Given the latest situation that so many of the models, assumptions and forecasts in WBC?s 2019 Plan have turned out to be wrong and have been amended or have been removed completely in the subsequent PSV 2021 issued only 2 years later, it is valid to ask what confidence can now be placed in the assumptions in the 2021 Plan? And with the implications of Brexit still developing and being understood (for example Warrington IBF was hurriedly built and opened in January 2021 with a capacity more than 10 times its actual usage in the first 9 months of 2021), and the ongoing impacts of Covid on the economy, on lifestyles, on shopping habits, on office working and home working and commuting to work still being assessed by both Government and by individual families, it is equally valid to ask how much confidence can be placed on existing planning policies and assumptions.

Reviewing the proposals for the SEWUE it is clear that the planned housing developments impact severely on the Lumb Brook Valley ancient woodland. The proposed housing would block in the existing ancient woodland on all sides and cut it off from the remaining supporting habitat. In general the potential impact on ancient woodland is not addressed in the PSV 2021. It is particularly surprising that the Mersey Valley Timberland Trail, which is a walking route from Runcorn to Lymm passing though ancient woodland in South Warrington is not mentioned at all in the PSV 2021. The supporting documents to the PSV 2021 make it clear that WBC considered 4 separate options for the SEWUE. It decided that Option 2 was preferable over the other three options because it offered good access to local green space, because the consequential increase in traffic would involve less additional congestion on existing local roads, required less new road building and because it could effectively link into existing local services . In my view this assessment is
incorrect and potentially biased towards developer interests and the fact that most of the land incorporated by Option 2 is owned by a single entity Homes England. The WBC assessment claims that Option 4 is more isolated. And could have a greater negative impact upon landscape character compared to Options 1 and 2. I could not disagree more with these poorly justified arguments in favour of Option 2 or the weak criticisms of Option 4. I consider that Option 2 should not be allowed to latch onto already overburdened services in Stockton Heath and is in danger of creating an urban sprawl.

The calculation of housing need remains based on 2014 data. The 2014 data will surely be updated in the near future and the impacts of Brexit and Covid will become apparent. It therefore makes good sense to incorporate several review points into the PSV 2021 and most importantly to limit the short term release of Greenbelt rather than releasing it all at once (for example by setting a low limit on Greenbelt release for the first 5 years of the PSV 2021 period). Surprisingly and with little justification the PSV 2021 includes a proposal to uplift the requirement for Greenbelt by an additional 5% to address potential ?slow progress? of developers in delivering houses on the plots of land they purchase. This ?Developers Allowance? was not included by WBC in the 2019 Plan and is both unjustifiable and gives an impression of ?putting the cart before the horse?. There should therefore be clear priorities incorporated in the PSV 2021 to use brown field land first before building on Greenbelt. Similarly priorities should be put in place to achieve town centre regeneration ahead of building on Greenbelt. WBC should have strong policies and controls in place in order to promote and incentivise the prioritisation of brown field sites and optimising the number and types of homes built on Brown field land. Furthermore ?Grey? field sites should be identified and encourage to relocate to out of town locations in order to free up these grey field sires for house building. These and other focused approaches could ensure that the release of Greenbelt land is carefully controlled and kept to a minimum.

As at today there are already important such factors of great significance to residents in Warrington which appear to have received minimal attention by WBC. Air pollution and theClimate Change emergency have achieved greater scientific recognition and consensus over the past few years and have also gained greater public attention with demand for planning to take these issues into account with clearly set out policies aimed at not making the situation worse. Air pollution is very local whilst Climate Change is global but these are both very relevant for a Town Plan covering the next 17 years. In particular Warrington is one of the worst towns in England for air pollution levels, especially PM2.5. It is important the PSV 2021 addresses these problems in a positive way and whilst it cannot alter the major constraints it can seek to avoid making the problems worse. In practice this could mean planning new housing such that the demand for car transport is minimised, the ability to service by public transport is maximised and HGV traffic is kept well away from the existing and new housing. WBC declared a Climate and Ecological Emergency in 2019 and issued a Green Strategy document in the same year. The strategy appears tobe focussed on commercial businesses (e.g. solar panels on large commercial warehouses and buildings) and few if any objectives relate specifically to house construction or the impact of new house building on the surrounding environment.

The proposal for the Economic Development Area located close to the junction of the M56 and M6 does not appear to be based on carefully studied demand for economic activity of various types but is rather based on simple projections from history which are unsurprisingly distorted by the developments at the Omega Site in North Warrington over recent years. In my view WBC is being unrealistic in its forecasts. Growth predictions are based on levels of activity which have never been achieved in South Warrington before. WBC appear to be assuming that the Economic Development Area aspirations can be achieved almost exclusively by Warehousing and Distribution activities. However this seems commercially driven rather than reflecting a strategic approach by the Council and creating job opportunities for local residents. Creating yet another Warehouse and Distribution centre close to a motorway is likely to be a retrograde step. New warehouses are likely to involve high levels of automation and continued innovation will mean that warehouse jobs are relatively easily replaced by further automation. It is unlikely to be a source of sustainable future employment and it will not futureproof Warrington?s economy. It is therefore difficult to see how such a proposal to create an Economic Development Area on Greenbelt land could possibly satisfy the criteria of ?exceptional circumstances?. Rather WBC should be looking into emerging technologies and exploring the opportunity for a science or technology park in the corridor between Manchester and Liverpool. The PSV 2021 should demonstrate an intention to achieve a high level of integration between economic growth areas and nearby housing developments. Additional housing and new economic activity areas should be mutually supportive. This does not appear to be the case between the current SEWUE proposals and the proposal to release Greenbelt land for this specific Economic Development Area. The cost of new housing in the SEWUE will not be affordable for warehouse and distribution jobs holders. A further observation is that distribution centres are best placed close to railways and therefore Fiddler?s Ferry is likely to be a better location.

The current Transport Plan document lacks detail and there is no clarity on the means of funding or delivery. It appears to be more of a wish list than a credible plan hand in hand with the PSV 2021. As it currently stands the infrastructure delivery plan is dependent on roads which are already overstretched. There is no confidence that the infrastructure needed to support an additional 4200 houses can or will be delivered either in the main settlements or in outlying ones such as Lymm. The PSV 2021 housing requirement delivery strategy places a major emphasis upon creating the SEWUE residential settlements in South Warrington and south of the three waterways. In contrast the Transport Plan recognises that the current preponderance of workplaces such as Lingley Mere, Omega, the Town centre, Gemini/Winwick retail parks, Woolston Grange and the Birchwood Science Park are all north of the three waterways. This is a clear mismatch which will very likely result in a high proportion of the employed members of households in the SEWUE creating a large increase in peak traffic through the pinch points leading to the bridges over the waterways. There is a further constraint not previously referred to. Peel Ports has ownership of all the swing bridges and the Cantilever Bridge within the Warrington network system. The Transport Plan needs to include a commitment to build a new transport route over the waterways which is under the Council?s control and integrated with the rest of the traffic network.