Ideally, the Council should ensure that the housing target aligns with its employment land target. The Consortium is fervently of the opinion that there is absolutely no chance that 816 dpa can sustainably accommodate the increase in workforce that would be associated with 316 hectares of employment land. Based on the Council?s own evidence base (BE Group?s 2021 EDNA Update), the 316 ha of employment land could be expected to align with a level of job growth equal to over 36,260 ? more than triple the level realistically associated with 816 dpa. Story?s view is that a (rounded) target of 1,015 dpa should be taken forward in the WUPSVLP, which aligns with the mid-point economic growth, adjusted for PCC rates. This was the approach formerly taken forward by its housing consultants in GL Hearn in 2019, with no robust justification for departing from it and some very clear errors in their latest update which invalidates the conclusions of their 2021 study. Given that this still does not align fully with the Council?s very ambitious employment land target, this figure could legitimately be increased. The very high levels of affordable housing need across the Borough, which could justify an uplift to the housing requirement, have been ignored yet again despite the High Court quashing the housing policies of Warrington?s current adopted Core Strategy back in 2015 partly because WBC had failed to accurately consider whether an increase in the total housing figure included in the WUPSVLP could help deliver the required number of affordable homes. The 1,015 dpa would meet over 70% of the total affordable housing need if 30% of all units came forward as social housing.

The Council seeks to phase the delivery of its housing requirement with a sizeable proportion of the supply being unjustifiably back loaded to the latter period of the plan. However, it is Story?s strong view that the Council should, as a minimum, apply an even approach across the plan period including in the first 5 years. Story would also advocate an approach that goes beyond this and instead of pushing need to the end of the Plan period, the buffer should instead be brought forward to ensure that a sufficient supply of land comes forward for development in the early years. The Council considers it can deliver 814 dpa over the first 5 years, but that by manipulating the need down to an untested 678 dpa, it can erroneously claim it has factored in a 20% buffer to the supply, thus avoiding the 5YHLS hurdle it would otherwise fail. Whilst it is acknowledged that Warrington has some larger strategic sites on Green Belt land that may come forward in the Plan, this should not be used as an excuse to postpone meeting households needs in full. To accord with the Framework [?59], Story considers that, in the future, a balanced strategy should be adopted, identifying a suitable supply of brownfield and greenfield sites that responds to an evidenced-based assessment regarding the size, type and tenure required. This should ensure that supply included in the Plan is capable of meeting specific needs of housing market areas in the sub-region. If a significant proportion of the Plan?s supply comprises large strategic sites, then a suitable supply of smaller, deliverable greenfield sites must also be identified to offset the infrastructure challenges strategic sites will face in coming forward any sooner. The SWUE has previously been accepted a suitable for allocation in the WSP 2019 and it should be re-allocated to meet the shortfall of new homes we have identified.

Story is firmly of the opinion that the Council has artificially inflated the claimed supply with the sole intention of trying to minimise the amount of Green Belt land released for housing, regardless of the deliverability of the claimed supply. Story has considerable concerns with the majority of the sites included in the Council?s supply, and the Council?s assumptions on a large number of sites are flawed and do not meet the tests of deliverable and developable as set out in Annex 2 of the Framework. Furthermore, the Consortium considers that the Council should not include windfalls in years 1-3 of the plan period, and a further 595 dwellings should also be discounted from the supply based on analysis conducted in relation to the Fiddler?s Ferry strategic site. As a result, in terms of the supply over the Local Plan period, Story considers that the Council has a shortfall in the developable supply of 2,448 dwellings when assessed against the Borough?s LHN (816 dpa). When considered against the housing requirement considered necessary by Story (1,015 dpa), there is a shortfall of 6,388 dwellings. Story therefore considers that the only option available to the Council to significantly boost the supply of housing and address the clear shortfall is to identify additional Green Belt land for release for housing. Identifying additional Green Belt land would also help to address Story?s concerns in relation to the diversity of the current land supply, as greenfield developments are more able to deliver larger 3 and 4 bedroom homes than constrained sites in the urban area.

