Respondent name
Paul O'Shea (Hollins Strategic Land)
Responses
Respondent Type
Landowner/developer
Policy Name/Part of plan
Whole Plan
Legally Compliant
No
Compliant with the Duty to Co-operate
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

The revised SVLP 2021 fails to comply with the DtC on the grounds that no assessment or understanding has been presented which deals with the likely imbalances of jobs and homes within the borough as a result of the Council?s strategic economic growth plans and delivery of housing only to meet demographic need. The SVLP 2021 is therefore not legally compliant.

Modification if applicable

Uplift housing number from the minimum and reinstate the Warrington Garden Suburb allocation.

Summary of comments

The revised SVLP 2021 fails to comply with the DtC on the grounds that no assessment or understanding has been presented which deals with the likely imbalances of jobs and homes within the borough as a result of the Council?s strategic economic growth plans and delivery of housing only to meet demographic need. The SVLP 2021 is therefore not legally compliant.

Respondent Type
Landowner/developer
Policy Name/Part of plan
Vision
Summary of comments

The strategic planning policies, as drafted, do not reflect the Council?s vision for Warrington 2038 and beyond. The proposed strategy is at complete odds with Warrington?s stated long term growth objectives. Strategic policies are not positively prepared and housing growth is supressed to meet only demographic needs.

Respondent Type
Landowner/developer
Policy Name/Part of plan
W1
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

The proposed strategic policies on housing do not translate to ensure sufficient homes are delivered to support its economic growth plans. The evidence illustrates that housing will be suppressed in future years as it is forecast on basic demographic need alone. The evidence on need fails to address acute affordable housing shortfalls, market signals and more fundamentally it completely ignores the economic growth strategy proposed. The Local Plan is therefore not sound.

Summary of comments

The proposed strategic policies on housing do not translate to ensure sufficient homes are delivered to support its economic growth plans. The evidence illustrates that housing will be suppressed in future years as it is forecast on basic demographic need alone. The evidence on need fails to address acute affordable housing shortfalls, market signals and more fundamentally it completely ignores the economic growth strategy proposed. The local plan is therefore not considered to be sound.

Respondent Type
Landowner/developer
Policy Name/Part of plan
DEV1
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Plan allows for baseline housing growth only based on demographic housing need alone.

Modification if applicable

The housing requirement be uplifted to at least 943dpa to meet affordable needs, address market signals and align with economic growth objectives. Warrington Garden Suburb allocation should be reinstated. Delete settlement allocations along with Fiddlers Ferry and Thelwall Heys housing allocations.

Summary of comments

The proposed approach to proceed with a high economic growth agenda is welcomed but planning for the baseline housing growth to meet minimum demographic need is a serious error of planning judgement on the Council?s behalf. Not only does it disregard national planning policy objectives to boost the supply of new homes but to continue such a planning strategy will no doubt lead to imbalances between large scale significant employment growth and new homes resulting in exacerbated house prices, unsustainable travel patterns and large scale in-commuting. Planning for the absolute minimum based on demographic housing need alone with no consideration given to market signals, affordability let alone the increase in job provision over and beyond baseline increase associated with the job forecast set out in the EDNA (2021) is flawed and unsound. In additional the Council's assumptions on delivery from urban capacity sites is overly optimistic and the Council has therefore failed to identify enough land to meet its housing requirement. Spatial strategy and in particular level of development allocated to Fiddlers Ferry site, Thelwall Heys and the settlements is further challenged. The stepped housing requirement is not justified and is not consistent with national policy.

Respondent Type
Landowner/developer
Policy Name/Part of plan
DEV2
Modification if applicable

The housing requirement be uplifted to at least 943dpa to meet affordable needs, address market signals and align with economic growth objectives. Reinstate Warrington Garden Suburb.

Summary of comments

Affordable housing need will not be met as a result of the proposed housing requirement. This policy is therefore not effective, justified nor consistent with national policy.

