Local Housing Needs Assessment and Employment Land Forecasts do not take into account the impact of the successful regeneration of Manchester and Liverpool on future demand for residential and employment land in Warrington. Densities proposed in the plan do not seem very ambitious - NPPF suggests significantly increased minimum densities should be established in town centres. Reflecting the change taking place in North West's economy and increasing densities will reduce the area of housing and employment land required during plan period.

SEWUE, MD5 and MD6 are not in accordance with 2012 core strategy as they are largely on Green Belt land, not accessible by public transport and will contribute to deterioration in air quality. Unclear why alteration of boundaries should be justified when no exceptional circumstances are presented. No evidence of discussions with neighbouring authorities on accommodating the identified need for development land. Green Belt should be maintained in light of the recognition of the effect that poor air quality has on public health - provides protection against pollution from surrounding motorways.

Site previously identified as making an important contribution to the Green Belt objective. The site it separated from the existing urban area and has limited access to public transport - difficult to see how this allocation is in line with WBC's sustainable development objectives. Suggests the sites principle justification is that it can be quickly developed - preferable for developers.

Proposed development of residential and industrial estates which are separated from the town and have no access to public transport infrastructure do not meet sustainability criteria. Development of this scale should provide a viable alternative to car use. Plan recognises that strategic road infrastructure may be required, but is vague on any details. Risk that new Green Belt allocation will place intolerable pressure on roads and public services which are already at capacity. Before development south of the MSC - funding and legally binding delivery mechanisms must be in place for infrastructure delivery. Plan does not place sufficient emphasis on encouraging cycling in the area. Risk that villages of South Warrington will lose their local character and be subsumed in an area of urban sprawl. Helpful if plan included a commitment to provide self build plots on any Council owned land released for development. The plan should include proposals for designing new roads in a way to discourage speeding and the provision of traffic calming measures for existing speeding hot spots.

Plan provides no evidence to demonstrate that existing logistics/warehousing facilities in the town provide well-paid employment for local residents. The loss of Green Belt to provide low income employment for non-residents is hard to justify. Targeting new employment development on higher skilled less land hungry uses would be more in keeping with the plan's stated objectives. If the release of Green Belt land can ultimately be justified it would be more sensible to allocate development on the town centre side of the ship canal and where ready access can be gained to the rail network.