Cushman and Wakefield (on behalf of the Council) has produced a Local Plan Viability Assessment (August 2021) [LPVA] to inform the preparation of the WUPSVLP. Story has reviewed the content and conclusions made within the LPVA. Based on its analysis, the Consortium has significant concerns in relation to the viability of sites, and the subsequent ability of the emerging Local Plan to deliver the required number of affordable dwellings. Story has concerns that a significant proportion of the Council?s claimed supply is unviable, particularly in the Town Centre and other low value locations in the Borough. Given that the LPVA base testing concludes that most of the development typologies cannot deliver a policy compliant level of affordable housing whilst meeting other policy requirements, more comprehensive typology testing should be undertaken. Viability testing undertaken on behalf of the consortium identifies that the Council should identify a greater quantum of greenfield sites in higher value areas which will be able to provide the required level of affordable housing and make required contributions to social and physical infrastructure.

Despite this Plan undertaking a Green Belt Review, no sites have been identified as Safeguarded Land to meet needs beyond the Plan period. Identifying Safeguarded Land does not allocate it for development and the same level of protection is afforded Green Belt provided the Council?s Local Plan is delivering the homes and employment land that it envisaged. The land identified in the Plan to meet needs beyond the plan period is predominantly from an increased proportion of unidentified windfall sites and from strategic allocations delivering dwellings beyond the Plan period. There is no certainty that the unidentified windfall sites will come forward as envisaged and required ?technological advances? to facilitate their delivery and there is considerable concern with regard to the delivery of some of the strategic sites delivering units beyond the Plan period. In the Consortium?s opinion, the selection of the most appropriate sites to be safeguarded should be identified in a robust and consistent Green Belt Review and based on a robust Site Selection methodology which considers matters including the sustainability, accessibility, deliverability and viability of the sites.

The distribution of a proportion of the housing requirement to the outlying settlements, including Culcheth, is supported. This will help to support the vitality and viability of local services and increase housing choice in these settlements. we note that the WSP 2019 endorsed a higher minimum delivery figure for the outlying settlements of 1,085 homes, compared to the 801 homes now proposed in Policy DEV1. The removal of Green Belt land to accommodate higher delivery figures around the outlying settlements has therefore been previously endorsed by the Council.

The distribution of a proportion of the housing requirement to the outlying settlements, including Lymm is supported. This will help to support the vitality and viability of local services and increase housing choice in these settlements. we note that the WSP 2019 endorsed a higher minimum delivery figure for the outlying settlements of 1,085 homes, compared to the 801 homes now proposed in Policy DEV1. The removal of Green Belt land to accommodate higher delivery figures around the outlying settlements has therefore been previously endorsed by the Council.

The Council?s overall spatial strategy of optimising development potential in the existing urban area, releasing Green Belt to provide strategic allocations and distribute development to outlying settlements is generally supported. However, Story objects to the overall distribution strategy on the basis that the allocation of the South West Urban Extension (SWUE) site is no longer proposed and the allocation of land at Fiddlers Ferry is not justified.

Story notes that the Government?s decision to make these standards optional suggests that they do not expect all properties to be built in accordance with them. If the standards are to be applied, the Practice Guidance sets out a clear set of criteria local planning authorities should address in order to justify them. With regard these criteria, we firstly note that no need evidence is provided in the SVLP 2021 or the 2021 LHNA to justify the policy requirement. With regards to viability, the Viability Assessment [?7.20] states that the NDSS has been applied within the appraisals as the minimum standard. However, it is not clear whether the impact of meeting this standard upon affordability has been considered. The policy approach should recognise that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and effect customer choice. Well designed dwellings below NDSS can provide a good, functional home. If the Council is able to provide sufficient evidence to justify the policy, Story considers that a transitional period should be applied.

