UPSVLP 0356
it is the representor?s position that the UPSVLP and its evidence base does not detail the steps the council took to liaise with St Helens Council properly and effectively.
A key representation we would make is to question how can a plan prepared in 2019 that proposed to de-allocate some 11% of existing Green Belt land so as to deliver required growth levels, and which was regarded as sound and satisfying other relevant tests, be superseded by a new plan prepared in 2021, which is also said to be sound, but which halves the amount of land proposed to be removed from Green Belt so as to deliver necessary amounts of new development.
key point we would make at the outset of these representations is to set out surprise that the 2019 version of the local plan was dropped. Furthermore, that the plan published in 2019, which was at the time regarded as legally prepared and sound and satisfying other relevant tests (linked to points already made on Duty to Cooperate), differs so significantly from the current version published for comment in September 2021, the UPSVLP. This later version of the plan is also regarded by the Council as legally prepared and sound. One has to question whether two versions of the same local plan given they are so different can both be regarded as satisfying all relevant tests. We have no confidence in the new UPSVLP and its evidence base. We are of the view the UPSVLP is designed to fail. We do not accept that the plan?s residential and employment land requirement are veracious nor sufficient to deliver the necessary levels of growth required to support a sustainable and successful Warrington and its Borough. The levels of growth planned for through the 2019 version of the local plan, and how growth was proposed to be delivered, was much closer to what the Borough needs and should be planned for through the UPSVLP.
Para 1.2.5 onwards
While the Council appears to want to justify the need for the new local plan, UPSVLP, by reference to Government housing methodology introduced at the end of 2020, and other factors, one key factor of influence is not stated in the UPSVLP but should be. This is the effect of local politics. And through this the much less ambitious and non-planning policy justified approach to delivering growth which also has, as an effect, the need to remove less land from Green Belt. As such it is our view that the key drivers for the UPSVLP are not planning policy justified rather required by local politics.
We have concerns about the significant redirection of the local plan development strategy. Indeed, any development strategy that involves such a sea change from its predecessor, which at the time was regarded as the right way forward and sound, has to be questioned. We would say that 4%, by reference to the amount of and broad location of Green Belt in the Borough, is too little, and that the amount proposed to be removed under the previous version of the emerging local plan, back in 2019, which was 11%, was a truer reflection of the natural growth needs of the Borough.
Paras 1.2.9 - 1.2.13
The plan should have but does not fully and properly exploit the development and growth potential of Warrington and its hinterland by reference to available infrastructure and historic plans for the town.
No real mention is made of the fact that Warrington was historically seen to offer considerable potential for growth and for this reason was designated as a New Town. Because of this new infrastructure was introduced and the town and borough was set to be grown in a fully planned and coordinated way. However, this appears to be underplayed by the current version of the local plan which promotes only low to moderate growth and in a very conservative way, thus ignoring the obvious and latent potential of Warrington and its periphery and satellite towns to be grown in a sustainable way.
Paras 2.1.16 - 2.1.19
The UPSVLP will not address the challenges and opportunities set out in this section given the reduced level of development that is being proposed, relative to the 2019 version of the Plan.
According to the UPSVLP, the Borough of Warrington varies significantly in terms of character, prosperity, health and access to services and infrastructure. While only a minor point, we would say that the town of Warrington is well served. It is the Borough?s smaller towns, Burtonwood and Winwick for example, that are less well served. In terms of 'Challenges' the Plan will not address 'Limited housing and employment land supply' and 'Housing affordability concerns' given lower level of development being proposed relative to the 2019 Plan. 'Meeting the needs of an aging population', 'Car Dependency', 'Traffic Congetion' and 'Air Quality Impacts' are all national issues but are not properly addressed in the Plan. We agree with the majority of 'Opportunities' but would again point out that they will not be delivered or realised if the plan under performs in terms of delivering necessary levels of growth which we say it won?t as the plan?s housing and employment land requirements are very low.
Paras 2.2.1 - 2.2.4
We would question how the vision will be delivered by reference to the actual plans and proposals of the UPSVLP.
