The Council has confirmed that this extent of highway safeguarding was first designated over 20 years ago. However, to date, no proposals have come forwards for the widening of Birchwood Way. The Warrington Local Transport Plan 4 [LTP4] refers to a potential future mass Transit or enhanced Bus Priority network which could be developed in the future. However, it is acknowledged within the document [Table 6.3] that this is only an indicative concept and no plans currently exist to progress the concept. The Council has also confirmed that no funding is currently in place, and nor is there a bid for funding, in relation to delivering this highways project. Whilst it is recognised that the land is only safeguarded for future highways purposes, it is not considered reasonable or necessary to designate such land where there is no realistic prospect that it is required for such purposes. There is no evidence whatsoever to suggest that the land will be required for the development of a mass transit network within the plan period, which expires in 2038. Indeed, the ?Transport Model Testing of the Warrington Borough Council Local Plan - August 2021? document that has been published as part of the SVLP 2021 evidence base only included the project as a possibility in modelling scenarios beyond 2038. Whilst it is acknowledged that highway safeguarding sometimes does identify within a Local Plan to meet future development needs beyond the current plan period. However, the safeguarding of this land has now spanned across a number of plan periods without coming forward. There is also little evidence to suggest that land that is potentially going to be allocated beyond the end of the plan period (i.e. land that is safeguarded to meet future development needs) will rely upon this possible infrastructure. Indeed there is no part of the Council strategy that would indicate these improvements will need to be brought about. It is not reasonable to safeguard my clients land when there is no prospect of the highway improvements being brought forward, and no evidence of a need either within or beyond the end of the plan period. This designation is unnecessarily fettering my clients interests, and does not represent an efficient and effective use of land. Whilst relatively small in size, the site lies in a sustainable location within the urban area. In order for exceptional circumstances to exist to justify release of Green Belt land the Council must first consider why development needs cannot be met within the urban area. This land could meet some of those needs, and reduce the scale of Green Belt release. Against this backdrop, the Council have already identified this part of the highway safeguarding as being suitable for residential development and disposed of it on that basis. Whilst it is appreciated that any residential development is subject to planning, it is unclear why the Council would sell the site if the land was still required to facilitate the future widening of Birchwood Way. Not least because the Council would be required to purchase back the land in order to deliver this project. By virtue of the Council selling the site, NWLI is of the view that it simply cannot be the case that the Council believes that the land is still required to deliver road widening along Birchwood Way. Indeed, the Council?s own evidence base does not indicate that there is any realistic prospect of this land being required for highways improvements within or in the foreseeable period beyond the plan period. This raises serious questions as to why the safeguarding of this land for transport infrastructure is proposed for retention within the SVLP 2021.

Policy DC1 relates to ?Warrington?s Places? and categorises the borough into various areas. The Site (Land at Newcombe Avenue, Orford, Warrington) is located within Suburban Warrington which confirms that it is located within the urban area. NWLI supports the designation of the Site as part of Suburban Warrington under Policy DC1. NWLI also supports the policy objectives for this area which sets out that Suburban Warrington: ??will be the focus for infill and small-scale development on brownfield and greenfield sites within the existing urban boundary?.

Firstly, it should be noted that at present, the Policies Map provides a single designation for Policies DC3 and DC5 (which relates to open space, sport and recreation provision). It is therefore assumed that Policy DC5 (which is addressed separately below) also applies to all areas designated under Policy DC5. However, it is unclear which specific elements of either policy are applicable to land covered by the designation. NWLI does not object in principle to Policy DC3 and the objective of identifying and enhancing green infrastructure across Warrington. However, NWLI does object specifically to the inclusion of the Site within the area covered by the policy. This is because the Council?s own evidence base does not support the identification of the site as ?green infrastructure?. The ward profile for Poplars & Hulme contained within the Council?s latest Open Space Audit (2015) does not identify the Site as any form of green infrastructure or open space. As such, it is unclear why this is proposed within SVLP 2021. Furthermore, and as discussed above, the Council has undertaken a comprehensive due diligence exercise where the Sites suitability for residential development was considered. The outcome of that exercise was that the site was suitable for residential development and the land was subsequently disposed of to a developer on that basis. Whilst the evidence associated with that exercise is not specifically associated with the evidence underpinning the SVLP 2021, it is still recent and relevant, and should be taken into account within the SVLP 2021. Bearing in mind that the Council has gathered evidence which established that the site is potentially suitable for residential development, it is unclear why the site is proposed to be designated for green infrastructure under Policy DC3. Whilst it is appreciated that the exercise undertaken by the council does not guarantee that planning permission would be granted for a residential development, it certainly contradicts the approach taken within the SVLP 2021 which proposes to designated the site for green infrastructure.

NWLI does not object in principle to Policy DC5 or the content of the policy itself. However, its unclear which part of the policy relates to the Site, which the proposal map identifies as being subject to the policy. The policy makes it clear that its purpose is to ensure that a comprehensive range of sport and recreation facilities will be provided across Warrington to meet the needs of the existing and proposed population. It is unclear how the Site contributes to this aspiration. The site is in private ownership and is not publicly accessible, nor is it safe for the public to access unsupervised.