The Plan is inconsistent with national policy. There is no sound or logical connection between aspirational growth and the spatial plan. No account taken of development activity in neighbouring authorities. The plan does not take into account climate change

The refresh of the EDNA was published simultaneously with the PSVLP, has the EDNA properly been considered? The study relies heavily on a continued growth scenario, in the assumption it is a concern that the approach is unreliable and unrealistic. The prediction of growth have varied at different times including when the PDO was produced. Many sites for growth are already in developers ownership, the view is that this is giving a supply led approach. Other areas that are considered in the plan to stimulate growth are not substantiated, this includes industry related to the European Union, HS2 and the Port of Liverpool.

Use of 2014 population projections is flawed. Average completions have only exceeded 816 pa twice over a 17 year period. Historical build rates on larger site(56dwpa) do not fit in with the 160dwpa on larger sites that is predicted in the plan. Paragraph 60 of the NPFF allows for scope for an alternative approach which reflects current demographic trends and market signs. The plan in delivering sustainable development in south Warrington would require cheaper housing (to support logistics jobs) which doesn't match with the market in south Warrington. The pattern of development would also be contrary to existing patterns in south Warrington. This pattern of development would exacerbate inequality as there are a lack of services in south Warrington. Increased housing neighbouring boroughs should be considered. The approach by Warrington is too inward directed. The Council's growth agenda predicates the housing figures. The HCA 205 guide suggests there is downward pressure on employment density, employment in B1 and B2 will be half the density than that expected by the plan? Previously high level of supply through Chapelford and Omega has led to expectations of developers of a high supply which is now being translated into demand on Green Belt sites. Sites that have been released in green belt areas and on green field sites have not delivered affordable housing and has restricted the regeneration approach on urban sites. This overall leads to a distorted land supply position and lack of delivery of affordable. Approach in Stretton as a result is not valid.

Analysis of Growth has overstated levels of growth. Allocation in Appleton overrides Green Belt considerations even when the Green Belt is considered to strongly meet Green Belt functions. Stobart application refused on Green Belt. Allocation is stimulated by developer pressure and speculation. Full examination of all options has not taken place., for example neighbouring authorities. Development in the Green Belt should be sustainable being next to a motorway junction is not sufficient.

Concerns on the ARUP Green Belt assessment as it references 'professional judgement' This approach contains flaws and fails to look at the Green Belt in Warrington as a single entity with regard to its functions. The approach adopted in the assessment breaks the Green Belt into small parcels and would enable a conclusion that development should be allowed to continue up to any point where a durable boundary with the Green Belt can be established. Sprawl is only applied to the main built-up/urban areas and fail to recognise historic patterns of growth. Consideration is not given to the conservation areas in south Warrington. Evidence for release of sites weak, suggest alternative approach is not to test the 5 purposes of Green Belt but assess against development pressures that impact on the function of Green Belt. Suggested that Winwick, Omega Burtonwood can be accommodated with out conflict with green Belt purposes. Other areas in Croft, Culcheth and Glazebrook etc. could accommodate managed settlement expansion. These have been discounted on a disproportionate weight given to settlement merger. 2014 Core strategy focused after the pattern of development promoted by the new town on growth in the town centre, this resulted in resistance to Green Belt release. Warrington's Green Belt should also be connected to growth and development elsewhere and its function should be understood in relation this and green belt elsewhere. Assessment is therefore weak. Topography and landscape boundaries (including waterways have not been referenced in the assessment and the impact of development of views over Green Belt has not been assessed. Proposals map understates the impact of development gaps in between areas will not be legible. The refusal at Barley Castle should be taken into consideration on the assessment of Green Belt release. The land that was formerly part of the New Town and highlighted for development should not necessarily come forward as infrastructure has not been provided in connection with these sites and there is a lack of clarity on the status of this land. The Parish Council welcomes modification of the Green Belt Boundary with land east of Dorothy Farm remaining in the Green Belt, also reason to Keep land on either side of Spark Hill in the Green Belt. Allocation of this land would result in significant harm and cannot be justified by the fact it is readily available and will provide a formation for a link road for the SWUE.