The planned vision for the town of Warrington and Borough is noted. We question whether the points in paragraphs 2 and 3 can be delivered and should in fact form part of a vision by reference to the low level of growth that is planned for in terms of new housing and employment. Regarding the premise that new development will be successfully integrated into Warrington?s transformed public transport system, the UPSVLP isn?t in fact proposing a transformed transportation system. It merely promotes more of the same, building on Warrington?s location at the crossroads of the M6 with M62 and M56 and the fact it is crossed north to south and east to west by main railway routes. As to the suggestion that there will be a transformation in how Warrington meets its energy needs, with a focus on renewable sources and decentralised networks, this is a very reasonable target, but we would again question how this target will be delivered by reference to the actual plans and proposals of the UPSVLP.
It is the representor?s position that the UPSVLP will not as is claimed deliver the sustainable growth of Warrington. By planning for a minimum of 14,688 new homes (equating to 816 per year) between 2021 and 2038 will not deliver the correct and needed levels of growth nor will they be able to adequately support Warrington?s economic sector and the proposed provision of 316.26 hectares of employment land between 2021 and 2038. The plan is planning for very low levels of growth not the higher level it previously suggested was necessary. Yet the reasons for this, by reference to the evidence base in support of the UPSVLP, are not fully justified.
It is not correct to suggest as is set out at paragraph 3.2.3 that plan Objectives have been refined during the process of Plan preparation, taking into account representations made during previous Local Plan consultations. It is our position that representation by many parties, certainly those from developers and landowners, have been ignored. This is because these generally supported higher growth levels than the previous version of the plan made provision for, yet the current version of the plan, the UPSVLP, drops these to an even lower position than envisaged by the previous 2019 local plan. Perversely, and argued so as to ensure that Warrington?s revised Green Belt boundaries maintain permanent in the long term, the plan does not seek to remove enough land from Green Belt as is necessary so as to ensure sustainable patterns of growth in the Borough and the necessary levels of growth. The fact land is needed to be taken out of Green Belt suggest that the boundary was drawn far too tightly when Green Belt was first designated. Indeed, many areas of Green Belt in the Borough in our view cannot be justified as they have no real role to play in the sense they are not stopping the coalescence of existing settlements or areas of development as the next settlement or area of development is some distance away. Other areas of Green Belt, like the representor?s land, cannot be regarded as strategic and could, be taken out of Green Belt and reallocated for development without harming strategic objectives. The objectives nevertheless confirm that some land needs to be released from the Green Belt. The plan goes onto say that the plan will ensure that development on former Green Belt land complements rather than competes with development within the existing urban area and that new infrastructure investment will benefit the Borough as a whole. The Objectives will also help to ensure that the revised Green Belt boundaries are able to endure over the long term, well beyond the end of the Plan period in 2038. We disagree with this. There is no sound planning sense behind nor justification for the removal of some land from Green Belt. For example, land at Burtonwood previously proposed for removal to enable an allocation for residential so as to support the natural and sustainable growth of Burtonwood has been deleted. This cannot be justified in planning terms.
The UPSVLP says at paragraph 3.3.9 that the Council believes this strategy option provides the best chances of meeting Warrington?s housing needs. We seriously question this statement and the ability of the strategy to deliver anything other than failure.
One has to question whether some 7,300 units can be delivered on brownfield land as the new local plan envisages, this by reference to supply of such land. Linked to this, the target for delivery on Green Belt land, some 4,500 units, is far too little. If, as we suspect, there is little serious prospect that the Council will be able to deliver 7,300 units on brownfield land, then the local plan development and delivery strategy will fail. And additional land will need to be released from Green Belt in future to meet what will be the large resultant shortfall. It is our estimation, based on previous versions of the local plan and evidence bases, that current brownfield land supplies will be unable to deliver more than approximately 5,000 units, leaving a shortfall of 2,300 to be delivered on land currently in Green Belt. The South East Warrington Urban Extension (SEWUE) cannot be delivered until a wide range of infrastructure and services to support the new development are developed. This will take time to be approved and procured and will impact on viability, which suggests that delivery during the plan period is not guaranteed. Regarding the Fiddler?s Ferry Opportunity site, there are serious deliverability issues associated with this development, not least is potential flood risk, given the sites location in low level land directly adjacent to the River Mersey, and the need to deal with contaminated land. Indeed, recent work (and related publicity) by agencies concerned with flood risk confirms this. The fact this site is set to deliver such a large part of the UPSVLP?s housing requirement has to be serious cause for concern.
