UPSVLP 2297
In short, the land to the north of Winwick is a sustainable site, which is available, suitable and achievable to accommodate new homes and there are no technical constraints to its delivery. The allocation and subsequent development of the site will provide much needed new homes of a mix of tenures and sizes to meet local needs, and will deliver a range of social, economic and environmental benefits.
Bellway are supportive of Warrington?s vision for 2038+, including the aspiration for new housing development to support economic growth and be focused on creating attractive, well designed, sustainable and healthy communities.
Whilst Bellway believe that the Council could have been more aspirational in terms of the scale of housing growth (see our response to Policy DEV1 for further details), they are content that the new spatial strategy for meeting Warrington?s need for new homes (as described at para 3.3.8) still disperses some ?incremental growth? to sustainable outlying settlements.
We support the acknowledgement in these paragraphs that it is not possible to meet all of Warrington?s development needs within the existing urban area and that there is a need to release Green Belt land in order to meet its housing requirement.
Para's 3.3.6 to 3.3.7
Bellway support section 3.4 which sets out the ?exceptional circumstances? for Green Belt release, in accordance with paragraph 141 of the NPPF.
In particular, Bellway support the recognition at paragraph 3.4.10 that Green Belt release in the outlying settlements will increase housing choice and support the vitality and viability of local services without placing unacceptable pressure on local infrastructure, whilst maintaining local character (paragraph 3.3.14). In this regard, we find that the plan is positively prepared, justified, effective and consistent with national policy.
Section 3.4
The latest 2020 Housing Delivery Test results show that Warrington had only delivered 57% of the total number of new homes required over the previous three years, thereby triggering ?the presumption? in paragraph 11 of the NPPF. A higher housing requirement would create more flexibility to help ensure that a greater number of new homes are provided over the plan period. In this regard, we find that the plan is not positively prepared.
Bellway would advocate the reinstatement of 945 dpa as the minimum figure to be provided.
Bellway are supportive of the revised 18-year plan period from 2021 to 2038. However, we are disappointed to see that the annual average housing requirement has been reduced by 14% from 945 dpa to 816 dpa. Whilst it is acknowledged that Warrington is meeting its minimum local housing need as identified by the standard method, we believe that the plan should set out a much more aspirational requirement to grow the borough.
1
The application of minimum (rather than maximum) requirements is a pragmatic approach which will allow the plan to adapt to changing housing needs over the plan period. It aligns with the updated supporting evidence base. In this regard, we find that the plan is justified and effective.
Bellway are supportive of the new distribution of housing across the borough and the dispersal of some growth to outlying settlements, including the proposed allocation of a minimum of 130 homes at Winwick (part 4(e)).
4
Smaller unconstrained sites (such as the land north of Winwick ? Policy OS6) can come forward in the meantime to deliver much needed housing. Bellway?s site at Winwick can facilitate the early delivery of new homes from 2023.
Bellway note that the plan proposes a stepped approach to housing delivery, with a lower requirement (678 dpa) in the first five years (2021 to 2025), and a higher requirement (870 dpa) in the latter 13 years (2026 to 2038).
7
This is important as there will be many considerations which inform the housing mix for individual sites. In this regard, we find that the plan is effective.
Whilst Bellway are committed to delivering a wide range of house types and tenures, it is important that the plan is flexible enough to react to changing needs over the plan period, including at the local level. We note that the policy wording has been amended to refer to the ?most up to date Local Housing Needs Assessment? and are pleased that reference to site specific considerations has been retained.
11
These additional requirements conflict with paragraphs 7, 8 and 20 of the ?Housing: optional technical standards? section of Planning Practice Guidance (?PPG?) (Reference IDs: 56-007-20150327, 56-008-20160519 and 56-020-20150327).
Bellway request that the relevant parts of this policy be amended to reflect the approach taken in part 11 (ie. by making reference to local need and site specific considerations). Without these changes, the policy is not justified or effective in this regard.
We are concerned that there is no evidence to justify the introduction of higher optional standards and that the policy does not consider there may be other site-specific factors (beyond viability and technical reasons) which make a site less suitable for such standards. Whilst, Bellway are committed to delivering a wide range of house types to different specifications, such requirements should be determined on a site-by-site basis, with consideration given to the need of the location in question and viability, as this may differ by location. Part 17 of the policy goes some way towards this but more flexibility is required in part 13.
