The strategic policies and specific allocations which seek to deliver the vision do not fulfil these aspirations. The omission of the Port Warrington allocation, prevents the ability of the Plan to capitalise on an existing fixed infrastructure asset on the Manchester Ship Canal to deliver much needed development to meet Port needs. Taking advantage of the infrastructure which Port Warrington offers would not only deliver significant economic benefits to Warrington and the North West but provides a significant opportunity to introduce a new piece of multi-modal port infrastructure enabling the Port further decarbonise its freight flows by reducing the volume of goods leaving and arriving at the port via road. It is noted that the draft Plan?s vision and objectives remains largely the same of the previous version published in March 2019. As such they were predicated It is therefore difficult to understand how the spatial strategy and subsequent allocation align with these objectives given that that the draft Plan has been altered so significantly.

Peel consider that the demand for employment land is high and this will be sustained over the Plan Period. As such Peel consider that that the Council has not allocated sufficient employment land. This is further compounded by the Council reducing the buffer in employment land supply from 5 to 3 years. The Council's proposal to address need through two large strategic locations poses an inherent risk, particularly given the Council acknowledges both the sites have constraints to development. In this regard it must be accepted that there is a risk that the timing of development on each will not adequately align with needs. It is considered that this poses an unnecessary risk for which the Plan offers no potential land alternatives or mitigation outside of a stated commitment to undertake a review of Warrington?s employment land needs before the end of the plan period. There is no guarantee that such an approach will be adequately responsive. Not meeting this need in a sufficient flexible manner could threaten Warrington?s status as a key driver of the economy as existing development land is used up, with potential development and investment being lost to other regions of the UK and potentially overseas. As a result, Peel consider the need for more land allocated for employment purposes to ensure a sufficient, adequate and choice of supply is maintained throughout the Plan period. This inevitably will require further land release from the Green Belt. However as current drafted, the draft Plan does not provide any sufficient flexibility. Nor does it make provision for safeguarding. As such, it is considered highly likely that the Green Belt will come under development pressure through the Plan period and Green Belt boundaries will not endure. This draft Plan is therefore in clear conflict with the NPPF.

Peel consider that the demand for employment land is high and this will be sustained over the Plan Period. As such Peel consider that that the Council has not allocated sufficient employment land. This is further compounded by the Council reducing the buffer in employment land supply from 5 to 3 years. The Council's proposal to address need through two large strategic locations poses an inherent risk, particularly given the Council acknowledges both the sites have constraints to development. In this regard it must be accepted that there is a risk that the timing of development on each will not adequately align with needs. It is considered that this poses an unnecessary risk for which the Plan offers no potential land alternatives or mitigation outside of a stated commitment to undertake a review of Warrington?s employment land needs before the end of the plan period. There is no guarantee that such an approach will be adequately responsive. Not meeting this need in a sufficient flexible manner could threaten Warrington?s status as a key driver of the economy as existing development land is used up, with potential development and investment being lost to other regions of the UK and potentially overseas. As a result, Peel consider the need for more land allocated for employment purposes to ensure a sufficient, adequate and choice of supply is maintained throughout the Plan period. This inevitably will require further land release from the Green Belt. However as current drafted, the draft Plan does not provide any sufficient flexibility. Nor does it make provision for safeguarding. As such, it is considered highly likely that the Green Belt will come under development pressure through the Plan period and Green Belt boundaries will not endure. This draft Plan is therefore in clear conflict with the NPPF.

