UPSVLP 0311
There remains an unwarranted fixation on economic growth at the expense of the Green Belt. This is out of step with the current and future economic climate, where climate change mitigation can be expected to require a much greater emphasis on sustainable development; and Greenfield development is inappropriate in the face of the well-documented impact on biodiversity and the UK?s diminishing level of food self-sufficiency and security.
Local Housing Needs Assessment
The ?new? standard method imposed by central government continues to use the 2014-based household projections, which are out of date and do not take into account the latest population projections.
The uplify of 10% to the housing requirement is arbitory and not justified.
This increase is not required by the standard methodology, which already includes an affordability adjustment (of 14.2%), and appears to be a mechanism for inflating the perceived Green Belt requirement, since the entire burden for meeting the additional allowance is met by the Green Belt (amounting to another 1500 houses).
The stated urban capacity of 11,785 dwellings is poorly supported by evidence and grossly underestimates the available housing.
On a best estimate basis, the data provided in the SHLAA supports an 18-year delivery of at least 15,440 new homes. If this is supplemented by empty residential properties (using 2019 figures), this yields an urban capacity of 17,922. If 10% of surplus employment land is also repurposed or redeveloped this implies a total urban capacity of at least 19,115, assuming all of it could be brought forward in the plan period. This amounts to 30% more than the stated housing requirement of 14,688; 2.4 times the housing need of 8,025 calculated by household growth forecasting; and 1,5 times the housing need of 12,528 calculated by jobs growth forecasting.
Under the NPPF 2021, redrawing the boundaries of Green Belt land requires the demonstration of exceptional circumstances, supported by full evidence and justification. This must also include a demonstration that all other reasonable options have been examined fully; and that the development strategy makes as much use as possible of suitable brownfield sites and underutilised land. These criteria have not been met
The evidence presented does not support the claimed housing requirement. The urban capacity assessment is not comprehensive in scope or timespan and, as a consequence, underestimates the available housing capacity. There is no evidence that all brownfield sites and underutilised land have been identified or that WBC has been at all pro-active in approaching the owners of land-banked sites; or taken measures to unlock or compulsorily purchase land to meet requirements in accordance with para 121 of the NPPF 2021. mThere is no demonstration that site assessment constraints have been revisited once it became apparent that urban capacity was insufficient. The absence of a plan for Warrington General Hospital is a serious omission, given its importance for the region?s healthcare and its potential impact if relocated ? releasing further urban land for housing and possibly requiring Green Belt land for a new site. The draft Local Plan cites (e.g. para 5.1.5) the requirement for more affordable housing as part of its justification for releasing Green Belt land. However, the largest release is planned for South Warrington, where house prices are highest. The LHNA shows that the price of accommodation is cheapest in the town centre and implies this is the most realistic site for affordable homes. The employment land need (which requires Green Belt release to be met) is based on extrapolating historical land take-up rather than an objective economic assessment, which has been positively excluded. The majority of Green Belt land targeted for release is the furthest away from the town centre and will promote rather than reduce the use of cars for visiting and working in town, aggravating congestion and air pollution, which are already at unacceptable levels. Where are the specific assessments that identify the impact on wildlife, their natural habitats, endangered species, biodiversity in general, ancient woodland, hedgerows and agriculture. Where is the evidence that the conclusions from such assessment have been taken into account in decision-making?
Having identified the ?need? to release Green Belt land the local plan does not prioritise building on existing brownfield sites as it should during implementation of the plan.
This principle is enshrined in the NPPF 2021. Instead, WBC relies on new building on Green Belt to accelerate housing delivery early in the 18-year plan.
WBC has missed the opportunity to plan decisively for the borough?s low carbon future. WBC?s commitment appears to be limited to the provision of (unspecified in number) EV charging points in the town centre, a requirement for 10% of energy from new developments to derive from renewable sources, and more emphasis on walking, cycling and public transport as modes of transport.
