UPSVLP 0426
Peel recognises and fully supports the strategic objectives of the PSLP 2021 including the regeneration of Inner Warrington and the delivery of strategic and local infrastructure as expressed through Strategic Objectives W1, W3 and W4.
Peel recognises and fully supports the strategic objectives of the PSLP 2021 including the regeneration of Inner Warrington and the delivery of strategic and local infrastructure as expressed through Strategic Objectives W1, W3 and W4.
Peel recognises and fully supports the strategic objectives of the PSLP 2021 including the regeneration of Inner Warrington and the delivery of strategic and local infrastructure as expressed through Strategic Objectives W1, W3 and W4.
The PSLP does not seek to meet the proper housing needs of the Borough over the plan period.
The Local Plan should proceed on the basis of a requirement to provide 1,050 dwelling per annum over the plan period.
The PSLP is presently planning for a level of housing growth which does not reflect its economic ambition and the amount of employment land it is seeking to bring forward. As a result, and without accommodating a commensurate level of housing growth, the Borough?s labour force will not grow to the level needed to realise its economic growth ambitions and to deliver the level of employment development which the PSLP seeks.
The PSLP significantly over-estimates the residential development yield from the urban area over the plan period resulting in a significant unmet housing requirement.
Adopt more realistic assumptions around the developable supply within the urban area based on the analysis in this representation or alternatively increase the flexibility allowance to say 25%. The PSLP should identify additional land in the Green Belt which is capable of providing up to 7,696 dwellings over the plan period to reflect the deficiencies in the urban land supply identified through this representation.
At this stage, and without consideration of the significant market constraints affecting the planned supply, the Council?s evidence base shows that the plan period urban supply amounts is at least 3,446 dwellings less than claimed by the Council. The Council has not presented a full schedule of sites which it considers to comprise the developable supply to the end of the plan period and so is in conflict with paragraph 68 of the NPPF. It is overly reliant on a fledging town centre residential market, the investor appetite for which is, at best, uncertain with a very significant level of risk that this market will not deliver at the level claimed by the Council. It has materially over-estimated the developable capacity of a number of specific sites within the identified supply. It has not justified the assumed uplift in past delivery rates from the urban area. It does not take account of the Council?s own evidence regarding the viability of residential development in different parts of the urban area which demonstrates that a number of areas within the Borough, most notably the Town Centre, are not viable for residential development even with nil affordable housing contributions.
The PSLP significantly over-estimates the residential development yield from the urban area over the plan period resulting in a significant unmet housing requirement.
The PSLP should identify additional land in the Green Belt which is capable of providing up to 7,696 dwellings over the plan period to reflect the deficiencies in the urban land supply identified through this representation.
At this stage, and without consideration of the significant market constraints affecting the planned supply, the Council?s evidence base shows that the plan period urban supply amounts is at least 3,446 dwellings less than claimed by the Council. The Council has not presented a full schedule of sites which it considers to comprise the developable supply to the end of the plan period and so is in conflict with paragraph 68 of the NPPF. It is overly reliant on a fledging town centre residential market, the investor appetite for which is, at best, uncertain with a very significant level of risk that this market will not deliver at the level claimed by the Council. It has materially over-estimated the developable capacity of a number of specific sites within the identified supply. It has not justified the assumed uplift in past delivery rates from the urban area. It does not take account of the Council?s own evidence regarding the viability of residential development in different parts of the urban area which demonstrates that a number of areas within the Borough, most notably the Town Centre, are not viable for residential development even with nil affordable housing contributions.
The proposed stepped housing requirement in the PSLP 2021, which assumes planning for a level which is below even the minimum need for homes over the first five years of the plan period is unjustified and reflective of an erroneous process of options appraisal where the ability of sites (specifically the SWUE) to deliver early during the plan period has not been considered.
