The proposed SEWUE fails to deliver the necessary highway and public transport infrastructure without the need for third party land (namely for Howshoots link). The SEWUE should be planned for in accordance with para 22 of NPPF with a clear 30 year vision and therefore the full extent of the Garden Suburb (as previously proposed to be allocated) should be allocated in the UPSVLP - this allocation should also have been fully assessed within the SA. Reverting to the larger allocation would allow all transport/highway improvements to be made within the boundary, provide a range of facilities, support infrastructure upgrades, provide a significant number of homes, provide ecological and landscape mitigation, provide opportunities for delivering improvements to remaining areas of Green Belt. The full extent of the Garden Suburb would also provide stronger Green Belt boundaries and would deliver more deliverable and developable land for housing development.

The proposed allocation at Thelwall Heys has not been supported by sufficient evidence demonstrating that it would not have undue impacts on designated heritage assets. There are other reasonable alternatives which would not result in such harm and since they have not been considered the allocation is not justified.

Accept in general terms that this is a suitable location to meet logistic development requirements of the Borough. However, this policy is not justified and will not be effective. Standing alone, the South East Warrington Employment Area is isolated and will fail to deliver suitable public transport links and other sustainable transport modes. In particular, it fails to deliver an east west / Howshoots link which necessitates the use of land controlled by this Consortium. These transport related issues can be resolved with the reinstatement of the former Garden Suburb allocation.

Evidence base documents should be published as they are completed rather than waiting for formal consultation in accordance with SCI. A number of evidence based documents are referred to but are not included in the evidence base for the second draft of the plan. A consultation period of longer than 6 weeks would have provided a fairer opportunity to digest and comment.

Preparation of the plan should not be rushed and Regulation 18 consultation may have been more appropriate for the revisions to the plan.

Reference is made to Green Belt Assessments Collated Report but this is not available for comment. Support for general area 10 being defined as weak parcel. More detailed parcel assessment based on call for site submissions rather than analysing how the areas could be better broken down. This has an impact now that the Garden Suburb has been reduced to the SEWUE. The proposed amended Green Belt boundaries are considered to be weak and are therefore not consistent with the NPPF. The overarching strategic 'weak' assessment should have a bearing on the individual parcel assessments but this does not seem to have been considered fully.

The vision statement itself is titled ?Vision ? Warrington 2038 and beyond?, suggesting that the vision for the Borough extends beyond the end of the Plan period. However, the vision statement does not refer to the time period for the vision and leaves this open ended. Given the that the UPSVLP intends to set a 30 year version for the Borough, this time period should be referred to in the vision statement.

Objective W1 sets out the strategic objective of delivering 816 homes per year (14,688 homes over the plan period). This objective is not positively prepared or justified and on this basis is unsound. See further response to Policy DEV1.

Objective W2 seeks to ensure Warrington?s revised Green Belt boundaries maintain the permanence of the Green Belt in the long term. This objective will not be achieved owing to the unsound policies in the Plan (see response to Policy GB1 ? Green Belt).

Objective W3 seeks to strengthen and expand the role of Warrington Town Centre as a regional employment, retail, leisure, cultural and transport hub, whilst transforming the quality of the public realm and making the town centre a place where people want to live. This objective is supported.

Objective W4 seeks to provide new infrastructure and services to support Warrington?s growth; address congestion; promote safer and more sustainable travel; and encourage active and healthy lifestyles. This objective will not be achieved owing to the unsound policies in the Plan (see response to Policy DEV1 ? Housing Delivery and Policy MD2 ? South East Warrington Urban Extension).

Objective W5 seeks to secure high quality design which reinforces the character and local distinctiveness of Warrington?s urban area, its countryside, its unique pattern of waterways and green spaces and its constituent settlements whilst protecting, enhancing and embracing the Borough's historic, cultural, built and natural assets. This objective will not be achieved owing to the unsound policies in the Plan (see response to Policy MD5 ? Thelwall Heys).

