Generally supportive of specific allocation policy for the SEWUE.

Homes England has the ability to increase the pace of delivery and therefore the number of homes to be delivered in the plan period should be referred to as a minimum figure.

Whilst it is fully accepted and supported that the development of the SEWUE will need to provide a range of housing tenures, types and sizes including affordable homes, there is no current evidence to suggest that typologies such as custom and self-build plots or supported extra care housing are required on this specific site or in the locality. Requirement should be based upon identified need, as identified in policy DEV2. Current wording is contarty to requirements of paragraphs 16 and 35 of the NPPF.

There is a lack of any up-to-date evidence to justify this very specific requirement relating to primary schools. Whilst the principal landowners do not dispute that a development of the planned scale is likely to require new school facilities, the precise number of primary schools at any given size is inextricably linked to the timing and location of development within the allocated area and the extent to which there is any available capacity in nearby schools at that point in time. To this end, the policy should not specify the number of primary schools required or their intake. Rather, it need only refer to the need for the SEWUE to accommodate on-site primary school provision commensurate with the impact of the new development based on up-to-date evidence of need and demand.

As with primary school requirement, the secondary school requirement is too specific and should instead refer to the need for the SEWUE to provide secondary school provision either on or off site, commensurate with the impact of development based on up-to-date evidence of need and demand.

The principal landowners are supportive of the requirement for a new leisure facility incorporating health provision. The costs and requirements within the supporting IDP need to be aligned with the policy requirements.

This section of the policy and paragraph 16 refer to the SEWUE being supported by inter alia ?other community facilities?, but no information or evidence is provided as to what might be required over and above the community facilities otherwise prescribed in the policy. Unless the Council can evidence and prescribe the need for additional facilities, propose that this element of criterion e) is deleted.

There is no up to date evidence to justify a requirement for a community recycling centre being met on land within the SEWUE. Reference to its need should be deleted if no evidence for requirement.

The policy requires implementation of ?exemplary? SuDS, however, the term ?exemplary? is not expressly defined within the policy or reasoned justification or indeed elsewhere within any other policies of the plan. On this basis, it is unclear how this aspect of the policy can be effective pursuant to paragraphs 16 and 35 of the NPPF, and therefore it is proposed that this reference is removed. Notwithstanding, the principal landowners have every intention of bringing forward development which complies with SuDS principles as set out in the NPPF and will work closely with key stakeholders to define an appropriate surface water management strategy for the SEWUE once more site-specific technical work has been undertaken.

The principal landowners support the principle of preparing a Development Framework in consultation with the Council, statutory consultees and the local community in advance of planning applications being submitted. This will provide a robust and comprehensive set of guiding principles and parameters for the delivery of the SEWUE, it will determine the likely phasing of development and ensure that infrastructure comes forward in the right place and at the right time. On the basis that this will need to be agreed by the Council and subsequently act as a material consideration in determining any future applications for development, it is a powerful tool which can address many site-specific issues reflective of up-to-date evidence once it becomes available. pg. 14 3.30. Paragraphs 4 ? 6 inclusive as drafted are clear and can be considered justified and effective in accordance with paragraph 16 of the Framework.

The principal landowners accept that it is necessary to deliver a highway improvement scheme to relieve pressure at the A49 London Road/B5356 Stretton Road junction (Cat & Lion junction) early in the development of the SEWUE. Paragraph 7 of Policy MD2 requires that the funding and delivery programme be agreed, and the related construction commences prior to the commencement of any residential development, and indicates, albeit without precision, that housing completions will be limited until the highway scheme is complete and operational. The parameters of the policy mechanism for controlling development are, however, lacking in precision and justification and are potentially unnecessarily restrictive. For example, the policy could unjustifiably prevent development coming forward elsewhere on the SEWUE that would not materially impact upon the Cat & Lion junction because of physical separation and non-car travel opportunities such as walking, cycling and proximity to established public transport connections. It also fails to define the ?highway scheme? to enable an understanding of the extent of works that will be required in the context of any restriction on completions. the wording of the policy must be clear, yet sufficiently flexible. the policy?s reference to limiting the number of housing completions until the highway scheme is complete and operational should be amended to refer to any limit being placed on the occupation of dwellings; because occupation is the potential generator of additional vehicle movements on the network.

