Redrow acknowledge that following the decline of high street shopping, town centres need to regenerate and that introducing new residents to the town centre forms part of this transition. Directing increased levels of housing to the Town Centre, primarily in the form of high density apartments can and should continue to be encouraged, however any proposed increase in delivery rates should be dealt with independently of the housing requirement for Warrington. Serious viability and deliverability concerns exist from this particular source of housing land supply.

Being located at the junction of the M6 and M62, on the West Coast mainline and surrounded by a critical mass of population within a commutable distance (Greater Manchester, Merseyside, Cheshire and Lancashire), Warrington has a distinct advantage when compared to other locations. This is borne out by the overwhelming success of the regional employment sites at Birchwood and Omega (which is continuing to expand, even into neighbouring St Helens to help meet their neighbouring employment land requirements). Considering the potential that these locations and the new Employment Areas at Fiddler?s Ferry (101 hectares) and South East Warrington (137 hectares) bring, it is clear that Warrington is a location that would buck the national and regional trend when it comes to economic growth and the potential for job creation is therefore significant. The 10% flexibility figure has only been introduced to account for potential shortfalls in the rate of delivery from identified sources of housing land supply and so is not a mechanism that should be used to capture economic growth aspirations. The baseline housing requirement is therefore what needs to be considered within this context. Following net annual housing completions of 359 (2017-18), 503 (2018-19) and 541 (2019-20) Warrington?s 2020 Housing Delivery Test measurement is 57%, meaning that in accordance with paragraph 14 of the NPPF, the presumption at paragraph 11d applies. The 2021 Local Housing Needs Assessment (LHNA) has also confirmed that affordable housing needs have increased in recent years. The 2021 LHNA has identified an affordable housing need of 433 homes per annum, which has increased significantly in a short space of time with the 2019 LHNA identifying a need of 377 homes per annum; a 15% increase. This will in the most part be due to the historic shortfall in housing completions that has occurred in Warrington. It is also considered that an uplift to the standard method of 816 dpa can be justified in accordance with Planning Practice Guidance as ?strategic infrastructure improvements that are likely to drive an increase in the homes needed locally, in the interests of achieving sustainable development.? are proposed, such as the Western Link. It has been established that a viability gap exists in respect of the delivery of this road and the homes proposed within the town centre and Inner Warrington are not likely to be able to make the financial contributions necessary to contribute towards its delivery.

The Local Housing Needs Assessment (LHNA) (GL Hearn, August 2021) stated that Town Centre sites are forecast to generate around 42% of new homes, despite constituting only 12% of sites within the Local Plan supply. The LHNA suggests a mix of housing size and tenure of which family homes comprise a large proportion. In addition, the LHNA suggests that it is likely that most 2 bedroom homes should be built as houses (or bungalows) rather than flats. Given the high densities proposed in the town centre area, where the majority of 2-bedroom properties are likely to be located, it seems unlikely that this will be achievable. Redrow is therefore concerned that Warrington will not meet its housing requirement by failing to provide sufficient family housing, due to an overreliance on high density development within Warrington Town Centre.

Redrow do not consider that Warrington Borough Council will be able to achieve the delivery rates prescribed by the Local Plan, even with the housing requirement stepping up after the first five years (from 678 dwellings per annum to 870 dwellings per annum). This indicates a clear requirement to bring forward more sites in the first five years of the Plan period (greenfield sites outside the town centre that are able to be delivered within the first five years and provide affordable housing and the necessary supporting infrastructure investments). There is little evidence to suggest that the existing urban area of Warrington will deliver a higher rate of housing completions than historic trends suggest, especially when considering that the new housing at Chapelford Urban Village accounts for a significant proportion of new housing over the last 10 years. Warrington Borough Council are currently operating under the presumption in favour of sustainable development, as housing delivery has fallen below 75% of the housing requirement over the last 3 years, with the measurement being 57%.

