Some of the Main Arguments

The main conflicts between the proposed residential development and the established local planning policy and strategy center on the premature release of safeguarded land, the absence of a demonstrable housing need, and the failure to adhere to the core principles of the plan-led system.

The most significant conflicts are:

1. Violation of Local Plan Phasing Strategy (Policy SUE1)

• Direct Conflict with Safeguarded Land Designation: The proposal is in direct violation of the adopted local planning strategy, specifically Policy SUE1 of the "Knowsley Local Plan Core Strategy (2016)". This policy explicitly identifies the application site as 'Safeguarded Land'.
• Intended Future Use: This designation means the land is intended to meet "post-2028 development needs". The application is considered a speculative application that attempts to release this land on an ad-hoc basis.
• Circumvention of Statutory Process: The application is premature and attempts to bypass the statutory and democratic process of the forthcoming Local Plan review, which is the proper forum for determining the site’s future. The applicant's own Planning Statement notes the earliest adoption for the new Local Plan is April 2028.

2. Absence of Justifiable Housing Need

• Undermining the Plan-Led System: The National Planning Policy Framework (NPPF) prioritizes a plan-led approach. This speculative application attempts to override this system without demonstrable need.
• Exceeding Housing Targets: There is no housing delivery crisis in Knowsley that would justify overriding the adopted Local Plan. In fact, the Council has demonstrably and significantly exceeded its housing delivery targets over the past three years, achieving a Housing Delivery Test score of 372%. This confirms a successful housing strategy and a healthy supply.
• Fundamental Contradiction in Justification: The applicant's case is based on a critical internal contradiction: the Planning Statement simultaneously celebrates the Council's successful housing delivery performance while attempting to justify the site's release by claiming an "emerging shortfall... (4.97 years)". This inconsistency invalidates the primary argument for the development.

3. Failure to Meet NPPF Requirements for Sustainable Development and Infrastructure

The proposal violates the principles of sustainable development by placing unmitigated strain on services and failing to provide a sound evidence base.

• Unsustainable Pressure on Education: The development would place an unsustainable and unmitigated burden on local infrastructure, particularly education, where there is a known capacity crisis. The applicant's generic promise of "off-site financial contributions" is deemed inadequate, especially where schools are physically unable to expand. This failure contradicts the Council's obligations under Paragraph 100 of the NPPF to ensure a sufficient choice of school places is available to meet the needs of new communities.
• Unreliable Transport Assessment (TA): The supporting Transport Assessment is based on outdated and fundamentally flawed socio-economic assumptions that do not reflect contemporary travel patterns (such as post-pandemic working or the likely car dependency of future higher-income residents).
  • Because the volume and distribution of traffic are miscalculated, the Council cannot be assured that the "residual cumulative impacts on the road network would [not be] severe" (a key requirement under NPPF, para 116).
  • The TA's conclusions regarding highway safety, traffic impact, and resulting air quality are therefore unreliable and invalid.
• Failure to Resolve Statutory Consultee Concerns: The applicant has failed to adequately address significant concerns raised by National Highways, a key statutory consultee. For instance, fundamental assessments—such as a Merge-Diverge Assessment for M57 Junctions 4 and 2, and evidence for routing assignment including M57 Junction 3—were requested but not provided, leaving the Council without necessary information on highway capacity and safety.

The policy conflicts show the proposal is attempting to bypass established rules—much like trying to skip ahead several chapters in a complex blueprint, asserting that the materials reserved for later are needed now, despite ample materials already being available and the structure being ahead of schedule.