Langtree supports the emerging Warrington Local Plan, however Langtree considers that some elements of the Plan should be updated to better reflect national policy and guidance. Langtree considers that certain aspects of the emerging Plan do not reflect national planning policy, including the approach towards safeguarded land for long term development and the approach towards housing allocations in the Outlying Settlements. It is difficult to understand from the evidence base how the Council has determined the approach towards safeguarded land and the housing allocations in the Outlying Settlements. Langtree considers that the Local Plan period is insufficient. Langtree suggests that the Plan period should fully encompass the proposed delivery of the Garden Suburb and be extended to at least 2052, which is a minimum of 30 years from the earliest the Plan could be adopted in 2022.

Langtree supports the ambitious Vision for Warrington, but suggests the Vision should be extended for clarity to reflect national policy and guidance. The Vision appears to be up to 2038 ?and beyond?. This lack of clarity could hinder the economic growth ambitions and is not positive. Langtree suggests that the Vision could be enhanced by looking further ahead and safeguarding land for long term development and meeting the housing needs of all communities and settlements within the Borough, including Appleton Thorn.

Langtree suggests that further housing sites are needed, including their site at Arley Road, Appleton Thorn. Given the scale of Appleton Thorn it should be considered as an outlying settlement and appropriate to accommodate new development. The Plan states through Policy DEV1 that the proposed number of new homes is a minimum to be achieved. However, there does not appear to be a mechanism identified to achieve a significantly more than this, other than the potential 10% flexibility. However, as highlighted earlier there are some questions on delivery rates and trajectory on some complex sites such as Fiddlers Ferry. Langtree would like to highlight that it is important to recognise that the development of new housing will bring forward additional economic benefits to the area. The relationship between economic performance in an area and housing is complex, but having the right quantity, quality and balance of housing in an area is necessary for economic growth. The Government has indicated that they are committed to seeing 300,000 homes per year delivered by the mid 2020?s and has reiterated that the local housing need figure ?does not present a ?target? in plan-making, but instead provides a starting point for determining the level of need for the area?. Local authorities remain responsible for determining how many homes to plan for, and this should take account of local circumstances. Langree therefore considers further sites should be allocated for housing in Warrington and that land at Arley Road, Appleton Thorn would be an appropriate site. Appleton Thorn is a significant outlying settlement adjacent to a major employment area but has not been identified to accommodate any new housing. Langtree recommends that the Council increases the flexibility of the policy to ensure the densities are realistic and achievable and ensure the delivery of homes that are appropriate to the market - the densities proposed may bedifficult to achieve and more sites may need to be allocated. Langtree does not consider a stepped requirement is necessary and that the appropriate provision of housing should be provided for the entirety of the Plan period. The Council's overall housing land supply should include a mix of short and long-term sites, Appleton Thorn land should be considered as a smaller non-strategic site.

Langtree suggests that Policy DEV2 does not reflect the positive approach of national policy and guidance. Support for the provision of affordable housing but concerns that given the identified need, insufficient housing land is identified and that further sites should be identified. Land at Appleton Thorn could be allocated to meet the need of market and affordable homes.

Langtree strongly supports the allocation of the South East Warrington Employment Area, but suggests there should also be safeguarded land for employment at Six 56 Phase II. Langtree question whether the Local Plan is looking too short term rather than as the Vision states beyond 2038, as the Council is not identifying future locations for growth for long term employment land. The Council acknowledges within the supporting justification that insufficient employment land is being identified for the Plan period with an 8 hectare shortfall. The Council seek to address this through the Omega Phase 2 scheme, which is located in St Helens. There is no guarantee that this additional land will count towards Warrington?s supply. Local Plans should be planned positively and should meet identified needs now. The Plan strategy explains that a review of Warrington?s employment land will be undertaken before the end of the Plan period to identify future locations of growth. The Plan is not identifying sites to come forward later on in the Plan, or safeguarded sites. Langtree is concerned that some identified areas of employment land such as Fiddlers Ferry are constrained and may not come forward as expected. Langtree considers there is a need for safeguarded land for employment within the emerging Local Plan. Langtree therefore suggest the Six 56 Phase II should be safeguarded for long term development. The site is available, suitable and achievable and is therefore deliverable.

Langtree supports Policy GB1 in principle, but there are aspects that should be reviewed as its operation lacks clarity and creates uncertainty. Langtree supports the identification and release of South East Warrington Employment Area from the Green Belt within Part 3 of Policy GB1. However, as highlighted earlier Langtree suggests there is a need for housing land to be released at Appleton Thorn and safeguarded land for long term employment development at Six 56 Phase II. Part 1 of Policy GB1 states that the general extent of the Green Belt is set through the Plan to at least 2050. However, as highlighted earlier the Plan states that the employment land will be reviewed before the end of the Plan period, which is currently 2038. This statement is inconsistent and does not reflect the strategy or evidence of the Plan.