Warrington has underperformed in terms of affordable housing delivery in recent years, with just 112 affordable housing completions reported in 2018/19 and 131 in 2019/20 and there has been an average of 142 affordable housing completions per annum for the period 2011-2020. This is notably lower than the annual affordable housing need identified in the 2021 LHNA (433 affordable homes per annum). When considering Warrington?s Housing Land Supply position, Redrow's representation has confirmed that planning applications are consistently accompanied with Viability Appraisals within the Town Centre and Inner Warrington, meaning that 20% affordable housing will simply not be delivered in the majority of cases on what is anticipated to account for 42% of future housing land supply. Redrow also have concerns regarding the realism of the quantum of housing that is anticipated to be delivered in the town centre as there is an absence of a strong housing market to make schemes viable on challenging sites and concerns regarding the availability of sites. Part 6 of Policy DEV2 then goes on to states that at least 25% of affordable housing units delivered by developers through planning obligations should be First Homes, and that these First Homes must be discounted by a minimum of 30% against market value and that this will be increased to a 40% discount south of the Manchester Ship Canal having regard to the nationally set cap of ?250,000. Redrow do not dispute the need for affordable but it must take into account viability on a case by case basis and provide flexibility to that effect.

Policy DEV2 requires that residential development should provide a mix of different housing sizes and types and should be informed by the Borough-wide housing mix monitoring target provided in WLP ?Table 3: Housing Demand in Warrington?. Table 3: demonstrates that the greatest demand in respect of market housing is for 3-bedroom family housing, accounting for 50% of overall demand. Redrow do not consider it appropriate to establish a prescribed housing mix at a borough wide level. The housing mix proposed in respect of individual schemes should take into account the findings of the most up-to-date Local Housing Needs Assessment, the requirements of Registered Providers and viability considerations relevant to the site and location in which the housing is proposed. This will help to ensure that actual housing needs are met on a case by case basis, which will inevitably vary owing to geographic location, market factors and changes in market conditions and housing needs over time.

Housing: optional technical standards Planning Practice Guidance (PPG) requires that justification for requiring internal space standards is provided by Local Planning Authorities. Redrow do not consider that Warrington have provided sufficient evidence of clear need to adopt internal space standards, nor has it been demonstrated that the inclusion of the NDSS standard does not affect the viability of development. Furthermore, there is also no ?reasonable transition period? following the Plan to enable developers to factor the cost of space standards into future land acquisitions.

Redrow supports the allocation of Culcheth Village as a neighbourhood centre and Glazebrook Village as a local centre, in the ?Hierarchy of Centres? in Policy DEV5

Notwithstanding Redrow?s doubts about whether the quantum of sites within the existing Warrington urban area and town centre in particular will even come forward, there seems a real risk that a strategy which relies so heavily on high density urban sites will fail to deliver enough of the type of dwellings required in the types of locations required. Redrow?s specific concerns are that the proposed strategy will not deliver sufficient levels of affordable or family housing to cater for the clear unmet need that exists. More sites are required in a variety of locations to provide a degree of choice and to meet market demand. The land being promoted by Redrow in Culcheth and Glazebrook have a particular role to play in providing housing that is more aspirational and is known to meet evidence housing demand in Warrington, as well as the requisite level of affordable housing.

Paragraph 143 of the NPPF states that identifying areas of safeguarded land would assist with ensuring that the Green Belt boundaries proposed endure and longer-term development needs are met well beyond the existing plan period. A trigger mechanism based upon actual rates of delivery should be incorporated in respect of future Local Plan reviews, which is an approach recommended at paragraph 33 of the NPPF. This would enable safeguarded land to come forward for development earlier in the plan period should the housing trajectory currently anticipated in the WLP fail to deliver the required level of housing. Policy M1 ?Local Plan Monitoring and Review? is the mechanism to achieve this. Redrow?s view is that this should also be taken a step further and suitable sites identified now as suitable ?Plan B? sites should these circumstances arise. This approach was endorsed by the Inspector conducting the Examination into the West Lancashire Local Plan and Policy RS6 sets out the triggers that apply for ?Plan B? sites to be considered, which are related to housing delivery performance considered against the housing target.