Objective W6 seeks to minimise the impact of development on the environment through the prudent use of resources and ensuring development contributes to reducing carbon emissions, is energy efficient, safe and resilient to climate change and makes a positive contribution to improving Warrington?s air quality. This objective is supported.

Object to the housing requirement in the UPSVLP and consider it unsound. Annual housing requirement should be set at a minimum of 945 dpa rather than 816 dpa, to align with economic ambitions, meet the needs of various groups and provide sufficient levels of afforable houisng. Challenge the Council's urban capacity figure which they consider has been overestimated and challenge the development trajectory - without additional deliverable sites housing need requirements will not be met over the 18-year plan period. Present own assessment of houisng land supply. Deficiency identifies requirement for additional land to provide for 4,664 homes based on 816 dpa and land for an additional 7,218 homes based on 945 dpa. Densities across the Borough are too prescriptive and policy should be made more flexible to ensure it is realistic, achieveavle and will ensure delivery of homes that are appropriate to the market. The stepped housing requirement is not justified and appears to be an attempt to reduce the backlog in housing supply at the start of the Plan period as a way of achieving a five-year land supply position on adoption. Requirements for housing for older people and self/custom build are not clear enough.

Support the need to provide affordable housing however some affordable housing provision (i.e. in the Town centre) will not be viable and will lead to non-delivery of affordable homes. The policy will therefore not be effective as a sufficient number of affordable homes will not be delivered over the plan period. Support for providing a range and choice of homes to meet the needs of local people however need a flexible and workable policy to ensure that housing delivery will not be compromised. Needs will vary in different locations and this should be recognised in the policy, along with viability considerations. Support for providing suitable space standards however there is insufficient evidence to justify this part of the policy at present. Optional standards to provide accessible and adaptable dwellings is unjusitifed and the requirements of NPPG have not been met.

it is unclear from the employment land requirement how many jobs this would provide, and thus how many homes would be required to support that jobs growth. It is also unclear how this employment land requirement compares to the ?policy on? approach of the SEP and again how many jobs this would provide, and thus how many homes would be required to support that jobs growth. South East Warrington Employment Area has become increasingly isolated with the removal of the Garden Suburb allocation. Fiddlers Ferry employment site is only viable if Green Belt land comes forward - see comments on Policy MD6.

Confusion potentially caused as only the Nexus 2021 Retail Update has been formally issued alongside the Local Plan for consultation as part of its evidence base despite this report still relying upon the evidence in the 2015 assessment for the Borough and there being a 2019 Nexus retail assessment available elsewhere on the Councils website. The Local Plan fails to adequately reference the disproportionate distribution of District Centres and main food shopping facilities across Warrington. The local plan also fails to adequately plan for main food retail needs in the south of Warrington based on the evidence presented by Nexus, on behalf of the Council. Provision should be strengthened through Policy MD2 South East Warrington Urban Extension. There is also some confusion in the names of retail centres - Neighbourhood Centres should be named Local Centres and vice versa.

The policy is unsound on the basis that there are exceptional circumstances for further Green Belt release to ensure that the Borough's development needs for housing and employment land are met, to address the issues of housing affordability, to require sufficient homes to support the planned level of economic growth, the creation of sustainable patterns of development. The identified release at SEWUE in unsound (see comments on MD2), identified Green Belt release at SEW Employment Area would result in an islolated area that is not sustainable (see comments on MD6), identified Green Belt release at Fiddlers Ferry (see comments on MD3) is unsound, the identified Green Belt release at Thelwall Heys is unsound (see comments on MD5). The exceptional circumstances for Green Belt release at various villages has not been fully justified. That part of the policy which deals with washed over Green Belt settlements in unsound and unjustified and needs to be updated. Further Green Belt release is required in South East Warrington to facilitate the Howshoots link road, regardless of whether or not the Garden Suburb allocation is reinstated.