The PSLP assessment of site options should be reconsidered and appropriate weight given to those Green Belt options, including the South West Urban Extension, which are demonstrably capable of making a meaningful contribution to meeting development needs during the first five years of the plan period benefits in this regard.
The onus is on the Council to justify a stepped trajectory rather than accept this as a consequence of the selection of sites. The Council should seek to avoid a stepped trajectory if possible and, to the extent that development options would achieve this, that should be acknowledged positively in the Council?s appraisal of those options. The Council has not considered this issue through its options assessment and has not given consideration to the fact that the South West Urban Extension is able to make a significant contribution to housing delivery early in the Plan Period. Allocation of the SWUE would partly address the issue of unsoundness relating to the stepped housing requirement.
The PSLP 2021 does not make sufficient provision to ensure the Green Belt can endure over the long term and avoid the need for a further Green Belt review beyond the plan period through the designation of safeguarded land for housing.
Release additional land in the Green Belt to be designated as safeguarded land to meet potential development needs beyond the plan period. Cumulatively, land capable of delivering up to 4,249 dwellings should be released for this purpose, with a proportion of this directed to the Outlying Settlements. If not allocated, then unsoundness relating to safeguarded land can be partly corrected by allocating the SWUE as safeguarded land to meet development requirements beyond the plan period.
The Council uses a number of unsubstantiated points to arrive at a conclusion that housing requirements will contract looking ahead to beyond the plan period. As a minimum the PSLP should proceed on the basis that the SM requirement continues to apply beyond the plan period. On the basis of the Council?s expectation that all the identified plan period supply will be delivered by 2038, the flexibility allowance should be removed from the calculation of post-plan period supply. Peel does not agree with the Council?s conclusion that there is no requirement to release land from the Green Belt specifically to meet development needs beyond the plan period. The Council has not satisfied the requirements of paragraph 140 of NPPF and is unsound as a result. In considering supply beyond the Plan period, there is effectively no provision in the PSVLP2021 for ensuring the Outlying Settlements post plan period needs are catered for. The effective result of this is that it is inevitable that the Green Belt boundaries around the Outlying Settlements will not endure beyond the plan period based on the strategy being pursed. This represents a further evidenced conflict with paragraph 140 of NPPF. To address this, the PSLP will need to identify a supply of sites adjacent to the Outlying Settlements which will ensure their proportionate share of post-plan period needs can be met.
The PSLP 2021 does not make sufficient provision to ensure the Green Belt can endure over the long term and avoid the need for a further Green Belt review beyond the plan period through the designation of safeguarded land for housing.
Release additional land in the Green Belt to be designated as safeguarded land to meet potential development needs beyond the plan period. Cumulatively, land capable of delivering up to 4,249 dwellings should be released for this purpose, with a proportion of this directed to the Outlying Settlements. If not allocated, then unsoundness relating to safeguarded land can be partly corrected by allocating the SWUE as safeguarded land to meet development requirements beyond the plan period.
The Council uses a number of unsubstantiated points to arrive at a conclusion that housing requirements will contract looking ahead to beyond the plan period. As a minimum the PSLP should proceed on the basis that the SM requirement continues to apply beyond the plan period. On the basis of the Council?s expectation that all the identified plan period supply will be delivered by 2038, the flexibility allowance should be removed from the calculation of post-plan period supply. Peel does not agree with the Council?s conclusion that there is no requirement to release land from the Green Belt specifically to meet development needs beyond the plan period. The Council has not satisfied the requirements of paragraph 140 of NPPF and is unsound as a result. In considering supply beyond the Plan period, there is effectively no provision in the PSVLP2021 for ensuring the Outlying Settlements post plan period needs are catered for. The effective result of this is that it is inevitable that the Green Belt boundaries around the Outlying Settlements will not endure beyond the plan period based on the strategy being pursed. This represents a further evidenced conflict with paragraph 140 of NPPF. To address this, the PSLP will need to identify a supply of sites adjacent to the Outlying Settlements which will ensure their proportionate share of post-plan period needs can be met.
