The current proposed submission version includes a 10% uplift amounting to 1469 additional houses. Given the reported strong demand by developers for sites and the almost certainty that green belt sites will be developed due to their ownership by the Homes and Communities Agency, this is excessive. Warrington has never delivered the level of housing growth proposed in this plan. Over the last 30 years the build rate has averaged 732 per year and in the last decade only around 550 per year. The EDNA update 2021 persists in recommending the most optimistic ?policy-on? approach to employment land estimates. This leads to additional green belt release which WBC are not obliged under the NPPF to provide and which are not supported by Warrington residents. The economic growth predictions which form the basis of the plan are heavily reliant on ambitions set out in the Warrington and Cheshire LEP Strategic Economic Plan and by the Atlantic Gateway Partnership. Both are private sector organisations, heavily influenced by large property developers who, together with WBC, sit on their boards. Forecasts, such as those by Oxford Economics and Cambridge Econometrics, which predict lower employment land requirements, are systematically excluded. Conversely, forward projections which include previous employment land take up at Omega, a national scale development, are used as a basis for future employment land supply requirements. There is also significant competition from similar sites large scale B2/B8 development outside the borough. These include very large scale brownfield sites, for example at Parkside in Newton-le-Willows.

The scale of green belt release in South Warrington will inevitably lead to developers bringing sites in the green belt forward for development long before sites within the existing urban area are exhausted. This is already happening in the planning application for warehousing for Six56. A key function of green belt is to encourage urban regeneration. The scale of release proposed will have exactly the opposite effect. We believe that in preparing the Local Plan, WBC have given undue weight to the green belt assessment prepared by Arup which is fundamentally flawed.

Warrington South East Urban Extension is expected to meet a significant proportion of Warrington?s forecast housing need over the next 15 years on a single site. We believe there are serious concerns regarding the ability of WBC to fund and deliver the necessary supporting infrastructure over this period. Inevitably, this would lead to pressure from developers to deliver against the Councils stated housing need without the ability to provide the supporting infrastructure which the Council state is critical to such a large and concentrated development. Further concerns surround the ability to correctly phase the development of infrastructure to match the rate of development. A failure to do so on such a large concentrated development with the special access difficulties posed by the Bridgewater and Ship canals could have serious consequences for the ability of WBC to achieve its housing targets. We believe that a more dispersed pattern of development is likely to be more deliverable. There is insufficient detail on the delivery of infrastructure in the Council's Infrastructure Delivery and the policy requirements to deliver infrastructure are too vague. Insufficient consideration has been given to the impact on Warrington General Hospital and the south Warrington waste water treatement works.

The geography of South Warrington is unique. The northern edge of the South East Urban Extension is bounded by the Bridgewater Canal. The Manchester Ship canal runs approximately parallel to the Bridgewater Canal at a distance of less than a mile. Residents travelling from the SEUE to any other part of Warrington or workers travelling to the proposed new employment zones must cross these waterways. The ship canal is crossed by either the Cantilever Bridge (narrow and height/weight restricted) or the Latchford Swing Bridge. The only major crossing for the Bridgewater Canal is the A50 Knutsford Road Bridge at the extreme eastern edge of the development. The most direct access to the proposed development is across Stanney Lunt Bridge and Lumb Brook Road under bridge (Grade II listed). Both are narrow single track historic masonry arch bridges controlled by traffic lights, the former weight restricted and the latter weight and height restricted. They already cause significant congestion. Throughout the plan making process, WBC have consistently refused to acknowledge or investigate the effect of south Warrington?s unusual geography and the Bridgewater canal crossings in particular.

A report prepared for the residents of Stockton Lane by a planning consultant familiar with Grappenhall raises significant concerns about the Arup methodology. Several examples of flaws in the assessment are set out below: 1. The scoring methodology scores areas/parcels against each of the five green belt purposes. However two of these purposes (preserving the setting of historic towns and assisting in urban regeneration) are judged to give approximately the same result in all cases. Despite the fact that they do not help to discriminate between areas, they are given the same weighting in the overall scoring as if they did. 2. The assessments fail to recognise Grappenhall village, Appleton Thorn, Stretton and Dudlows Green as distinct settlements and therefore do not give sufficient weight to the surrounding green belt?s role in maintain their distinctive character. 3. The assessments fail to give sufficient weight to the role of green belt in restricting ribbon development in General Area 10. The Arup methodology notes that land which is restricting the growth of ribbon development should be classified as ?strong? then systematically ignores this requirement in the general area assessments (for example in GA10). 4. The reasoning as to why an area/parcel only makes a weak contribution to the green belt are inexplicable. For example: a. For GA10 the reasoning states ?The A56 and the canal form a durable northern boundary between the GA and the built up area which could prevent sprawl?. The resulting classification as ?weak? is then used as an argument to justify releasing land beyond this ?impermeable barrier? from the green belt. The same circular argument is used to justify classifying GA10 as ?weak? in the ?preventing encroachment? categories. The same argument is repeated in the individual parcel assessments on the northern boundary of GA10. We believe that GA10 and some if its parcels have been incorrectly assessed and in fact make a strong contribution to the green belt. b. NPPF para 143 requires green belt boundaries to be defined ?clearly using physical features which are readily recognisable and likely to be permanent?. It is reasonable to assume that this test should therefore be applied when assessing existing boundaries. Again, using GA10 as an example, the failure to recognise the role of the Bridgewater Canal in this regard illustrates the misleading nature of the assessments undertaken. c. The results of these assessments are in some cases baffling. An example, which was key to the decision making process for the SWUE is shown below where parcels of essentially uniform farmland between parallel roads are given classifications of moderate and strong respectively. 5. There is a systematic bias which results in land in South Warrington owned by the Homes and Communities Agency being assessed as making a weak contribution to the green belt. There is clear evidence of ?confirmation bias? in the assessment of South Warrington green belt. 6. General areas / parcels are classified as making a weak contribution to the green belt even when they are assessed as making a moderate contribution in several categories. The test for green belt release is ?very exceptional circumstances?. The proportionality method applied seeks to reduce the importance of an area/parcel and is used to reduce the importance of areas affected by the confirmation bias described above. If an area makes a moderate contribution too one of more purposes then it?s overall contribution cannot be said to be weak.