According to the LHNA town centre residential development accounts for around 42% of total supply, although it not made explicitly clear within the evidence base exactly which sites make up the supply, nor how they relate to the Town Centre Masterplan. Concerns have been expressed elsewhere in this representation regarding this approach and the absence of any compelling evidence to justify the approach being taken. The type of housing needed in Warrington will not be delivered (family housing and affordable housing) and significant concerns exist in respect of viability and the ability for these sites to contribute towards or deliver the key infrastructure needed to support development of this scale. The Housing Delivery Test measurement, appeal decisions and continuous absence of a five year housing land supply all described within this representation clearly point towards alternative sources of housing land supply needing to be identified if Warrington?s housing requirement is to be met in full during the plan period.

Redrow agree that new development should be located in areas with easy access to high quality and regular public transport services and in sustainable and accessible locations. As set out in Section 5 of this
representation, a greater level of housing growth can be sustained in Culcheth and this approach to housing distribution would adhere to the principles set out under Policy INF1. Likewise, being located immediately adjacent to Glazebrook train station, the land being promoted by Redrow would adhere to these principles, representing sustainable development that promotes the use of public transport.

Policy INF2 identifies the proposed route of the Warrington Western Link as safeguarded land as it is considered essential to support the spatial strategy set out within the WLP. On this basis, a significant quantum of residential development is proposed to come forward within these areas, which has influenced the overall spatial strategy contained within the WLP. Redrow have concerns regarding this approach as the Western Link still needs additional funding to be delivered and once secured, it will take a number of years to be constructed and in turn housing completions will come forward much later in the plan period than currently envisaged. When considering the overall spatial strategy in respect of meeting employment land needs, the WLP (at paragraph 3.3.26) has effectively constrained the identification of new employment sites at this stage until such point as key infrastructure, including the Western Link, is delivered.

The LHNA confirms that the Town Centre is to account for around 42% of all new homes over the Plan Period and Section 4 of this representation confirms that residential developments within the Town Centre are consistently accompanied with a Viability Appraisal and that a planning contribution towards wider infrastructure provision is not considered to be viable. Sites that are known to be deliverable and viable should represent a much greater proportion of the overall housing land supply for Warrington if the objectives of Policy INF5 are to be fulfilled. This will not only ensure that the impact of new residential developments are appropriately mitigated against, it will also help to contribute towards any infrastructure deficits that currently exist to the benefit of existing communities. The sites being promoted by Redrow in Culcheth and Glazebrook are known to be viable and deliverable and so therefore can provide an appropriate planning contribution towards essential infrastructure in line with the principles set out under Policy INF5.

Designing high quality, accessible neighbourhoods that encourage walking, cycling and public transport are at the heart of what Redrow strive to achieve, as well as incorporating best practice principles such as Manual for Streets wherever possible and so the principles of Policy DC6 are supported. To demonstrate this, Redrow have prepared an innovative placemaking framework which establishes eight design principles (the ?Redrow 8?) to define how Redrow achieve high quality design within all their developments. These core principles are ably demonstrated through the intended approach that is to be taken in respect of the three sites in Culcheth and Glazebrook being promoted by Redrow as part of this consultation response.

Redrow welcome the acknowledgement that carbon reduction targets in the short term should align with an achievable betterment (10%) against the Building Regulation (Part L) in respect of carbon reduction as this is a standard that the housing industry are currently striving to achieve. There are however other initiatives emerging such as the Future Homes Standard, which is a transition that Redrow and the rest of the housebuilding industry are also familiar with. Redrow are of the view that reference to meeting the Future Homes Standard could also be included within the policy wording in order to take into account wider industry standards. This allows for any further changes to Building Regulation (Part L) to be accounted for because as currently worded, the 2013 regulations which are currently in force are not explicitly referred to. It could therefore be the case that future changes to Building Regulation (Part L) aligns itself with the Future Homes Standard, at which point a 10% carbon emissions reduction against Part L could be considered onerous.