Paragraph 106 of the NPPF requires planning policies should provide for any large scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The associated footnote confirms that examples of such facilities include ports and that policies for large scale facilities should, where necessary, be developed in collaboration between strategic policy-making authorities and other relevant bodies (such as the Port developer/operator). There are also other aspect of national planning policy and Planning Practice Guidance which require policy makers to clearly take into account the needs to specific and/or specialist sectors. Peel have provided evidence to demonstrate that there is clear market demand for the type of facilities which are proposed at the expanded Port Warrington (and WCP) in order to meet the specific needs of the Port of Liverpool and Peel Ports. It is required in order for anticipated port growth, activity and demand is not constrained and economic growth stymied. There are clearly no alternatives in meeting this demand elsewhere, either regionally or locally. The proposed allocations in the draft Plan seek to meet generic B8 needs at a strategic/local level. They do not constitute a reasonable alternative to landing, handling and processing cargo at Port Warrington and its associated WCP. The draft Plan therefore fails to take advantage of existing fixed port infrastructure in the borough and is absent in respect of meeting an clear identified need for the port network to expand to accommodate identified growth in port freight demand. This is a clearly inconsistent with national planning policy and is unsound. Moreover, the significant locational advantages and its infrastructure which Port Warrington offers, notably its potential to take advantage of its multi-modal transport options, provides a significant opportunity to introduce a new piece of multi-modal port infrastructure in the centre of the north west with large population centres in close proximity. Its rail connection enables the Port further decarbonise its freight flows by reducing the volume of goods leaving and arriving at the port via road. This ability cannot be achieved anywhere else in Warrington, including the proposed allocations at Fiddlers Ferry and South Warrington.

Paragraph 106 of the NPPF requires planning policies should provide for any large scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The associated footnote confirms that examples of such facilities include ports and that policies for large scale facilities should, where necessary, be developed in collaboration between strategic policy-making authorities and other relevant bodies (such as the Port developer/operator). There are also other aspect of national planning policy and Planning Practice Guidance which require policy makers to clearly take into account the needs to specific and/or specialist sectors. Peel have provided evidence to demonstrate that there is clear market demand for the type of facilities which are proposed at the expanded Port Warrington (and WCP) in order to meet the specific needs of the Port of Liverpool and Peel Ports. It is required in order for anticipated port growth, activity and demand is not constrained and economic growth stymied. There are clearly no alternatives in meeting this demand elsewhere, either regionally or locally. The proposed allocations in the draft Plan seek to meet generic B8 needs at a strategic/local level. They do not constitute a reasonable alternative to landing, handling and processing cargo at Port Warrington and its associated WCP. The draft Plan therefore fails to take advantage of existing fixed port infrastructure in the borough and is absent in respect of meeting an clear identified need for the port network to expand to accommodate identified growth in port freight demand. This is a clearly inconsistent with national planning policy and is unsound. Moreover, the significant locational advantages and its infrastructure which Port Warrington offers, notably its potential to take advantage of its multi-modal transport options, provides a significant opportunity to introduce a new piece of multi-modal port infrastructure in the centre of the north west with large population centres in close proximity. Its rail connection enables the Port further decarbonise its freight flows by reducing the volume of goods leaving and arriving at the port via road. This ability cannot be achieved anywhere else in Warrington, including the proposed allocations at Fiddlers Ferry and South Warrington.

Paragraph 106 of the NPPF requires planning policies should provide for any large scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The associated footnote confirms that examples of such facilities include ports and that policies for large scale facilities should, where necessary, be developed in collaboration between strategic policy-making authorities and other relevant bodies (such as the Port developer/operator). There are also other aspect of national planning policy and Planning Practice Guidance which require policy makers to clearly take into account the needs to specific and/or specialist sectors.

Paragraph 106 of the NPPF requires planning policies should provide for any large scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The associated footnote confirms that examples of such facilities include ports and that policies for large scale facilities should, where necessary, be developed in collaboration between strategic policy-making authorities and other relevant bodies (such as the Port developer/operator). There are also other aspect of national planning policy and Planning Practice Guidance which require policy makers to clearly take into account the needs to specific and/or specialist sectors. The options assessment process has overstated the ecological impacts of the loss of part of Moore Nature Reserve and the potential impact on the Western Link. The unique and fixed location of Port Warrington and its necessary expansion means that ecological impacts cannot be avoided by locating the development elsewhere. Peel have provided evidence to demonstrate that this impact can be mitigated and at least a 10% net gain in biodiversity be achieved. The rebuttal evidence provided by Peel conforms that the Council?s conclusions that both Port Warrington and WCP would have adverse impact on WWL are not justified by detailed evidence and are unfounded. As has been previously confirmed by the Council via the previous version of the draft Plan, the proposals are both achievable and deliverable. Further, the options assessment does not take into account the ability of Port Warrington and WBC to make a contribution to the delivery of the Western Link.

