General concerns regarding external influences (e.g Brexit) on the plan, uncertainty over key national infrastructure affecting Warrington (namely HS2 and Northern Powerhouse Rail), the impact of emerging national strategies which have not been taken into account, changes to the planning system, climate change and changes in working and social practices post Covid. As a result the plan cannot be considered sound.

There is no justification for predicted levels of growth which are central to the spatial expression of the plan. There is no sound or logical connection between aspirational growth and the spatial plan. The Plan takes no account of wider issues of climate change or the impact of loosing wide areas of currently undeveloped land to development. There is no need for the scale of Green Belt release. Development is South Warrington is not sustainable and the plan should be directing development elsewhere to protect it from development. The character and distinctiveness on parts of south Warrington are unduly affected - SEWUE envelops Stretton, Appleton Thorn and encroaches on Grappenhall Village and development proposed in Lymm extends the established limits of the settlement. Major allocation cannot be delivered in the manner presented in the plan, the impact of site allocations is incomplete, allocated sites do not give appropriate weight to key planning material considerations.

The development needs resulting from the presumed levels of growth does not take account of development activity and opportunity in neighbouring authorities. There is consequently no justified need for the level of housing or employment development anticipated by
the plan. Ambitious employment growth based almost entirely on expansion of logistics sector. Assumed levels of household growth are unrealistic and do not represent historic trends or ONS population growth. Use of 2014 household growth rates distorts scale of
growth since 2014. In the case of Warrington the later 2018 household growth rates are more closely aligned to trends. 2018 figures would provide for a housing supply target of 458 dpa across the plan period instead of 816. Average completions for the period 2010-2020 are 500 dpa. Disconnect between the scale of housing proposed and relationship with employment sectors. Density figures require a sense check.

There is no need for the scale of Green Belt release proposed. Evidence base does not support the Green Belt release proposed. A more realistic assessment of housing land supply and employment land requirements reduces the case for development on greenfield Green Belt sites. Purpose and functions of Green Belt in South Warrington are evident, with no demonstrable exceptional circumstances to justify release. The plan fails to show NPPF requirement to enhance environmental quality and access to remainder of the Green Belt. The assessment of Green Belt is in places erroneous.

No justification for the scale of Green Belt release proposed. Proposed infrastructure does not deal with existing pressures or issues of congestion. Concern over the ability to deliver truly affordable housing. There is no clear provision for the compensatory improvement to the environmental quality and accessibility of land remaining in the Green Belt [NPPF para 142]. There is no need for development which will result in an unacceptable level of harm to air quality and the environment. There is no need for development which will destroy the character and distinctiveness of Warrington and its constituent settlements. No clarity on how significant infrastructure would be delivered - funding methodologies are flawed and unreliable and are based on returns from development, including development beyond the plan period. Infrastructure is therefore considered undeliverable. No detail on infrastructure required to cross various watercourses. This allocation contradicts policy TC1 and proposed enhancements to the Town Centre. Increases problems with air quality, poses issues relating to the environment and flood risk, development proposed in areas affected by noise, no assessment of development on hydrology, no consideration for loss of land being developed on health and well being. Assessment of ecological impacts lacking. Development envelops Stretton, Appleton Thorn and encroaches on Grappenhall Village. Heavy dependence on cars and general disregard for climate change agenda. Some areas proposed for Green Belt release perform strongly in the Green Belt assessment whilst others performing less strongly are to be retained in Green Belt. Limited details on new road infrastructure proposed such as the Cat and Lion improvements. There are no details of the extent and form of the key elements of infrastructure including the rationale behind gypsy and traveller accommodation and community waste recycling provision.

This site is not suitable for residential development and was rejected as a safeguarded site in a previous plan review prior to the adoption of the UDP. The Inspector concluded that the site should remain in the Green Belt. The SWP feel this position has not changed and cannot be undermined. The allocation lacks detail would result in encroachment and sprawl, contains Grade 2 and 3 agricultural land and does not fully consider the impact on heriatge assets within the site. Also concerns about site access issues and impact on surrounding roads. Flood risk not acknowledged.

The SWP contends that logistics based employment development in South Warrington is unnecessary and would fail to deliver the stated economic and social benefits claimed and necessary to justify release of land from the Green Belt. No detail in the plan as to how this site would be masterplanned. The proposed development subsumes the village of Appleton Thorn which will lose its identity. Strongly performing Green Belt parcels are included within the allocation.