Aspects that appear to be substantially lacking in the plan are: Encouraging micro-generation; Home insulation New Builds ? are building regulations sufficient or should further requirements be placed on new developments?; Home Insulation Existing Housing - What can be done to incentivise existing home owners and businesses to better insulate their buildings? EV take-up ? Given the phasing out of new petrol and diesel fuelled cars and vans by 2040 (and the desire for this to occur sooner) how can WBC incentivise residents and visitors from the wider area to switch to EVs? EV charging network ? how will the growing requirement for public and domestic charging points be met? Electricity distribution ? at least a doubling in capacity is predicted to support the switch to EVs and replacement of gas-fired heating. Is this taken into account in all new developments? How will the existing network be upgraded without causing major disruption? Can this be minimised by co-ordinating with planned development? Move away from natural gas ? How will this be achieved (e.g. heat pumps, district heating, electric heating, hydrogen)? What does this imply for new developments and infrastructure? How will the recent announcement in the Spring Statement that new homes from 2025 will be highly efficient and will have low-carbon heating from the outset be implemented? What does this imply for Warrington as a whole over the period of the plan?; Low carbon economy ? how can WBC incentivise businesses linked to decarbonising? E.g. discounts in corporates rates for renewable businesses, use of renewable energy sources etc; Has biomass energy production and district heating been considered (e.g. using sustainable fuel, or municipal waste and carbon capture)?; Isn?t it time to reassess the viability of renewable energy development in the area?; What scope is there to incentivise carbon capture and storage schemes in the area ? as part of energy production (see above) or industrial processes?; Afforestation ? Has afforestation been considered, either as a carbon sink, or for sustainable uses?; Agriculture ? what can the borough do to encourage low carbon farming practices?; Air quality ? Air quality improvements predicted by the Local Plan Air Quality Modelling over the period of the plan take credit for assumed improvements in vehicle technology. However, this depends on consumer take-up, which is beyond WBC?s control given its current policies.. As part of a joined up plan, delivered in part by the Local Plan, transformation to a low carbon borough can also have a positive economic benefit.
EDNA
The ENDA's land requirement should be based on the OE and CW forecasts and not historic takeup which significantly over-states the land requirement. Further, as the OE and CE forecasts are used in the LHNA there is an inconsitency in the Plan.
OE and CE backed estimates of the employment area land need are reasonably consistent and lead to calculated shortfalls ranging between 6.5 to 36 ha. In the words of the EDNA, ?The Oxford and Cambridge Forecasts represent two realistic projections for how jobs might change in Warrington to 2037, reflecting factors such as the economic impacts of Covid-19 and the Christmas 2020 Brexit Deal??. It is therefore surprising that these forecasts have been entirely disregarded in favour of the most generous historical forecast (predicting a shortfall of 277 ha based on 24 years of growth), which uses the simplistic assumption that forward growth will mirror past growth. This assumption is invalid both nationally, considering factors such as Brexit, the ongoing pandemic and climate change, and locally. In reaching its conclusions, the EDNA pays lip service to the most recent trends, which show a notable decline in demand/take-up. Noting the clear downward trend and economic forecasts, the evidence presented is insufficient to support the level of employment area land recommended to be set aside, particularly since the majority is currently Green Belt land, which is protected anyway (and therefore does not need reserving as an employment area). The Strategic/Local Take-up model should therefore be discounted.
Using 2018 ONS data and recognising that household growth is declinging over time and therefore a reduce rate should be considered for the last 8 years of the Plan implies a housing need of of 458 per year for the first 10 years and 430 for subsequent years of the plan, or a total of 8,025. This is a reasonable, evidence-based deviation from the standard method (which is not, in any case, mandated by government); and can be justified on the grounds that the alternative is building on Green Belt land, which itself requires exceptional justification, and which an arbitrary housing target does not provide. This is lower than the identified urban capacity. If jobs growth is considered then, applying a median estimate to the housing requirement would reuslt in a houshold requirement of 11,489 which is broadly similar to stated urban capcity, although it is considered this urban capacity is under estimated.