The Council's supply of land for housing relies heavily on the Town Centre. Policy relies on the Town Centre SPD which relates to the currently adopted plan and its status once the new plan is adopted is unclear. The Council's assumptions on what might come forward are not realistic. The policy is also unjustified as imposing a requirement for electric charging points on all development could lead to a massive over provision of capacity which is neve r properly utilised.

Policy will not be effective as the SEWUE will fail to deliver necessary highway and public transport infrastructure, the proposed Fiddlers Ferry allocation is remote and detached from the main urban area of Warrington, the proposed SEW Employment Area is isolated and will not be sustainable. The policy is unjustified as imposing a blanket requirements for all development to provide plug in charging infrastructure for electric vehicles could lead to a massive over provision of capacity that is never properly utilised.

This policy will not be effective on the basis that the proposed allocation at the South East Warrington Urban Extension does not comply with the aspirations of the Council's adopted Local Transport Plan, and fails to deliver a sustainable and comprehensive long term transport and access strategy for this part of Warrington. Areas of safeguarded land for transport infrastructure is supported.

The requirements of this part of the policy will not be effective. It is not within the direct control of housebuilders or developers to provide Broadband infrastructure. The NPPF at paragraph 114 makes it clear that local planning authorities should support the expansion of electronic communication networks, however it does not seek to prevent development that does not have access to such networks.

This policy will not be effective insofar as only Warrington Garden Suburb allocation can provide a centrally located District / Neighbourhood Centre to accommodate the necessary services and community facilities for a large housing area in south east Warrington.

This policy will not be effective on the basis that some developments, particularly those within the urban area, will not be viable to provide the required contributions towards infrastructure.

It would be helpful if this policy could cite those areas where a Neighbourhood Plan has been made or is in the process of being prepared. If such plans exist or are to come into place, the NPPF confirms that strategic policies should consider what level of development should be afforded to neighbourhood plan areas in line with paragraph 66 of the NPPF.

Reference to the Bridgewater Canal under part 2d and the policy expectations under Part 4 of this policy, which confirms that harm to heritage assets will only be permitted where this is clearly justified and outweighed by the public benefits of the proposal. These components of this policy corroborates our representation towards the proposed Thelwall Heys allocation, which cannot be supported on this basis as it would be contrary to this policy and National Planning policy.

Reference to the Bridgewater Canal under part 2d and the policy expectations under Part 4 of this policy, which confirms that harm to heritage assets will only be permitted where this is clearly justified and outweighed by the public benefits of the proposal. These components of this policy corroborates our representation towards the proposed Thelwall Heys allocation, which cannot be supported on this basis as it would be contrary to this policy and National Planning policy.

Parts of this policy will need to be redrafted in the context of the recent Environment Act 2021. Also consider the policy should list the opportunity to deliver a significant Country Park around Grappenhall in accordance with the need for a comprehensive, master planned approach to the Warrington Garden Suburb / South East Urban Extension area (See comments on MD2).

Policy will need to be redrafted in the context of the recent Environment Act 2021 and the July 2021 revisions to the NPPF at paragraph 7 further to resolution 42/187 of the united national General Assembly and Transforming our World: the 2030 Agenda for Sustainable Development. Need for a general bio-diversity net gain policy that will have to apply across the plan as a whole and to the site specific allocations. At present, the Local Plan is inconsistent in this regard. For instance, the Peel Hall site allocation policy MD4 Criteria 29 refers to measurable bio-diversity net gain but other site allocation policies don't.

Support Part 3 of the policy which notes that development proposals that may affect European sites of International Importance will be subject to the most rigorous examination in accordance with the Habitats Directive, however the policy requirements have not been satisfied in the context of Policy MD3 Fiddlers Ferry.

Support this component of the Policy but bearing in mind the entire southern parcel of the Fiddlers Ferry site allocation falls within a designated Local Wildlife Site this policy cannot be satisfied.