Approach of the EDNA in dismissing forecasts on the basis of historic growth rates and take up of employment considered to be fundamentally flawed.

Proposed policy DEV4 of the PSV makes no specific reference to the breakdown of employment uses in either the allocation for employment development at Fiddlers Ferry or Appleton/Stretton.

The assessment of Green Belt is weak and erroneous in places. There are instances in the proposed SEWUE and SEW Employment Area where strong performing parcels are proposed for allocation while weaker performing ones are not. The GB Assessment fails to fully consider the purpose of the Green Belt in protecting the setting of historic settlements.

This allocation has also been considered in previous versions of the development plan and the value of the Green Belt in this location recognised. The evidence fails to recognise the cumulative impact of the release of both of these sites and how improvements to remaining Green Belt will be made. Concerns also about access to the site. Concerns about noise levels as the site is dominated by the Thelwall Viaduct. Also in close proximity to the motorway air quality management area.

The proposed allocation of land at Rushgreen Road is poorly presented and appears to give limited consideration to the development of adjoining land under planning permission 2017/31816. Inconsistencies between the description of the site in the August 2021 Green Belt Assessment and the land proposed for allocation in UPSVLP which does not reference the land now developed but currently in the designated Green Belt.

The claim that Omega has created in excess of 8,000 new jobs is unsupported by any evidential material. It is considered that many of the jobs are not new but relocated from elsewhere as existing business consolidated operations in single large units. There is evidence that the Covid pandemic has prompted further rationalisation particularly in those parts of the logistics sector related to hospitality.

Ref to the Town Centre SPD and Town Centre Masterplan - Neither of these documents can be afforded significant weight. The SPD does not supplement the current development plan but anticipates adoption of a later plan. The Masterplan has not been sanctioned under any formal planning process.

Ref to HS2 and Northern Powerhouse Rail intersection further enhancing the Town's connectivity is speculative with no certainty as to direct linkage to HS2 and no specific proposals for Northern Powerhouse rail. Proposals to link a east- west route to Bank Quay station would be practically difficult with wide issues in terms of impact on the Green Belt, ecology, environment.

The plan will not deliver sustainable growth. The release of Green Belt will threaten not support regeneration of inner Warrington.

The release of Green Belt for employment and residential development in South Warrington will reinforce the disconnect between residents and use of the town. Residents will continue to use ready access to the motorway network to access, town centre retail and leisure in more attractive locations.

New infrastructure will not achieve both objectives to support growth and address congestion. New infrastructure will just shift the location of congestion and will continue to place demand on the existing highway network. New infrastructure will be insufficient to meet the increased demand created by new development.

Character and distinctiveness will be considerably diminished. Historic and cultural assets will be harmed.

The tests applied to consider Green Belt release were flawed, dependent on subjective assessment and weighted to consider one green belt purpose over another. Issues identified are capable of resolution with a dispersed pattern of development able to link with existing and imminent infrastructure improvement.

The presence of the designated battleground does not sterilise the scope for development in the vicinity of Winwick. The designation should be considered on a par with designated ancient monuments, conservation areas and listed buildings which have not been considered a barrier to development elsewhere in the Borough.

The HRA recognises that development proposed will have potential unacceptable impact on ecologically significant areas as a result of issues of air quality. There would remain scope for more modest development without encroachment into designated areas.

The options assessment takes no account of the potential balancing factors which might support development in these locations including proximity to existing employment areas; access to improving infrastructure, including West Warrington Railway Station; proximity and impact on the most deprived wards in the Borough.

It is not clear how the Western Link resolves existing problems of congestion. The route will divert some traffic travelling from South Warrington to Omega around the edge of the town centre, but it will not serve to improve access to the town centre. The route will deposit traffic onto the A56 in Walton and the A57 in Sankey onto already congested parts of the network. The route would serve no obvious purpose to serve traffic generated by the proposed Garden Suburb. The business case for the route relied heavily on the scope to access land on Warrington Waterfront and Port Warrington for development, both now deleted from the plan. It is considered questionable whether the route can serve the dual purpose of serving the traffic generated by the new development and relieve existing congestion at the same time.

A stepped trajectory is welcomed but raises question over the ability to fund and deliver infrastructure prior to development taking place, where funding is dependent on developer contributions to a large extent. The ability to commit to infrastructure delivery of the scale proposed, in advance of development is questioned. Adjustment of the plan to cover the usually expected 15 year period would afford greater scope to reflect Warrington's true development needs which at the moment are overstated.

