Richborough Estates object to the use of the Government?s standard method to calculate housing need. The Borough is a buoyant location for employment uses given its location in close proximity to the strategic motorway network and the Council set out at Table 6 of the WPSVLP that they have an employment land requirement of 316.26ha against an identified supply of 308.58ha. Richborough raise concerns that by adopting the SOAN figure, which is based on affordability, the Council will be unable to deliver sufficient housing to meet the employment requirement. Richborough also suggest that if the Council wants to meet its affordable housing needs, it will need to push a higher overall housing requirement than the SOAN currently calculates.

Asteer Planning has not assessed all the sites within the urban area which have been identified to deliver housing within the Plan period as part of Warrington?s UCS 2019. As has been demonstrated above, the delivery of a minimum of 1,327 dwellings in the Town Centre Masterplanning Area is overstated and is not deliverable. However we expect this number to increase because the Council has overstated the densities within the Town Centre area. On the basis that Warrington?s urban capacity is overstated and should be reduced by at least 1,327 dwellings and that there is no possibility of the Council?s neighbouring authorities meeting this need, further sustainable sites within the Green Belt are required to ensure that Warrington meets its housing requirements in full within the Plan period. Further the Council?s Housing Trajectory is hugely dependant on the delivery of sites within the Wider Urban Area. In the first five years of the plan 2,244 of the 4,071 homes (55%) are set to be delivered in the Wider Urban Area, where a number of sites have significant infrastructure and delivery challenges, including Warrington Waterfront and the Southern Gateway Area. Richborough Estates propose that additional land should be identified for Green Belt release adjacent to the outlying settlements. The most appropriate location is accessible land which adjoins existing sustainable settlements with access to existing services. Lymm is one of the largest and most sustainable settlements in the Borough with a wide range of existing facilities and services and access to the strategic highway network and therefore it is proposed that additional Green Belt land is released at Lymm to ensure that the Council can meet its housing requirements in full. The release of additional small and medium housing sites will also improve the delivery of housing in the short term and will boost the Councils 5-year housing land supply.

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.

WBC has demonstrated that in order to meet its development needs exceptional circumstances exist for Green Belt release. Richborough Estates strongly agree with WBC that exceptional circumstances exist to justify the release of Green belt land for development, in line with paragraph 140 of the Framework.

Richborough Estates have continually raised concerns in relation to the conclusions of the Green Belt Assessment (?GBA?) which appear fundamentally unjustified and inconsistent with regards to the Lymm Green Belt. Richborough Estates has significant concerns regarding the site selection process and the rejection of those sites from making a ?strong? contribution to the Green Belt, such as Land at Cherry Lane Farm. Richborough Estates own Green Belt assessment, which is provided at Appendix 2 concludes that the Cherry Lane Farm site makes a weak contribution to the Green Belt and therefore should have been considered as part of the Council?s site selection process. The Council?s overall conclusion that the site has a strong contribution to the Green Belt is flawed because it only identifies the site as making a strong contribution to 2 of the 5 purposes, with 1 purpose identified as having a moderate contribution and 2 purposes have no contribution. Even by using the Council?s own assessment, the site should have been scored as an overall moderate contribution to the Green Belt and if it had done so the site would have formed part of the Local Plan site selection process. Richborough Estates also question why an updated assessment of Green Belt sites has not been undertaken as part of the recent evidence base. The site at Cherry Lane does not feature in the updated Site Assessments and given the Council undertook a full review of the Local Plan, the site at Cherry Lane should have re-assessed as part of that process.

Approximately 50% of the site at Pool Lane remains in Flood Zone 2 and 3. Richborough Estates consider that the sequential assessment has not been appropriately applied because there are reasonably available sites appropriate for housing development in areas with a lower risk of flooding, such as Cherry Lane Farm, which sites entirely within Flood Zone 1. As defined by the Framework (paragraph 162), the aim of the sequential test is to steer new development to areas with the lowest risk of flooding. Development should not be allocated or permitted if there are reasonably available sites appropriate for the proposed development in areas with a lower risk of flooding. The Council has prioritised a site partly within the floodplain over a site they perceive to have some Green Belt merit. Such an approach of significantly elevating a subjective Green Belt judgement over a technically assessment risk (potentially to human health) would appear perverse.

Richborough Estates Green Belt Assessment concludes that the site has an overall weak contribution to the Green Belt which further promotes the site as a suitable and appropriate site for Green Belt release and housing allocation. In light of the above, the site selection process followed by the Council is not sound because it is not justified and has not taken into account reasonable alternatives. The site is suitable, available and achievable and can deliver residential development within the first five years of the Plan period. It has 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. Lymm is one of the largest and most sustainable settlements in the Borough with a wide range of existing facilities and services and access to the strategic highway network .The site at Cherry Lane Farm is sustainably located in close proximity to a wide variety of services and facilities which are within a short walking and cycling distance of the site and can therefore be considered an appropriate location for residential development in accordance with the Framework. This approach is supported in a written opinion prepared by Giles Cannock QC which regards Lymm as one of the most sustainable settlements
which can accommodate future development in the Green Belt.

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.