News & Views

Extract from:

Hale Parish Council's Representations to the Consultation of Hale Borough Council's Submission Draft of the Delivery and Allocations Local Plan (DALP) September 2019.

Section 4.Objection to Liverpool John Lennon Airport Operational Land and Airport Expansion

4. CS(R)17: Liverpool John Lennon Airport Operational Land and Airport Expansion 

4.1 Hale Parish Council objects to Policy CS(R)17 in the strongest possible terms. 

4.2 In consultations conducted by Hale Parish Council, this development appears at odds with the long-term aspirations of the community for access to green space and full enjoyment of the environment by residents and tourists alike. 

4.3 Hale Parish Council has begun work on a Neighbourhood Plan and an early survey conducted in 2018 indicates that there is strong objection to the expansion of Liverpool John Lennon Airport (LJLA). 

4.4 The Liverpool Airport Referendum that took place in Hale on 10 October 1993 can evidence further dissent to the expansion of LJLA. Whilst data from twenty-five years ago may seem somewhat out-dated, it works to show the longstanding local opposition to the proposals, which saw 88.5% percent of voters object to an expanded airport that would result in a 12 million passenger throughput per annum. 

4.5 A Planning Application submitted by Liverpool Airport in 1993 resulted in an Inquiry and despite the justification of the evidence for the proposed expansion being deemed unsubstantiated at the time, it appears there has been little change in the scale, reasoning and magnitude of growth proposed in the “Masterplan 2030” and “Masterplan 2050” produced by LJLA that has been used by Halton Borough Council to serve as an evidence base for this Policy. 

4.6 Positioned in line with the Master Plan of LJLA, this Policy forms part of a plan that relies upon a growth in passenger numbers. The forecasts offered by LJLA that form part of the justification for expansion, are not quantifiable and do not accurately reflect actual historic passenger growth. It should be noted that whilst LJLA had predicted in 2007 their total annual traffic throughput would reach 8.3 million by 2015, this was a prediction that subsequently demonstrated an over projection of 4 million. In actual fact, there has been a loss of passengers per annum from 5.5 million per year in 2007 to just 5.1 million per year in 2018. This dramatic loss in passenger figures was despite the construction of a new multi-level car park, the opening of three budget hotels within half a mile, and the reconstruction of the runway to ILS Category III standards. With such precarious passenger figures and no long-term stability in passenger growth, it is unclear why Page 29 of the LJLA Masterplan 2050 displays such a positively correlating year-on-year future forecast in passenger figure growth and LJLA should be challenged to demonstrate the reliability of these figures. 

https://www.liverpoolairport.com/media/2957/liverpool-john-lennon-airport-master-plan-to-2050.pdf 

4.7 The desired outcome of the 2007 Master Plan to attract further investment has shown little longstanding sustainability with the airport failing to attract permanent investors. The past decade shows large percentages of changes in ownership, buybacks and re-sales, with the 2030 Master Plan facilitating no measurable growth to the tourism, employment or prosperity of Halton during this timeframe. There is no correlation between this development and the future success of LJLA and it has been perceived by some residents as nothing more than an exercise to land-take. This year, Peel, the owner of LJLA, has been a forced seller of its LJLA shares because it has very little liquidity. LJLA has a net debt of £75M in its 2018 accounts and - more concerning - it has never achieved a profit. 

https://www3.halton.gov.uk/Pages/planning/policyguidance/pdf/evidencebase/areaspecific/ALL LJLA.pdf 

4.8 LJLA assume that increases in airport use will be as a result of creating additional International routes and a freight handling facility - an “if you build it, they will come approach. Growth levels are unrealistic and undeliverable based largely on an unpredictable and transient logistic market. Manchester Airport serves as an International Airport only approximately thirty minutes away from LJLA and there has been no success when past schemes have been brought forward for International flights to operate from LJLA. International airline operators have expressed no long-term interest in LJLA and it only manages to retain its current budget airline operators with attractive incentives that are not sustainable to the business model. 