The PSLP will not meet the qualitative housing needs of the Borough, including the need for family housing and affordable housing through over reliance on areas where development viability is compromised and through an over reliance on locations expected to provide apartments (principally the town centre).
The PSLP should seek to allocate land in more viable development areas where affordable housing can be provided as part of an overall housing mix and to create a more balanced mix of house types, relative to need, over the plan period.
There is a clear mismatch between the type of housing being planned for and the qualitative needs of the Borough and its residents, characterised by an over-reliance on the provision of apartment products in the Town Centre and a resultant under provision of family housing relative to needs. Notwithstanding comments regarding realistic yield from the Town Centre market, this alone means that the Council should reduce its reliance on the Town Centre to meet the PSLP needs and increase the allocation of sites for family housing. That is not to say the Council?s ambitions for the regeneration of the Town Centre and growing its residential population should be diluted but rather that the extent to which any yield from this location goes to meeting the calculated housing requirement for the purposes of the Local Plan, its contribution should be moderated to reflect its limitations in meeting the qualitative needs identified. Any housing requirement proposed is self-evidently a minimum and can be exceeded if there is an opportunity to grow the Town Centre residential market in the interests of delivering the Council?s regeneration aspirations for this location.
The PSLP will not meet the qualitative housing needs of the Borough, including the need for family housing and affordable housing through over reliance on areas where development viability is compromised and through an over reliance on locations expected to provide apartments (principally the town centre).
The PSLP should seek to allocate land in more viable development areas where affordable housing can be provided as part of an overall housing mix and to create a more balanced mix of house types, relative to need, over the plan period.
There is a clear mismatch between the type of housing being planned for and the qualitative needs of the Borough and its residents, characterised by an over-reliance on the provision of apartment products in the Town Centre and a resultant under provision of family housing relative to needs. Notwithstanding comments regarding realistic yield from the Town Centre market, this alone means that the Council should reduce its reliance on the Town Centre to meet the PSLP needs and increase the allocation of sites for family housing. That is not to say the Council?s ambitions for the regeneration of the Town Centre and growing its residential population should be diluted but rather that the extent to which any yield from this location goes to meeting the calculated housing requirement for the purposes of the Local Plan, its contribution should be moderated to reflect its limitations in meeting the qualitative needs identified. Any housing requirement proposed is self-evidently a minimum and can be exceeded if there is an opportunity to grow the Town Centre residential market in the interests of delivering the Council?s regeneration aspirations for this location.
Urban Capacity Assessment
The Council has not published a full schedule of housing sites which it considers to be developable over the plan period 2021 to 2038, with the latest such evidence being the 2020 SHLAA, which includes a number of sites which have been completed prior to the start of the plan period.
The Council should provide full details of sites which comprise the claimed urban housing land supply of 11,785 dwellings over the plan period.
The Council has not presented a full schedule of sites which it considers to comprise the developable supply to the end of the plan period and so is in conflict with paragraph 68 of the NPPF.
Options Assessment Process
The Council has selected strategic sites for allocation at SEWUE, Warrington Waterfront and Thelwall Heys for residential development through reliance on a very limited evidence base.
The Council should commission a full environmental and technical evidence base in relation to SEWUE, Thelwall Heys and Warrington Waterfront to enable their relative merits and sustainability to be assessed and compared on a fair and equal basis.
