The 2021 Draft Local Plan makes provision for 861 new homes per annum for the duration of the plan period (through to 2038). Whilst we very are supportive of the provision of new homes in Warrington, we note this is the minimum number required by government, and are disappointed that this figure has been reduced from the more ambitious figure of 945 homes per annum (as was proposed in the 2019 version of the plan). There has been a consistent significant under provision of housing in Warrington in recent years, and we feel the plan should set the bar higher in terms of home provision over the next 15 years, and rely less on the provision of housing beyond the duration of the plan period.

The removal of Burtonwood, Mersey Brook Lane and the South West Urban Extension as housing land allocations is noted and considered acceptable.

The inclusion of Fiddler?s Ferry Power Station (for both employment and housing) is strongly supported

The inclusion of Thelwall Hays is strongly supported

The ?front loading? of community infrastructure such as health care, schools, highways and parkland is also strongly supported. This will enable smaller landowners and developers - such as ADS, Riverside Estates and The Egerton Trust - to bring forward windfall sites to further support the provision of housing in the borough.

The uplift in the total provision of allocated employment land from 276ha in 2019 to 289ha (subject to the Omega extension enquiry) in 2021 is supported. We consider this allocation and uplift presents off-setting opportunities over the plan period for the conversion of existing accessible and geographical desirable allocated and / or unallocated operational employment sites into housing - notably those at Station Road, Penketh, and ADS Recycling Centre, Camsley Lane. Whilst these sites are proposed to remain in the Green Belt (for reasons understood because of their separation from any existing settlement), they both can be defined as ?previously developed land? and fall under the provisions of NPPF (2021) para 149(g) to enable redevelopment.

The land at Woodlands Alpaca Farm is considered to make still less of a positive contribution to the Green Belt than that at Thelwall Heys. The site is physically separated from the open fields to the south by Trans Pennine Way, is obscured from view by an existing high-boundary wall (therefore not ?open?) and is directly impacted both visually and audibly by Stockport Road - a main east-west thoroughfare in south Warrington. The benefit of access to open space for recreation and biodiversity can also be considered to apply to the site at Woodlands Alpaca Farm, in spite of the new housing designation at Thelwall Heys, because of adjacent access to the Trans Pennine Way, the canal, and open fields beyond. For these reasons we are supportive of the proposed Green Belt land release and the re-allocation of the site as being within ?suburban Warrington? and by implication suitable for housing delivery

In the context of significant housing under provision and borough-wide green belt release in areas without the same level of existing community infrastructure and services, we consider this site to represent a sustainable, deliverable and desirable alternative (or supplementary) location for green belt release as part of the Local Plan development process. Much like land at Woodlands Alpaca Farm, its proximity to the existing settlement boundary presents an opportunity for a modest yet efficient and sustainable allocated housing site. The nearby carriageway of Walton Lea Road (80-100m east of the existing settlement boundary, which follows the brook) provides a convenient and clear-cut new boundary, ensuring no further ?creeping? into the green belt. Access could (should) be brought in from the road, thereby preserving the privacy and amenity of the existing suburban accommodation to the east.

The site is currently used for employment uses. Such lies are protected in adopted planning policy - but the ADS group would like to take this opportunity to register their interest in alternative employment sites within the borough to accommodate a relocation, expansion and potentially enable public-private partnership waste recycling services (including waste incineration) should the opportunity arise. ADS would then look to redevelop the site at Camsley Lane for housing (making use of the provisions in NPPF 149(g)), bringing forward a housing windfall site of up to 35 new homes, subject to relevant material planning (and market) considerations. The site is in a desirable residential location, and is considered more suitable (and viable) for housing than for its current uses; the yard is at capacity, and the surrounding green belt designation limits the businesses opportunity for expansion.

Warrington Borough Council have not allocated any new burial sites since 1964 and the opening of Walton Lea Crematorium. The Draft Local Plan 2021 makes no explicit reference to the expansion of existing or allocation of new burial sites ad or cemeteries (though they are defined as being an essential and / or important ?social and community facility? (para 7.4.4), going on to highlight that ?the management and protection of existing facilities is just as important as the assessment of the need for new provision? (para 7.4.6)). The (approximately) 4ha of land to the south of Fox Covert Cemetery represents a sustainable and readily deliverable opportunity to plan for future burial and plot demand within the borough, expanding the existing Council-managed facility to the north. The site is within the ownership of the ADS group, and they would be willing to engage in proactive discussions to lease, sell or partner with the Council to enable any expansion. Such a solution would make best use of existing infrastructure (including access) and workforce, and would accord with prevailing public understanding of the site as a place of final rest, and remembrance. The site is a five minute drive from Warrington?s only crematorium, allowing ease of access between the two sites for funerals, memorials and ash scatterings. The site is within the green belt, but NPPF (2021) para149(b) makes clear that the provision of ?appropriate facilities? - including cemeteries - should not be considered an exception to inappropriate development in the green belt.

The current uses comprise light industrial and storage uses to the east, and a caravan storage site to the west. A number of office- and industrial-to-residential permitted development conversions took place on the site in 2018. The eastern element of the site (approximately 9,000sqm and comprising light industrial and storage units as well as office accommodation (now all mostly converted into residential units)) was subject to a pre-application enquiry in 2020 (PR/2020/04461). Feedback from WBC indicated that because of the existing development on the site, the principal of redevelopment could be considered acceptable, subject to the provisions of (then) NPPF 145(g) (now 149(g)) and other material planning considerations. The site?s principal constraint was identified as being that of highways safety and access. Station Road - along with a considerable area of land and the nearby Fiddler's Ferry Power station (recently decommissioned and now falling within the Council?s proposed housing allocation site) - is under the ownership and control of SSE. NUKO Planning has approached SSE on behalf of Riverside Estates to facilitate discussion on the roads sale and release to no avail, with resource being cited as the reasoning. Since the time of the pre-application NUKO Planning has sought legal advice on undertaking improvements to Station Road to enable safe highways access in accordance with Riverside?s Right of Way. We have been advised that: We have a right to improve this road up to a width of 5.5m - including to adoptable standards if we wish; Subject to the agreement of the Council (presumably dependant on necessary and acceptable improvements to its condition) there are existing mechanisms to see this road brought under WBC Highways adoption, with or without the consent of the current owner, but; In any event the decommissioning of the power station, the likely removal of the railway lines, and the allocation of housing on the former Fiddler?s Ferry site represents an opportunity to re-enter into negotiations with SSE, with the support of the Council and / or their regeneration partners, Warrington & Co. On that basis, the site?s potential for a bespoke and unique housing development becomes both apparent and deliverable. It is accepted that there are challenges associated with access, but we are keen to work with the Council to find solutions to these. We also acknowledge that the site is also partly in employment use. However the emerging 2021 Local Plan presents the opportunity to relocate these uses onto one of the Council?s identified new employment sites. The increase in allocated employment floorspace can be considered more than sufficient to accommodate the low-grade caravan storage facility and the modest additional employment uses on the site, and would unlock the potential for this site to shine as a flagship riverside development in WBC.