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St Helens Borough Local Plan Submission Draft

The St Helens Borough Local Plan 2020-2035 Submission Draft was the subject of consultation from 17 January 2019 until 13 May 2019. The council received more than 2,000 responses to the consultation, which have been collated and are being carefully considered as the council works towards submission of the plan.

The next stage in the Local Plan process is for the Local Plan Submission Draft, supporting documentation and all of the responses received from the consultation to be submitted to the Government. An independent planning inspector will then be appointed to examine the plan.

As part of the examination, the inspector will hold public hearing sessions to discuss the plan. It is anticipated that the plan will be submitted to the government in autumn 2019, with public hearings likely to take place in the spring.

If you submitted a response during the Local Plan Submission Draft consultation, you will receive an email or letter from the council notifying you when the plan has been submitted to the government for examination.

Consultation Documents

The submission documents include:

Other supporting documents:

Other evidence-base documents:

Other documents:

We process your personal data as part of our public task to provide planning and development guidance, and will retain this in line with our Information and Records Management Policy. For more information on what we do and on your rights, please read our Privacy Notice and the council's generic data protection webpage.

What is a Local Plan?

A Local Plan sets out local planning policies and how land should be used. It also determines how much development is required and what should be built in different locations. The Local Plan can be just one document, or several documents which collectively form the 'Local Plan'.

How is a Local Plan used?

The Local Plan helps to guide the investment decisions of the Council and other organisations. It is also used to help decide if planning applications for new development should be approved (although other considerations can also be relevant).

Is there already a Local Plan for St.Helens?

The Local Plan for St.Helens Borough currently includes: 

  • the St.Helens Core Strategy (adopted 2012);
  • the St.Helens Unitary Development Plan (UDP) Saved Policies (adopted in 1998, most recently revised in 2013);
  • the Merseyside and Halton Joint Waste Local Plan (adopted in 2013); and
  • the Bold Forest Park Area Action Plan (AAP) (adopted in 2017).

What areas do these documents cover?

The Core Strategy and the UDP Saved Policies cover the Borough of St.Helens. This includes (for example): Haydock; Garswood; Newton-le-Willows; Rainford; Rainhill and various smaller settlements as well as St.Helens town itself. 

The Joint Waste Local Plan covers the local authority areas of Halton, Knowsley, Liverpool, St.Helens, Sefton and Wirral.

The Bold Forest Park Area Action Plan (AAP) just covers an area around Bold in the southern part of St.Helens Borough. 

Will these documents be replaced by the new Local Plan?

The Council intends to replace both the Core Strategy and UDP Saved Policies with its new Local Plan. The Joint Waste Local Plan and the Bold Forest Park AAP will be retained until they require updating.

Why are we preparing a new Local Plan for St.Helens?

The Government requires each local authority to have an adopted Local Plan. This must be reviewed regularly to meet the development needs of the area. If the Plan becomes out of date, it no longer carries as much weight when planning applications are being decided, making it harder for the Council to resist proposals for inappropriate forms of development.  

A review in 2015 identified a deficit in employment and housing land provision in St.Helens. This triggered a need to prepare a new plan to replace all parts of the Core Strategy and UDP Saved Policies.

What will the new Local Plan be called?

The new Local Plan will be called the 'St.Helens Borough Local Plan 2020-2035'.

What area will the new Local Plan cover?

The new Local Plan will cover the Borough of St.Helens.

What period will the Plan cover?

The Plan will focus on the period 2020 to 2035, but is also proposed to include “safeguarded” land (see later questions) to help meet development needs after 2035.

What evidence must the Plan be based upon?

The Plan must be based on a wide range of evidence covering matters such as: need for employment and housing development; land availability; town centres and shopping; environmental issues; and various other matters.

What steps must the Council go through in preparing the Plan?

Before the Council can adopt the Plan, it must go through steps set out by the Government. These include: initial consultation; publication of the Plan; submission of the Plan to the Government; and examination of the Plan by a Government-appointed independent Planning Inspector. The overall process takes several years to complete.

What has happened so far?

The St.Helens Local Plan Core Strategy, adopted in October 2012, stated that land may be required from the Green Belt to meet housing need from 2022 onwards. In November 2015, in light of new evidence concerning development needs and land availability, the St.Helens Council Cabinet agreed to prepare a new Local Plan to replace all parts of the Core Strategy.

