Bellway strongly supports the sustainable growth of Warrington. The draft Local Plan proposes to deliver 14,688 new dwellings between 2021 and 2038, which has been calculated using Central Government?s revised ?standard methodology?. Bellway are fully supportive of the standard methodology but emphasise that the methodology identifies a minimum figure. In order to meet this target, WBC will need to release Green Belt land for housing. The WLPSV has demonstrated that in order to meet its development needs, exceptional circumstances for Green Belt release exist. In addition to large strategic allocations identified in Policy DEV 1, the emerging Plan makes a number of more modest allocations, which are immediately deliverable and do not require any significant infrastructure investment to facilitate their delivery, including ?Land at Heathcroft Stud, Croft?. Bellway strongly supports the proposed Green Belt release at Croft for a minimum of 75 homes in draft Policy DEV1 at point 4b. It is necessary for the Council to ensure that a range of sites are allocated. These should include a realistic number of small and medium sized sites which are well connected to existing services and amenities and are therefore deliverable in the short term. This approach is in line with Paragraph 69 of the NPPF, which recognises that ?small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built-out relatively quickly. Local Authorities should therefore ensure their Local Plans allocate a sufficient number of small and medium sites, such as Land at Heathcroft Stud, Croft to safeguard the Borough?s five-year housing land supply.

In relation to point 2 of the Policy, whilst Bellway does deliver housing to meet everyone?s requirements, provision and extent of such should be assessed and agreed on a site-by-site basis between the Council and the developer, having regard to local needs, the Council?s latest evidence base and viability at the time of any planning application. A suitable caveat should be included within the wording of point 2. in relation to point 4 of the draft policy and the requirement for provision of self-build / custom build plots on the site, the Council should base this requirement on the evidence base. It is understood that the Council?s self-build register shows a need for self-build plots, which is very limited and does not justify provision being sought on all allocated housing sites. There is a need for the smaller housing sites such as Croft to deliver housing quickly so that the Council can demonstrate a 5-year supply because the larger strategic sites will rely on the delivery of infrastructure, which means housing delivery will be slower. It is therefore proposed that sites that are under control of major housebuilders such as Bellway are not requested to deliver self-build / custom build provision and that more appropriate sites are selected. It is therefore requested that point 4 is removed or amended so that flexibility is applied. on points 8 and 9 of the draft Policy ?Open Space and Recreation?. Whilst Bellway does not object to the principle of the requirement, Bellway will reserve the right to comment on any methodology established in relation to financial contributions for playing pitches and indoor facilities and would not support a policy requirement for playing pitches and leisure facilities; If this threatened the viability and/or deliverability of the site. in relation to point 11 (biodiversity net gain), the policy should seek to encourage biodiversity net gain to be incorporated into the overall design concept but any mandatory requirement for a net gain to be achieved via the metric calculator should be deleted (the metric calculator being only one way to calculate net gain). point 13 of the draft policy requires a scheme of compensatory improvements to the environmental quality and accessibility of land remaining in the Green Belt. The PPG states that authorities should set out policies for compensatory improvements informed by supporting evidence and opportunities could include new or enhanced green infrastructure, woodland planting, landscape and visual enhancements and new walking routes. The PPG goes on to say that there should be early engagement with all interest groups to consider matters such as the scope of works required. The Council has not set out any indication that such early engagement has taken place and there is no evidence to support its requirement for compensatory measures. There is no indication as to what such measures would consist of or what the implications may be for viability. It is unclear as to how an applicant, and the decision-maker, may interpret and respond to this policy requirement and we would suggest that this requirement is deleted or clarified.