The NPPF recommends that small and medium sized sites make an important contribution to meeting the housing requirements. There is no evidence that the Local Plan is re-using any of these land parcels and is just relying on the wholesale release of Green Belt.

It fails to meet the economic objective insofar as the plan does not ensure that sufficient land of the right type and in the right places and at the right time. It fails to meet the social objective insofar that the whole of the proposed South East Warrington Urban Extension (SEWUE) completely fails to provide the accessibility of services requirement. It fails to meet the environmental objective insofar as it will significantly increase air pollution throughout the south Warrington conurbation. It excludes any reference for the provision for indoor social, cultural and recreational facilities for the variety of indoor activities required within a balanced society. The plan fails to make effective use of land currently used in the central town areas - town centre businesses with large carparks and warehouse areas should re-utilise these areas for higher density affordable housing. The plan also fails to achieve appropriate housing densities - the estimated housing density generally throughout south Warrington is circa 15 ? 20dph and as low as 11dph in some higher priced areas.

The Green Belt Assessment defining the two parcels of land under R18/88, namely East and West, have had their assessment weighting revised from the 2019 assessment. Specifically, the East site has been upgraded to ?moderate? from ?weak?, yet it is still proposed for development.

It fails to meet the plan making objectives by not including a deliverable or sustainable plan with sufficient detail on sustainable transport solutions. In particular the SEWUE excludes any plans to improve the routes over the Bridgewater Canal or Manchester Ship Canal. The local plan does not comply with the requirement of the NPPF (Para 186) and the requirement to protect the population from increased air pollution. In fact, it specifically proposes a residential and commercial solution that will significantly increase levels of air pollution through the introduction of potentially thousands of additional cars and HGVs throughout the SEWUE area. The local plans proposal to significantly increase the housing stock in Stretton does not align with NPPF (Chapter 9) policy in protecting Stretton Village by way of conserving the local environment. The release of Green Belt is contrary and inconsistent with Defra Agricultural Policy regarding protecting the best and most versatile (BMV) agricultural land from significant, inappropriate or unsustainable development.

The Green Belt Assessments employed by the WBC consultants (ARUP) over the three maturations of the local plan, specifically applied to the area in and around the village of Stretton are flawed and inconsistent. The application of guidance rules is inconsistent and favours developers in the designation and weightings applied to certain parcels of land.

The Green Belt Assessment - Garden Suburbs Options Report produced by Arup & Partners (April 2021), shows four housing options for the area. All options except Option 2 show the Green Belt enduring permanent boundary as Stretton Road, with no development to the south of that boundary. This is consistent with many previous maps developed by the Warrington Unitary Development Authority since 1973.

The proposed allocation does not comply with the NPPF (July 2021) in releasing Green Belt parcel R18/008 West for the unethical and unjustified financial advantage of the private developer, Miller Homes. It does not provide exceptional circumstance in accordance with the principles of the NPPF and is deemed unethical.

The enabling infrastructure proposal is flawed, unworkable and presents an increased potential for traffic congestion on the A49 from the Cat and Lion signal junction to Junction 10 of the M56. It also severely restricts local traffic accessing the immediate Stretton village facilities. Furthermore, it introduces health and safety issues for the emergency services accessing local residents.

The provision of indoor facilities forms a vital role in a balanced and well-designed community infrastructure.
The Updated PSVLP 2021 clearly caters for outdoor sports and large leisure/recreational facilities, walking and cycling. However, it completely omits facilities and accommodation within the proposed SWEUE to cater specifically for indoor sporting and other community activities for young and older people, the disabled and the disadvantaged. These facilities are completely lacking as they are not included anywhere within the local plan. This non-specific exclusion is not even considered or made provision for in the policy DEV6 ?Warrington?s Quality of Place?.

The Policy refers to sustaining and supporting the health and wellbeing of local communities within the various centres but it does not include any requirement for developers to provide suitable indoor activity accommodation for activities for sports clubs and a wide range of social activities.

Support of Parts 2(d) and (e) that addresses the requirements of social or community infrastructure. However, to comply with promoting health and wellbeing, it should require developers to include the requirement to provide buildings for indoor accommodation for activities.

Although this Policy refers, to outdoor sports and recreation facilities it should not be limited to outdoor pursuits. Indoor sporting activities should be included in this policy in order to make a fuller and more comprehensive provision for all indoor community activities across the spectrum.