A consultation was carried out in January 2016 on the scope of the new Local Plan. The Council then prepared the 'St.Helens Local Plan 2018-2033 - Preferred Options' document, which set out its preferred options for the policies to be contained in the Local Plan. A consultation was held over eight weeks from 5 December 2016 to 30 January 2017.

How was the Local Plan Preferred Options consultation publicised?

The consultation was publicised widely, for example in local newspapers and websites and via e-mails sent to individuals and organisations on the Council’s Local Plan database. Letters were sent to properties within 200 metres of sites proposed to be removed from the Green Belt to accommodate new development. Notices were placed next to sites being proposed for development, and posters were distributed.

Council officers also hosted 15 day-time, evening and weekend drop-in sessions in different locations across the borough to provide information on the Preferred Options and answer questions from the public.

How many responses were received to the Preferred Options consultation?

5,695 responses were received to the Preferred Options consultation.

What has happened since January 2017?

Since the consultation on the Local Plan Preferred Options closed on 30 January 2017, the Council has assessed the issues raised in the comments received alongside the changing requirements of Government policy, undertaken further work on the evidence base and prepared the St.Helens Borough Local Plan 2020-2035 - Submission Draft (LPSD).  

How will I know what issues were raised in the Preferred Options consultation?

The Council has published a Report of Consultation setting out: which bodies and persons were consulted at the Preferred Options and other earlier stages; how such consultation was undertaken; a summary of the main issues raised; and how these issues have been taken into account. The Report of Consultation can be viewed at www.sthelens.gov.uk/localplan.

What is the current stage of the Local Plan?

The Council has now published the Local Plan Submission Draft (LPSD). This is the version that the Council intends to adopt at the end of the process. People can submit comments on the LPSD in the period up to 5pm on 13 May 2019 (see later questions).

When was the Local Plan Submission Draft (LPSD) published for comment?

The Council made the LPSD and supporting documents available for public comment on 17 January 2019. Comments must be received by the Council by 5pm on Monday 13 May 2019 (see later questions). 

What Council approval exists to publish the LPSD?

Approval to publish the LPSD and its supporting documents was given at a meeting of the full Council on 19 December 2018. 

How has the Council let people know about this?

The Council has widely publicised the LPSD via a range of methods. This has included articles and adverts in the local press and media, websites and social media. It has also notified people who made comments at previous stages or asked to be notified so that they know that they can make new representations. Residents and businesses in close proximity to sites being proposed for development or safeguarded for future development have also been notified by letter.

Anyone wishing to receive an electronic consultation e-mail can sign up to our Local Plan consultation database by emailing the Council at planningpolicy@sthelens.gov.uk.

Where can I view the Local Plan Submission Draft (LPSD)?

The Plan and all its supporting documents and relevant notices are available on the Council’s website at www.sthelens.gov.uk/localplan. Paper copies of the documents are also available at Ground Floor Reception, St Helens Town Hall, St Helens WA10 1HP. The Plan and some supporting documents can also be viewed at all Council libraries. View a list of libraries and their opening hours.

How can I find out if land near me is affected?

The LPSD is accompanied by a Submission Draft 'Policies Map', showing which areas are to be protected from development and areas which are to be allocated for new development. This map is available to view at www.sthelens.gov.uk/localplan and in paper form at the locations referred to above. 

Will there be any public events about the Local Plan?

A drop-in event will be held in the Bold/Clock Face area at Clock Face Recreation Club, Crawford Street on Tuesday 9th April 2019, from 4.30-8.30pm.

10 other events were held from 22 January to 4 March 2019, in St.Helens Town Centre, Rainhill, Thatto Heath, Newton-le-Willows, Eccleston, Garswood, Haydock, Chester Lane, Rainford and Windle.

How can I ask questions about the Local Plan Submission Draft (LPSD)?

We hope that the LPSD document, its evidence base, these Frequently Asked Questions and the Council’s proposed explanatory notes will answer your questions – please take time to read them. However, you can find out more by attending one of the drop-in events (see earlier question) or by e-mailing the team at planningpolicy@sthelens.gov.uk. Please note that if we have a lot of queries it may take several working days before we respond. 

If I wish to comment on the LPSD, how will I be able to do this?

