The Updated PSVLP 2021 is not consistent with achieving sustainable development in terms of its transport effects. The scale of new housing planned for South East Warrington is so great, and the likelihood of mass car ownership and use, so obvious, that the traffic consequences for the very constrained transport network in South and South East Warrington would inevitably be seriously damaging in terms of congestion and increased difficulty of movement. The latter would apply particularly to vulnerable road users such as schoolchildren and people with disabilities trying to cross roads, general pedestrians and cyclists and also elderly drivers who would find the elevated traffic levels intimidating. The significant increase in road traffic would also pose a serious threat to delivering a more reliable bus service.

The Plan is thus fundamentally flawed in transport terms. It has not considered establishing a significantly-greater concentration of housing to the west and north-west, in the area between the redeveloped Fiddlers Ferry site and the Liverpool-Warrington-Manchester railway where it intersects with the A5080 Farnworth Road. To the east, the Plan has not explored the possibility of establishing significant new residential housing in the area between the railway at Birchwood station and the A57 road. Also, the Plan does not adequately exploit the potential of expanding Winwick. Winwick is very well-linked to Warrington town centre (and Central Station) via the A49, which is dual carriageway (southwards) throughout. Essentially, the Plan puts very heavy emphasis on developing the South-East and South of Warrington. This completely mismatches with the quality of the highway network elsewhere, where (as pointed out) there are extensive sections of dual carriageway to the west (A57), north (A49) and east (A57). The radial routes to the south (A49 and A50) are not only not dual carriageway, but include Manchester Ship Canal crossings that are intermittently-unavailable and of course physically incapable of upgrading/widening.

The Plan will not be deliverable over the Plan period. The approach should be to (1) realistically-assess the present transport network (2) secure practical and near-certain-fundable improvements, and then (3) distribute the housing based not on inherited Homes England land-banks but upon where the transport network has capacity to cope with increased demand. The approach that has been taken by Warrington Borough Council is pragmatic, but far too weak in aspiration, seemingly-unaware in terms of long-term consequences, and very short indeed on transport solutions.

The Plan is most-emphatically not consistent with current National Planning Policy Framework (NPPF) thinking. The NPPF requires that developments are ?sustainable?. The transport effects of the Plan will certainly compromise the ability of future generations to meet their travel needs efficiently, effectively and in an environmentally-sustainable manner. The Plan will bequeath future generations with intractable transport difficulties. The Plan has completely ignored the potential of the local rail network to give easy access to Warrington town centre, Liverpool and Manchester (including both airports). The Local Plan is not consistent with national policies on containing HGV movements to a minimum, switching as much freight as possible to rail or water, and addressing the carbon footprint of HGV movements.

The NPPF also states (para 149) that ?A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this (include)??.limited affordable housing for local community needs under policies set out in the development plan??.?. The massive proposed housing and employment developments in South and South East Warrington clearly do not fit this exemption. The Plan does not maximise the use of land in the existing urban area.

The majority (with the exception of the proposed Fiddlers Ferry allocation) of the designated warehousing and distribution areas have no rail access and their expansion will only increase HGV movements and thus increase emissions.

The objectives of Policy TC1 are supported. However, it is thus vital as part of the strategy that high-quality public transport access to the town centre is maintained. The locating of a very large number of new houses in South Warrington would seem to directly work against this. The main routes for bus services are along the A49 through Stockton Heath and along the A5061 through Grappenhall and Latchford. Both of these locations, suffer from significant highway congestion, not only during the morning and evening peaks but at some other times during the day.

It is clear that the plan for a very large number of new homes proposed for South Warrington, whilst they could be provided with facilities to encourage walking, cycling and public transport, will struggle to actually implement a worthwhile long-term modal share for these sustainable modes. There is clearly no means of actually ensuring that the thousands of new residents of South Warrington would in reality adopt bus travel as their mode of choice.

The Centre Park/Bank Quay link would be likely to intensify highway traffic flows past Bank Quay station, further isolating it from the town centre for rail passengers. A replacement bridge linking Ackers Road with Station Road would introduce additional flows of HGVs to residential roads. The Warrington Western Link would primarily be useful (obviously) to traffic on the A56 south-west corridor. At its northern end it would likely exacerbate congestion on the Sankey Way. It would be unlikely to have any significant material benefit for traffic in South Warrington.