The Plan should not blindly aspire to accommodating growth at any cost. The Plan should support the appropriate management of growth so as to secure ?the right development in the right place?. The Plan does not solve the issue of current congestion and potentially makes it worse by adding traffic to different points on the network.

The policy should be framed so as limit the number of dwellings to that which can be accommodated by infrastructure provision ? numbers should be maximum rather than minimum.

There is a lack of clarity as to how 20% of development is to be delivered for older people.

Impact of recent approvals should be assessed relative to need. The plan needs to be clear in terms of location and avoid imposing this form of development in an unplanned manner.

The development of a logistics based employment use in the Garden Suburb is poorly considered. As with other development involving freight movement, development which fails to provide scope for access to rail or water should be resisted.

Although titled retail and leisure policy DEV5 makes reference to service provision through a hierarchy of centres including neighbourhood hubs, which are not defined in the plan. The Council consistently places emphasis on service provision through the establishment of neighbourhood hubs at Woolston Orford Park and Gt Sankey. No such provision is highlighted for South Warrington.

It is considered that the Plan has not properly taken account of development proposals in the adjoining areas, proposed in respective local plans and within the GMSF. The GMSF agenda to focus development on existing areas of growth in South Manchester whilst promoting regeneration in North and East Manchester is inconsistent with approach to growth advocated in the Submission Draft.

Disconnect with key areas of growth and the town centre contradicts ambitions to strengthen viability and vitality. No indication of how jobs growth and particularly higher value jobs will be created. Query likelihood HS2 and Northern Powerhouse rail connecting in Warrington Town Centre. The plan misses the opportunity to explore relocation of the outdated Warrington Hospital on to a site within the town centre connected with accessible transport facilities and the means of releasing the existing site to residential development. Misplaced ambition over sites such as the stadium quarter and the failure to note the potential for redevelopment of the site of New Town House are demonstrative of the muddled thinking of the Plan. Plans for retail in the town centre seek to buck the trend for High Street development. The inaccessibility of the town centre from the areas of South Warrington which are the subject of development proposals and the focus on employment land for logistics functions, do not support town centre regeneration.

The ability of South Warrington to accommodate the level of development proposed without significant improvement to the local highway network is accepted. A new crossing of the Manchester Ship Canal might serve this purpose. The safeguarding is limited to the immediate approach and the bridge itself but makes no provision of wider improvement merely linking to already congested and problematic parts of the network. Previous safeguarding, particularly that associated with the New Town Master plan, recognised that the crossing would need major additional infrastructure to be effective. The safeguarding tabled is ineffective and meaningless. The Western Link Road is presented as a route serving the additional development proposed in South Warrington and to relieve town centre congestion. Policy recognises and quotes national guidance in terms of the Western Link principally relating to access to development land within the Warrington Waterfront and Port Warrington ? not to these other objectives.

It is not clear as to the nature and extent of development required to facilitate such improvements and the associated works required. Improvement to the Bell House Farm Sewage Works in Walton will require development in the narrow wedge of Green Belt between Walton and Moore. The plan makes no reference to water supply which has been an issue in Warrington historically delaying progress with development. In the context of climate change and the scale of development proposed in neighbouring conurbations there should be certainty as to how a concentration of development in South Warrington can be accommodated as per the expectation of the NPPF. The plan makes no reference to the use of sustainable methods of dealing with foul or surface water.

The proposed SEWUE Garden Suburb is the largest single residential development site outside historic New Town proposals, yet it alludes to the delivery of community facilities rather than establishing a clear and coherent policy for the delivery of such accommodations. There is a considerable risk in the absence of such a policy that development will occur without the essential and necessary facilities being in place. Given the scale of development and the increase of population inherent in the plans, vague reference to the possibility of a new hospital is inadequate. Plans should provide for a more certain and clear approach led by the Council and Warrington &Co in consultation with the commissioners and providers of health care. This is especially so as the existing hospital site represents a major redevelopment opportunity within the urban area which would support a range of objectives relating to the regeneration of the town. The Council has failed to utilise powers which are available to facilitate and prompt development. Given the scale of development and the increase of population inherent in the plans, vague reference to the possibility of a new hospital is inadequate. Plans should provide for a more certain and clear approach led by the Council and Warrington &Co in consultation with the commissioners and providers of health care. This is especially so as the existing hospital site represents a major redevelopment opportunity within the urban area which would support a range of objectives relating to the regeneration of the town. The Council has failed to utilise powers which are available to facilitate and prompt development. This is an excellent example of side stepping consideration of difficult options and a tendency to revert to the less challenging approach of development of green field Green Belt sites. Whilst providing for the general provision of a neighbourhood centre in the SEWUE there is no clarity as to how a neighbourhood hub might in reality be delivered.