The Council has issued guidance notes and forms to help you submit comments (formally known as ‘representations’) on the LPSD. Any comments must be submitted in writing, either by:

You are advised to use the form which has been provided. Representations should identify specifically which element of the Plan they refer to and (if you are objecting) how the Plan should in your view be changed to address your concerns. 

Copies of the form and guidance notes are available to download at www.sthelens.gov.uk/localplan and in paper form at local libraries and at: Ground Floor Reception, St.Helens Town Hall, Victoria Square, St.Helens, WA10 1HP

How long will I be given to comment on the LPSD?

All comments on the LPSD or its supporting documents must be received by the Council either online or via the e-mail or postal address specified above by 5pm on Monday 13 May 2019. Comments received after that date and time will not be considered. This is an extension from the previous deadline of 13th March 2019. This extension will apply for all individuals and groups across the borough. If you have already made a comment, you do not need not make repeated comments. All comments that were originally submitted will be taken into consideration.

Who can comment?

Anybody may submit comments on the Plan. However, as names of the people who do so (but not their address or contact details) will be published, young people under the age of 13 should obtain their parent’s or guardian’s permission beforehand.

What things should I consider when I submit my comments?

The Plan will (once submitted for examination by a Government Inspector - see subsequent questions) be assessed against ‘soundness’ tests set out in paragraph 35 of the National Planning Policy Framework (July 2018). These tests require the Plan to (in summary) be:

  • positively prepared;
  • justified;
  • effective; and
  • consistent with national policy

Further details of these requirements are set out in the National Planning Policy Framework.

You may therefore wish to frame any comments you submit in relation to these tests.   

Will I have another chance to comment on the Local Plan before it is finally adopted?

The current consultation is the last scheduled opportunity for people to make comments on the Plan. The Council does not intend to modify the Plan after this, unless the Planning Inspector during the following examination stage (see below) recommends that changes be made.

What will happen after the Local Plan Submission Draft (LPSD) has been published for comment?

Following the end of the publication period, the Council will submit the LPSD to the Government for examination by an independent Government Planning Inspector. It will also submit supporting documents and evidence as well as the representations received in response to the LPSD and a summary of the key issues raised in them.  

When and how will the Plan be examined?

The Council expects to submit the documents referred to above in summer 2019. A Government Planning Inspector will then examine the documents and hold public hearings to decide if the Plan meets requirements set out by the Government. He or she will then issue a report setting out his or her conclusions.

Will I be able to take part in the public hearings?

The public hearings will be open to all to attend. However, the Inspector will determine who will be invited to speak at the hearings. He or she will also take into account all the representations received in response to the LPSD.

Will the comments submitted in response to the Preferred Options consultation in 2016/17 be forwarded to and considered by the Inspector?

A summary of the key issues raised by respondents to the Preferred Options and earlier scoping consultation, and how they have been addressed, will be supplied to the Inspector. However, the actual comments received during these stages will not be submitted unless the Inspector asks to see these.

What may the Inspector decide when he or she examines the Plan?

The Inspector may either decide that:

  1. The Plan is “sound” and legally compliant in the form that it has been submitted by the Council; or
  2. The Plan is not “sound” and/or legally compliant; or
  3. Changes (known as “modifications”) to the Plan are required.

If the Inspector finds the Plan to be “sound”, he or she will then issue a report allowing the Council to adopt the Plan. If he or she finds that the Plan is not “sound”, the Council will not be able to adopt it. If he or she finds that modifications are needed (option 3 above), people will be invited to submit comments on the modifications. If the Inspector agrees that the modifications are satisfactory following this further publicity, he or she would then issue a report allowing the Council to adopt the Plan.

When does the Council expect to finally adopt the Plan?

The Council expects to adopt the Plan in 2020.

How will the Plan be implemented?

The Plan will be primarily implemented via planning applications, which would normally be submitted by the landowner or a developer.  All planning applications would be subject to their own public consultation process before being considered by the Council.

Will the Plan need to be reviewed after it is adopted? If so, how often?

Current regulations state that the Council would be required to 'review' its Local Plan at an interval of no more than five years following its adoption. The Government's Planning Practice Guidance explains that at the five-year stage the Council would need to decide whether a) one or more policies needs to be updated or b) none of the policies requires any updates.