The phasing of the provision of infrastructure in line with the provision of development is supported. However, there is concern that new developer-funded bus services will not be permanent and subject to reduction or complete disappearance within a few years.

Support for the allocation of the Waterfront. However, the is concern (and it is not made clear) that the development of the site is linked to the delivery of the Western Link Road. It should be possible to deliver most of the new urban quarter without the Western Link. Connecting the two schemes inextricably together seems artificial and contrived.

The potential medium and long term impacts of congestion in South and South-East Warrington have not been given material prominence in the published Plan. There is virtually no mention of them in relation to, for example, Stockton Heath high street, or Latchford gyratory, or the A50 through Grappenhall; no mention of the effects of increased congestion upon bus services; increased noise of traffic for those living on the A50, Thelwall New Road, Latchford, Kingsway, Hunts Lane/Ackers Road, Grappenhall Road, the A49 London Road and Wilderspool Causeway; or of increased highway safety issues.

The proposed allocation does not make the best use of the location. There seems no obvious reason why the brownfield site could not be expanded onto adjacent undeveloped land, including land on the north side of the A562. A greatly-expanded Fiddlers Ferry ?garden suburb? would support better facilities such as schools and shops and better public transport services. In this instance, the viability of bus services would be considerably enhanced by expanding the proposed pre-2038 housing total to, 4,000 homes with a commensurate reduction in proposed housing in South Warrington.

The Thelwall Heys development site thus does not enjoy any convenient public transport access. There are currently no bus stops on the relevant sections of either the A56 Knutsford Road (east of the A50/A5061/A56 junction) or the A56 Stockport Road and the development would be singularly difficult to serve by bus.

The potential medium and long term impacts of congestion in South and South-East Warrington have not been given material prominence in the published Plan. The siting of a major employment centre fully four miles out of the Town Centre, and remote from most of the bus network and any rail facility, directly contradicts a number of Government and TfTN policy documents. It also contradicts a range of transport policies. Provision of a bus shuttle to the Town Centre will not overcome the access problems. The Plan?s preference for a non-rail-served, non-waterway-served logistics mega-base alongside the intersections of the M6/M56 in place of the Port Warrington proposal (which would have created a road/rail/maritime freight interchange) is contrary to Government policy. Increased traffic flows, congestion and air quality problems would primarily affect the A50/A5061 through Grappenhall and Latchford but would also affect other secondary routes across South Warrington.

The development is clearly far beyond convenient walking distance to/from Warrington town centre. Cycling is unlikely to be significant in terms of a modal share. Buses will struggle to be competitive with car journey times into Warrington town centre. It is likely that these 170 homes would increase congestion within Lymm and at already-stressed locations such as Thelwall New Road/Knutsford Road swing bridge. The Updated Plan refers to the need for ?other necessary network improvements as identified by an appropriate Transport Assessment?. But there are no specific proposals, other than the commitment to ensuring bus stops are accessible to pedestrians. It is unsatisfactory to be expected to support a significant new residential development in the absence of any clear proposals to deal with public transport requirements.

The development is clearly far beyond convenient walking distance to/from Warrington town centre. Cycling is unlikely to be significant in terms of a modal share. Buses will struggle to be competitive with car journey times into Warrington town centre. It is likely that these 170 homes would increase congestion within Lymm and at already-stressed locations such as Thelwall New Road/Knutsford Road swing bridge. The Updated Plan refers to the need for ?other necessary network improvements as identified by an appropriate Transport Assessment?. But there are no specific proposals, other than the commitment to ensuring bus stops are accessible to pedestrians. It is unsatisfactory to be expected to support a significant new residential development in the absence of any clear proposals to deal with public transport requirements.

Concern that the AECOM modelling is not a sufficiently robust assessment upon which to assess the proposed allocations in south Warrington. A number of the assumptions used in the modelling are challenged. Whilst, it is relatively straightforward to credibly model the ?hard? elements of LTP4, such as the provision of a new link road, it is highly speculative to attempt to model ?soft? issues such as bus service provision, bus service reliability, actual bus service use, actual cycling use, and actually walking use. Hence, there is concern that there is inbuilt ?optimism bias? in AECOM?s work, with the latter unrealistically-assuming that buses always run to time, and that cycling and walking (in permanently-fine weather and continual daylight) are always available as attractive ?green? travel options. In addition, it does not take account of the COVID pandemic, which has hugely upset normal transport use and it is still far too early to be confident that a stable ?new normal? has been arrived-at.