The blanket requirement appears to be policy led rather than informed by evidence. Story is also concerned that the LHNA does not fully address the requirements of the Practice Guidance. For example, no assessment of the accessibility and adaptability of existing stock appears to have been undertaken as required by the Practice Guidance. It could be the case that a significant proportion of the existing stock is capable of helping to meet the identified need which would reduce the need for further provision. The evidence does not identify any local circumstances, which demonstrate that the needs of Warrington differ substantially to those across the North West or England. If the Government had intended that evidence of an ageing population alone justified adoption of optional standards, then such standards would have been incorporated as mandatory in the Building Regulations, which is not currently the case.

Whilst Story generally supports the provision of homes that are suitable to meet the needs of older people and disabled people in principle, we are concerned that the approach to assessing needs for M4(3) dwellings does not align with the Practice Guidance. For example, the LHNA does not appear to consider the size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes) and appears to focus on meeting this need through standard housing which is likely to artificially inflate requirements for this type of housing. Part M of the Building Regulations sets a distinction between ?wheelchair accessible? (a home readily useable by a wheelchair user at the point of completion) and ?wheelchair adaptable? (a home that can be easily adapted to meet the needs of a household including wheelchair users) dwellings. The Practice Guidance states that policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling. Part 16 of the policy does not identify this distinction and as drafted suggest that 10% ?wheelchair accessible? dwellings may be required which could result in ?wheelchair accessible? dwellings being sought when they are not actually required. Story considers that the most effective way to provide sufficient housing to meet M4(3) category requirements in the correct locations would be to increase the proportion of this type of accommodation in specialist housing for older people. This could involve the allocation of specific sites to help meet this need. We recognise that not all wheelchair housing will be provided through such specialist housing and consider that any requirements for M4(3) dwellings on market housing sites could be based on assessments of local need at the time of a planning application.

The land take for such uses could have a significant impact upon the development potential of sites for general market housing and upon development viability. The Framework [?34] is clear that such policies should not undermine the deliverability of the plan. It is also unclear whether the impact of this requirement upon site viability has been factored into the Council?s Viability Assessment.

Story Homes agrees that an exceptional circumstances case has been demonstrated for the release of Green Belt land around the outlying settlements, including Culcheth. The land to be released is identified in the 2016 Green Belt Assessment as making a ?weak? contribution to the Green Belt purposes. Story Homes agrees with this assessment. Only three parcels around Culcheth fall within this ?weak? category? with the remaining 12 being assessed as ?strong'. Given this ?weak? Green Belt contribution and the strong sustainability credentials of the site, land at Warrington Road, Culcheth is appropriate for removal from the Green Belt and is fully supported by Story as an allocation for new homes.

The WUPSVLP 2021 [?3.4.1 to ?3.4.16] sets out the exceptional circumstances sought by the Framework [?140] to justify the release of Green Belt land. Story Homes agrees that an exceptional circumstances case has been demonstrated for the release of Green Belt land and notes that in the WSP 2019 this previously included a demonstration of the exceptional circumstances for the release of the SWUE, the purpose of which was to provide a new sustainable community supported by local infrastructure and services, facilitated by the Western Link. Story considers that this exceptional circumstances case still exists and that the removal of the site from the Green Belt continues to be justified on this basis. In addition, for the reasons we have identified in these representations, additional Green Belt release is required in order to meet the requirement for new homes we have identified over the Local Plan period and beyond. This need is much greater than set out in the exceptional circumstances case in the WUPSVLP 2021 given the requirement and supply issues we have identified and there is no alternative but to release more Green Belt land to address these matters.