There is also no clear explanation of the plan is ignores the lack of connectivity between the south of the town, the town centre and the north. The plan is no longer related to the LTP4 and the issues and needs identified in the latter over transport in the town, this is a loss. The Parish Council challenges the Plan's assumption that the level of development proposed can be accommodated. The Parish Council contends that the scale of development without a clear commitment to funding will be disastrous leading to congestion and diminution in air quality. The IDP is flawed as it allows for infrastructure during or after the plan period, given it is recognised that current infrastructure is insufficient it should be provided at the beginning of the plan period. No additional crossings for the Bridgewater or Manchester Ship canals are indicated which are necessary to support the new development proposed in south Warrington as well as existing traffic. The proposed Western Link Relief Road will draw more traffic through the southern A49 corridor. The evidence base should look at the impacts on the local highway network of the Western Relief Link Road. None of the submitted papers provide evidence of the viability of the Western Link Relief Road. The road is also poorly located being to far west for use by the majority of south Warrington Residents. The proposed infrastructure improvements for the SWUE are not set out clearly and there re concerns over the acceptability of and impact of this road. Costs in the IDP are difficult to assess against these works. There is no clarity on Junction 10 M56 and Junction 20 M6 proposed improvements that are mentioned. Concerns that the improvements to the Cat and Lion junction will not resolve congestion as there will be 4,200 additional new homes for it to serve.

The Plan alludes to the provision of community Infrastructure but gives no firm details. The proposal to relocate the Warrington Hospital should be at the core of the plan with a comprehensive and considered background to a town where high growth levels are predicted. Little evidence in the plan that a comprehensive review has taken place and the plan fails to meet the social objectives for achieving sustainable development.

The parish Council contends that the scale of development without a clear commitment to funding will be disastrous leading to congestion and diminution in air quality. The IDP is flawed as it allows for infrastructure during or after the plan period, given it is recognised that current infrastructure is insufficient it should be provided at the beginning of the plan. period. No additional crossings for the Bridgewater or Manchester Ship canals are indicated which are necessary to support the new development proposed in south Warrington as well as existing traffic. The proposed infrastructure improvements for the SWUE are not set out clearly and there re concerns over the acceptability of and impact of this road. Costs in the IDP are difficult to assess against these works.

There are existing Air Quality Management Area (AQMA) in Warrington. The proposals within the plan will increase the impact on air quality in the town. The AQM study produced previous versions of the draft plan has not been updated. The closure Fiddlers Ferry for example has not been considered. Road transport has been identified by DEFRA (June 2020) as of particular concern. This report notes plans for growth and need for long term action. All links from Greater Manchester fail WHO standards. There is no scope for public transport improvements as Warrington is outside Greater Manchester Combined Area (GMCA) area. The assumptions in the AQMS 2019 are flawed as they take no account of impact of traffic flows of canal bridges. Logistics growth which is road transport is promoted however there is no clarity on how the industry will deal with modal shift on freight. The AQM Study assumes that technological changes will happen outside of the plan period which will lead to a decrease in air quality due to congestion. Nether does this report take account of the closure of the road bridges which can significantly increase traffic and therefore air pollution. The impact on some of the major arteries into the town is therefore no properly assessed in the plan period. ENV8 seeks to manage the impact of road transport during the plan period with little detail on the impacts too be avoided (e.g. Manchester Mosses). Difficult to see how development proposed in south Warrington can meet the policy requirements.

