General tenet of the paragraph is supported in identifying the key challenges facing the Borough with amendments as suggested.

Although the vision correctly refers to Warrington consolidating its role as one of the most important economic hubs in the UK and that it will see the development of major new employment locations, there should be more reference to improvements to the existing public transport system.

Para. 3.1.13 refers to the Warrington Local Transport Plan but no account is taken of the contents of Table 4 of the LTP which refers to the CLC line (capacity and service improvements) and Birchwood Park and Ride as this is one of a number of schemes supported by Transport for the North which can now be delivered through the Warrington Local Plan.

W1 fails to make sufficient provision to meet the employment land needs of the Borough.

W2 fails to ensure the long-term permanence of the revised green belt boundaries by failing to make sufficient provision for additional employment land.

W4 fails to give sufficient weight to the importance of providing new public transport infrastructure.

W5 is supported. It is essential to secure high-quality design.

W6 is supported. It is essential to support development that reduces carbon emissions

The Spatial Strategy as proposed in the local plan is not acceptable. It is heavily dominated by sites in the south of the Borough where infrastructure provision is poorer and the impacts of development upon the environment would be more pronounced. Development to the east of Warrington, where it can be assimilated with public transport improvements should be included in the spatial strategy.

It is not accepted that an urban extension to the east of Warrington would have significant ecological impacts as there is sufficient land available outside of any designated mossland or areas of biodiversity significance and the minerals reserves are not of such significance such that they would prevent development taking place.

Cumulatively the Spatial Strategy paragraphs fail to make sufficient provision for additional employment land at South Station Place, Birchwood. This will result in a shortfall of employment land within the Borough.

Whilst the general exceptional circumstances set out in para. 3.4.1-3.4.9 are broadly supported in terms of there being exceptional circumstances for green belt release in Warrington, there should be an additional bullet for para. 3.4.10

This policy is strongly objected to as it fails to allocate land at South Station Place, Birchwood for Employment development. The identification of only two substantial allocations for employment development is of grave concern as any issues in respect to delivery will result in a major shortfall of employment land within the plan period. As such an additional site should be allocated which can be brought forward in the early years of the plan period. DEV4 refers to a review of Warrington?s employment land supply but states elsewhere that the changes to the green belt boundary are long term and there is no requirement for safeguarded land to be provided. Indeed, there are no further changes to the green belt anticipated prior to 2050. These two
approaches are contradictory.

Part 1 of Policy refers to no further changes to the green belt prior to 2050. This is contradictory to the proposal for a review of Employment Land Requirements prior to the end of the plan period. The rigid approach to the green belt taken now will mean that there will be no opportunity to identify additional land for release from the green belt at that time. Land proposed for removal at south Warrington employment area performs a number of green belt functions and its removal would be harmful to the overall character and openness of the Warrington green belt. It is poorly related to existing settlement
boundaries and there are doubts about whether it is an appropriate parcel of land to be considered for green belt removal and whether it would be deliverable within the plan period.

Section 3 of Policy INF1 should include reference to the proposed improvements to Birchwood Station.

Although the General Safeguarding Principles set out in the Local Transport Plan and noted in Part 1 are supported, including the provision of a park and ride and improvements at Birchwood station, part 2 of Policy INF2 should include safeguarding of the proposed improvements to ensure that they are brought into fruition.

The identification of Greater Manchester Wetlands Nature Improvement Area is appropriate and reference to this is supported.

We support the need for good design to be at the core of all development proposals.

The EA has recently made substantial amendments to the online Flood Map but there remains a number of inconsistencies and it is essential that the Council works closely with the EA to ensure that site allocations and decision making are based upon accurate and up to date information.

A number of the sites allocated for green belt release and allocation for development are located within areas where there is some evidence of mineral resources being present. However, the benefits of bringing the sites forward for development clearly outweigh the presence of any such minerals.

Figure 16 does not provide an up to date and accurate portrayal of the distribution of peat within the Borough particularly to the east of the M6 corridor. Much of the peat in this area was removed during the second world war to be used as fuel.

This is supported although there may be an opportunity to extend this further to provide stronger support for net carbon zero development.

The allocation of land at Fiddler?s Ferry for Employment Uses is appropriate in principle but there are significant concerns about the deliverability, viability and timescale of the development proposed such that it would not be appropriate to rely on this site to make a tangible contribution towards employment land supply within the Borough during the plan period.

The extent of the proposed removal of land at South East Warrington and its allocation for employment development conflicts with national planning guidance for green belts. The land does not relate to any existing settlement boundary and only has a slight relationship with a small area that lies outside of the existing green belt. As such the removal of the whole site from the green belt will conflict with the purposes of green belt and be detrimental to the essential characteristics of the green belt which is its openness. The scale of the development and the extent of infrastructure required to support it also bring the viability and deliverability of the site within the plan period into question.

The site provides a unique opportunity to open up a new southern access to Birchwood railway station which would allow for station improvements, the provision of a park and ride and community facilities, and land for turnbacks for the CLC line. The provision of a link road to the station would open up the land for the provision of an employment led scheme for industrial uses and logistics, alongside a more flexible business hub. The development would also provide a small number of live work units in replacement of existing dwellings and the creation of large areas of public open space and nature conservation facilities which will result in biodiversity net gain whilst ensuring the protection and improvement of the adjacent local wildlife and other sites. A full description of the proposal and the exceptional circumstances which justify the release of this site are set out in the submitted Framework Document. Supporting reports also submitted for other technical matters, e.g. Peat, transportation, Landscape.