UPSVLP 0422
Figure 1
Prioritise the climate emergency given half of Warrington is expected to be underwater due to the adverse flooding impacts. Improved biodiversity should also be more prominent in the vision due to the degradation of ecology in the past few decades. An improved environment will best support Warrington?s economic and housing ambitions. CPRE suggests a more succinct vision with a reordered bullet list.
When considered the vision appears to prioritise economic factors over social and environmental ones and therefore the local plan is imbalanced.
Too many houses and too much employment land identified.
CPRE agrees that Warrington?s Green Belt should be protected, but it disagrees that Green Belt should be released.
Warrington should not undermine the role of the combined authority areas of Liverpool and Greater Manchester.
This should refer to integrated transport provision.
CPRE supports this objective.
CPRE supports this objective.
Recommend a reduced amount of housing as 14,688 dwellings at 2.34 people per household equates to housing for an additional 34.370 persons or +16.4% of the existing population. CPRE recommends a minor modification to ensure a contribution of housing land from windfall and small sites is included in the 5-year housing supply in accordance with the NPPF.
Welcome the reduction in number of houses to 816 pa and the reduced Plan period, however; only 468 dwellings per annum have been completed over the last 3 years and Plan target is double that. Despite Government mandate about data to be used informing projections and the way housing need is calculated, it is flawed and does not reflect reality. Failure against the Government?s stringent Housing Delivery Test will quickly find the local plan out of date, and more rural land will be lost to housing and associated urbanisation. With a reduced housing requirement, the Council can be more reasonably be expected to maintain a 5-year supply of housing land. Policy does not mention windfall sites (unanticipated land) and the contribution of small sites, yet recently windfall has come forward at Padgate Campus, Bank Quay and Fiddlers Ferry.
CPRE object to the listed allocated sites in the Outline Settlements and disagrees with the land being taken out of the Green Belt as it is not justified, but note that the density should be appropriate to its location and higher, as 30dph seems excessively low.
4
Bullet 7 sets out a staged approach, which although CPRE supports, points to as evidence of the housing requirement being too high to reasonably satisfy during the plan period.
7
We recommend 30% for Inner Warrington and elsewhere, with at least 60% social rent across the local authority area.
CPRE agrees more ?genuine? affordable housing is needed.
CPRE supports the provision of enough land to accommodate the needs of this community.
CPRE recommends that there needs to be a Brexit and Covid sense-check of employment needs given so much property has been vacated. An understanding if the changes and whether they will last in the long term is important. Consideration of what land use the vacant property can be repurposed for is important.
Economic development quantum identified in the Economic Development Needs Assessment (EDNA 2021), is considered overly ambitious when considering the reality of the economy.
Changes in retail due to technological advancement, Brexit and Covid are required to better understand the sharp increase in online shopping and working from home are likely to be permanent features, and consequently a precautionary approach is recommended.
Specifically CPRE objects to the release of all Green Belt land allocations. In our view Green Belt release is unjustified and it could be avoided in entirety, if the high quantum of development identified is reality checked. We think there are more sites to be identified on the Council?s Brownfield Register. Finally, the site selection promotes development of greenfield land at the rural fringe and open greenspace and this is contrary to the spatial distribution of development that the Warrington Draft Local Plan Vision and Strategic Objectives aim to achieve.
CPRE is broadly content with this policy. We welcome any enhancement of the Town Centre?s Environment as set out under bullet 7.
7
The text in 1.a to 1j may require editing to ensure the strategic road network is not prioritised for investment in advance of other modes.
Warrington is very poor in terms of its transport network and enabling walking and cycling due to its car domination.
1a to 1j
CPRE is concerned that more freight is transported on water and therefore no development should impede use of the Bridgewater and Manchester Ship Canals, the latter connecting to Liverpool Port.
CPRE is broadly supportive.
CPRE is broadly supportive.
CPRE is broadly supportive of the policy, particularly the points concerning Countryside & Settlements
The Local Plan needs to protect and enhance this in the local plan policy.
There is important industrial heritage and railway history connected with the world?s first commercial railway, the Chat Moss Line.
CPRE recommend inclusion of specific reference to the value of hedgerows and the need for more retention and planting due to the nature based solutions to climate change and biodiversity collapse.
CPRE is supportive of the local plan having a strategic approach to the Green Infrastructure. Suggest one change.
Policy DC4 and other relevant policies could in CPRE?s view more simply and precisely require all development to follow the harm avoidance, mitigation and compensation hierarchy set out in national policy (NPPF paragraph 180 a). It also needs to be made clearer that, in line with emerging statutory duties, development proposals in all locations will be expected to deliver or contribute to a net gain in biodiversity.
CPRE is supportive of the purpose of DC4 Ecological Network. Warrington should have more policy reference to hedgerows as currently the only reference is to ten allocated sites.
CPRE is broadly supportive. Consideration should be given to what is appropriate provision in the Green Belt. No buildings should be allowed in the Green Belt and the intrinsic value of openness should be maintained.
CPRE recommends an improved policy wording for landscape character protection and enhancement in the future. Landscape is more than just ?the view?. It?s the ever-changing relationship between people, place and nature. We also think the policy should refer to latest best practice and guidance and accord with Birkbeck D and Kruczkowski S et al (2020) Building for a Healthy Life.
CPRE is broadly supportive as it campaigns for good design and layout to ensure sustainable development is integrated into development.
For bullet 6 and restoration it is important that rural land is returned to the same or better condition and that it is not considered previously developed.
CPRE supports the sustainable use of a waste hierarchy to reduce, reuse and recycle to minimise waste.
Bullet 6
CPRE agrees that new development should not result in increased flood risk from any source, or cause other drainage problems, either on the development site or elsewhere. Many of the government?s nature-based solutions to the climate emergency to date have focused on trees, but hedgerows are also crucial in soaking up carbon, protecting against flooding and aiding nature?s recovery.
The wording of the policy may be improved by saying no development in peat will be permitted in accordance with the areas shown in Figure 16.
CPRE strongly objects to the exploration of hydrocarbons as all fossil fuel must remain in the ground to fulfil the nation?s international commitments on Climate Change. We are pleased to see peat resources will be protected.
The policy is deficient in ensuring land in rural areas should be left in an improved condition and not considered as previously developed.
CPRE is broadly supportive of the policy. Siting of renewable energy development should not harm rural landscapes that are otherwise unbuilt. Electric vehicle infrastructure should be supported by the local plan.
In addition to air and noise, CPRE wishes tranquillity to be specifically referred to.
CPRE is broadly supportive. We welcome reference to avoiding light pollution, particularly in areas of relative dark skies.
CPRE cannot provide detailed site comments on each allocation, but reserves the right to comment on the following allocations at the examination on topics where we have commented, such as Green Belt protection, ecology, best and most versatile land, development density, design, traffic management etc.
CPRE believes it is important that performance against local plan policy indicators as set out in Appendix 2 are captured in Annual Monitoring Report. We think the local plan should keep track of the carbon lifecycle of developments that it allows in the future to better understand how new development contributes to carbon zero target of 2030.
It is of concern how rapidly the countryside around Warrington has been urbanised as illustrated in Figure 1. Given the Spatial Strategy acknowledges the scale of development over the years on brownfield sites, CPRE questions why the Local Plan cannot be more ambitious on delivery of new homes on brownfield land in the future.