The draft Proposals Map shows Story?s land at Reddish Lane and Rushgreen Road, Lymm as remaining within the Green Belt. Story objects to the inclusion of this land within the Green Belt and considers that this land should be allocated for residential development in the Local Plan for the reasons we have set out in these representations. Story disagree with the Council's Green Belt Assessment of the Reddish Lane site. We consider that the site makes a ?Moderate? contribution to three of the purposes of the Green Belt and ?No contribution? to two of the purposes (1 and 2). We therefore consider the overall contribution to be ?Moderate?. It represents a logical location for release which will have relatively limited harm to the general extent of the Green Belt and is suitable for release and allocation for residential development. The Council?s October 2016 Green Belt Assessment included an assessment of individual parcels and identified the Rushgreen Road site as part of parcel LY9 which was considered to have an overall contribution of ?Moderate?. In the July 2017 Green Belt Assessment of SHLAA sites, the Rushgreen Road site was assessed as an individual parcel [R18/016] and was considered to have an overall contribution of ?Weak?. The Council?s own evidence base would therefore support the removal of the Rushgreen Road site from the Green Belt.

Part 1(j) of the policy states that the Council will expect development to consider how it can be futureproofed, through the provision of measures to support new and emerging technologies, such as Autonomous Vehicles. Whilst Story recognises the potential benefits of futureproofing development, there can be no guarantee that some forms of new and emerging technology will ever reach the mass market. It is therefore difficult to foresee which forms of technology will need to be supported through development at the current time. In any event, it is likely that technology such as autonomous vehicles will be designed to adapt with existing development, and futureproofing may not therefore be required to accommodate it.

Story welcomes the proposed mechanism for the consideration of viability at the planning application stage as this will allow any unexpected costs and viability issues to be appropriately addressed. We note that a breakdown of s106 contributions for Policy OS2 allocation at Culcheth has been provided in Appendix 13 of the Viability Assessment by category (Primary School, Secondary School, Health etc.). However, whilst this information is welcomed, Story considers that the Council's evidence also needs to include details of how the Policy requirements for the allocation have been derived. In this regard, Story notes that there is a lack of transparency in the Infrastructure Delivery Plan [IDP] on this matter. There is no specific breakdown in the IDP of the projects to which the contributions sought by Policy OS2 would contribute so it is not clear whether they are justified.

Story notes that no clear justification or evidence is provided for the 10% renewable or low carbon sources requirement or 10% carbon reduction in Parts (b) and (c) of the policy. In addition, the Government has confirmed that the new Part L standards will be introduced through Building Regulations from June 2022 and the Future Homes Standard is due to come into force in 2025 which will affect development over the plan period. Story considers that the Local Plan should comply with the Government?s intention of achieving net zero carbon development through the Building Regulations. The appropriate costs should be applied in the viability assessment to account for the provision of these standards. This does not appear to be the case at present as a figure of ?2,250 per unit has been applied to meet the standards in
parts (b) and (c) of the policy but the Viability Assessment [?7.237] suggests that the average additional cost to meet Part L would be ?4,847 per plot. With regard to decentralised energy networks, there are practical, technological and viability constraints with regard to their delivery based on low carbon technologies.

Story objects to this requirement as there is no clear justification for the vehicle and HGV thresholds identified and they appear to be arbitrary figures. In this regard, we note that in the SVLP 2019, the thresholds were 1,000 vehicles and 200 HGVs and the WUPSVLP 2021 provides no explanation as to why the figure has been dramatically reduced in the latest version of the policy.

Part 3 of the policy seeks the provision of a minimum of 30% of homes to be affordable in accordance with Policy DEV2. Story supports the provision of 30% affordable housing on the site.

