Richborough estates strongly support the Council?s case for Green Belt release however raise concerns that the amount of Green Belt release proposed is understated because the Council has overstated the urban capacity. Richborough Estates raise concerns regarding the reliance on large sites and urban capacity sites which may have viability challenges and do not currently have planning permission. Richborough Estates advocates that additional small and medium sized sites, such as Hollins Green, should be allocated for housing because they are often built out relatively quickly and make an important contribution to meeting the housing requirement (paragraph 69 of the Framework), specifically the five year housing land supply. Given it is unclear whether the Council will be able to demonstrate a 5YHLS at the time of adoption, Richborough Estates reserve the right to comment on the 5YHLS position at the EiP stage.

Richborough Estates strongly supports the proposed Green Belt release at Hollins Green in order to deliver new homes, in accordance with draft Policy DEV1 (4c). The site is suitable, available and achievable and can deliver residential development (100 dwellings) within the first five years of the Plan period. It has also been demonstrated that there are a series of compelling social, economic and environmental benefits which would be secured through the development of the site for housing. These benefits would be enjoyed by both future residents of the development and existing members of the wider community.

Richborough suggest that achieving the stated densities within the town and urban areas whilst overcoming technical and viability issues and complying with the nationally prescribed space standards, Building Regulation Standard M4(2) ?Accessible and Adaptable Dwellings? and M4(3) Wheelchair User Dwellings will be challenging. Richborough suggest that the site at Hollins Green could accommodate a higher density than the 30 dph stated in Draft Policy OS3. The Development Statement enclosed at Appendix 2 demonstrates that the site at Hollins Green can accommodate a minimum of 100 dwellings at 35 dph.

Richborough Estates do not object to the principle of draft Policy DEV 2, but would like to make the following comments: i. Richborough Estates object to DEV 2 (14) which requires all dwellings to have an appropriate outdoor amenity space. The policy is entirely subjective, is not clear or precise and is not based on proportionate evidence. On this basis DEV2 (14) is not justified and should be removed from the WPSVLP in accordance with paragraph 35 of the Framework; ii. Richborough Estates generally support DEV 2 (15 and 16) which relate to accessibility standards and fully support DEV (17) which requires the standards to be subject to technical and viability assessments. iii. Richborough Estates are committed to delivering a wide range of house types the mix of which will be informed by market requirements and discussed with Officers at the planning application stage. Richborough welcome the amendments to Draft Policy DEV 2 (18) which relates to housing for older people and support the removal of the 20% requirement on all residential developments of 10 dwellings or more.

Richborough Estates support the sustainable growth of Warrington Borough and strongly support the Council?s aspirations to release land from the Green Belt in order to meet the minimum requirements of draft objective OBJ1 and draft policy DEV1. Richborough Estates strongly agree that exceptional circumstances exist for land to be released from the Green Belt, in line with paragraph 136 of the NPPF, to enable the Council to meet its minimum housing requirements in full.

Richborough Estates strongly supports the proposed removal of the Hollins Green site from the Green Belt at Draft Policy GB1 and the amendment to the Green Belt boundary shown on Figure 6 and the position of Hollins Green as an inset settlement within the hierarchy. Richborough Estates emphasise that Hollins Green is an appropriate location for housing development. The removal of the site from the Green Belt will facilitate the development of an appropriate and sustainably located site which is capable of delivering a minimum of 100 dwellings to meet the requirements of draft Policy DEV1. The release of the Hollins Green site from the Green Belt fully aligns with Objective 2 of the WPSVLP, which is to ensure Warrington?s revised Green Belt boundaries maintain the permanence of the Green Belt in the long term.

The Council?s 2018 GBA and 2021 Green Belt Report concludes that the Hollins Green site makes an overall moderate contribution to the Green Belt. Richborough Estates disagrees with this assessment and it has been demonstrated by Richborough Estates? own assessment that the site makes an overall weak contribution to the Green Belt.

Richborough Estates object to the housing trajectory figures for Fiddlers Ferry because of the timescales set out for the Local Plan adoption in the Council?s LDS and the requirement for a Development Framework to be in place before any housing is delivered, which from our experience takes 1 ? 2 years.

