UPSVLP 0417
The Local Housing Need (LHN) derived from the Government?s Standard Methodology should only be the starting point for determining WBC?s housing target. There are clear and indisputable arguments to increase the LHN figure significantly.
Boost the housing requirement to 1,015dpa over the extended Plan period (2021 ? 2039).
The Council?s own housing evidence (the 2021 LHNAU) and the UPSVLP have different timeframes.
The Local Plan is working to an 18-year timeframe (2021/22 to 2038/39), and therefore should cover the period 2021 to 2039.
The Local Plan is working to an 18-year timeframe (2021/22 to 2038/39), and therefore should arguably be running from 2021 to 2039, not 2038. In contrast, GL Hearn?s housing need assessment is over a 17-year timeframe, running from 2021 to 2038. This error is indicative of the extent to which the Local Plan and its own evidence base are fundamentally flawed, unjustified and unsound as a result.
The Council has unjustifiably and arbitrarily sought to reduce their housing requirement in the first 5 years.
Remove the stepped housing requirement
The UPSVLP proposes to lower targets over the first 5 years to just 678 dpa (17% below the Standard Methodology LHN). This conflicts with the Government's aspiration to frontload housing delivery by factoring in a buffer of additional deliverable sites, brought forward from later in the plan period11. It appears to be a mechanism designed to protect WBC from losing 5YHLS arguments at appeal given the availability of sites which the LPA have previously considered to be acceptable in principle, rather than providing homes for local residents in urgent need.
Part 7
Failure to provide an appropriate mix, size and type of housing. The proposed supply pays no regard to the Council?s evidence on housing need which advocated that 65% of the supply needs to deliver 3 & 4 bedroomed properties.
The solution to this concern and for the Plan to be found sound is to provide more greenfield sites capable of delivering the larger property types set out in the Council?s own housing need assessment.
Lichfields? analysis indicates that there is an overall need for 34% 1-bed and 2-bed properties over the period 2021-2038, and a 66% need for larger 3-bed+ properties. This broadly aligns with the need for larger properties identified in the LHNA, which has been taken forward in the emerging UPSVLP. However, The Consortium is concerned that the supply of sites in Warrington will not deliver the mix of homes identified in the emerging UPSVLP. Given the extremely high density being advocated in the Town Centre Masterplan document (240 dph), it is impossible to understand how any larger 3 and 4 bedroomed family homes will be delivered of the 8,000 homes identified in this area to 2040. The members of this Consortium are very experienced developers and housebuilders yet they have never seen town houses or family homes being delivered at an average density of 240dph. As such, this Plan as drafted will fail to deliver 65% of dwellings as larger properties. The Consortium considers that providing larger houses is vital as they can act as a mechanism for people to move around within the market and free up housing along the housing ladder.
The need for housing, generally and in respect of an acute affordability issue, will not be met across the Plan period, specifically in respect of serious deliverability concerns in respect of WBC?s stated housing land supply.
Remove at least 2,448 dwellings from the housing land supply (table 1 Land Requirements over the Plan period page 39 of the UPSVLP) and be replaced by alternative sources of supply including the South West Urban Extension. A number of smaller and sustainably located Green Belt releases for residential development (i.e. sites with capacity to deliver 200-500 units) should be identified, through an appropriate evidence base, within this additional land supply.
The Lichfield evidence endorsed by Ashalls, demonstrates that WBC has exaggerated the claimed housing land supply in order to reduce the overall proportion of Green Belt release required to meet the identified needs. It also demonstrates that WBC has paid insufficient regard to the definition of ?developable? (Annex 2 of the NPPF) and the evidence required to meet this test. Furthermore, from a basic assessment of the 5 Year Housing Land Supply (5YHLS) based on their detailed analysis carried out on a proportion of the Council?s supply, Lichfields has considerable concerns in relation to WBC?s ability to meet the requirements of NPPF para 74.
The Council has overestimated the deliverable and developable capacity of the Fiddlers Ferry site in the Plan period.
Provide additional evidence to justify its allocation, including: updating the incorrect and underplayed impacts it will have in the Sustainability Assessment, which as a consequence will also require WBC to reconsider its UPSLVP strategy to ensure that they have identified the most appropriate sites for release from the Green Belt; provide robust evidence to counter the delivery concerns that are identified in the representations; and ensure that sufficient land is provided in alternative locations to account for any shortfall in provision at Fiddlers Ferry and ensure the housing requirement is met.
Not only that, the timescales for the delivery of the site as set out in the Plan are fanciful and are not grounded in any sense of reality. It is the consortiums view that the SA in relation to the assumptions made on Fiddlers Ferry is fundamentally flawed, results in an unstainable approach to development, it is not sound, and it is not legally compliant. The identification and delivery of a brownfield site which over exaggerates its impact in the SA should not surpass the allocation of other more sustainable greenfield releases where it is clearly not justified. Not only that, Fiddlers Ferry is wholly unviable and as a consequence it is highly questionable whether the development could ever be delivered without significant intervention. We also have concerns with the loss of Green Belt land in this location and the lack of evidence to justify that this is the most appropriate site for Green Belt release. It is not clear why the Green Belt element of this site is required to come forward. Given the significant number and complexity of the issues raised in relation to the developability of this site, it is consider that the Council?s delivery trajectory is completely at odds with the reality of delivering complex strategic sites and the Council need to identify alternative sites to plug the gap in the supply trajectory. Not only that but the Consortium considers that the Council has not followed a logical approach in terms of identifying the most appropriate sites for release from the Green Belt and the loss of this proposed allocation would result in the erosion of the strategic gap between Warrington and Widnes.
