Fleetwood Farm: What the Council’s Strategic Planning Team Said
(Application Ref: 2024/1028/FUL – 12 Church Road, Banks)
🏛️ Background
The developer proposes to demolish existing buildings at Fleetwood Farm and build 20 new dwellings — 8 houses, 4 bungalows, and 8 “cottage-style” apartments.
West Lancashire Borough Council’s Strategic Planning Team (Ref: NM/DM26/2025) were asked by Development Management to review new information about flood risk and policy compliance.
Their response, dated 13 October 2025, is the fourth formal consultation on this case.
Strategic Planning are not the decision-makers; they are the council’s Local Plan policy experts who advise whether a proposal follows national and local planning policy.
⚖️ What the Council Found
1️⃣ Housing Land Supply
West Lancashire can currently show only a 1.86-year housing land supply, far below the 5-year minimum.
Because of this shortfall, housing policies in the Local Plan are “out of date.”
However, other policies — on design, heritage, flood risk and sustainability — still apply.
This triggers the “tilted balance” under paragraph 11 of the NPPF:
planning permission should be granted unless the site lies in a protected area (e.g. flood-risk land, heritage site) or the harms outweigh the benefits.
2️⃣ Flood Risk
National mapping shows Fleetwood Farm is at risk from river, tidal, surface-water, and groundwater flooding.
Even though agencies believe risk could be managed, the site is still classed as a “protected area” under national rules.
This means flood risk remains a valid reason for refusal if not convincingly addressed.
3️⃣ National Guidance Changes (Sept 2025)
Recent updates to the National Planning Practice Guidance (NPPG) tightened flood-risk rules:
The Sequential Test must look for safer, lower-risk sites before developing here.
Because Fleetwood Farm faces multiple sources of flooding, this test still applies.
The national housing shortage cannot override flood-safety rules.
4️⃣ Alternative Sites Tested
Strategic Planning examined five other sites in Hesketh Bank and Tarleton:
Site
Summary of Findings
Result
Newarth Lane (HB.037)
Habitat & access problems; only 6 homes possible.
Dismissed
Moss Lane (TNP015)
Root protection & access limits; up to 8 homes possible.
Dismissed
Mark Square (TA.065)
Policy conflicts; not suitable.
Dismissed
Blackgate Lane (TA.018)
Similar scale issues.
Dismissed
Sylvan Nurseries (TA.012)
Lower flood risk, but sits on Protected Land where >10 homes breaches Policy GN1.
Not suitable
They also noted two recent appeal cases where larger “Protected Land” developments were debated, confirming such cases are exceptions, not the rule.
5️⃣ Final Strategic Planning Conclusion
Fleetwood Farm “passes the Sequential Test” because no better, lower-risk site of similar scale was identified.
The next stage is the Exception Test, which weighs whether the flood risk can be justified by public benefits.
Strategic Planning note that part (a) of this test (demonstrating wider sustainability benefit) has been met.
Heritage and design concerns raised earlier still stand.
Final judgment will rest on the case officer’s planning balance — considering flood safety, housing need, and policy conflicts.
🧭 What It Means for Our Campaign
This is not an approval.
The Sequential Test only means there isn’t an obvious safer site; it does not mean the proposal is acceptable overall.
Flood risk remains critical.
The council still must apply the Exception Test and ensure any risk is clearly outweighed by public benefits.
Heritage and design remain key issues.
Strategic Planning’s earlier advice still applies — the site lacks a focal point and fails to reuse the historic farm buildings that define local character.
Our community alternative fits policy.
A mixed-use village square retaining the farmhouse, barns, and landscape features would:
Deliver public benefit,
Protect heritage,
Support sustainability and local identity, and
Align with Local Plan Policies SP1 (sustainable development), GN5 (design), and EN4 (heritage assets).
📣 Next Steps for Supporters
Reference this official document in all objections and statements — it confirms that flood risk and policy balance remain unresolved.
Emphasise that your vision — keeping Fleetwood Farm and creating a true village centre — delivers more public benefit and stronger policy compliance than a housing-only estate.
Continue to support the Parish Councils hard work highlighting flaws in the planning application. If you have any views that may help please reach out to them
Encourage local councillors to support a heritage-led, mixed-use revision that sustains Banks as a coastal community rather than erasing its last historic farmstead.
Link to full strategic planning response below