Respondent Type
Landowner/developer
Policy Name/Part of plan
DEV4
Summary of comments

Support for the Council's ambitious economic plans however housing growth is not aligned with this. The HNA 2021 has not assessed housing need based on historic take up rates and instead uses unrelaiable labour demand forecast.

Respondent Type
Landowner/developer
Policy Name/Part of plan
LHNA
Evidence Base

LHNA

Summary of comments

Support for the Council's ambitious economic plans however housing growth is not aligned with this. The HNA 2021 has not assessed housing need based on historic take up rates and instead uses unrelaiable labour demand forecast.

Respondent Type
Landowner/developer
Policy Name/Part of plan
W2
Modification if applicable

Focus Green Belt release at South East Warrington and reinstate the Warrington Garden Suburb.

Summary of comments

Support the Council?s objective to ensure Warrington?s revised Green Belt boundaries maintain the permanence of the Green Belt in the long term. However, we disagree with the Council?s identified areas of land to be removed from the Green Belt and the new defined boundaries on the grounds that the approach is unsound. Tehre are no exceptional circumstances to justify local level site allocations in the outlying settlements. Similarly Fiddlers Ferry and Thelwall Heys allocations are not justified. The SEWUE is not effective and should be extended to reinstate the full former Garden Suburb.

Respondent Type
Landowner/developer
Policy Name/Part of plan
W4
Modification if applicable

Reinstate the Garden Suburb allocation which would allow the delivery of greater transport infrastructure including mass transit package. Also amend Policy INF1 to refer to A50 link and mass transit package. Amend INF2 to refer to the same.

Summary of comments

Object to transport policies under objective W4. The spatial strategy to deliver new homes will exacerbate dependency on the private car and will further impede the delivery of critical transport infrastructure to encourage shifts in travel behaviours.

Respondent Type
Landowner/developer
Policy Name/Part of plan
MD2
Modification if applicable

Reinstate the Garden Suburb allocation to increase capacity of the SEWUE.

Summary of comments

Whilst the location of the allocation is supported in principle, the boundaries are not justified by the evidence base. In terms of capacity of the sites to deliver 4,200, there is no robust evidence to support this claim. The eastern boundary of the site is not durable. The allocation would therefore fail to deliver the homes required without the need to review Green Belt boundaries within the plan period and beyond. The allocation fails to meet wider policy objectives such as those contained within the LTP4 .

Respondent Type
Landowner/developer
Policy Name/Part of plan
MD3
Modification if applicable

Amend the Fiddlers Ferry allocation to focus on the brownfield part of the site for employment uses only.

Summary of comments

The Fiddlers Ferry allocation is not suitable for the development of new homes. It will narrow the Green Belt gap between Warrington and Widnes, infratstructure needs have not been fully considered, the southern part of the site is susceptible to flooding and the site is sensitive in terms of ecology.

Respondent Type
Landowner/developer
Policy Name/Part of plan
MD5
Modification if applicable

Reinstate the Garden Suburb allocation.

Summary of comments

Heritage and ecology constraints mean the allocation is not justified. The benefits of the allocation do not outweigh the hard caused by removing this land from the Green Belt. The allocation is not justified by the evidence base (namely the SA which does not assess the site against the Garden Suburb option).

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS1
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS2
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS3
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS4
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS5
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
OS6
Sound
No
Why you consider the Draft Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate

Settlement allocations are unsound and unjustified. The benefits of Green Belt release do not outweigh the harm.

Modification if applicable

Amend strategy to include a revised policy to allow for land to be released at the outlying settlements based on housing need. Reinstate Garden Suburb allocation.

Summary of comments

There is no evidence to support the specific allocations at the Outlying Settlements. There are no exceptional circumstances provided to justify the need for the allocations at these settlement or scale of land release from the Green Belt.

Respondent Type
Landowner/developer
Policy Name/Part of plan
M1
Summary of comments

The proposed policy fails to include flexibility in the plan and provides no contingencies if sites fail to deliver in line with the trajectory. There is a need to identify safeguarded land in order to ensure the Council has a contingency option to meets it housing obligations over the plan period.