Peel fundamentally disagrees with the conclusions reached by the Council with respect to the relative sustainability of the different options which is influential in determining which forms the basis of the Local Plan. A number of conclusions are drawn which do not stand up to scrutiny and run contrary to the prevailing evidence. Most notably, Peel considers that the Council has misrepresented the constraints to development at SWUE and the impacts which would arise from its development and there is some evidence which indicates that the Council has not undertaken the relative assessments on a consistent basis. In its assessment of the SWUE, the Council has: over-estimated the Green Belt impacts arising from the development of the SWUE, underestimating the impact of the South East Warrington Urban Extension (SEWUE) in this regard; incorrectly concluded that the SWUE will give rise to unacceptable impacts on the proposed Warrington Western Link Road and therefore will have a severe impact on the highway network; incorrectly concluded that the SWUE is constrained by education capacity constraints; failed to recognise the beneficial effects of the SWUE in being able to justifiably and viably provide a contribution towards the delivery of the Western Link ; an unjustified change in approach to the assessment of the SWUE through the Sustainability Appraisal process with particular regard to its ability to contribute to the delivery of strategic infrastructure (the Western Link).The Council has also not fully considered the benefits of the site in providing early housing delivery, or considered a smaller allocation as it has done with the previous PSVLP 2019 Garden Suburb Allocation. With regard to sites allocated, there is limited technical evidence to test and demonstrate their deliverability and the extent to which they represent sustainable sites with respect of a number of critical technical matters including landscape impact, flood risk, ecology, noise, utilities capacity and agricultural land classification whilst there is no evidence to demonstrate how and that sites can be satisfactorily accessed. These sites have not proven to be deliverable over the plan period or that they represent the most sustainable options when considered against reasonable alternatives as a result.
The Council has selected strategic sites for allocation at SEWUE, Warrington Waterfront and Thelwall Heys for residential development through reliance on a very limited evidence base.
The Council should commission a full environmental and technical evidence base in relation to SEWUE, Thelwall Heys and Warrington Waterfront to enable their relative merits and sustainability to be assessed and compared on a fair and equal basis.
Peel fundamentally disagrees with the conclusions reached by the Council with respect to the relative sustainability of the different options which is influential in determining which forms the basis of the Local Plan. A number of conclusions are drawn which do not stand up to scrutiny and run contrary to the prevailing evidence. Most notably, Peel considers that the Council has misrepresented the constraints to development at SWUE and the impacts which would arise from its development and there is some evidence which indicates that the Council has not undertaken the relative assessments on a consistent basis. In its assessment of the SWUE, the Council has: over-estimated the Green Belt impacts arising from the development of the SWUE, underestimating the impact of the South East Warrington Urban Extension (SEWUE) in this regard; incorrectly concluded that the SWUE will give rise to unacceptable impacts on the proposed Warrington Western Link Road and therefore will have a severe impact on the highway network; incorrectly concluded that the SWUE is constrained by education capacity constraints; failed to recognise the beneficial effects of the SWUE in being able to justifiably and viably provide a contribution towards the delivery of the Western Link ; an unjustified change in approach to the assessment of the SWUE through the Sustainability Appraisal process with particular regard to its ability to contribute to the delivery of strategic infrastructure (the Western Link).The Council has also not fully considered the benefits of the site in providing early housing delivery, or considered a smaller allocation as it has done with the previous PSVLP 2019 Garden Suburb Allocation. With regard to sites allocated, there is limited technical evidence to test and demonstrate their deliverability and the extent to which they represent sustainable sites with respect of a number of critical technical matters including landscape impact, flood risk, ecology, noise, utilities capacity and agricultural land classification whilst there is no evidence to demonstrate how and that sites can be satisfactorily accessed. These sites have not proven to be deliverable over the plan period or that they represent the most sustainable options when considered against reasonable alternatives as a result.
The Council has selected strategic sites for allocation at SEWUE, Warrington Waterfront and Thelwall Heys for residential development through reliance on a very limited evidence base.
The Council should commission a full environmental and technical evidence base in relation to SEWUE, Thelwall Heys and Warrington Waterfront to enable their relative merits and sustainability to be assessed and compared on a fair and equal basis.