Redrow support the recognition of the importance that monitoring has and that it is essential to ensure that sufficient housing site are identified to meet Warrington?s housing requirement on a rolling basis. Redrow do however have some concerns in respect of some elements of the policy wording. Given the concerns expressed earlier in this section regarding the impact that higher density development will have on delivering the known demand that exists for family housing in Warrington, Redrow strongly object to Criterion 2c, which intends considering increasing density on allocated sites in order to increase the delivery of housing and affordable housing. Increasing density does also not necessarily make developments more viable. Criteria 3 and 4 of Policy M1 need to be more committal in respect of the need to undertake a review or partial review of the Local Plan should there be an identified shortfall in housing land supply. The identification of safeguarded land and the ability for unallocated sites to come forward in line with the presumption at paragraph 11 of the NPPF should also be incorporated. The continued absence of a five year housing land supply would represent a fundamental failing of the WLP to plan proactively for Warrington?s future housing needs. Paragraph 33 of the NPPF requires policies to be reviewed to assess whether they need updating no later than five years from the adoption date of a plan, irrespective of any monitoring activity. The criterion set out under Policy M1 therefore need to provide sufficient clarity and commitment to proactively address a shortfall in housing land supply as soon as it occurs.

Redrow have a number of fundamental concerns with the housing strategy as it relates to the Town Centre and Waterfront areas, which can be summarised as follows: The claimed annual completion rate of 421 dpa from the Town Centre and Waterfront areas based upon the Warrington Town Centre Masterplan is considered to be overly optimistic in consideration of past trends in Warrington; A number of the identified SHLAA sites lie within Flood Zones 2 and 3 and so from a sequential perspective, other sites are available and better placed to meet housing needs within Flood Zone 1, especially within the context of the Green Belt review that is being undertaken as part of the Local Plan preparation process; The complexity of land ownership and tenancies has not been taken into account when producing the Town Centre Masterplan and so a non-delivery rate must be applied from this source of housing land supply; The considerable length of time needed to deliver the Western Link Road has not been factored in to the Housing Trajectory for the Waterfront Area in particular and so a considerable lead-in time should be allowed for before the development can be considered capable of delivering a significant quantum of housing (10 years is suggested). There are concerns with the viability of town centre development as evidenced in the Council's own Local Plan viability assessment which questions the deliverability of dwellings, their ability to contribute to required infrastructure as set out in the Infrastructure Delivery Plan and to contribute to meeting Warrington's affordable housing needs. Redrow have concerns with the validity of the Council?s claim that all of the SHLAA sites that have been identified are developable. SHLAA sites that have been the subject of a now expired planning permission could still remain within the ?developable? housing land supply, but have simply been pushed further back into the plan period. It is therefore incumbent upon the Council, to adequately test the reasons as to why individual sites may not have come forward. For example, in respect of a site?s availability this could mean establishing whether there are any unresolved multiple ownerships that may have resulted in the site not coming forward for development. This exercise does not appear to have been undertaken in respect of the SHLAA sites in the urban area that might historically have been stalled. On this basis, Redrow consider that a non-delivery rate of 10% from this source of housing land supply is
entirely justified and additional Green Belt sites should identified as new Housing Allocations to make up the shortfall in the baseline supply position.

Redrow have a number of fundamental concerns with the housing strategy as it relates to the Town Centre and Waterfront areas, which can be summarised as follows: The claimed annual completion rate of 421 dpa from the Town Centre and Waterfront areas based upon the Warrington Town Centre Masterplan is considered to be overly optimistic in consideration of past trends in Warrington; A number of the identified SHLAA sites lie within Flood Zones 2 and 3 and so from a sequential perspective, other sites are available and better placed to meet housing needs within Flood Zone 1, especially within the context of the Green Belt review that is being undertaken as part of the Local Plan preparation process; The complexity of land ownership and tenancies has not been taken into account when producing the Town Centre Masterplan and so a non-delivery rate must be applied from this source of housing land supply; The considerable length of time needed to deliver the Western Link Road has not been factored in to the Housing Trajectory for the Waterfront Area in particular and so a considerable lead-in time should be allowed for before the development can be considered capable of delivering a significant quantum of housing (10 years is suggested). There are concerns with the viability of town centre development as evidenced in the Council's own Local Plan viability assessment which questions the deliverability of dwellings, their ability to contribute to required infrastructure as set out in the Infrastructure Delivery Plan and to contribute to meeting Warrington's affordable housing needs.