The principal landowners are not convinced of the necessity for the paragraph relating to development adjacent to the allocation boundary on the basis that other policies of the Local Plan, in combination, should be sufficient to ensure that the delivery of the Plan?s allocations are not compromised. It is also not clear what is meant by the word ?integrity? in the context of the policy, and how the Council would apply this? For the policy to be effective this reference should be removed with the sole focus being on the prevention of the adverse impact of any other development upon the delivery of the SEWUE and its associated infrastructure. Alternative wording is suggested in the appendices.

The Development Framework will define the nature and form of development across the SEWUE and identify the proposed phases of development. As confirmed by the Deliverable Proposition and ?A Deliverable Allocation? document, the principal landowners will seek to deliver a minimum of 30% affordable housing across the SEWUE, including the new national requirement for First Homes and the other requirements of draft Policy DEV2. However, the phasing of delivery will be inextricably linked to the overall phasing strategy for the allocation. On this basis, to make this aspect of the policy more precise, it would be helpful if cross-reference to the Development Framework being the mechanism to determine the approach being the appropriate tool.

The principal landowners are satisfied with the wording of these paragraphs, subject to the wording at 3.a) above being revised to be consistent with these later paragraphs and the requirements of draft Policy DEV2.

As per the comments in respect of paragraphs 3.b) and c) above, the wording of the policy ought to be less specific to reflect the absence of any evidence at this stage confirming the precise requirements for school facilities within the allocation during the plan period and beyond. Instead, these further paragraphs of the policy should refer to a requirement for ?on-site primary school provision? and ?on or off-site secondary school provision? of a scale commensurate with the impact of development

With regards the second sentence (dealing with the location of new primary schools), whilst the principle of the approach is agreed, this is a matter that will ultimately be determined as part of the Development Framework for the site. As such, if it is considered by WBC that it is right that the policy includes a reference to the siting of new schools (the view of the principal landowners is that this is unnecessary), the principal landowners propose that the wording of the policy is revised to identify that such matters will be considered and agreed during preparation of the Development Framework.

Subject to the precise requirements for the new leisure facility being identified and its provision suitably evidenced and justified in relation to mitigating the pg. 17 impacts of development at the SEWUE, the principal landowners welcome WBC?s support for this being co-located with any planned secondary school facility (also to be justified) and the ability to make best use of available land and resources in planning for sustainable development.

Confusion between number of local centres referred to in Policy DEV5 for the SEWUE and that referred to in MD2. Scale of the local centres proposed also needs to be made clear in Policy MD2. The requirement for a retail needs assessment is contrary to NPPF para 90.

The principal landowners support the requirement to achieve biodiversity net gain (BNG) across the SEWUE. However part 23 of policy MD2 is not clear as drafted - development phases rather than development parcels should be referred to in order to align with the Development Framework. In addition, the Policy needs to allow for the situation whereby not every parcel of development will be able to achieve the desired level of BNG and may be reliant upon the provision of, for example, an earlier or later phase with a greater extent of green infrastructure and opportunities for achieving the highest quality of habitat improvement or creation. support paragraph 23 including the requirement for the approval of an overarching BNG, or ecological enhancement strategy which demonstrates how BNG will be achieved across the SEWUE, to which each planning application, or phase of development, must have regard to and demonstrate compliance with.

The proposed description of the Green Belt boundary does not accurately reflect that which has been drawn on the draft Policies Map. This is not unsurprising given the overall scale of the site and the way in which the boundary has been defined with reference to existing highways, field boundaries, woodland belts, etc. Rather than seek to describe the boundary more clearly (in words), the principal landowners are of the view that the boundary should be defined only by cross pg. 19 reference to the Policies Map and therefore that this description should be removed from the policy completely.