Peel fundamentally disagrees with the conclusions reached by the Council with respect to the relative sustainability of the different options which is influential in determining which forms the basis of the Local Plan. A number of conclusions are drawn which do not stand up to scrutiny and run contrary to the prevailing evidence. Most notably, Peel considers that the Council has misrepresented the constraints to development at SWUE and the impacts which would arise from its development and there is some evidence which indicates that the Council has not undertaken the relative assessments on a consistent basis. In its assessment of the SWUE, the Council has: over-estimated the Green Belt impacts arising from the development of the SWUE, underestimating the impact of the South East Warrington Urban Extension (SEWUE) in this regard; incorrectly concluded that the SWUE will give rise to unacceptable impacts on the proposed Warrington Western Link Road and therefore will have a severe impact on the highway network; incorrectly concluded that the SWUE is constrained by education capacity constraints; failed to recognise the beneficial effects of the SWUE in being able to justifiably and viably provide a contribution towards the delivery of the Western Link ; an unjustified change in approach to the assessment of the SWUE through the Sustainability Appraisal process with particular regard to its ability to contribute to the delivery of strategic infrastructure (the Western Link).The Council has also not fully considered the benefits of the site in providing early housing delivery, or considered a smaller allocation as it has done with the previous PSVLP 2019 Garden Suburb Allocation. With regard to sites allocated, there is limited technical evidence to test and demonstrate their deliverability and the extent to which they represent sustainable sites with respect of a number of critical technical matters including landscape impact, flood risk, ecology, noise, utilities capacity and agricultural land classification whilst there is no evidence to demonstrate how and that sites can be satisfactorily accessed. These sites have not proven to be deliverable over the plan period or that they represent the most sustainable options when considered against reasonable alternatives as a result.
The Council has selected strategic sites for allocation at SEWUE, Warrington Waterfront and Thelwall Heys for residential development through reliance on a very limited evidence base.
The Council should commission a full environmental and technical evidence base in relation to SEWUE, Thelwall Heys and Warrington Waterfront to enable their relative merits and sustainability to be assessed and compared on a fair and equal basis.
Peel fundamentally disagrees with the conclusions reached by the Council with respect to the relative sustainability of the different options which is influential in determining which forms the basis of the Local Plan. A number of conclusions are drawn which do not stand up to scrutiny and run contrary to the prevailing evidence. Most notably, Peel considers that the Council has misrepresented the constraints to development at SWUE and the impacts which would arise from its development and there is some evidence which indicates that the Council has not undertaken the relative assessments on a consistent basis. In its assessment of the SWUE, the Council has: over-estimated the Green Belt impacts arising from the development of the SWUE, underestimating the impact of the South East Warrington Urban Extension (SEWUE) in this regard; incorrectly concluded that the SWUE will give rise to unacceptable impacts on the proposed Warrington Western Link Road and therefore will have a severe impact on the highway network; incorrectly concluded that the SWUE is constrained by education capacity constraints; failed to recognise the beneficial effects of the SWUE in being able to justifiably and viably provide a contribution towards the delivery of the Western Link ; an unjustified change in approach to the assessment of the SWUE through the Sustainability Appraisal process with particular regard to its ability to contribute to the delivery of strategic infrastructure (the Western Link).The Council has also not fully considered the benefits of the site in providing early housing delivery, or considered a smaller allocation as it has done with the previous PSVLP 2019 Garden Suburb Allocation. With regard to sites allocated, there is limited technical evidence to test and demonstrate their deliverability and the extent to which they represent sustainable sites with respect of a number of critical technical matters including landscape impact, flood risk, ecology, noise, utilities capacity and agricultural land classification whilst there is no evidence to demonstrate how and that sites can be satisfactorily accessed. These sites have not proven to be deliverable over the plan period or that they represent the most sustainable options when considered against reasonable alternatives as a result.
The South West Urban Extension represents a sustainable and deliverable residential development site which can meet the need for additional housing land during the plan period. It also represents the most sustainable of the candidate Green Belt releases being considered for housing development. Its omission from the PSLP is based on an inadequate and deficient assessment process which has over stated its harmful effects relative to other sites and which has not had proper regard to its benefits, including its ability to contribute to the delivery of the Western Link Road and deliver dwellings early in the plan period.
