NPPF paragraph 22 requires Strategic Policies to look ahead over a minimum 15-year period from adoption of the plan. The Warrington plan, therefore, on its own admission, plans for the minimum period of 15 years from the suggested adoption date. This is too tight a timescale for the plan to be considered sound based on the anticipated date of adoption and that is a significantly different plan to that previously
published in March 2019 (also a pre submission plan), with amended allocations, deleted allocations, new allocations, a shortened plan period, a reduced housing requirement, and a significantly revised evidence base. The use of the base minimum plan period is overly optimistic in these circumstances, especially given the Plan includes larger scale developments, where it is anticipated that development will continue beyond the current Plan period. Detailed reasoning set out in Lichfield's Report.

Object to the proposed housing requirement of the plan; it fails to meet the housing needs of Warrington. As such the policy is unsound. The use of a stepped housing trajectory is not appropriate in the circumstances of Warrington?s acute housing needs, as the need for housing delivery is now and in the early years of the plan period not later in the plan period as proposed by the Council. The reliance on a ?review or partial review of the local plan? to remedy a fall in the delivery of housing in the local plan period is not appropriate in the circumstances of this plan and further allocations and reserve land should be allocated in the Plan. Detailed reasoning set out in Lichfield's Report.

The Plan makes clear that Affordable Housing is a significant issue for the Plan to address, however, the Plan fails to tackle this issue and the policy is therefore unsound. The issue of under provision
of affordable housing in this plan is of great concern and is an issue of soundness. It is clear that even the anticipated low levels of affordable housing will not be delivered by this plan. The suggestion that the SEA is being used to support a preferred policy approach, rather than inform the most appropriate policy approach, must be thoroughly re-assessed. Detailed reasoning set out in Lichfield's Report.

The policy seeks to establish green belt boundaries to at least 2050, with scant evidence or assessment as to how these can be assured. There is no secure forward supply to 2050 set out, therefore the plan fails the requirement of paragraphs 140 & 143 (e) of NPPF. As such more land should be released from the green belt through this local plan process to avoid the need for further releases in the period up to 2050. policy refers to ?a scheme of compensatory improvements? to be provided, without setting out the circumstances where such a scheme is required, nor indeed who will provide such a scheme, and to whom that scheme should be submitted. Detailed reasoning set out in Lichfield's Report.

The areas wash over sites allocated for development in this plan, thereby creating uncertainty over their delivery within the plan period. As such the policy is unsound. The ability to develop the allocated sites without further ?in principle? studies must be settled in this local plan, and further assessment to achieve this must be undertaken before this plan is submitted for Examination. As a minimum, and in order to ensure that the plan is deliverable, ENV 3 should be amended to make plain that criteria set out in policy will not apply to sites allocated for development.

We have numerous criticisms of the proposed allocations in the plan, and these are set out in the Lichfield?s statements.

The monitoring and review process set out in this policy is too long and will not result in development needs being met in the circumstances where the policy is invoked: i.e. a
situation of sustained low delivery. It is unsound. This is not an adequate response to under-delivery in a Borough already under significant housing need and with an extremely low housing land supply at present. Detailed reasoning set out in Lichfield's Report.