Redrow consider the lead in times and delivery rates for the SEWUE to be realistic. As such the site is capable of delivering the level of housing set out in the Local Plan's Housing Trajectory.

Detailed technical work to inform feasibility and viability considerations has not been undertaken on what is an extremely complex site. For example, critical to the delivery of the housing proposed to the south of the railway line will be the ability to access the land. A bridge is currently in situ across the railway line, however this incorporates a number of pipelines and it is clear from the Regeneration Vision document that no technical feasibility work has been undertaken to assess the capability of the bridge to accommodate the traffic and vehicle movements necessary to serve the site. If the bridge needs replacing this represents a significant cost that could have a severe impact upon the ability to deliver housing to the south of the railway line on a viable basis. Redrow questions the approach being taken at Fiddler?s Ferry from a Green Belt perspective as it is inconsistent with previous stages of the Local plan preparation process, which have avoided the release of critical locations that make a ?Strong Contribution? to the five purposes of the Green Belt.

In the interests of planning for sustainable growth and in the context of Redrow?s concerns regarding the potential shortfall from other sources of housing land supply, our view Is that a much higher level of housing growth should be directed towards Culcheth. A housing distribution figure of around 600-700 homes is entirely appropriate and proportionate to the size of the settlement of Culcheth and the range of accessible shops and services within its Neighbourhood Centre. It will enable an increase in delivery of much needed affordable housing in the village. Redrow considers that the Council's Sustainability Appraisal and site assessment process has overstated the negative impacts of land west of Culcheth and understated its benefits. Conversely, the impacts of the site proposed to be allocated at Warrington Road have been understated and benefits overstated. Redrow does not agree with the conclusions reached in respect of the Land west of Culcheth, compared to the site allocated at Warrington Road, in both Green Belt terms and promoting sustainable means of transport. Redrow?s analysis has demonstrated that Land west of Culcheth is the most sustainable site in Culcheth and should be allocated for residential development. Nevertheless, should the housing distribution figure increase in Culcheth, as Redrow has demonstrated it should, or in the worst case scenario that additional land be required to be safeguarded beyond the Plan period, Land west of Culcheth has been identified as the most suitable alternative, taking other submitted sites in to consideration. Redrow can confirm that the site is capable of delivering around 350-450 family homes (including affordable housing) in Culcheth, helping to ensure that the WLP housing strategy meets housing needs in full and achieves an appropriate distribution of growth around the District of the type, size and mix required to meet the identified needs.

The site is available, suitable and achievable with a realistic prospect that housing will be delivered on the site within five years and represents a unique opportunity to deliver a truly sustainable development. The development is centred around Glazebrook Train Station, which will provide residents with direct access to the wide range of employment, shopping, leisure and cultural opportunities available in Manchester, Liverpool, Warrington and Trafford Park. The development also offers the opportunity to significantly enhance the use of Glazebrook Train Station through the provision of a Park and Ride Facility, promoting sustainable methods of travel. Redrow can confirm that the site is capable of delivering around 600-700 family homes (including affordable housing) in Glazebrook, helping to ensure that the WLP housing strategy meets housing needs in full and achieves an appropriate distribution of growth around the District of the type, size and mix required to meet the identified needs. Small scale commercial and community uses can also be integrated into the scheme and the inter-relationship with neighbouring Cadishead and Irlam further enhances the sustainability credentials of the site.

Redrow consider that a much higher level of housing growth in Culcheth (650-750 dwellings) is entirely justified given the size of the settlement (third largest in the borough), the wide range of shops and services
available (the settlement has the infrastructure capacity to accommodate more housing) and the need for the outlying settlements to make up the considerable shortfall that exists in relation to existing sources of housing land supply. Within this context, Redrow can confirm that this site is deliverable and has the capacity to accommodate around 70 homes.