Whilst it is accepted that new development should contribute to achieving an appropriate mix of housing, no evidence has been provided by the Council to demonstrate how the cost of providing self build plots has been taken into consideration in the Local Plan Viability Assessment. The Council has a legal obligation to grant sufficient planning permissions to meet the demand for self-build and custom housebuilding. It is considered that the Policy approach would not be effective, as it would provide no guarantee that the Council?s obligation to ensure that sufficient self and custom build plots are provided to meet demand, would be achieved. As it is not known what level of provision for such plots could be achieved on schemes by market housing developers, across the borough, the Council cannot rely on these sites as the source of supply to meet this demand. The Council should therefore identify an alternative mechanism to ensure that this demand can be met. Story Homes considers that the only way this can be achieved is through the Council identifying standalone sites which are specifically allocated to meet this demand. Providing self or custom build on market housing sites will also create issues with the apportionment of planning obligations between the ?market? housing area and self -build plots. It may also be the case that those undertaking custom builds do not wish to accommodate a plot on a ?market? housing site as this may limit the potential for customisation if schemes need to reflect the character of the surrounding development. Story also notes that the Council?s commitment to delivering of self build plots is set out in policy DEV2 so there would still be a mechanism for the Council to secure plots within the local authority area if this requirement is removed from Policy OS2.

Part 7 of the policy states that development will be required to make a contribution towards the provision of additional primary care capacity. However, there is no clarification in the policy or the explanatory text as to why such a contribution is required and no evidence is presented to justify it. In addition, it is not clear whether the contribution sought would be financial or involve the provision of facilities on site.

Whilst Story recognises the importance of providing open space within new development, any requirement needs to be CIL compliant, in particular that it is necessary to make the development acceptable in planning terms. The need for these facilities therefore needs to be demonstrated through the appropriate evidence including an assessment of existing provision.

Story recognises the benefits of pursuing opportunities for net gains in biodiversity; however, the Framework does not set out a blanket requirement for all development proposals to achieve this aim. Story acknowledges that the Government will mandate biodiversity net gain soon and is factoring in the additional obligations. However, whilst legislation on this matter has recently received Royal Assent, it is understood that there will be a transitional period before the provisions of biodiversity net gain come into effect. Therefore, whilst Story agrees with conserving biodiversity and geodiversity across Warrington, we do not consider the requirement to deliver net gains across all developments to be consistent with national policy at present.

Part 13 requires a scheme of compensatory improvements to the environmental quality and accessibility of land remaining in the Green Belt to be provided. Financial contributions will be considered where this would help to ensure that the benefits of compensatory improvements can be maximised by providing them in the most appropriate location. This approach accords with the Framework [?142] and the option of providing financial contributions is supported.

Part 15 of the policy states that the development will be required to make a contribution towards the delivery of sustainable transport modes. However, no explanation is provided in the policy as to what these sustainable transport modes are and why this contribution is necessary to make the development acceptable. Story notes that the site is well served by existing bus services which provide access to Warrington town centre and local employment opportunities as Birchwood. It is also located within walking distance of a range of shops, services and facilities in Culcheth, as well as well as Culcheth Community Primary School and Culcheth High School on the opposite side of Warrington Road, and will encourage walking and cycling through the provision of pedestrian and cycle routes. In the absence of any evidence to justify this contribution Story is concerned that Part 15 of the policy would not be found sound.

Story notes that no clear justification or evidence is provided for the 10% renewable or low carbon sources requirement or 10% carbon reduction in Parts (b) and (c) of the policy. In addition, the Government has confirmed that the new Part L standards will be introduced through Building Regulations from June 2022 and the Future Homes Standard is due to come into force in 2025 which will affect development over the plan period. Story considers that the Local Plan should comply with the Government?s intention of achieving net zero carbon development through the Building Regulations. The appropriate costs should be applied in the viability assessment to account for the provision of these standards. This does not appear to be the case at present as a figure of ?2,250 per unit has been applied to meet the standards in
parts (b) and (c) of the policy but the Viability Assessment [?7.237] suggests that the average additional cost to meet Part L would be ?4,847 per plot. With regard to decentralised energy networks, there are practical, technological and viability constraints with regard to their delivery based on low carbon technologies.