Draft Policy OS3 requires the site to accommodate a density of 30 dph. Richborough Estates can construct housing to an average minimum density of 35 per net developable hectare. The Illustrative Masterplan at page 36 of the Development Statement shows how this can be achieved across the site along with policy compliant public open space provision. Green Belt Compensation (13) ? Richborough Estates suggest that financial contributions could be directed towards the Rixton Clay Pits SAC, located north of Lymm, given that the site is identified in Appendix 1 of the Council?s Infrastructure Delivery Plan (2021) as having a circa ?190k funding gap. Richborough Estates also object to the inclusion of point 19, which would require any development on the site to meet a proportion of its energy needs from renewable or low carbon sources. The WPSVLP does not consider location, orientation and design as a way of reducing greenhouse gas emissions through planning for new development and is therefore inconsistent with paragraph 150 of the Framework. The WPSVLP does not explain clearly what constitutes ?suitable development? for renewable and low carbon energy as required by Paragraph 155 of the NPPF. Furthermore, the WPSVLP does not have a clause whereby new development should comply with development plan policies for decentralised energy supply unless it can be demonstrated by the applicant that this is not feasible or viable, as detailed at paragraph 157 of the Framework. it is unlikely that any site below circa 800 dwellings would be able to consider a combined heat and power (?CHP?) system and therefore such requirements should only be applied to the larger strategic sites.

Richborough Estates does not object to the principles of the draft Policy. However, Richborough Estates would not support any policy requirements which threatened the viability and/or deliverability of development and request that these policies have subject to viability clauses inserting.

Richborough Estates does not object to the principles of the draft Policy. However, Richborough Estates would not support any policy requirements which threatened the viability and/or deliverability of development and request that these policies have subject to viability clauses inserting.

Richborough Estates does not object to the principles of the draft Policy. However, Richborough Estates would not support any policy requirements which threatened the viability and/or deliverability of development and request that these policies have subject to viability clauses inserting.

Richborough Estates generally supports the policy which requires development to provide or contribute towards the provision of the infrastructure needed to support it and agrees that the Council should consider viability at the planning application stage where appropriate.

In relation to draft Policy DC5 Richborough Estates generally supports the approach of the policy. However, WBC?s Playing Pitch Assessment (PPS) and assessment of indoor/non-pitch sports facilities are currently being finalised and a developer contributions methodology is yet to be finalised to establish appropriate levels of contributions. This affects points 5 and 6 of Policy DC 5, which sets out the context for Playing Pitches and Indoor and Recreation Facilities respectively. Therefore, Richborough Estates reserves the right to comment on any methodology established in relation to financial contributions for playing pitches and indoor facilities Richborough Estates would not support a policy requirement for playing pitches and indoor sport and green infrastructure if this threatened the viability and/or deliverability of the site.

Richborough Estates has a history of delivering high quality development and therefore, generally, has no objection to the criteria set out in draft Policy DC6. However, Richborough Estates would like to make the following comments on Point 7 of the Policy. The explanatory text explains that the Council intends to produce and publish a framework for treatment of the public realm to ensure consistency throughout the Borough. Richborough Estates reserves the right to comment on this document when this is published. Richborough Estates would not support a policy requirement that threatened the viability or deliverability of development.

ENV7 as it is not consistent with paragraphs 153 and 157 of the Framework which promote layout, building orientation, massing and landscaping to minimise energy consumption. There is no clear explanation within the policy or evidence base, for the WPSVLP of what constitutes ?suitable development? for renewable and low carbon energy in accordance with paragraph 155 of the NPPF. Furthermore, there is no clause whereby new development should comply with development plan policies for decentralised energy supply unless it can be demonstrated by the applicant that this is not feasible or viable, as detailed at paragraph 157 of the Framework. Richborough Estates objects to the requirements for all strategic housing and employment allocations to maximise opportunities for the use of decentralised energy systems by making provision to enable future connectivity in terms of site layout, heating design and site wide infrastructure design, ensuring that at least 10% of their energy needs can be met from renewable or other low carbon energy and to reduce carbon emissions by 10% over Part L. This is because it is unlikely that any site below circa 800 dwellings would be able to consider a combined heat and power (?CHP?) system and therefore such requirements should only be applied to the larger strategic sites only.