The PSLP should reinstate draft allocation MD3 South West Urban Extension from the PSLP 2019.
The Council has previously concluded, through the evidence base to the 2019 PSLP, that the SWUE represents a sustainable and suitable site to meet the then higher development needs. Through a consortium of developers with an interest in this site, a deliverable masterplan is presented within an up to date development prospectus. This is supported by a body of technical work which demonstrates that the site is not affected by any insurmountable constraints which would prevent it from coming forward. Evidence is provided to demonstrate that the site is viable and can make a contribution to meeting the affordable housing needs of the Borough and strategic infrastructure needs of the Local Plan. The consortium of developers have signed a Memorandum of Understanding outlining a commitment to work collaboratively to bring the site forward in a timely and coordinated manner. This demonstrates a high level of commitment and provides added reassurance that a comprehensive approach will be taken to ensure the site is effectively masterplanned and infrastructure delivered through the development at the appropriate time. The site comprises Green Belt parcels which the Council has determined made a moderate contribution to the Green Belt. Importantly, it is framed by defensible boundaries provided by the Manchester Ship Canal, the West Coast Mainline, the A56 and Runcorn Road. It is well contained by defensible features so as to avoid strategic harm to the Green Belt. Nothing has materially changed to indicate that the SWUE would not be a suitable and sustainable development allocation in the context of a need to identify additional land
to meet the housing needs of the Borough.
The South West Urban Extension represents a sustainable and deliverable residential development site which can meet the need for additional housing land during the plan period. It also represents the most sustainable of the candidate Green Belt releases being considered for housing development. Its omission from the PSLP is based on an inadequate and deficient assessment process which has over stated its harmful effects relative to other sites and which has not had proper regard to its benefits, including its ability to contribute to the delivery of the Western Link Road and deliver dwellings early in the plan period.
The PSLP should reinstate draft allocation MD3 South West Urban Extension from the PSLP 2019.
The Council has previously concluded, through the evidence base to the 2019 PSLP, that the SWUE represents a sustainable and suitable site to meet the then higher development needs. Through a consortium of developers with an interest in this site, a deliverable masterplan is presented within an up to date development prospectus. This is supported by a body of technical work which demonstrates that the site is not affected by any insurmountable constraints which would prevent it from coming forward. Evidence is provided to demonstrate that the site is viable and can make a contribution to meeting the affordable housing needs of the Borough and strategic infrastructure needs of the Local Plan. The consortium of developers have signed a Memorandum of Understanding outlining a commitment to work collaboratively to bring the site forward in a timely and coordinated manner. This demonstrates a high level of commitment and provides added reassurance that a comprehensive approach will be taken to ensure the site is effectively masterplanned and infrastructure delivered through the development at the appropriate time. The site comprises Green Belt parcels which the Council has determined made a moderate contribution to the Green Belt. Importantly, it is framed by defensible boundaries provided by the Manchester Ship Canal, the West Coast Mainline, the A56 and Runcorn Road. It is well contained by defensible features so as to avoid strategic harm to the Green Belt. Nothing has materially changed to indicate that the SWUE would not be a suitable and sustainable development allocation in the context of a need to identify additional land
to meet the housing needs of the Borough.
The Council has adopted a deficient process in the selection of sites for allocation in the Outlying Settlements resulting in the allocation of sites which do not represent the most sustainable when considered in the round and against reasonable alternatives.
