The consultation period was too short. The 6 week period of consultation is generally taken to be the minimum acceptable period by the Government. This updated version makes significant changes to the previous version. It is almost impossible for the ordinary working families who are affected by the plans to review the 1,000s of pages of evidence in such a short time.

The National Planning Policy Framework (NPPF) 2019, paragraph 20(d) makes clear that conservation and enhancement of landscapes should be a strategic policy. The proposed local plan, dominated by a growth aspiration, is inconsistent with the preservation of landscape character. The release of a significant amount of Green Belt will destroy the village, open countryside and agricultural character of south Warrington.

Based on the revised housing growth requirements of 816 dpa, the amount of Green Belt land required is calculated to be 4,372 homes. Of these 1,469 homes are a flexibility allowance above the need identified in the LHNA. The underlying shortfall is therefore 2,903 homes. This is approximately 3 ? years at the end of the 17 year planning horizon. Plans should be reviewed at least every 5 years so there are at least two more Local Plan reviews before Green Belt needs to be released for housing growth. When more realistic housing completion rates are used the need for any Green Belt release moves beyond the planning horizon. The Council?s estimates are based on a housing need of 816 dpa, which is significantly above the historic completion rate of 573 dpa. The Council estimates that the Urban Capacity is 11,875. This can therefore, accommodate over 20 years of housing growth at the historic rate.

The average employment land take-up over the past 10 years is 4.19ha pa. If this rate were sustained over the plan period then the total requirement would only be 71.3 ha. Therefore, even using the mid-range estimate as suggested would allow for significant growth above the historic level. The pandemic response has resulted in significant changes to working and shopping patterns. Significant numbers of people now work from home or in a hybrid pattern. This means that significantly less office space will be needed in the future. Furthermore, the pandemic has accelerated the shift to online retailing. A number of major retailers in the town have already closed (e.g.. Marks and Spencer and Debenhams). This trend is likely to continue. Vacated retail space can be repurposed for other employment
uses. It can therefore be concluded that there is no case to release Green Belt for employment land.

Overall the Sustainability Appraisal shows that there are likely significant adverse effects on Natural Resources and Landscape, as well as negative effects on Health & Wellbeing; Accessibility; Historic Environment; Biodiversity and Geodiversity; Climate change and Resource use (section 9.14 of the sustainability appraisal report). The appraisal does not show the likely significant effects of a range of lower growth scenarios. All scenarios considered involve release of Green Belt.