Support for the use of evidence base to determine the requirement/provision of open space, sport and recreation provision. A clause should be added to the policy to make clear that requirements will only be necessary where viable. The policy should further clarify how the requirement will be calculated, through reference to an SPD.

Support for the provision of new waste facilities on industrial estates and in employment areas and note this is required as part of Policy MD2 (SEWUE) however no indication as to where this should be, especially since no employment areas are proposed here. Need for robust masterplanning exercise.

No issue with policy per se but fail to see how the southern parcel of the Fiddlers Ferry allocation can be justified.

Consider Part 3 of the policy is sufficiently flexible with regard to mineral extraction and development.

Support part 7 of this policy relating to Peat Resources and these should be clearly marked on the Policies Map. Presence of peat further demonstrates the limited opportunities for Warrington to grow outwards and why development in South East Warrington is critical.

Parts 1 to 3 of the policy are supported insofar they seek to support renewable / low carbon energy infrastructure and minimise carbon emissions in new development.

Parts 1 to 3 of the policy are supported insofar they seek to support renewable / low carbon energy infrastructure and minimise carbon emissions in new development.

Parts 1 to 3 of the policy are supported insofar they seek to support renewable / low carbon energy infrastructure and minimise carbon emissions in new development.

Whilst the need to minimise carbon emissions is supported, applying a blanket requirement such as this is unjustified and not consistent with national policy as the Deregulation Act (2015) included an amendment to the Planning and Energy Act 2008 to remove the ability of local authorities to require higher than Building Regulations energy efficiency standards for new homes

Whilst the need to minimise carbon emissions is supported, applying a blanket requirement such as this is unjustified and not consistent with national policy as the Deregulation Act (2015) included an amendment to the Planning and Energy Act 2008 to remove the ability of local authorities to require higher than Building Regulations energy efficiency standards for new homes

Policy ENV8 clearly highlights that need to consider air quality impacts very seriously and the need to plan for optimised public transport infrastructure investment and the encouragement of model shift. The site allocations do not grasp this opportunity and the options chosen will in fact result in greater long term impacts in terms of air quality on the Manchester Mosses SAC.

Accept that this is a suitable location for housing development, there is a significant risk that the delivery of the site could be delayed considerably due to the need for major highway works that require a detailed business case to be ratified and a comprehensive land acquisition / CPO process to be undertaken. Own assessment shows that site would only deliver 670 homes over the Plan period. As such, the policy as currently drafted is not justified or effective.

There is insufficient evidence available to conclude that the development of the site will not cause harm to a European protected ecological site as identified by the HRA. There is insufficient evidence available to demonstrate that site specific exceptional circumstances exist to release the land from the Green Belt for residential development. The development of the site would have significant adverse impacts on the role and purpose of the Green Belt and undermine its permanence in this particular location. The residential allocations are isolated from the main urban area of Warrington and its associated services and the existing outlying villages within the Borough. The residential allocations would also be isolated from existing residential areas and services within Halton Borough Council. There is no correspondence from Halton Council confirming the proposed policy would not adversely impact on services, facilities and infrastructure with their Borough boundary. There is insufficient evidence that the southern proposed residential area could be developed viably noting its current use for ash deposits and it being surrounded by flood risk area.

Accept that this is a suitable and deliverable site, however, own assessment shows that it would only deliver 741 homes over the Plan period. This policy will not be effective.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Exceptional circumstances/evidence to justify the release of these sites from the Green Belt have not been detailed. There is a preferable strategic Green Belt parcel on the edge of the main settelement that is considered to be 'weak' that is not currently proposed for development which would assist in delivering infrastructure to South East Warrington.

Welcome the inclusion of a monitoring policy within the plan, however, specific monitoring triggers should be introduced to this framework. This will help to ensure that action will be taken when a target is not met and a policy needs reviewing. A more comprehensive approach to the monitoring and delivery of Policy MD2 and Policy MD6 will be required if the former Garden Suburb is not reinstated.