Land at Lady Lane, Croft should be prioritised for allocation for residential development ? 200 dwellings during the plan period or 100 dwellings during the plan period and 100 dwellings beyond the plan period (through a safeguarded land designation)
Peel consider that the Council has overstated the performance of the proposed OS1 allocation in respect of access and use of previously developed land, whilst understating the performance of the Lady Lane site in respect of remediation, ecology and access. Further the allocated site is considered to make a strong Green Belt contribution and the Lady Lane site a weak contribution. The Lady Lane site would also provide the potential to meet longer term needs. Taking these points together, it is clear that Peel?s proposed site presents a more sustainable and more suitable allocation to deliver both the plan period and post-plan period needs of the settlement compared to the selected site allocation OS1.
The Council has adopted a deficient process in the selection of sites for allocation in the Outlying Settlements resulting in the allocation of sites which do not represent the most sustainable when considered in the round and against reasonable alternatives.
Land north of Culcheth should be prioritised for allocation for residential development ? 300 dwellings during the plan period and 300 dwellings beyond the plan period (through a safeguarded land designation)
alongside the provision of highway improvements to Warrington Road, potential expansion area for Culcheth Secondary School, the development of a country park and other open space.
Peel consider that the allocated site makes a strong contribution to the Green Belt, would have a medium to high impact on visual amenity, would not achieve effective integration into the existing build environment of Culcheth. Peel's proposed site makes at most a moderate contribution to the Green Belt, will provide extensive recreational benefits for the existing community, offer the potential to expand the high school and provide highways improvements. Peel's site is considered to have less visual impact, provides a more natural extension of the settlement and provide the potential to meet longer term needs through provide safeguarded land. Taking these points together, it is clear that Peel?s proposed site presents a more sustainable and more suitable allocation to deliver both the plan period and post-plan period needs of the settlement compared to the selected site allocation OS2.
The Council has adopted a deficient process in the selection of sites for allocation in the Outlying Settlements resulting in the allocation of sites which do not represent the most sustainable when considered in the round and against reasonable alternatives.
Land at Manchester Road, Hollins Green should be prioritised for allocation for residential development ? 200 dwellings during the plan period or 100 dwelling during the plan period and 100 dwellings beyond the plan period (through a safeguarded land designation)
Peel consider the Council has understated the performance of the Manchester Road site in respect of Air quality impacts, agricultural land and landscape. Further Peel consider that the proposed site allocation OS3 makes a strong contribution to the Green Belt and the Manchester Road site makes a weak contribution. The Manchester Road site would also provide the potential to meet longer term needs. Taking these points together, it is clear that Peel?s proposed site presents a more sustainable and more suitable allocation to deliver both the plan period and post-plan period needs of the settlement compared to the selected site allocation OS3.
The Council has adopted a deficient process in the selection of sites for allocation in the Outlying Settlements resulting in the allocation of sites which do not represent the most sustainable when considered in the round and against reasonable alternatives.
Land at Rushgreen Road, Lymm should be prioritised for a residential led mixed use development for 115 dwellings during the plan period including potential community, health, education, sports, recreation and tourism uses through a safeguarded land designation)
Peel consider the Council has understated the performance of the Tanyard Farm site in respect of remediation of contaminated land, agricultural land and access. Further, the northern site within allocation OS4 is located entirely within Flood Zones 2 and 3. There are alternative sites available which are located outside of Flood Zones 2 and 3. The sequential test in NPPF is not met. This should result in the site being discounted at the outset. Approximately 50% of the southern site is located within Flood Zone 2. Insofar as there are alternative sites available which are located outside of Flood Zones 2 and 3, this should weigh against the allocation of this site. Further, Peel consider the Green Belt performance of 0S4 has been understated and the site is further away from Lymm neighbourhood centre than the site being promoted by Peel. Taking these points together, it is clear that Peel?s proposed site presents a more sustainable and more suitable allocation compared to the selected site allocation OS4.
The Council has adopted a deficient process in the selection of sites for allocation in the Outlying Settlements resulting in the allocation of sites which do not represent the most sustainable when considered in the round and against reasonable alternatives.