There are inherent weaknesses in the approach taken to secure the delivery of infrastructure. One of the principles behind the large scale allocations of SEW Employment Area and the SEWUE Suburb is the ability of larger schemes to fund and deliver larger scale infrastructure requirements. It is unclear from INF5 how planning obligations will provide a tool adequate to deliver funding for the infrastructure required. The plan needs to be more explicit in approach and contain appropriate mechanisms to ensure that piecemeal development of allocations does not circumvent the necessary contributions to infrastructure provision. The absence of a CIL charging mechanism, prepared as an integral part of the development plan is a weakness. It is considered that there is considerable scope for challenge of costings within the IDP. Under estimation of costs will result in an inability to secure funds for provision. The PDO and related viability appraisal attracted criticism in terms of the over valuation of development. Value in development is critical to the ability to secure sufficient resource to the extensive list of physical and social infrastructure required to support the development and to achieve the wider benefits expected by the Council. It is uncertain whether viability appraisals have covered the complete costs of nfrastructure provision. Costs have in any case been shared with potential development beyond the plan period. If high levels of viability are to be secured, the form, character and tenure of housing provision is likely to be affected.

The list of visitor attractions in Warrington does not reflect key assets in South Warrington, these should include: Trans-Pennine Trail, The Bridgewater Canal Corridor, Grappenhall Walled Garden, Grappenhall Village, Lymm Village and Lymm Dam. These attractions draw visitors from across the Borough and beyond. They contribute significantly to the character of the town and its constituent parts. The recognition of such locations is critical if the stated visions for Warrington are to be delivered. These sites are amongst those which have been vital to the health and wellbeing of the towns? residents during the pandemic. The function of these places needs to be recognised and protected.

The proposals conflict with the concept of protection of the towns historic environment and heritage assets. The proposed allocations give rise to conflict with the character and appearance of a number of conservation areas and other designated heritage assets. Allocations will undermine the significance of a range of heritage assets.

The plan fails to reference the decision of the Council to call an Ecological Emergency across the Borough in 2020. Policy relates entirely to the protection of existing, recognised ecological sites. It does not provide clear guidance as to how biodiversity will be enhanced just how existing sites will be protected. There is no strategy to guide such enhancement, simply generic statements. The plan proposes to remove substantial areas of south Warrington from the Green Belt. These areas are predominantly undeveloped, green field sites. They represent environmental and ecological assets which are simply handed over for development, with no clear consideration as to how if they must be developed, they become exemplar models for the enhancement of biodiversity NPPF para 174.

The designation of large scale development in South Warrington runs counter to the aspirations of this policy. Master plans are indicative of a failure to understand the context in which the developments would be delivered The Plan makes no clear provision for proposals to build on any inherent character and quality which already exists. Revisions to the NNPF in 2021 have changed the emphasis to be given to the creation of well designed places ? NPPF Section 12. Plans should set out a clear design vision ? design policies should reflect local aspirations. References in the ?Why we have taken this approach? back ground to policy to latest guidance are not reflected in the policy itself DC6 is effectively unchanged from previous versions of the PSV.

Air Quality ? provision is made within ENV8 to resist development which has an adverse impact on air quality, but in proposing the development contained within the Plan, with the consequent impact on congestion and air quality, the Council effectively undermines the purpose and objective of this policy. In order to protect the Manchester Mosses Special Area of Conservation this policy seeks to manage development which produces more than 200 HGV movements per day on the M62 ? questions the allocation of a large logistics site close to this part of the motorway network. The allocations in South Warrington place new residential development in close proximity to the AQMAs following the motorway network. The policy seeks to resist development near too busy roads or noisy businesses. The allocated sites in South Warrington are commonly adjacent to the main arterial routes crossing the Borough including motorways. Parts of the SEWUE abut existing and proposed areas of employment use and the highway network which accesses these sites. The design of the strategic link indicates that it would take HGV?s from Barleycastle to the A49 across an allocated residential area. The objectives of policy ENV8 are contradicted by the development plan allocations.

Concerns over the approach to public engagement throughout the gestation of the Local Plan. Poorly presented to the public, events poorly organised (at PDO stage). Lack of engagement with representative bodies, including parish councils. The Council has not followed its own SCI. The effectiveness of the consultation process has been weakened as a result.