UPSVLP 1130
There is inadequate justification for the levels of predicted growth. There is considerable uncertainty regarding the calculation of the required number of new houses.
It would make good sense to incorporate review points into the Plan and most importantly to consider possible mechanisms for setting limits on the short term release of Green Belt rather than releasing it all at once (for example by setting a low limit for the first 5 years of the Plan period).
There is no justification for the proposed housing numbers can realistically be delivered.
House building at a rate of 816dpa is well in excess of the rates that have been achieved in the 5 year period 2013-2018 prior to Brexit and Covid impacts, when average house building was below 500pda. There is little evidence that the resources available locally in the UK can support these levels of house building in the next 5 years.
There is no justification for the scale of release of Green Belt land and no mechanism for minimising Green Belt release as the plan progresses over a 17 year period.
The release of Green Belt should be controlled by the Council with the interests of the residents in mind rather than led by developer aspirations and short term profits. WBC should adopt an approach, which sets out a phased release of Green Belt land with carefully scheduled review points and further consultations with residents to ensure that all current and future factors are taken into account.
It is UK government guidance that Green Belt should be protected as far as practical. This has been reinforced by recent public comments by the Prime Minister. There should therefore be clear priorities put in place to use brownfield land first before building on Green Belt. WBC should have strong policies and controls in place in order to promote and incentivise the prioritisation of brownfield sites and optimising the number and types of homes built on brownfield land. It is difficult to see how such a proposal to create an Economic Development Area on Green Belt land could possibly satisfy the criteria of ?exceptional circumstances?.
There is inadequate justification for focusing economic growth on warehousing and distribution.
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 WBC with an emphasis on creating job opportunities for local residents. The Updated PSVLP 2021 should demonstrate an intention to achieve a high level of integration between economic growth areas and nearby housing developments. The cost of new housing in the SEWUE is unlikely to be affordable for warehouse and distribution jobs holders.
There is inadequate consideration given to avoiding making worse the levels of air pollution.
Not building a dual carriageway from Junction 10 on the M56 to Junction 20 on the M6 at Lymm which travels through existing and new housing in the SEWUE that could provide a thoroughfare for HGVs.
Warrington is one of the worst towns in England for air pollution levels, especially PM2.5. Some of the reasons for these current statistics are understandable because of the concentration of traffic flows at peak times due to the constraints imposed by the waterways and motorways. It is important the Updated PSVLP 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.
There is inadequate consideration of the means of addressing issues related to Climate Change.
Climate Change is an important issue. New policies are emerging (e.g.. electric cars and their supporting charging infrastructure, phasing out gas boilers and introducing heat pumps, new standards of insulation) as well as new threats (e.g.. flooding and environmental pollution). The full implications have yet to be understood but flexibility needs to be built into the Plan.
There is no explanation of how the current transport routes will cope with the increased traffic and there is no clarity on the means of delivery.
The Updated PSVLP 2021 is supported by a Transport Plan document. 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 to support the Updated PSVLP 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.
There is no need to commit to the SEWUE which will threaten the landscape and character of the villages in South Warrington.
The Woodland Trust has addressed the issue of housing developments adjacent to ancient woodland or its supporting habitat and has recommended ensuring that a buffer zone of at least 50mis put in place. Furthermore, recent amendments to the Environment Bill considered and passed by the House of Lords has included recommendations of a minimum 50m buffer zone.
The area of land included in the SEWUE is adjacent to or incorporates substantial areas of ancient woodland. In particular the Lumb Brook Valley (which includes the Dingle and Fords Rough) and Grappenhall Heys are recognised areas of ancient woodland. It should be noted that UK Government advice to local planning authorities is that ?You should refuse planning permission if developments will result in the loss or deterioration of ancient woodland, ancient trees and veteran trees unless: I) there are wholly exceptional reasons; ii) there is a suitable compensation strategy in place. 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 Plan. 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 Updated PSVLP 2021.
Distribution centres are best placed close to railways and therefore Fiddler?s Ferry is likely to be a better location.
The 2014 data will surely be updated soon as the impacts of Brexit and Covid become progressively apparent. The forecast of economic growth is vaguely justified and seems to be driven by new housing creating economic growth rather than the other way round (as would normally be expected).