4.9 In the 1990s, Liverpool Airport had originally proposed an airports development strategy to limit Manchester Airport's growth to that achieved from a single runway, and increase the use of Liverpool. In 1997 the Secretary of State agreed with the Inspector's conclusion that this approach would not "accord with policy that airports should be free to compete as far as possible and to provide the necessary facilities to enable airlines to meet demand”. The original forecasted 12 million per annum passenger throughput at Liverpool Airport was dependent upon the adoption of a strategy that would limit Manchester Airport's 

growth to that achieved from a single runway. However, on 15 January 1997 the Secretaries of State for the Environment and Transport granted planning permission for a second runway at Manchester Airport. The Secretary of State was of the view, therefore, that the case for the expansion of Liverpool Airport in the magnitude proposed had “not been demonstrated on grounds of need”. The inconsistent year-on-year passenger figures ever since would serve as evidence that the Secretary of State at the time showed justified concern and it is now unclear how LJLA propose to attract such large passenger figures without evidence of the market demand and reliability on the failure of Manchester Airport's expansion. 

4.10 Whilst Hale Parish Council question the demand for LJLA to become an International Airport, it would encourage LJLA to optimise its current passenger capacity. In 1997 the Secretary of State agreed with the Inspector that this “ development would make neither good use of the existing runway nor, other than in the short term, best use of the existing terminal facilities. "Further conclusions were drawn for the better utilisation of “the existing capacity of that airport site”. Hale Parish Council would support LJLA to grow within the boundary of its existing runway and terminal. 

4.11 Paragraph 136 of the NPPF notes “Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or updating of plans. Strategic policies should establish the need for any changes to Green Belt boundaries having regard to their intended permanence in the long term, so they endure beyond the plan period. Where a need for changes to the Green Belt boundaries has been established through strategic policies, detailed amendment to those boundaries may be made through non-strategic policies including neighbourhood plans”. 

4.12 This Policy offers no regard to the importance of Green Belt and its purposes in preventing urban sprawl. As set out in NPPF, “the essential characteristics of Green Belts are their openness and their permanence". With the absence of any development currently on the land, the Green Belt is currently open and un-built. This Policy would reduce the openness and permanence of the Green Belt by occupying approximately 30 hectares of land, and any runway extension would form a distinct feature of the site which would reduce openness in the area by domineering an area of land currently enjoyed by residents, offering no amenity value to neighbouring properties, the bridleway, or adjoining roads and footpaths. 

4.13 The Civil Aviation Authority have placed no requirements on the removal of this land from its designation as Green Belt. Indeed the Runway End Safety Area (RESA) does occupy a small portion of this land (equivalent to approximately 1 hectare), but it is not clear how this can be used to justify the removal of the 30 hectares of land proposed in this Policy. 

4.14 Defined as an inappropriate development, this scheme is by its very nature, harmful to the Green Belt. Not least due to the fact that this particular parcel of land is the last remaining wedge that acts as the only buffer of countryside in between LJLA and residential properties of Hale. Any development on this land would destroy the essential characteristics of Green Belt, in effect merging Halton with Liverpool. 

4.15 Halton's Green Belt has to be seen in context. It does not exist in isolation but functions alongside and with the Green Belts of North Cheshire. Changes to the Green Belt on this particular parcel of land are higly likely to be influential on the Policies of the adjoining region, encouraging cross-boundary encroachment into the open countryside and the merger of pockets of developments of long established, distinct, historic settlements. 

4.16 Other areas of the Evidence Base used for the DALP describe Hale as washed over by Green Belt. This Policy seems to contradict and confuse this position placing a new Green Belt boundary to the east (in Hale Bank) and to the west (with LJLA). The edges of the Village are no longer protected in this Policy from development with the previous weight of Green Belt. 

4.17 The proposed scale of Green Belt release creates a number of tensions with the function and purpose of the Green Belt. The Halton Local Plan Green Belt Site Assessment only views sprawl in the context of outward sprawl from Hale. Not inward sprawl from Liverpool. As this parcel is not adjoining the settlement boundary of Hale, it is classed as having much less impact against this purpose of the Green Belt. This skews a quantative assessment and does not consider the ultimate impact on function of the Green Belt as a single entity. 

https://www4.halton.gov.uk/Pages/planning/policyguidance/pdf/newdalp/assessments/Hale.pdf 

4.18 It is worthy of note that with the exception of one other area, none of the settlements in the Borough retained within the Green Belt, have designated heritage value which Green Belt designation might be designed to protect. 