Land at Rushgreen Road, Lymm should be prioritised for a residential led mixed use development for 115 dwellings during the plan period including potential community, health, education, sports, recreation and tourism uses through a safeguarded land designation)
The release of land within Parcel LY16 represents the most sustainable approach to meeting the housing needs of Lymm. Within this context, land off Rushgreen Road (land east of Tanyard Farm) would be the least sensitive area for release within Parcel LY16 and should be prioritised over other areas within the same parcel.
There is a need for the PSLP to allocate additional land for employment development during the plan period in order to meet the objectively assessed need.
The PSLP should allocate land at Statham Meadows for allocation for employment / mixed commercial development during the plan period.
The site is suitable and achievable for commercial development. It has been submitted to the Council as part of previous representations, including through 2016 Scope and Contents consultation and in response to call for sites consultations. This site also has the potential to be used for motorway services or roadside retail purposes, or part of a mix of uses alongside some employment development. The site?s location on the M6 and A57 would lend itself to such uses; ensuring users of these busy stretches of strategic road have access to good quality welfare and break facilities as critical to the safe operation of the road network. (Reference is made to a previous proposal for a MSA on this site which was refused by the Secretary of State in 2002.) Notwithstanding this, the site is not included in the Council?s Site Assessment Proformas Report (2019) nor is it considered in the Council?s 2021 update. The Council has therefore not taken account of this development opportunity, and appraised this alongside others as part of the Local Plan process. It is requested that the site is assessed as part of an update to the Council?s Site Assessment Report to enable it to be considered on a comparative basis and in the context of the increased employment land required identified in the joint submission made by Peel Land & Property Holdings (UK) and Peel Ports. The site can be accessed satisfactory and safely, residual traffic impacts will not be severe and the site will be sustainable and accessible.
The PSVLP 2021 fails to set out a clear and credible delivery strategy for the Western Link ? a critical piece of infrastructure to deliver the Local Plan ? and to address the significant challenges to funding this in the context of reduced development requirements, the removal of previously proposed allocations which would otherwise contribute financially to the Western Link and evidence that development in identified growth areas within the urban area is, at best, marginal and so with limited prospects of being able to contribute, financially, to the Link Road.
The PSLP is substantially reliant on the delivery of the Western Link to unlock development capacity in the town centre and at Warrington Waterfront. The 2019 PSLP proposed that the SWUE site, as proposed for allocation at the time, would be one of three allocations which would make a proportionate contribution towards the delivery of the Western Link in order to help meet a ?70m funding shortfall. This was a key component of the delivery strategy for the link road. Two of these allocations, Port Warrington and the SWUE, are now no longer proposed in the PSLP 2021 with the only remaining site which is identified as making a contribution to the Western Link being the Warrington Waterfront residential proposal (providing an estimated 1,070 dwellings over the plan period and representing a small proportion of the overall plan requirement). It is noted that the Council?s viability appraisal reports that development at the Waterfront is unviable and so its ability to contribute to the Western Link is, at best, in doubt. The Council previously settled on a strategy of developer contributions as part of its plan to deliver the Western Link and identified this as an appropriate means by which this would be achieved having considered other options. The Council is now closing off a critical funding stream in no longer proposing the allocation of Port Warrington and SWUE. In doing so, it has failed to recognise this particular benefit of these sites ? in having a direct relationship with the Western Link and therefore justified in making a contribution to it ? in the appraisal of development options and its conclusions regarding the merits of these site options relative to others. That represents a clear deficiency in the PSLP evidence base which does not provide a justified basis to underpin the options selected as a result. In short the selected option is unsound on this basis.
Peel supports the strategy of focusing growth on the main settlement of Warrington and extensions to it. Peel also supports the Council?s position that exceptional circumstances exist to justify the release of land from the Green Belt. The Council has sought to maximise the use of land outside of the Green Belt, as first priority, and thus exceptional circumstances are presented to warrant a Green Belt boundary review in order that the Borough?s full plan period housing and employment needs can be met.