13, 15, 16 and 17
This is a much more flexible approach and would allow such requirements to be determined on a site-by-site basis, with consideration given to the need of the individual area in question and viability. In this regard, the plan is effective.
Bellway are pleased that the requirement for 20% of homes to meet the needs of older people has been removed and replaced with a more generic statement that housing for older people should be provided on sites with 10+ units.
18
Therefore, we request the policy be amended to make reference to strategic sites in other boroughs. Without this change, the plan is not positively prepared or effective.
Bellway support the provision of over 316 hectares of employment land to support both local and wider strategic employment needs. The land to the north of Winwick (Policy OS6) is well-placed to provide new housing in a logical location to support the growth of the employment areas identified in this policy. It is also well-placed in relation to nearby strategic sites located in adjacent boroughs, including the Omega Extension (in St Helens) and the Parkside development and associated link road to the north of Winwick (also in St Helens), which were approved by the Secretary of State on 11 November 2021. However, the strategic importance of the cross-boundary travel to work areas that exist within the sub-region has not been properly recognised.
In this regard, the plan is positively prepared, justified, effective and consistent with national policy.
Bellway supports the removal of the land at Winwick from the Green Belt, to facilitate the allocation of the site to deliver minimum of 130 homes under Policy OS6.
The proposed allocation of the land north of Winwick (Policy OS6) would help prevent Winwick from merging with the main urban area of Warrington to the south, in accordance with paragraph 138 of the NPPF. In this regard, the plan is deliverable and consistent with national policy.
Bellway supports the approach to the inset settlements (including Winwick) to be protected in terms of their relationship with the main urban area and their individual scale and function. The commitment to accommodating some new development outside of the existing settlement boundary through release of Green Belt is welcomed.
Given the relatively modest scale of the proposed allocation at the land north of Winwick (Policy OS6) and its relationship to the existing settlement, it would be unreasonable to impose this requirement on Bellway?s site. Such an approach would unnecessarily delay the delivery of much needed housing within Winwick.
Bellway consider that the reference to masterplans and design codes to be deleted and any such requirement be incorporated into the specific site allocation policies (except for Policy OS6), but only where this is considered necessary and it serves a meaningful planning purpose.
Bellway note that part 6 expects masterplans and design codes to be used for larger sites and areas, and in particular for proposed urban extensions, and that such masterplans/design codes may be formally adopted as SPD's. However, the policy does not clarify what site size threshold this requirement would apply to.
6
The new homes that are built by Bellway are energy efficient. This is achieved through compliance with minimum Building Regulations requirements and a ?fabric first? approach. As Building Regulations requirements are increased by the Government over time, then energy efficiencies will consequently be achieved without the need to duplicate or increase standards through planning policies. Without the proposed change, the plan is not justified or consistent with national policy.
The Council should instead comply with the Government?s intention of setting standards for energy efficiency through Building Regulations, as part of its ambitious climate change targets. As such, part 5 should be removed or alternatively be expressed more as an ambition that such sites should aspire to achieve (instead of being imposing mandatory requirements).
Bellway note that part 5 has introduced a requirement for a 10% reduction in carbon emissions (Part L) alongside 10% renewable and/or other low carbon energy sources, as alternatives to the requirement for maximising opportunities for the use of decentralised energy networks. However, it is unclear how it is intended that developers should interpret this requirement or how it would work in practice.
5
As worded, the policy would unnecessarily increase the burden for developers of proposed allocated sites. Without changes to make clear that this requirement does not apply to allocated sites the plan is not effective or consistent with national policy.
Part 8 of the Policy should be amended to make clear that this requirement does not apply to allocated sites.
Bellway are concerned that Part 8 requires development proposals to demonstrate that any loss of the best and most versatile agricultural land will be minimised. In some instances, the public benefits of development outweigh the economic and other benefits of retaining agricultural land. Indeed, the Plan has already concluded this to be the case in proposing to release sites from the Green Belt and allocate them for development, including the land north of Winwick (Policy OS6).
8
We note that a number of changes have been made to the requirements within the policy compared with the earlier draft Policy OS9 in the Proposed Submission Version (March 2019). Overall, we are broadly supportive of the revised policy and find the plan positively prepared, justified, effective and consistent with national policy in this regard.
Bellway strongly support the proposed allocation of the land north of Winwick for a minimum of 130 homes. It is available, suitable and achievable to accommodate new homes and there are no technical constraints to its delivery. The allocation and subsequent development of the site will provide much needed new homes of a mix of tenures and sizes to meet local needs and will deliver a range of social, economic and environmental benefits. It will positively contribute towards meeting Warrington?s overall housing requirement and supports the Government?s objective of significantly boosting the supply of homes in paragraph 60 of the NPPF.
