’s report commissioned by the Parish Council.

Yours sincerely

 

Claire Jenkins

Claire Jenkins BA hons

Parish Clerk

Copy to residents attending meeting on 19 January 2026