If any Plan policies need to be updated, there would need to be appropriate public consultation and an independent examination by a Government Inspector before any such change could be confirmed. The Council could not change any of the Policies within the Plan following its adoption (on safeguarding or any other matter) without going through this process.

How can I get involved?

You can submit comments ('representations') on the Local Plan Submission Draft (LPSD) in the period up to 5pm on Monday 13 May 2019. You can ask to be added to the Local Plan database so that you will be notified of any other future stages. Comments received after that date and time will not be considered. This is an extension from the previous deadline of 13 March 2019. This extension will apply for all individuals and groups across the borough. If you have already made a comment, you do not need not make repeated comments. All comments that were originally submitted will be taken into consideration.

FREQUENTLY ASKED QUESTIONS ABOUT ISSUES BEING ADDRESSED IN THE LOCAL PLAN

What are the possible benefits of the Local Plan?

The Local Plan could bring a wide range of benefits. For example, it could help generate more jobs for local people and thereby support local retail and leisure facilities and other services, creating yet more jobs. It could also enable a wider choice of affordable and general market housing to be provided, including dwellings that can be adapted to the needs of the elderly.

The Plan could also, by creating more jobs and better housing and reinforcing the protection of public open space and sports facilities, benefit the health of local people.

What period will the new Local Plan cover?

The new St.Helens Borough Local Plan will cover the period from 2020 to 2035.

Why will the Plan cover this period?

National policy now requires the Plan to cover at least 15 years from its expected date of adoption i.e. from 2020 (N.B. this is a change from the previous Preferred Options stage, for which the Plan period only ran until 2033).

Do we need more employment land?

The Council has identified that at least 215.4 hectares of new employment land should be developed in St.Helens Borough between 1 April 2018 and 31 March 2035.

What evidence has been used to assess employment land needs?

Evidence on this issue is set out in various documents including the St.Helens Employment Land and Premises Study 2015, the draft Liverpool City Region Strategic Housing and Employment Land Market Assessment (SHELMA) 2017 and the St.Helens Employment Land Needs Assessment Update 2018. Further information about employment land needs is set out in the Local Plan Submission Draft (LPSD) document under policy LPA04.

Do we need more housing? If so, how much new housing is needed in the Plan period?

The Council has identified a need for at least 9,234 new dwellings (at an average of at least 486 new dwellings per year) to be completed between 2016 and 2035. Allowing for expected completions before 2020, this figure translates to a minimum of 7,245 dwellings within the Plan period from 1 April 2020 to 31 March 2035. These figures are in addition to any new dwellings needed to replace demolition losses.  

What evidence has been used to assess the need for new housing?

The Council’s assessment of housing needs takes into account trends in household and economic growth as set out in relevant evidence including the St.Helens Strategic Housing Market Assessment Update 2018. Further information about housing needs is set out in the LPSD document under Policy LPA05.

How does the housing requirement compare to that identified at Preferred Options stage in 2016?

The housing requirement of 486 dwellings per annum (dpa) is less than the figure of 570 dpa stated at the Preferred Options stage. It is, however, consistent with up-to-date evidence and the Government’s aspiration for at least 300,000 new homes per year to be built in the country as a whole by the mid-2020s.    

How will new development impact on services and infrastructure, for example schools?

The Council has developed an Infrastructure Delivery Plan, which considers the infrastructure requirements resulting from new development. This acts as the starting point for establishing what infrastructure is required to support the development of particular sites. Relevant Plan policies (see, for example, Policy LPA08 of the LPSD) also address this issue.

What is Green Belt land?

Green Belt is not a physical feature but a concept created by the planning system. It is not about the ecology or habitat value of the land and most parts of England do not have any Green Belt. Green Belts are not intended to prevent development at all cost but to restrict it to ensure efficient use of land and prevent major settlements from merging into each other.

How much of St.Helens is covered by Green Belt?

At present, 65% (or 8,844 hectares) of the borough’s land area is designated as Green Belt. This percentage figure exceeds that within any other local authority area in Merseyside.

Are changes to the Green Belt being proposed?

Yes. The Council has undertaken a comprehensive review which identifies areas that could most suitably be removed from the Green Belt to ensure that needs for new housing and employment land can be fully met. This is set out in the St.Helens Green Belt Review 2018. This document forms a substantial revision of an earlier draft review which informed the Local Plan Preferred Options (LPPO) in 2016.