The Council has not identified areas of safeguarded land between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period.
Safeguard land to provide for an additional 6,309 dwellings. The land to be identified as Safeguarded Land should be varied in size and be capable of coming forward in the short term, should the need arise at any point in the plan period.
We consider that WBC need to consider whether this minimum additional supply is sufficient to meet the identified needs when pursuing an economically aligned housing strategy, which we have demonstrated would require an additional 6,309 dwellings. This land should be identified now and safeguarded to meet the needs beyond the Plan period and ensure that the Green Belt boundaries endure beyond the Plan period too. The land to be identified as Safeguarded Land should be varied in size and be capable of coming forward in the short term, should the need arise at any point in the plan period. This would allow any future Local Plan Review to allocate the safeguarded sites for development and ensure they are capable of delivering units in the first 5 years post adoption of the Review.
The Council?s decision that the South West Urban Extension is no longer to be allocated in the Local Plan is not justified, consistent with National Policy and does not amount to the plan being positively prepared
Reinstate the South West Urban Extension
The SWUE is suitable, achievable, deliverable (and developable) and that there are no impediments to delivery early in the Plan period. the Council is wrong in its reasons for removing the SWUE from the current Local Plan and that none of the Councils stated reasons are fundamental to the delivery of this land as a sustainable urban extension. In its options assessment process the Council has overstated the impacts of the SWUE and understated the benefits relative to the other sites considered as part of the options assessment process. In particular, the Council has overstated the impacts of the SWUE in respect of the Western Link, secondary school provision, built leisure facilities and Green Belt and understated the benefits in terms of early delivery.
The Council?s decision that the South West Urban Extension is no longer to be allocated in the Local Plan is not justified, consistent with National Policy and does not amount to the plan being positively prepared
Reinstate the South West Urban Extension
The SWUE is suitable, achievable, deliverable (and developable) and that there are no impediments to delivery early in the Plan period. the Council is wrong in its reasons for removing the SWUE from the current Local Plan and that none of the Councils stated reasons are fundamental to the delivery of this land as a sustainable urban extension. In its options assessment process the Council has overstated the impacts of the SWUE and understated the benefits relative to the other sites considered as part of the options assessment process. In particular, the Council has overstated the impacts of the SWUE in respect of the Western Link, secondary school provision, built leisure facilities and Green Belt and understated the benefits in terms of early delivery.
Land south of Chester Road, Walton should be removed from the Green Belt and included within the Local Plan, either as part of the SWUE or as a stand alone allocation/safeguarded site or white land because it serves none of the purposes of the Green Belt and is a sustainable and deliverable residential development site that will directly contribute to meeting core objectives of WBC?s UPCVLP, namely homes within the first 5 years of the Plan period, much needed affordable homes and specialist elderly care accommodation, as well as providing land that is critical to the delivery of the WWL.
Land south of Chester Road, Walton should be removed from the Green Belt and included within the Local Plan, either as part of the SWUE or as a stand alone allocation/safeguarded site or white land because it serves none of the purposes of the Green Belt and should be removed from it.
Land South of Chester Road as a significant site in its own right should the Council require it as an alternative option to meeting their housing land supply shortfall, particularly their 5YHLS. It is a sustainable and deliverable residential development site that will directly contribute to meeting core objectives of WBC?s UPCVLP, namely homes within the first 5years of the Plan period, much needed affordable homes and specialist elderly care accommodation, as well as providing land that is critical to the delivery of the WWL. Evidence is provided to demonstrate the site should be recorded as making a 'weak' contribution to the Green Belt. Detailed evidence is provided to demonstrate the deliverability of the scheme and it is contended that there is adequate capacity in local health and education facilities to accommodate this increased demand arising should the site come forward as a stand along development.
Land south of Chester Road, Walton should be removed from the Green Belt and included within the Local Plan, either as part of the SWUE or as a stand alone allocation/safeguarded site or white land because it serves none of the purposes of the Green Belt and is a sustainable and deliverable residential development site that will directly contribute to meeting core objectives of WBC?s UPCVLP, namely homes within the first 5 years of the Plan period, much needed affordable homes and specialist elderly care accommodation, as well as providing land that is critical to the delivery of the WWL.
Land south of Chester Road, Walton should be removed from the Green Belt and included within the Local Plan, either as part of the SWUE or as a stand alone allocation/safeguarded site or white land because it serves none of the purposes of the Green Belt and should be removed from it.
Land South of Chester Road as a significant site in its own right should the Council require it as an alternative option to meeting their housing land supply shortfall, particularly their 5YHLS. It is a sustainable and deliverable residential development site that will directly contribute to meeting core objectives of WBC?s UPCVLP, namely homes within the first 5years of the Plan period, much needed affordable homes and specialist elderly care accommodation, as well as providing land that is critical to the delivery of the WWL. Evidence is provided to demonstrate the site should be recorded as making a 'weak' contribution to the Green Belt. Detailed evidence is provided to demonstrate the deliverability of the scheme and it is contended that there is adequate capacity in local health and education facilities to accommodate this increased demand arising should the site come forward as a stand along development.
There are compelling arguments to increase the overall housing need which have been totally ignored and frankly misinterpreted by WBC and its housing consultants. These include the misalignment with the Plan?s very high employment land target; and the very high levels of affordable housing need across the Borough. The solution to address this concern and to be found sound is to increase the housing requirement so that it aligns more closely with the Council?s economic growth proposals. Our modelling indicates that the Council should be planning for at least 1,015 dpa, which is more closely aligned with the Council?s previous 2019 target, would address realistic economic growth targets and help to deliver over 70% of its affordable housing need.