My comments are related to the earmarking of green belt land to meet housing targets. The National Planning Policy Framework para 74 states that ?Green Belt boundaries should only be altered in exceptional circumstances and be fully evidenced and justified? I believe the Plan does not achieve this with sufficient rigour.
Comment no.1
The treatment of ?flexibility? is biased towards the development of Green Belt in para 4.1.10. Flexibility is argued to be required to cater for variability in land supply which can only refer to urban land. However, without explanation, flexibility is incorporated by inflating the housing demand number. A !0% reduction in urban land availability, would result in that land being allocated from our Green Belt so reducing green belt requirement to 4082. Also a 10% increase in urban availability would reduce the Greenbelt requirement to 1724. I consider this is a more logical treatment of Flexibility and in both scenarios would reduce the expectation and need to develop within the Green Belt. Therefore it is essential to keep the availability of brownfield land under constant review to ensure that Green Belt development is kept to an absolute minimum.
Comment no.2
The plan is focussed towards the housing requirements related to the development of Warrington. However it is well known that a significant proportion of housing in Green field areas such as Lymm is bought by purchasers whose jobs are outside the Borough. This effect has not been addressed in the plan other than in par 3.1.10 which highlights the problem but offers no solutions. The outcome is that the current Residents of the Warrington will, in effect, lose Green Belt to accommodate the needs of neighbouring Boroughs. This highlights the need to more understand this effect otherwise it is not possible to ?fully evidence and justify? the exceptional circumstances where Green Belt will be irrevocably lost.