4.19 Hale village has maintained a rural character for centuries and this development would be a significant and irreversible impact on the landscape. The proposal is not in keeping with the Conservation Area of Hale Road and would considerably alter its approach. The SSSI site to the south of this site and RAMSAR site further enhances this land parcel. The LJLA Masterplan 2050 highlights no specificity as to how these would be protected and enriched. The approach taken in the Halton Local Plan Green Belt Site Assessment seems to wrongly suggest that sprawl can only relate to the main settlement boundary, with this land parcel 

ng a moderate contribution to Green Belt. This approach is flawed. If that approach applied there would often be little purpose in insetting settlement in the Green Belt. Once it is accepted that consideration should be given to the heritage value of the area through conservation status, consistency requires the same approach to land surrounding the conservation area that is heavily dependent on setting provided by the Green Belt. Hale Parish Council would argue this land parcel makes a significant contribution to Green Belt and should be categorised as such and retained. 

4.20 The historic agricultural and recreational use of this land has been well established in local sentiments for over a century. Not only is the site wholly in Green Belt, but it has been recognised by Natural England as Grade 1 agricultural land – forming some of the ‘Best and Most Versatile agricultural land in the country. Hale is the only area in Halton (and one of only two areas in the whole of Cheshire) to contain any Grade 1 agricultural land and the proposed development would result in a substantive loss to one of Halton's highest-quality land parcels. 

4.21 “Plans should set out a positive strategy for the conservation and enjoyment of the historic environment.” (NPPF 2019 Paragraph 185]. The site offers significant historical importance, once used as the only salt mine across Liverpool and Halton – an industry pioneered by the Blackburne family of Hale in the seventeenth century that served as the nursing mother to the rise of the flourishing trading history of Liverpool's docklands. This land should be protected as a historical landmark, providing educational benefit and acting as a destination for tourists. This Policy is not in line with the DALP's Strategic Objective 10 – to "support the conservation and enhancement of the historic and natural environment”. 

4.22 In 1997 the Secretary of State agreed with the Inspector's conclusion that aircraft noise and the visually intrusive impact of aircraft would seriously harm the setting of Speke Hall, an important Grade 1 listed building. The Secretary of State agreed with the Inspector's conclusion that there would be a "detrimental noise impact adversely affecting the setting of the listed buildings in Hale and the character of the two conservation areas in Hale”. 

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4.23 It is concluded that whilst the Halton Local Plan Green Belt Site Assessment document provides a useful discussion tool, it is weak in providing evidence of sufficient clarity and certainty to properly assist and to justify, the tests for excluding parts of the Green Belt from continued protection. 

4.24 The site as a whole provides a positive contribution to the landscape and scenic beauty of Hale. Currently, there is no LJLA development within the boundary of Hale or Halton and an introduction of a runway extension would introduce a commercial character to the Village and require developme currently undeveloped part of Hale. The site is visible from a number of surrounding vantage points and, in all of these, the proposed runway extension would be a sizeable addition to the landscape. Views of the River Mersey and adjacent Welsh Mountains visible from this site would be obliterated. Furthermore, the hard surfacing that would need to be laid to provide access to and from the proposed freight facility would damage local ecology and the new warehousing would be visible from several more vantage points on both sides of the Estuary – providing an incongruous eyesore to the rural nature of the area. 

4.25 This Policy focuses on releasing Green Belt primarily to provide sites for logistics developments which will bring a low density of poorly paid and low skilled jobs that will neither provide “balanced regeneration? or “sustainable growth or provide ‘high quality new employment. It will also encroach on the land, reduce the incentive for urban regeneration and seriously erode the gaps between settlements. A continued focus on this Policy is unlikely to reduce the deprivation levels of Halton and alternative approaches might be more effective such as encouraging a higher skilled and educated workforce within a more balanced economy. 

