Consultation on the 2019 Plan was inadequate and the Council should not rely on responding to that consultation as the starting point for the new Plan. The Plan should have been based on a new round of early involvement consultation and needed to be on a broader more accessible and inclusive basis as required by Government Guidance. The council states that ?due to Covid 19 restrictions? they ?were unable to meet the commitments of the SCI? whilst some mitigations were put in place they were wholly inadequate for meaningful community engagement to inform The Plan, that is they relied heavily on electronic communication and ?web? presence particularly unsuitable for the demographic of specific areas addressed by the plan. The council have therefore failed to ?front load? the planning process as required by Government Guidance.

The Objective Assessment of Needs, that is the number of new dwellings required is weak, it contains widely varying estimates (for example job creation estimates ranging from 490 to 874 pa). Where the data varies arbitrary mid point estimates have been used along with many assumed values. So whilst the methodology no doubt follows Government guidelines the input data and assumptions are far from justified and not based on proportionate evidence. Furthermore it does not consider alternatives to derive sensitivity data or error margins. As a result the Objective Assessment of Needs is not justified and as this forms the primary input to The Plan. Further, its fails to take full account of the town?s unique spatial position given the constraints of the surrounding motorways and linear restrictions of the Mersey, Bridgewater Canal and Manchester Ship Canal with their limited crossings.

From the plan and supporting evidence it is clear that infrastructure improvements are not guaranteed, merely a wish list of improvements. Many remain un-costed in the supporting documentation and there is little to justify cost estimates where they do exist. In many cases funding is not identified and many have no funding allocation at all. Most rely on ?developer funding? and will be a condition of detailed planning permission being granted to developers ? however this is not a guarantee, developers will negotiate to the lowest figure possible to be set against a poorly estimated cost. It is highly unlikely that adequate funding will be found for all these infrastructure improvements whilst at the same time stating they are ?essential? and ?will? happen is misleading.

The transport plan for the South East Warrington Urban Extension Draft Local Plan shows, largely unfunded, improvements to the roads infrastructure around Appleton and its environs. without improvements to Stockton Heath and the pinch points created by the Manchester Ship Canal they are largely pointless. The traffic flow through Stockton Heath (and Upper Stretton from the other direction) is already unacceptable with heavily polluting delays at many times of the day. The new employment area will increase the flows of traffic from, for example, Latchford, Wilderspool and other new developments North of Stockton Heath. Without planned traffic relief across the Mersey plain and Ship Canal, traffic will not even reach the improved junctions. The most likely use of the new employment area will be logistics and from that point of view its position seems ideal and will aide the movement of HGV?s to an improved motorway junction, however employees are likely to come from the town to the North and West i.e. across the Mersey, Ship Canal and Bridgewater Canal through the newly built South East Urban Extension which in itself will add significantly to traffic (also generally moving South and Eastward to the motorway junctions in the morning and vice versa in the evening). Furthermore the failure to improve routes from the South to North is contrary to WBC?s stated aim of ?making Warrington town centre more affluent and vibrant?. It is also to be regretted that the roads infrastructure development is not scheduled until 2038 in some cases. Which, even if successful means 15 years of congestion and pollution of the area. Other fanciful plans such as a rapid/mass transit corridor, or large-scale modal shifts are frankly laughable as is their delivery in the period of The Plan, let alone fundable

Social infrastructure depends on developer funding and where it is defined in The Infrastructure Plan it is ill defined, not costed and will not be available for the majority of the plan period (if indeed any of it). Primary healthcare and community leisure facilities are already overwhelmed in the area of The Plan. The phasing and uncertainty surrounding these facilities will place an intolerable burden on existing facilities until new facilities can come on stream (say 10 years), in which time, without over-dramatising, will put the health and indeed lives of existing residents at risk during that time. The Plan recognises the need for additional waste and recycling centre capacity south of the Manchester Ship Canal but does not identify any specific location or area for such a facility, again as with other infrastructure any such facility will require developer funding and will only be available after the majority of other development has taken place.

The case for the use of green belt land for housing (notably at Thelwell Hays) is not convincing and relates not to the ultimate need for its use but for the releasing of developer funding and meeting the largely arbitrary requirement for development in the early years of The Plan. The number of houses to be built on green belt land is comparatively small, consequently it is well within the error band of the Objective Assessment of Need, but because it is phased first (to release funding and meet the arbitrary early years target) it will be lost whether or not that need materialises. As per Messrs Johnson and Gove?s recent comments Government does not support the use of green belt unless absolutely necessary. There is little evidence in the plan that viable alternatives to its use have been explored. The use of green belt land should be a last resort both in planning and delivery. There is little evidence of either in The Plan.

The Plan shows a relative increase in the amount of accessible green amenity space. This is disingenuous and misleading, whilst the absolute area of amenity green space might increase, simple assumptions based on house numbers shows the per capita amount of amenity green space is reduced. The existing green space, such as The Dingle, Fords Rough and Lumb Brook Valley is already badly degraded by its heavy use. Even with the modest improvements proposed this increased usage will lead to further degradation and reduction in its value as amenity green space or protecting biodiversity. Anybody looking at these existing areas will see extensive erosion and an almost complete lack of understory contributing to flood risk and reducing the value of this amenity green space to resident?s well-being. The basic tenant of the draft plan should be to provide at least the current level if not more per capita green space than currently exists.

The green spaces, whether amenity or green belt, are insufficiently connected. Along with the severe degradation of existing spaces, which can only increase under the draft plan, this will lead to reduction in biodiversity and wildlife. The green space that does remain in the plan needs to be increased, and to be reconfigured to create more integrated wildlife corridors in line with current best practise. The significant green spaces for example Millennium Green, Lumb Brook and The Dingle need linking together and to the remaining green belt, agricultural land and woodland by green corridors, of sufficient width to prevent isolation of wildlife populations.

Firstly the phasing of early build being on green belt land is a commercial decision, it aims to release developer funding The Plan contains insufficient evidence that alternatives have been considered to meet the early years? target (which in itself is unjustified). The Objective Assessment of Needs exceeds the expected natural population growth, meaning the total number of dwellings in the plan may not be built. It is irresponsible in the extreme to sacrifice the long-term amenity of the green belt for short-term commercial gain. In line with recent government statements the use of green belt land should be a last resort and not considered until all brownfield sites have been utilised. The phasing of the infrastructure ?required? by The Plan roads, community hubs and medical centre is unsupportable. Not withstanding the lack of confidence that these improvements will ever be delivered even as planned they subject current and future residents to lack of critical infrastructure for many years. Few, if any, of the infrastructure projects required appear to be a condition to be met before building can commence. As a minimum the funding of these infrastructure projects should be a pre-condition to any building commencing, preferably construction of the infrastructure should be completed in advance of building commencing.