The provision and extent of housing to meet the needs of everyone should be assessed and agreed on a site-by-site basis between the Council and the developer to improve the policy from a justified and effective perspective.
A suitable caveat should be included within the wording of Part 2 of the policy.
The provision and extent of housing to meet the needs of everyone should be assessed and agreed on a site-by-site basis between the Council and the developer, having regard to local needs, the latest evidence and viability at the time of any planning application (Bellway have raised similar concerns with draft Policy DEV2 above).
2
Bellway are not aware of any substantive evidence to justify the provision of self-build/custom build plots on the land to the north of Winwick. It is understood that the Council?s self-build register shows limited need; the Local Housing Needs Assessment identifies a waiting list of 168 on the self-build register, but the report itself notes that there may be some double-counting. There is no indication that the Council has sought to understand the preferences (e.g. location and type of housing) of those who have expressed an interest. Neither Bellway nor the existing landowner have received any interest for self/custom builds on the site. Indeed, we anticipate that such a large housing estate would not be attractive to self/custom builders. Without the deletion of Part 4 of the policy, the plan is not justified.
Bellway request that Part 4 of the policy be deleted. Instead, the Council should encourage self-build/custom builders on non-allocated sites across the borough, or alternatively allocate more appropriate specific sites for this purpose, as opposed to requiring provision from sites that are under control of major housebuilders.
In order to obtain a robust assessment of the demand for self/custom build housing, local planning authorities should assess and review the data held on their registers, and then supplement it with secondary data from sources such as building plot search websites, ?Need-a-Plot? information available from the Self Build Portal and enquiries for building plots from local estate agents. Furthermore, it should be recognised that there is a need for smaller housing allocations such as Winwick to deliver homes quickly and early on in the plan period to help boost the five year supply. This is in comparison to the larger strategic sites which will require delivery of infrastructure to come forward meaning that housing delivery will be slower. The Council should reflect on the delays that could be caused by the delivery of complex self/custom builds on all sites.
4
Any requirement that threatened the viability and/or deliverability of the site would not be effective or consistent with national policy.
Whilst Bellway do not object to the principle of the requirements in parts 8 and 9, we reserve the right to comment on any methodology established in relation to financial contributions for built leisure facilities and playing pitches. For the avoidance of doubt, Bellway would not support any requirement if it threatened the viability and/or deliverability of the site.
8 and 9
Any mandatory requirement for BNG to be achieved via the metric calculator should be deleted. Without this change, the plan is not justified, effective or consistent with national policy.
Bellway request that Part 11 should seek to encourage biodiversity net gain (?BNG?) to be incorporated to the site?s overall design concept. Any mandatory requirement for BNG to be achieved via the metric calculator should be deleted.
The Defra Metric is only one way that BNG can be calculated and so any mandatory requirement for BNG to be achieved via the metric calculator should be deleted.
11
The Council has not demonstrated that any early engagement has taken place and there is no evidence to support the requirement for compensatory measures. There is no indication as to what such measures would consist of, or what the implications may be on viability. It is unclear as to how an applicant, and the decision-maker, may interpret and respond to this policy requirement. This requirement is not justified, effective or consistent with national policy.
Bellway request that this part of the policy be deleted or clarified.
Bellway objects to Part 13?s required scheme of compensatory improvements to the environmental quality and accessibility of land remaining in the Green Belt. Paragraph 2 of the ?Green Belt? section of PPG (Reference ID: 64-002-20190722) states that authorities should set out policies for compensatory improvements informed by supporting evidence and opportunities could include new or enhanced green infrastructure, woodland planting, landscape and visual enhancements and new walking routes. Paragraph 3 (Reference ID: 64-003-20190722) goes on to say that there should be early engagement with all interest groups to consider matters such as the scope of works required.
13
Bellway controls the land to the north of Winwick, between Golborne Road and Waterworks Lane, which is proposed to be allocated by Policy OS6 for a minimum of 130 homes. A supporting Delivery Statement (Appendix 1) was prepared in support of Bellway?s representations to the Proposed Submission Version in June 2019. A Coloured Sketch Layout (Appendix 2) was subsequently prepared in November 2019 and shows an illustrative layout for 160 new homes.