Unwarranted fixation on economic growth over protection of Green Belt. This is out if step with current and future economic climate and climate change. New standard method overestimates the number of new dwellings required and urban capacity is underestimated. Although climate change is considered the measures proposed are not sufficient. Exceptional circumstances for the release of Green Belt have not been demonstrated.

The new standard method continues to use 2014 household projections which are out of date. The stated housing need in no way reflects Warrington?s need for housing in a post-Brexit and post-pandemic world. Projecting average annual housing need over a 10 year period is not accurate when the rate of household increase is slowing. A lower housing need figure could be used in which Green Belt release is not required, the standard method is not mandated by government. Economic forecasts used in calculating the housing number bring a large amount of uncertainty, longer terms projections should be given less weight. Urban capacity can accommodate housing need when the figures are calculated in a more realistic manner. Object to the 10% flexibility factor which further over inflates the Green Belt requirement.

SHLAA 2021 is not available for comment and the SHLAA 2020 shows a lower urban capacity figure. Where does this figure come from? SHLAA depends on a call for sites exercise undertaken in 2016. This should be updated. The period covered by the SHLAA is inconsistent with the development plan period. No clear reasons why some sites in the SHLAA are ?constrained?. Has all land and sites with planning permission been taken into account? Has Port Warrington site been considered for example? The Town Centre masterplan does not appear to have been fully considered. Disagree with the cautious approach taken when the result is Green Belt release ? actions should be taken to ensure this is minimised. The SHLAA underestimates urban capacity and number of vacant existing properties.

Exceptional circumstances for Green Belt release have not been demonstrated neither have all other reasonable options been examined fully. It has not been demonstrated that the development strategy makes as much use as possible of suitable brownfield sites and underutilised land. The absence of a plan for Warrington Hospital is a major omission as this could have an impact on the amount of Green Belt required for development. Green Belt land for employment development is based on historical take up and is not accurate. Green belt release proposed will encourage more car use, pollution and congestion. No specific assessments of the impact on wildlife.

Concerned that the OE and CE forecasts have been disregarded in favour of the more optimistic historical take up rate. Doesn?t have regard for Brexit, the pandemic or climate change. Inconsistent with the assumptions used in the LHNA. No robust evidence is provided of genuine market demand. Concerns for proposed logistics jobs ? unlikely to benefit Warrington directly and much competition re logistics sites in the region. Too much uncertainty for the level of Green Belt release proposed for employment uses.