Based upon the following information we believe the Policy to be unsound, not justified or effective.
DEV1 Clause 2. Distribution
Strategic Housing Land Availability Assessment (SHLAA) and Brown Field Register.
The Plan heavily relies on the delivery of housing within the existing urban area, the existing inset settlements and any other sites identified in the Council?s Strategic Housing Land Availability Assessment (SHLAA) and on its brownfield register. Given the environmental issues and significant remediation works that these types of sites can often be subject to and issues around land ownership and assembly, we suggest that of the 11,785 new homes proposed on brownfield land it is likely that not all will be capable of being delivered within the plan period or at all. WBC acknowledges that the availability of brown field land will reduce during the Plan period but believes that technological advances the remediation and design will free up additional sites for development. No evidence has been provided to demonstrate this adding to the uncertainty of housing delivery.
DEV1 Clause 3. Sites to be removed from the Green Belt and allocated for Residential development
It is uncertain that the number of new homes identified on sites removed from the Green Belt can be delivered within the plan period. Given the environmental issues and significant remediation works required at Fiddlers Ferry we suggest that of the 1,310 new homes proposed not all will be capable of being delivered within the plan period or at all (refer to representation on Policy M3). In addition, the 2400 homes identified for the South East Warrington Urban Extension are heavily reliant on significant infrastructure improvements to be delivered up front. The sizable investment needed for this is not yet secured and there is likely to be lengthy delays in the delivery of homes.

Based upon the following information we believe the Policy to be unsound, not justified or effective.
Much of the Green Belt land identified requires either significant up front infrastructure investment before homes can be built (a. South East Warrington Urban Extension) or wide scale remediation and ecological mitigation before homes can be delivered (c. Land to the east and south of Fiddlers Ferry Power Station).
Land at Thelwall Heys and Fiddlers Ferry both require Heritage Impact assessments and Fiddlers Ferry requires the owners to produce a comprehensive Development Framework document including a Project Specific Habitat Regulations Assessment setting out ecological mitigation requirements. Thelwall Heys and Fiddlers Ferry have significant constraints on development that limit the number of homes that can be delivered on the area of land being removed from the Green Belt.
According to the Green Belt Assessment, land allocated at Fiddlers Ferry is judged as making a moderate and high contribution.
There is not sufficient evidence provided to show that other sites in the Green Belt, that were previously allocated in the PSVLP 2019 for Residential development, and where there would be less of an adverse impact on ecology and heritage, have been considered as reasonable alternatives.
There is a reliance on those sites identified to be removed from the Green Belt to be sufficient in meeting the housing need and the trajectory for the delivery of homes. However, if as expected the housing numbers are not achieved on other land the existing list will be insufficient. There is an over-reliance in the plan for homes to be delivered from the Council?s Strategic Housing Land Availability Assessment (SHLAA) Brown field Register and Fiddlers Ferry. Given the environmental issues and significant remediation works that these types of sites can often be subject to, particularly on the scale of Fiddlers Ferry, and issues around land ownership and assembly, we suggest that of the 13095 new homes proposed it is likely that not all will be capable of being delivered within the plan period or at all.

Based upon the following information we believe this Policy to be not legally compliant and unsound.

Green Belt land at Fiddlers Ferry, in particular land to the south, with its open mosaic habitat, local wildlife designations and location to the Mersey Estuary SPA / Ramsar has a high ecological value. In the Habitat Regulations Assessment (HRA) it identifies that development of the Green Belt could have significant effects on European protected sites. Policy MD3 sets out the need for a further Project Specific HRA to be produced. The presumption therefore is that before this Project Specific HRA is undertaken, it is unknown whether any development proposed is deliverable, or if it is, the scale of the on-site mitigation that would be required and the number of homes that could be delivered.

In accordance with Clause 24 a Project Specific HRA is required to assess the adverse impacts of development on the integrity of the Mersey Estuary Special Protection Area. If the results from the ecological surveys as required under para. 10.3.24 confirm that the land to the south of Fiddlers Ferry constitutes a significant area of supporting functionally linked land (FLL) the potential on-site mitigation could reduce the housing numbers considerably. This could be to the extent where the economics of delivering the mitigation outweighs the return from the number of homes that could be delivered. There is therefore significant uncertainty around the 900 homes (450 within the plan period) identified on land to the south, being delivered at all.

Therefore, before the project specific HRA is produced and mitigation known there is no certainty any of the Residential development proposed can be delivered.

Other Green Belt sites, previously allocated for Residential development in the PSVLP 2019, with a lower potential for adverse impacts on European protected sites and important habitats and with a similar potential for delivering homes, should be considered as reasonable alternatives to land at Fiddlers Ferry (refer to attachment Representation Moseley Land, Grappenhall).

Plan is unsound as DEV1 does not fully consider all sites available for development in the shorter term.

Plan is unsound as DEV1 does not fully consider all sites available for development in the shorter term.

Plan is unsound as DEV1 does not fully consider all sites available for development in the shorter term.