Langtree suggests Policy INF5 is amended so that it is clear and creates certainty. Point 5 explains the areas to be included in planning contributions, but then states that these areas are not limited. Langtree would like to highlight that national guidance states that policies on planning obligations should be clear so that they can be accurately accounted for in the price paid for land. Point 6 suggests that the only areas that can be discussed on viability are new areas that have arisen post preparation of the Plan. However, Langtree query the Viability Appraisal in relation to the South East Warrington Employment Area, which does not reflect accurately the proposal. Langtree support the overall conclusion on the viability of the site, however Langtree suggest there is an over emphasis on additional utilities and strategic infrastructure costs and that further evidence and reasoned justification should be provided or the Viability Appraisal be updated to reflect the proposed employment allocation.

Langtree query the Viability Appraisal in relation to the South East Warrington Employment Area, which does not reflect accurately the proposal. Langtree support the overall conclusion on the viability of the site, however Langtree suggest there is an over emphasis on additional utilities and strategic infrastructure costs and that further evidence and reasoned justification should be provided or the Viability Appraisal be updated to reflect the proposed employment allocation.

Langtree suggests that Policy ENV7 is amended so that it is clear and creates certainty. Langtree supports tackling climate change and reducing carbon emissions. However this should be undertaken in an efficient and comparable manner between authorities and areas. Langtree considers that Councils should comply with the Government?s intention of setting standards for energy efficiency through the Building Regulations. The key to success is standardisation and avoidance of individual Councils specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers, suppliers and developers. The Council should not need to set local energy efficiency standards to achieve the shared net zero goal because of the higher levels of energy efficiency standards the Government are bringing in. Langtree is also concerned with Point 5 which states that within the major allocations should reduce carbon emissions and maximise opportunities for decentralised energy systems. This is then reinforced as a ?requirement? however decentralised energy networks are generally unviable for many schemes. Point 6 also needs to be reviewed on this basis.

Langtree is concerned that Policy ENV8 is tied into Policy MD6 and the allocation of the South East Warrington Employment Area. Point 20 of Policy MD6 states that development within the allocation will be required to mitigate air quality impacts on the Manchester Mosses SAC in accordance with Policy ENV8 (Part 4). Langtree would therefore suggest that given the South East Warrington Employment Area is not specifically on the M62 Motorway the references to specific allocations should be removed from the policy. Furthermore, the policy does not recognise site locations and distances to Manchester Mosses SAC. The South East Warrington Employment Area is some distance from Risley Moss, Holcroft Moss and Astley & Bedford Mosses. Therefore, Langtree suggest that the term ?must devise a scheme-specific range of measures? creates inflexibility within the policy and is too onerous. This should be amended to a term that reflects the evidence on a site by site basis. This should be amended to ?should devise a scheme-specific range of measures?.

Langtree strongly supports Policy MD6 which allows for the development and delivery of the South East Warrington Employment Area. However, the site is controlled and will be delivered by two parties. Although the site is a single allocation the policy needs to recognise that the two parcels are able to be delivered independently of each other. Langtree supports the need for a comprehensive masterplan, however this should be prepared within the context that each individual parcel is able to come forward on its own and accommodate its own green infrastructure, utilities, and drainage and transport requirements. Paragraph 10.6.5 does not reflect this situation and stipulates the scale of the Development Framework and what it needs to include and that the site cannot come forward until it is agreed by all parties. This is carried forward into Point 3 of Policy MD6, which could therefore constrain and hinder the timely delivery of the development unnecessarily. Langtree considers this can be addressed through an agreed comprehensive masterplan and individual planning applications, which can be directed by a clear and concise Local Plan policy. This strategic approach should be reflected and continued throughout the policy and descend into each criteria. Currently, the site specific requirements from Point 5 onwards are do not reflect this approach, lack clarity and are onerous. Langtree would also like to highlight that Point 21 does not reflect national policy and guidance - Langtree suggests that this aspect of the policy is updated to reflect the Framework Chapter 16 Conserving and Enhancing the Historic Environment.

Langtree suggests that Policy M1 is updated to incorporate a review mechanism for employment land to create clarity and certainty.

Langtree suggests that their site at Knutsford Road, Six 56 Phase II is included in the Plan as safeguarded land for long term development. Full details included as to why the site is deliverable, available, suitable and achievable and as to why development of the site would be an effective use of land.

Langtree suggests that their site at Arley Road, Appleton Thorn should be identified for housing. Langtree has highlighted some concerns with the housing land supply and spatial distribution of new housing. Langtree also believes that some new housing should be directed towards Appleton Thorn as a larger sustainable Outlying Settlement. Full details of the benefits of allocation this site are set out.