Story objects to this requirement as there is no clear justification for the vehicle and HGV thresholds identified and they appear to be arbitrary figures. In this regard, we note that in the SVLP 2019, the thresholds were 1,000 vehicles and 200 HGVs and the WUPSVLP 2021 provides no explanation as to why the figure has been dramatically reduced in the latest version of the policy.

The Council has introduced a new mixed-use allocation into the Plan at the latest stage and Storey has considerable concerns in relation to the principle of the site?s inclusion. Not only that, the timescales for the delivery of the site as set out in the Plan are fanciful and are not grounded in any sense of reality. It is the consortiums view that the SA in relation to the assumptions made on Fiddlers Ferry is fundamentally flawed, results in an unstainable approach to development, it is not sound, and it is not legally compliant. The identification and delivery of a brownfield site which over exaggerates its impact in the SA should not surpass the allocation of other more sustainable greenfield releases where it is clearly not justified. Not only that, Fiddlers Ferry is wholly unviable and as a consequence it is highly questionable whether the development could ever be delivered without significant intervention. We also have concerns with the loss of Green Belt land in this location and the lack of evidence to justify that this is the most appropriate site for Green Belt release. It is not clear why the Green Belt element of this site is required to come forward. Given the significant number and complexity of the issues raised in relation to the developability of this site, it is consider that the Council?s delivery trajectory is completely at odds with the reality of delivering complex strategic sites and the Council need to identify alternative sites to plug the gap in the supply trajectory. Not only that but the Consortium considers that the Council has not followed a logical approach in terms of identifying the most appropriate sites for release from the Green Belt and the loss of this proposed allocation would result in the erosion of the strategic gap between Warrington and Widnes.

The SEA assesses the Fiddlers Ferry site to be deficient in a number of regards and we consider that these deficiencies have not been properly considered and the negative effects will be greater than assessed. This is likely due to the fact that the site has only been introduced as an allocation at this late stage and insufficient time has been available to compile all of the relevant evidence and fully consider the effects of the site. We do not consider that the site performs as strongly as has been assessed in the SA and there are a number of issues which raise questions over its suitability for allocation, in particular with regard to accessibility which is poor and given the size of the site is likely to result in significant use of the private car, leading to congestion and air quality concerns. Story is also concerned that the biodiversity effects have not been properly assessed and may be worse. It is not clear how the Council can make assumptions on the significant impacts on biodiversity as it has not been confirmed at this stage what mitigation is to be provided. As a more general point, it is not clear how the Council can make assumptions on the significant impacts on the environment when it is not clear at this stage how the site is to be remediated and what mitigation is required. Story considers that the findings of the 2021 SA in relation to the Air Quality effects of the SWUE are not justified. The effects have been overstated, and the SWUE would in fact have lower effects, even when considered in combination with the South East Warrington Urban Extension [SEWUE].

The SWUE is suitable, achievable, deliverable (and developable) and that there are no impediments to delivery early in the Plan period. the Council is wrong in its reasons for removing the SWUE from the current Local Plan and that none of the Councils stated reasons are fundamental to the delivery of this land as a sustainable urban extension. In its options assessment process the Council has overstated the impacts of the SWUE and understated the benefits relative to the other sites considered as part of the options assessment process. In particular, the Council has overstated the impacts of the SWUE in respect of the Western Link, secondary school provision, built leisure facilities and Green Belt and understated the benefits in terms of early delivery.

The information submitted with these representations demonstrates that Story?s land at Reddish Lane and Rushgreen Road: 1 Is in a highly sustainable location in close proximity to the existing services and facilities within the village centre. 2 Makes a ?Weak? to ?Moderate? contribution to the key purposes of the Green Belt and is therefore suitable for release given the lack of more suitable land for release. 3 Provides an opportunity to create a high-quality development which is sympathetic and responsive to the existing settlement character of Lymm; and, 4 Would provide a more suitable location for residential development around Lymm than some of the draft allocations identified in the Local Plan. There are no physical constraints or other potential impacts or environmental conditions which could preclude the development of the sites for housing.