Objection to DC/2022/02326 Shorrocks Hill Country Club, Lifeboat Road, Formby

DC/2022/02326 Shorrocks Hill Country Club Lifeboat Road Formby Liverpool L37 2EB

17th February 2023

Planning Department

Sefton MBC

Hybrid planning application seeking outline consent for the erection for up to twenty-five custom-build dwellings with access to be determined and all other matters reserved; full planning permission is sought for the sitewide layout (all areas excluding housing plots); including associated infrastructure, access and landscaping; and the construction of a 100-space public car park with WC block.

Formby Parish Council objected to this development at the Local Plan hearings, the proposal is within the Coastal management zone, the development represents the extension of the settlement of Formby west towards one of the fastest eroding coastlines in the country.  Formby point lost 700m of coastline between 1920 and 1970.  Although the pattern of erosion has changed since then, climate change, more extreme weather events and sea level rise, raises a question mark over the more recent accretion.  Over all the last 100 years has seen a net retreat of the coast at Formby Point.

National Planning Policy Framework (NPPF) para 174, states that “Planning policies and decisions should contribute to and enhance the natural and local environment by:

  1. c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate;”

Much of this site is previously undeveloped with a far smaller proportion consisting of the old country club building and sports facilities.  The scale of this proposed development is out of character with other developments within the Coastal Management Zone which consists of sparsely dotted dwellings around Alexandra and Albert roads.

The application site is 4.67 hectares whereas the land released in the Local Plan is 3.3 hectares, this represents a further green belt grab.  The Justification for developing 3.3 hectares and not simply the existing structure was the wider benefits that the scheme would bring.

Formby has seen a significant number of windfall sites coming forward for development, the latest being the Royal Public House Liverpool Road Formby, since the Sefton Local Plan was adopted in 2017, this has diminished the need for housing sites like that at Shorrock’s Hill to meet objectively identified need for housing.  Further more Formby and Little Altcar Neighbourhood Plan section notes that Formby has a “disproportionately high percentage of houses with four or more bedrooms”.  The Neighbourhood Plan seeks to address this with policy H4 Housing Mix which requires development of over 15 dwellings to provide no less than 33% 1 and 2 bed properties and no more than 15% 4 or more bed properties.  The current proposal fails to meet this housing mix.  Further more the development includes a 3 storey property contrary to Policy H5 of the neighbourhood plan.

Local Plan Policy NH4 The Sefton Coast Section 3 says “within the Coastal Change Management Area as shown on the Policies Map, development must take into account the risk of coastal change and the vulnerability of the development and must:

  1. Be located in accordance with a sequential approach to risk and vulnerability,
  2. Be safe over its planned lifetime, and
  3. Provide wider sustainability benefits

In order to provide wider sustainable benefits Sefton Local Plan policy MN2.15 set out what the applicant must provide in order to satisfy this policy.

MN2.15 Land at Shorrocks Hill, Lifeboat Road, Formby, states that “Development of this site must:

  • ensure that sufficient information is provided with the planning application to enable the Council to make a Habitats Regulations Assessment. Any planning application at this site should seek to avoid increased recreational pressure upon the SAC and address any likely significant effects upon these habitats as a result of the individual project alone;
  • secure the long term management of the adjacent woodland Local Wildlife Site between the site and Formby Point Caravan Park, to minimise impact on the adjacent internationally important nature sites;
  • provide for full public access into the area of woodland between the site and Formby Point Caravan Park in a manner which minimises impact on the adjacent internationally important nature sites;
  • extend the existing Formby no. 52 Bridleway through the woodland area from Lifeboat Road to Alexandra Road;
  • provide a new 100 space public car park in the northern part of the allocation; and provide a new public toilet block adjacent to the car park and secure its long term management.

The application fails to fully address every condition set out within this policy.  As acknowledge by the Consultee response from Natural England the applicant has not provide sufficient information in order to make a Habitat Regulation Assessment.  They also fail to demonstrate how they are to secure a long term management of the woodland Local Wildlife Site between the development and Formby Point Caravan Park, or how they intend to provide public access “in a manner which minimises impact on the adjacent internationally important nature sites”.  There has been no attempt to address the extension of Formby no. 52 Bridleway, through to Alexandra Road.  Although there is provision for a 100 space public car park the Highways manager notes that there are no disabled places or provision for pedal cycles and the long term management of the car park and toilet block has not been secured.

The Traffic Statement submitted in support of the application, has been criticised by Sefton’s Highways Department. Amongst its failing are;

  • The ATC traffic survey being carried out in September, and due to this does not support or reflect the number of trips the proposed car park will generate, this has implications for the design of the proposed junction with Lifeboat Road.
  • No information was provided on the weather conditions during the 7 day survey, which may significantly affect trips to the existing Lifeboat road car park.
  • The scores within the Minimum Accessibility Standards Assessment are incorrect. The Highways officer pointing out that the “applicant must note that the site is not within 800m of a district centre”.  Further more it is 1000m to the Coop mini market, 1500m to the nearest train station, and 2400m to the District Centre, more than 3 times the preferred maximum for journeys by foot.
  • Sefton Highways point out that there are no provisions for disable parking which will require wider bays, this development will require 6 disabled parking bays.

The considerable failing of the Transport Statement is also contrary to policy GA1 of the Neighbourhood Plan, ‘enhancement of existing and provision of new rights of way’(public access to woodland),  GA2 the applicants Minimum Accessibility Standards Assessment is in accurate and Transport statement is flawed for reasons set out by Sefton’s Highways team above, and GA3 ‘new residential Streets will be designed with a regard to the needs of pedestrians and cyclists and other highway users. Sefton’s Highway Team commenting on the proposed access road state that “the lack of pedestrian facilities leading to the dwellings do not provide suitable access and in this form the Council would not consider its adoption.

The Local Lead Flood Authority object to this application and recommend refusal as there is insufficient information to assess the principle of sustainable drainage proposals and surface water management for the proposed development, the Lead Local Flood Authority object to this application and recommend refusal of planning permission until further information has been submitted to the local planning authority”.

It is clear that this application should never have been validated, as it did not provide sufficient information to determine the proposal, and it should be refused as premature and contrary to national and local planning policy.

Formby Parish Council felt that this allocation within the Local Plan had serious questions about its  sustainability in back 2017.  Since then pressure on the coast has increased, visitors to the Lifeboat Road National Trust Car parks have increase, and the congestion and parking (irrespective of traffic orders and parking restriction) has become intolerable.  The car park will do little to improve the situation as demand will always out strip supply during periods of warm weather, and this proposal will create yet another bottle neck.  The proposal offers very few wider benefits and threatens to exacerbate a growing problem for Formby residents near to the coast.

For the reasons listed above we would ask that this application be refused.

Yours sincerely

Claire Jenkins BA hons

Parish Clerk