We agree as is set out in paragraph 3.4.1+ that the Council is able to fully evidence and justify the exceptional circumstances required for Green Belt release, for all Local Plan allocations, in accordance with the NPPF. However, it is our position that the Council can, and should have , planned for far greater levels of Green Belt releases, as was the case with the previous version of the Local plan, also justified by reference to NPPF, so as to create a truly sustainable and deliverable development strategy.
We do not accept that the Council has carried out a believable review of its SHLAA and Brownfield Register. Had the Council done so it would have come to the obvious conclusion that there is insufficient brownfield land and underutilised land, along with a meagre reallocation of Green Belt, to meet stated growth targets.
The UPSVLP contends that the new local plan will ensure that as much use as possible is made of suitable brownfield sites and underutilised land, yet its processor, the 2019 version of the local plan, openly confirmed that there was insufficient brownfield and underutilised land to meet required levels for growth in housing and employment. Put simply, what?s in the current version of the draft local plan, the UPSVLP, does not marry with statements and related work used to justify the previous iteration of the draft plan (2019 version), nor can the current claims be evidenced. The only way the Plan targets can be met is if more land is taken out of Green Belt, as was accepted and promoted through the previous version of the local plan.
Paras 3.4.2- 3.4.6
The targets, based on the development and delivery strategy of the UPSVLP, will not be met.
It is not accepted that, over the 18 year plan period from 2021 to 2038, a minimum of 14,688 new homes will be delivered to meet Warrington?s housing needs. This is not possible by reference to the sites/areas of land the UPSVLP envisages will come forward for development (allocated or windfalls which fall with the urban area).
Land north east of Junction 9 of M62 with A49, including land owned by the representors, should be allocated.
We do not accept that this target of 11,785 new homes within the existing urban area is believable nor is it deliverable. The sites listed in the UPSVLP which are planned to be removed from the Green Belt and allocated for residential development we do not accept can deliver the necessary levels of new development to meet the planned housing target delivery figure: South East Warrington Urban Extension ? our concerns relate to amount of new infrastructure required, cost of such infrastructure, technical constraints, market interest and viability. Land at Fiddlers Ferry - our concerns include delivery and technical concerns not least of which is flood risk. Thelwall Heys ? we would question whether this level of development is deliverable. Allocated sites to be removed from the Green Belt adjacent to following outlying settlements of Croft ; Culcheth; Hollins Green; Lymm ? we question whether this level of development is deliverable. In addition, and linked to the criticisms made above, we also question why no meaningful amounts of land are planned to be allocated for development in Burtonwood and the likes of Winwick. This settlement has been excluded but similarly sized or smaller less significant settlements like Croft, Culcheth and Hollins Green receive allocations. Burtonwood had an allocation in the previous version of the draft plan and would seriously benefit from an allocation. And this is the same for Winwick and the representor?s land could satisfy this need.
Given the acknowledgement about historic under supply, due to the inadequacy of history development, delivery and settlement strategies of previous iterations of the local plan, one has to question why a figure of 816 units per annum has been selected. Surely, so as to ensure delivery of an appropriate number of units per annum, a bigger target figure should have been adopted.
We are of the view that, at the very least, 900 per annum - approximately +10% of the figure planned to be used, should have been adopted.
Policy DEV2 should be complemented by another policy setting out circumstances whereby and where planning applications for wholly affordable housing schemes which are not allocated as such will be considered positively. This would be in the form of, for example, policies which are similar to Green Belt exception policies.