It is considered by the Parish Council in SWUE would not deliver adequate amenity for new residents and be detrimental to existing ones. Reference is made to the M6 and Thelwall viaduct which is close by and is heavily trafficked. The M56 is also close by and is a heavily used motorway giving out much noise. A roads in the vicinity are similarly heavily used. Existing area of south Warrington will lose connectivity with the countryside around. This key characteristic of the town would be diminished. There is no confidence in the development of the draft allocated sites that the development would in line with the NPFF 130 and add to the quality, landscape character and setting of the area and will not promote health and well being. The encroachment into open countryside will change the character of the areas. Flood risk- the updated evidence cover a wide range of issues however the developments in south Warrington as with previous developments have increased discharge and reduced permeable surfaces for rainwater. The SFRA shoes that communities in south Warrington are at risk of surface water flooding. No hydrology information for south Warrington. Issue should be considered prior to development and not left to individual planning applications

The loss of areas of greenfields to development in south Warrington will have a significant and severe impact on biodiversity in the area and across the borough. The HRA update 2021 was only .published just before the new PSVLP. Can the finding have been properly assessed. The HRA recognises impacts on Rixton Clay Pits and Manchester Mosses Special Area of Conservation fro the south Warrington proposed. No account taken of the impact on human receptors of development. Acceptance of development is dependent on ongoing reduction of transport emissions. This approach in the HRA is considered dubious as the reduction will only be seen at the end of the plan period and takes no account of development through the plan period. The plan reflect a position from LTP4 that vehicle movements can be restricted. There is no explanation of how this can be achieved. This contradicts evidence from the Stobart development and consequently there is no rationality behind identifying and controlling air pollution.

The character of south Warrington is driven by its distinct settlements. The settlements are separate from the main urban area and are distinguishable as separate settlements. These areas were protected in the 2014 core strategy. The landscape appraisal of the plan is superficial and fails to take account of the views across landscape that will be lost as a result of the SEWUE. The greenfields and Green Belt help maintain the separation and distinctiveness of these settlement from the main urban areas. More weight is given to settlement in north Warrington despite the fact they have no formal heritage status. The objectives of the Plan as set out in the Vision are not secured.

RTPI and TCPA have produced A Guide for Local Authorities - The Climate Crisis - A Guide for Local Authorities on Planning for Climate Change. This recommends that climate policy should be embedded into planning policy as a strategic priority. The NPFF the plan should take a proactive approach to mitigating against climate change in paragraph 153 and that the NPFF the NPFF requires an holistic approach to climate adaption. Warrington BC declared a climate emergency in 2019 the PSVLP shows no evidence that it includes policies that meet with climate change including energy efficiency for example in the major development allocations. The Parish Council are concerned that climate change is not at the centre of the plan. The plan is not pro-active as required by para. 153 of the NPPF No focus on remediation of brownfield sites and concentrates on developing brown field sites. There is little scope for any of the developments in south Warrington to become exemplars for standards of energy efficiency.

The economic basis of the plan is unsound and is overly ambitious based as it is on unsound assumptions. The ability of the plan to deliver planned infrastructure , regeneration and health and well being is misunderstood and not achievable. Land proposed for development is not in the right place to serve resident needs and will not support strong vibrant communities. Employment and accessible housing in the wrong place. Too much unskilled work and export of higher paid skilled work. The plan proposes development that will have a devastating impact on biodiversity as it is mostly green field. Car use will predominate in such development.

No exceptional circumstances to justify Green Belt release of this site.

The site allocated makes a significant contribution to the Green Belt. It has stronger openness with predominantly non durable boundaries, strong role in preventing encroachment. The site also assists in regeneration. It is a highly prominent site from major roads and public footpaths . Impacts should be considered with regard to other available sites.

s do not cover a new link over the The deliverability of the plan can be questioned in a number of ways: unachievable growth levels; failure of delivery of housing build rates in the past; funding of infrastructure; and viability. The plan cannot be considered sound due to the lack of evidence on the costs and funding of infrastructure. Costs against the SWUE in the IDP are put at ?45k a dwelling which equates to ?199million. However the costs do not cover a new leisure centre or crossing over the ship canal etc. The Parish Council feels the Council should provide more detail and certainty around the costs.

There was no effective engagement prior to issue of the Submission Draft with public interest groups or statutory bodies mandated to support local, public interests.

There was no effective engagement prior to issue of the Submission Draft with public interest groups or statutory bodies mandated to support local, public interests. The evidence base was not placed in the public domain before issue of the draft plan as part of the Full Council process. The Council's own SCI was not followed.