What changes does the Council propose to make to the Green Belt?

In the Local Plan Submission Draft (LPSD), the Council proposes to release 24 sites (totalling around 695 hectares in area) from the Green Belt to help meet future development needs. These will supplement the land supply from sites in the current urban area. They include:

  • 6 sites (totalling around 207 hectares in area) to be allocated for housing development up to 2035;
  • 8 sites (totalling around 253 hectares in area) to be allocated for employment development up to 2035;
  • 8 sites (totalling around 148 hectares in area) to be “safeguarded” for future housing development beyond 2035; and
  • 2 sites (totalling around 86 hectares in area) to be “safeguarded” for future employment development beyond 2035.

What is meant by “allocating” a site for development?

The LPSD proposes to allocate a number of sites for housing or employment development. If such allocations are confirmed in the finally adopted Plan, they would establish that the land is suitable in principle for development. It is anticipated that sites which are allocated for development will mostly be developed before 2035.

What is meant by “safeguarded” land?

The LPSD proposes to remove some sites from the Green Belt but “safeguard” them for potential future development after 2035. The LPSD states (in Policy LPA06) that planning permission for the development of the safeguarded sites will only be granted following a future Local Plan review that proposes such development. The Policy also states that proposals for housing or employment development of safeguarded sites in the Plan period will be refused.

How do the current proposals for Green Belt release compare with those proposed by the Council at the ‘Preferred Options’ stage in 2016?

In the Local Plan Preferred Options (LPPO) consultation in 2016/17, the Council proposed to release 51 sites (totalling about 1,187 hectares in area) from the Green Belt to meet future needs for housing and employment development. The current proposals (set out in the LPSD 2019) would result in 27 fewer sites and around 492 hectares less land being released from the Green Belt to meet development needs. 

Are there any other proposed changes to Green Belt boundaries?  

The LPSD proposes some other changes to Green Belt boundaries. These are not required to accommodate new development, but are needed to ensure that the boundaries follow clearly identifiable features as required by national policy. They include “consequential changes” (which would result from the removal of nearby land to accommodate development) and other minor corrections to the boundary. Further details are set out in section 6 of the St.Helens Green Belt Review 2018.

How much of the Green Belt in St.Helens would be affected by the changes? How does this compare with what was proposed in 2016?

If the changes which are currently proposed (in the LPSD) are confirmed when the new Local Plan is adopted, the proportion of St.Helens Borough which is Green Belt would reduce from its current figure of about 65% to about 59%. The Preferred Options proposals (2016) would have resulted in the figure reducing to about 56%.

What is the current status of the proposed changes to Green Belt?

No changes to the Green Belt have been confirmed so far. Any changes to the Green Belt proposed by the Local Plan Submission Draft (LPSD) would only come into effect once the Plan has undergone its examination in public and been formally “adopted” by the Council, which is expected in 2020. 

What about using brownfield land instead of Green Belt land?

Previously developed (often referred to as “brownfield”) land includes – subject to limited exceptions – any land which is or was occupied by a permanent structure or fixed surface infrastructure. It can occur in the Green Belt as well as in urban areas. Most brownfield land in St.Helens is in existing urban areas and its regeneration remains a key priority for the Council. However, there are often more challenges and costs associated with brownfield land, and there is not enough suitable, available and deliverable brownfield land available to meet our housing and employment needs in the long term.  

It should also be noted that not all land within the urban areas is “brownfield”. For example, existing or former playing fields would in many cases fall outside this category.

What proportion of St.Helens' housing needs before 2035 would be met by developing land which is brownfield and/or within current urban areas?

The LPSD identifies that, of the expected housing need of 7,245 dwellings between 1 April 2020 and 31 March 2035, 5,550 (i.e. 77%) would be delivered on sites identified in the St.Helens Strategic Housing Land Availability Assessment (SHLAA) 2017. The sites identified in the SHLAA are in urban (i.e. non-Green Belt) locations and are mostly brownfield.  

Why does it appear on the Policies Map that a lot of the housing sites will be built on land to be taken out of the Green Belt?

The LPSD identifies 10 sites to be allocated to meet housing needs before 2035. Of these, six sites (with a combined Plan period capacity of 2,056 dwellings) would be removed from the Green Belt, while four sites (with a combined Plan period capacity of 2,029 dwellings) would be from urban areas. 