We are of the view that the employment land requirement should be increased to 350 ha (10%+) so as to ensure delivery of important employment development opportunities based on historic under supply and delivery of key sites.
The employment land requirement should be increased to 350 ha (10%+)
We question whether the UPSVLP?s employment land distribution strategy is what it needs to be to ensure that trends in demand and local market conditions are taken into account and addressed.
Land north east of Junction 9 of M62 with A49, including land owned by the representors, should be allocated.
UPSVLP confirms that the Town Centre will provide the main location for new Class E Office development yet demand for such development in this location is low. It is high in peripheral locations well located close to the junctions on the sub-regional motorway network. As such this element of the wider delivery strategy will fail. Regarding the Employment Areas that are identified to be the primary locations for industrial, warehousing, offices, distribution development and other B Class Uses, these are already established and in the main are better located. As such these are likely to continue to prove attractive to investors and occupiers. These include Omega; Woolston Grange; Appleton & Stretton Trading Estate; Winwick Quay; Birchwood Park; Centre Park; Lingley Mere; Gemini Westbrook. A number of new sites will be allocated as new Employment Areas in order to provide sufficient land to meet Warrington?s Employment Land Requirements: South East Warrington Employment Area (136.92 hectares) and Fiddlers Ferry Power Station (101.0 hectares). We have concerns about the employment land planned for Fiddlers Ferry given site related constraints and flood risk issues. If we are correct and this allocation has to be dropped for reasons of this ilk, then the strategy is some 100+ hectares short of land/sites.
To better meet Objective W4, we suggest that the UPSVLP should allocate land for development to better meet the need of travellers on the Borough?s Road network.
A suitable site would be land north east of Junction 9 of M62 with A49 at Winwick, largely land owned by the representors.
We question whether this allocation, by reference to the terms and scope of Policy MD2, can deliver the levels of development envisaged under the policy, and by when, this because of technical issues, infrastructure requirements, related costs and related viability issues. The implication of this is the likely failure of the UPSVLP to deliver development targets, both housing and employment land.
We would question whether this policy can deliver all that is expected of it, in particular due to concerns of technical issues including contaminated land and flood risk concerns. Indeed, we question whether the site should be allocated for development. If we are correct relating to our concerns regarding the suitability of this site for an allocation for development as set out in the UPSVLP, then some 1,310 homes and a considerable amount of employment land will not be delivered in the plan period, leaving the UPOSVLP development strategy incapable of delivery over the plan period.
Land north east of Junction 9 of M62 with A49, including land owned by the representors, should be allocated for employment or residential development.
This representor is particularly concerned about the lack of working arrangements with the local planning authority roughly to the north and north west of Warrington, St Helens Council, by reference to its sites detailed earlier. This is contrary to the liaison that took place with the authority to the south east, Halton, but perhaps this was because the Council needed to secure support for the new allocation at Fiddlers Ferry, upon which a great deal of emphasis is being placed in development delivery terms. The implication of this is that it is the representor?s position that the Council has not positively prepared the new draft local plan, UPSVLP, and as such it cannot fully justified its development strategy. The evidence base does not detail the production or carrying out of research to justify its approach to dealing with the land and settlements in Warrington Borough that are north, north west of the main conurbation of Warrington, close to the boundary with St Helens. This is linked to large allocations planned immediately over the boundary, including a major urban extension project at Bold, all of which we would say has skewed how the new version of the Warrington plan, the UPSVLP, deals with the development needs of settlements and need for allocations for development in this part of the Borough. There is, for example, no planning justification whatsoever for the previously planned allocation at Burtonwood, as proposed through the Proposed Submission Version Local Plan (2019 (?2019 version of the local plan)) being dropped. linked to this, one has to question why, in a similar vein, sites like the representor?s sites north east of Junction 9 of M62 with A49 at Winwick have not been better considered for development, or allocated, given the benefits development there would bring the Borough in sustainable development terms.