4.26 Planning policies should ensure that new development is appropriate for its location taking into account the likely effects of pollution on health, living conditions and the natural environment. [NPPF Paragraph 180] By its own admission, LJLA uses Hale as a flight path to impact the fewest number of people, the majority of the time. Residents are concerned that the geographical extent of the air traffic noise impact of the development on residential amenity. In an already strained setting, this Policy proposes to further deplete the environment of a rural community already exposed daily to high levels of noise pollution and poor air quality from low-flying aircrafts. Extending the runway would result in the Public Safety Zone encroaching on further properties in Hale, placing more residents at risk should there be an aircraft failure. The DALP does not reference the fact that, although monitoring is poor across the Borough, what limited information there is suggests somes areas of Halton already suffer some of the poorest levels of air quality in the Country and that this contributes to health problems that can be linked to illness and premature death. There is no complete analysis of the true impacts of the scale of development proposed and consequent use of the transport network in terms of air quality. This Policy appears inconsistent with the DALP's Strategic Objective 11 – to “improve the health and well-being of Halton's residents throughout each of their life stages, through supporting the achievement of healthy lifestyles and healthy environments for all”. The Policy seems further at odds with the DALP's Strategic Objective 12 – to "prevent harm and nuisance to people and biodiversity from potential sources of pollution and foreseeable risks”. 

4.27 No evidence has been provided to show the significant carbon footprint that would be used to develop this proposal and the impact that increased aircrafts would have on the health of the local population. The 

engineering that would be required to excavate this land would appear incongruous to DALP's Strategic Objective 9 – to “minimise Halton's contribution to climate change through reducing carbon emissions and ensure the Borough is resilient to the adverse effects of climate change”. 

4.28 The Secretary of State did not agree that the need for an Eastern Access Road and realigned runway amounted to very special circumstances and further concluded that it had not been demonstrated in this case that the harm to the Green Belt was clearly outweighed by other considerations. 

4.29 Hale Parish Council object to the inclusion of the Eastern Access Road in this Policy – there are no figures to justify the need for such infrastructure and no proposed financial models in place. 

4.30 This Policy ignores the need for core farming activities and local agricultural employment. The Eastern Access Road would deplete a farming community of its resources and work to reduce local employment. 

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4.31 This Policy will not result in sustainable tourism in our local area. In fact, it will significantly degrade it. Policy HC7 acts as a further failure to recognise the value of visitor attractions in Hale, with significant omissions. Hale Parish Council would therefore like to recommend the inclusion of the below sites as visitor attractions, in line with Policy HC7, which each attract on average approximately one hundred visitors per day.

4.30 To conclude, in 1997 the Secretary of State agreed with the Inspector that the development proposed by LJLA "would harm the Green Belt, and the setting of Speke Hall and of other listed buildings, and conservation areas. It would have impacts of increased noise in Hale.” The Secretary of State also noted “the ecology of the area would be affected” and “the development would also result in the loss of some best and most versatile agricultural land”. LJLA handled a peak of 5.5 million passengers per annum in 2007 and it has so far failed to achieve the same success with the same resources. There is little argument to suggest that further resource would produce favourable results. Growth levels are unrealistic and undeliverable. There is little evidence in any supporting documentation to suggest the health and welfare of local residents have been factored into the proposals presented and what health impacts this Policy could contribute to following a significant loss of open space and increased pollution and carbon footprint. The assessment of current areas of Green Belt is weak and although purporting to provide for a methodical and analytical approach to assessing the value of land against the 5 purposes of the Green Belt the approach still relies on judgement, which in a number of cases can be contested. Whilst this Policy claims to support the economic growth of LJLA, the scale and location of Green Belt proposed to be released undermines the wider objectives of the DALP. The release of relatively easy to develop land will directly conflict with the purpose of the Green Belt to promote and support urban regeneration within current boundaries. Hale Parish Council believes LJLA has not shown existence of very special circumstances sufficient to outweigh the clear harm to the Green Belt and request Halton Borough Council to consider the loss of open space and the overall impacts on residents this encroachment into the countryside will have. 

Hale Parish Council would like to be kept updated on future stages of the Halton Local Plan 2014 2037 – namely the submissions of the Plan for examination, publication of the Inspectors Recommendations and adoption of the Plan. Please note – email is the Council's preferred method of communication. 

Hale Parish Council considers it necessary to participate at the oral part of the examination. Hale Parish Council is a statutory consultee in the planning system and a significant contributor to the vibrancy of Hale. There is an on-going commitment to work with Halton Borough Council and support its future success. There are matters which arise from the Plan which will impact on the Parish Council's activities and therefore the Parish Council believe that our participation at the oral part of the examination will enable a full and well-informed discussion of the more controversial elements of the Plan, ensuring we are able to fully represent the views of our electors, fulfilling our duty to residents, and thereby helping the Inspector to understand the arguments as fully as possible. 

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