Paragraph 106 of the NPPF requires planning policies should provide for any large scale transport facilities that need to be located in the area, and the infrastructure and wider development required to support their operation, expansion and contribution to the wider economy. The associated footnote confirms that examples of such facilities include ports and that policies for large scale facilities should, where necessary, be developed in collaboration between strategic policy-making authorities and other relevant bodies (such as the Port developer/operator). There are also other aspect of national planning policy and Planning Practice Guidance which require policy makers to clearly take into account the needs to specific and/or specialist sectors. The options assessment process has overstated the ecological impacts of the loss of part of Moore Nature Reserve and the potential impact on the Western Link. The unique and fixed location of Port Warrington and its necessary expansion means that ecological impacts cannot be avoided by locating the development elsewhere. Peel have provided evidence to demonstrate that this impact can be mitigated and at least a 10% net gain in biodiversity be achieved. The rebuttal evidence provided by Peel conforms that the Council?s conclusions that both Port Warrington and WCP would have adverse impact on WWL are not justified by detailed evidence and are unfounded. As has been previously confirmed by the Council via the previous version of the draft Plan, the proposals are both achievable and deliverable. Further, the options assessment does not take into account the ability of Port Warrington and WBC to make a contribution to the delivery of the Western Link.

Taken together and full recognition of the impacts of the proposals including on the Green Belt, the following comprise compelling exceptional circumstances: The unique and strategic economic opportunity presented at Port Warrington to facilitate the growth and regeneration of Warrington and the wider region; The drivers of growth derived from increased port activity, including that arising from Liverpool2 and the resultant demand in further port development land to serve this demand; The significant economic benefits that the expansion of Port Warrington and the WCP would deliver over the Plan Period including job creation; The acute absence of sites capable of meeting port growth and meeting this need sustainably through multi-modal means; New employment space (WCP) uniquely positioned close to an expanded Port Warrington but also in close proximity to Warrington Town Centre offering a unique development proposition that is important to delivering a successful expansion of the Port and which can assist in meeting the quantitative and qualitative employment land requirements in the borough across the plan period; and The enhancement of a new Country Park which is to be of a scale, quality and range of activity which will result in the delivery of one of the largest country recreational and ecological parks in the North West and of sub-regional importance alongside the long management of the retained Moore Nature Reserve. These are very weighty considerations which in combination, outweigh and justify the identified impact on the purposes of Green Belt and other identified harm arising from the proposed release of land for development necessary to achieve the optimal expansion of Port Warrington along with the WCP. It is therefore considered that the amendments to the Green Belt are justified and able to ensure that an appropriate balance is struck between sustainable economic growth whilst safeguarding its natural and built environment. Exceptional circumstances are proven.

Peel consider the proposed approach to planning for future development needs is ineffective, unjustified and unsound. The previous version the Plan clearly acknowledged that the prospect of Fiddlers Ferry becoming available for redevelopment would assist in meeting future longer term employment needs such to the extent that safeguarding additional land for employment beyond the Plan period was not required. However, the current draft Plan undertakes no considered assessment of longer term needs and makes no provision whatsoever of the need for safeguarded land for employment purposes. There is no justification contained within the Plan or its evidence base which explains the approach which has been adopted. It is quite clear that needs for employment development will continue beyond the Plan period at least at the current rates and Green Belt boundaries will come under development pressure during the Plan period. For the Plan to effectively make no provision to meet these needs is unjustified. It makes it inevitable that Green Belt boundaries will need to be reviewed at the end of the Plan period if not before.