The land is located to the rear of The Plough public house and residential properties on Mill Lane, Houghton Green and comprises one half of a wider parcel of land in two separate ownerships. Whilst a PROW runs down the centre of the land, there is no means or right of public access to either parcel of land from it. Our client?s land has no physical link to any adjoining land and is enclosed by the M62 motorway to the north and Mill Lane to the east, which is sited at a higher level. The land is used for grazing and has been used for this purpose for many years. Access can only currently be obtained from Mill Lane via a field gate in the southeast corner of the site. The site is in private ownership and public access is prohibited. It is entirely unclear from the UPSVLP, accompanying proposals map and supporting evidence base whether the site is designated as ?Green Infrastructure? or ?Open Space? and therefore whether draft Policy DC3 applies to the site or draft Policy DC5. In order to rectify this situation, the Council should make all evidence that informs the ?green infrastructure? and ?open space? designation readily available for public scrutiny and the Council should then go out to further consultation on this matter. To not do so is prejudicial to interested parties. it is not in our view appropriate to combine ?green infrastructure? and ?open space? designations. The designations are entirely different and subject to differing policies. For the Plan to be justified and sound, it should be very clear and immediately obvious whether a particular parcel of land comprises ?green infrastructure? or ?open space?. In the case of our client?s land, it is not possible to determine from the evidence base which designation applies and thus which policies are applicable to the land. A review of the Open Space Audit 2015 identifies that all sites that are designated as such have been categorised into one of seven open space typologies. No information is however available as part of the UPSVLP evidence base or elsewhere on the Council?s website as to what typology each individual site designated as open space falls into. By not doing so it is impossible to understand the reason for the designation. In the absence of this information being available for public scrutiny, the Plan cannot be considered to be justified and thus sound. On request, the Council have provided a spreadsheet (which is attached to these representations) which shows that they have identified our clients land (Site ref. 246 on the Popular & Hulme table) as open space within the ?natural / semi natural green space? typology. The companion guide to the now superseded PPG17, provides a definition of this typology and its purpose which is ?wildlife conservation, biodiversity and environmental education and awareness?. The land in question is none of the above and is nothing more than a field used for grazing on the edge of the urban area. Furthermore, it is simply not the type of land that the document intended be categorised as ?natural / semi natural greenspace?. The site is used for grazing and has no special wildlife conservation or biodiversity value. It is a clearly defined parcel of land on the edge of the main urban area of Warrington bounded by built development on all sides. It also provides no role as a wildlife link to and from other land. It is no different to any other field used for grazing within the area. The site does not conform with the definition of open space set out in the NPPF. Our client?s land provides no opportunity for sport and recreation and therefore it immediately fails the test for open space. It also has no public access or public value. Whilst is has some visual amenity value as an undeveloped parcel of land, it is no different to any other parcel of grazing land. Notwithstanding this fact, a parcel of lands visual amenity value is not a test in its own right.

Notwithstanding the fact that the Council are currently subject to the Housing Delivery Test and cannot currently demonstrate a five-year supply of land for housing, the Plan relies very heavily on the housing requirement (67%) being met from sites identified in the SHLAA and thus windfalls and in relation to housing in the main urban area of Warrington, almost entirely on windfalls. By reference to Policy DEV1, it is very clear that for the main urban area of Warrington, which is the location to which the majority of new housing should be directed, it is proposed that pretty much all new housing should come from housing windfalls and sites within the SHLAA. It is our client?s view that this approach is wholly inappropriate and inconsistent with government guidance contained in the NPPF. Furthermore, we are aware of sites, such as our clients land at The Plough, which the SHLAA notes as being suitable, available and viability, but which is subject to a restrictive policy within the draft Plan. The Council is thus seemingly arguing that its SHLAA demonstrates that they can deliver a specified number of new houses and thus that the Borough?s housing requirement can be met, with no need for allocations in the main urban area of Warrington. However, some of these sites are potentially not deliverable due to significant policy constraints. The Plan also fails to comply with the NPPF requirement to identify a number of small and medium sized sites to meet at least 10% of the areas housing requirement.

The site is located in a highly sustainable location and is not subject to any constraints other than the current proposed ?green infrastructure / open space? designation, which our client considers is inappropriate and unjustified and should be deleted. Development of the site for housing would provide much needed additional housing in a highly accessible and sustainable location well served by local facilities within Houghton Green. The site is within the main built up / urban area of Warrington and is located directly adjacent to existing residential development. The site is in Flood Risk Zone 1 and is not subject to any ecological or heritage constraints. Whilst it is close to the M62 motorway, it is considered that any noise can be addressed with appropriate mitigation. Some work has been undertaken on a potential layout for the site, which we have enclosed with this letter. This shows one way in which the site could be developed. The site?s location formed the basis for its promotion as a residential site in the 2017 Call for Sites exercise. Notwithstanding this fact, a residential land use is entirely compatible with surrounding uses and would make a positive contribution to the Council?s deliverable housing land supply. The Council agreed with this proposition and formally recognised the site as a suitable, available, and achievable site within the SHLAA (2020), under reference 3309. The recent approval of the Peel Hall site immediately to the west and the current application on the neighbouring site (2021/39462) confirms that Warrington Borough Council see the urban area abutting the M62 motorway as being suitable for residential development.