This may give the impression that more land will be developed on sites removed from the Green Belt than sites in the urban area.  However, this is not the case for the period before 2035 as there are many urban sites which are not shown as allocated sites (for example, due to their limited size).      

Where can I find out more about brownfield and urban sites in St.Helens?

The St.Helens Brownfield Register 2017 includes 98 brownfield sites, all of which are suitable in principle for housing development. The Register can be viewed on the Council website at www.sthelens.gov.uk/localplan.

The St.Helens Strategic Housing Land Availability Assessment (SHLAA) 2017 comprehensively assesses expected delivery from sites in current urban areas (which are mainly but not exclusively brownfield). It includes: sites with existing planning permission; 59 other sites of over 0.25 hectares in size; and an estimated delivery of around 90 dwellings a year on small “windfall” sites (i.e. sites which are less than 0.25 hectares in size). The windfall figure is based on how many homes have been built on these smaller sites in the past.  

Has an allowance been made for the fact that some sites may not be developed as quickly as expected?

It is possible, for example due to delays in infrastructure delivery, that some sites will not be developed as quickly as expected. For this reason, the assumed delivery from capacity identified in the SHLAA between 2020 and 2035 has been reduced from 6,344 to 5,550 units. A contingency of 20% has also been included in the capacity of land removed from the Green Belt. Further details of these allowances are set out in the reasoned justification to Policy LPA05 within the LPSD document.              

How can I identify the sites that are proposed to be allocated for development for housing or employment in the Local Plan Submission Draft?

The LPSD identifies sites which are proposed to be allocated for housing development as sites “1HA”, “2HA”, “3HA” etc. Sites proposed to be allocated for employment development are identified as sites “1EA”, “2EA”, “3EA” etc. This contrasts with the Preferred Options consultation document (2016), which identified housing allocations as “HA1”, “HA2”, “HA3” etc. and employment allocations as “EA1”, “EA2”, “EA3” etc.

How can I identify the sites that are proposed to be “safeguarded” in the Local Plan Submission Draft?  

The LPSD identifies sites that the Council proposes are to be removed from the Green Belt but safeguarded for potential housing development after 2035 as sites “1HS”, “2HS”, “3HS”, and so on. Sites proposed for safeguarding for employment are named “1ES”, “2ES”, and so on. This contrasts with the Preferred Options consultation document (2016), which identified sites safeguarded for housing as “HS01”, “HS02”, “HS03” etc., and those safeguarded for employment as “ES01”, “ES02”, “ES03” etc.

Of the sites proposed for employment development, how many would be on land removed from the Green Belt?

The LPSD proposes to allocate 11 sites, with a total capacity of 265.3 hectares, to meet employment needs between 1 April 2018 and 31 March 2035. Of this total, eight sites (with a total capacity of 253.55 hectares) would be on land removed from the Green Belt. The remaining three sites would be on non-Green Belt land.

Why does the total capacity of proposed employment site allocations (265.3 hectares) exceed the needs identified (for 215.4 hectares)?  

Within the employment land supply it has been identified that site 1EA (land at Omega South Western Extension, which has an area of 31.2 hectares) will, due to its location and access arrangements, help meet the needs of Warrington rather than St.Helens.  The remaining capacity (234.1 hectares) is sufficient to cover the 215.4-hectare minimum figure plus an allowance for flexibility.            

Is it likely that the sites proposed to be allocated or “safeguarded” for future development in the LPSD will be included in the final Plan?

These details will only be confirmed once the Plan has gone through its remaining stages, including its examination by an Inspector and its adoption.

What type of development will occur on the development sites identified in the Local Plan and exactly when will it happen?

The Local Plan will set out details of how and when certain sites should be developed and, for what purposes. Precise details of any specific development will only be confirmed if and when a planning application is submitted and approved. In some cases, the Council may require these to be informed by a wider master plan. The timing of any development will also be affected by the intentions of the landowner and developer. 

How much weight does the emerging Local Plan carry in decisions on planning applications?

The policies of the Plan will only carry full weight in the consideration of planning applications after the Plan is adopted. However, the policies set out in the LPSD may carry some weight in decisions made before the Plan has been adopted. The extent of any weight attributed to the policies in such circumstances will be likely to depend, for example, on the extent of any unresolved objections to the policies.

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