The principle of the requirement for compensatory measures is supported by national planning policy (see paragraph 142 of the NPPF) and is one which the principal landowners support and are positively planning for in bringing forward development of the SEWUE. However the policy does not make clear whether it would preclude the use of land owned by others, for example that which is owned and managed nearby to the SEWUE by the Woodland Trust. An amendment to the wording has been suggested.

The principal landowners are supportive of the requirement for well connected cycling and walking routes but it is unclear how such links will be provided to the SEW Employment Area specifically and who will be responsible. Similarly regarding the provision of public transport links. Reference to the improved connection to A50 should be removed as would require third party land, instead reference should be made to an improved connection to Grappenhall Lane. The requirement for contribution to improvements to J10/M56 and J20/M6 needs to be evidenced. Clarity re safeguarding of mass transit routes required through the Development Framework. More clarity needed in relation to requirement for contributions to crossing over the Bridgewater canal and Ship Canal and need for this must be evidenced - this aspect of the policy is unjustified and would require third party land. Change also proposed to the way in which requirement for 'other network improvements' is dealt with.

Support for encouraging sustainable travel options but a single site wide travel plan is unlikely to be practical, suitable or deliverable. Suggest instead that an overarching travel plan is produced followed by a range of site-specific travel plans for each phase of development and alternative wording is set out accordingly.

Whilst the principal landowners support the Council?s ambitions for the Bridgewater Canal, and the opportunity that it offers as a recreational resource, the extent to which the SEWUE is expected to contribute towards this aspiration and in what manner is not made clear in the Policy and the Infrastructure Delivery Plan (IDP) is silent on the issue. Para 31 should be deleted unless there is further justification.

Part 32 should simply cross refer to Policy ENV2 to avoid unnecessary repetition. See suggested wording.

Again this could be simplified by cross reference to Policy ENV2 rather than providing the detail here. See suggested wording.

The first sentence of this paragraph is not required as this is fully addressed in draft Policy INF5. Requirements in relation to surface and foul water drainage are addressed through draft Policy ENV2. clean water strategy is also dealt with in Policy INF3. This paragraph should therefore be deleted.

Requirement for community recycling centre has not been justified and should be omitted unless up to date evidence can provide to the contrary. Even if it can be justified there is no need for the repetition here unless more detail can be provided which is relevant to MD2.

The wording of paragraph 37 is imprecise where it refers to the Urban Extension being ?as energy efficient as possible?. On the basis that such terminology is undefined, this aspect of the policy cannot be effective, and no evidence has been provided to suggest that the site allocation requirements are any different to those outlined more generally for new development pursuant to draft Policy ENV7. The principal landowners are of the view that this paragraph represents further unnecessary wording within the policy and could be readily deleted and replaced by a simple cross reference to Policy ENV7.

Paragraph 39 should be deleted as it repeats the provisions of draft Policy ENV8.

The principal landowners question the necessity for this paragraph given the guidance on heritage assets in the Framework. Furthermore, whilst the SEWUE Heritage Impact Assessment is available, it has been undertaken reflective of a point in time and clearly as development comes forward, the assessment of heritage assets will need to take account of changes in setting. Some alternative wording is proposed to better align with national guidance.

The purpose of Figure 18 is not clear. The boundaries of the SEWUE are defined on the proposals map. Figure 18 is also not conistent with the published Deliverable Proposition and therefore the landowners question the intention of its inclusion in the plan.

There are aspects of the IDP (notably in Appendices 1 and 2 of the document) that the principal landowners do not agree with. However, reflective of the fact that the IDP is a ?living document? and the relative stage of the Plan making process that has been reached, it is not considered that there is any benefit in commenting on specific aspects of the IDP at this stage when, notwithstanding those concerns, the principal landowners remain confident that the allocation is deliverable and viable as demonstrated by the supporting Local Plan viability evidence, the published Deliverable Proposition and more recently produced and ?A Deliverable Allocation? document.