if there is a significant cross-boundary highway issue arising from the Bold Forest Garden Suburb which constrains allocations in Warrington (despite the absence of evidence that this is the case), then the Council has failed to comply with the Duty to Cooperate for the following reasons: Firstly, the Council has failed to work jointly with St Helens Council to identify the extent of the issue, and to consider whether it can be overcome through mitigation measures. No evidence on the alleged impact is presented as part of the evidence base. Secondly, the Council?s approach is inconsistent with the evidence presented to the St Helens Local Plan examination. The evidence of St Helens Council does not raise any issues in terms of the impact upon Burtonwood. As far as we are aware Warrington Council has not contested the robustness of that evidence. Thirdly, if there was likely to be an impact upon Burtonwood as a result of allocations in St Helens (of such significance that it necessitated Warrington Borough Council to alter its Local Plan) then it could have been expected that Warrington Borough Council would have objected to the St Helens Local Plan. However, the Statement of Common Ground between Warrington Council and St Helens Council submitted to the St Helens Local Plan examination references the Bold Forest Garden Suburb at paragraphs 4.19 and 4.20, but does not raise the possibility of severe impacts or suggest that it may constrain future development in Burtonwood or any other part of Warrington. It simply commits the parties to continue working together to understand that impacts and to agree the details of any necessary mitigation through the masterplanning process (bearing in mind that the principle and quantum development would be established by the allocation). The position agreed in the St Helens Local Plan examination appears to contradict the position set out at paragraph 4.33 of the draft Statement of Common Ground that Warrington Council has published as part of the evidence base of the UPSVLP, which states that ?WBC is particularly concerned about the potential impact on residents in Burtonwood?. It remains to be seen whether St Helens Council will agree with that position, and if it does agree, presumably this then needs to be raised with the Inspector examining the St Helens Local Plan.

The proposed plan period for the Warrington Local Plan is 2021 to 2038. The base date, primarily used for the monitoring of the housing and employment land supply, is 1 April 2021, and therefore the end date of the strategic policies relating to housing and employment land supply is 31 March 2038. This means for the strategic policies to cover at least 15-years from adoption, it must be adopted by 31 March 2023 which is before the date of adoption set out in the latest Local Development Scheme of July 2023 which in itself is considered to be unrealistic. Further, the housing trajectory seems to run to 2039 which is in conflict with the proposed end date of the Plan. The policies of the Warrington Local Plan should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. However, the UPSVLP does not set out any vision looking beyond 2038. There is very little consideration of housing and employment needs and supply beyond the end of the plan period. The analysis of the housing need and supply position beyond the plan period is inadequate and flawed. Save for identifying that some sites will continue to deliver beyond the plan period, there is no realistic vision or direction for how future needs may be met.

The UPSVLP seeks to pursue the minimum housing requirement derived from the Standard Method, but pays little regard to the need to boost the supply of housing, tackling the affordability issues, aligning the housing requirement with the Plan?s economic aspirations or seeking to boost the supply of affordable housing to meet existing needs.

The Council's reasons in discounting a higher level of development in the outlying settlements are spurious and without any substantive evidence. No consideration has been given to the development capacity and needs of individual settlements. It was considered by the Council in the 2019 PSVLP that there was a need to allocate land to provide 160 dwellings in Burtonwood, and that there were exceptional circumstances to justify the release of Green Belt in the settlement. However, the 2021 UPSVLP now proposes no allocations or Green Belt release in Burtonwood. There is no justification for this change of approach. Warrington has not provided any evidence on the highways impacts on Burtonwood arising from the Bold Garden Suburb in St Helens and whether these impacts can be overcome. The Council?s approach is inconsistent with the evidence presented to the St Helens Local Plan examination. The evidence of St Helens Council does not raise any issues in terms of the impact upon Burtonwood. if there was likely to be an impact upon Burtonwood as a result of allocations in St Helens (of such significance that it necessitated Warrington Borough Council to alter its Local Plan) then it could have been expected that Warrington would have objected to the St Helens Local Plan. However, the Statement of Common Ground between Warrington Council and St Helens Council submitted to the St Helens Local Plan examination references the Bold Forest Garden Suburb at paragraphs 4.19 and 4.20, but does not raise the possibility of severe impacts or suggest that it may constrain future development in Burtonwood or any other part of Warrington. It simply commits the parties to continue working together to understand that impacts and to agree the details of any necessary mitigation. Wain Homes do not agree with the Council's conclusion that the omission of development in Burtonwood does not have a material impact on the Plan's spatial strategy. The Council?s own evidence identifies a need to allocate land and release Green Belt in these settlements to meet development needs. If allocating land in the outlying settlements does not have any impact on the spatial strategy, then the exceptional circumstances would not exist for Green Belt release in any of the settlements. The Council?s decision not to provide any allocations in Burtonwood fails to have any regard to local development needs, including the need for affordable housing, the sustainability of Burtonwood and the need to support and maintain the village?s services and amenities in the future. The Council?s decision also fails to consider whether there are sustainable options for meeting development needs in Burtonwood.

Wain Homes? representations in relation to housing land supply are addressed in the submissions of Lichfields made on behalf of the consortium of developers and housebuilders. In addition Wain Homes consider there is an overreliance on the SHLAA to deliver housing in the plan period for the following reasons: there is a lack of evidence underpinning the delivery of sites identified in the SHLAA; a great number of the SHLAA sites are not proposed to be allocated and do not have planning permission; identifying a site as developable in the SHLAA provides no guarantee that it will become available or that a planning permission will be implemented; the Council?s supply includes large numbers of apartment schemes in central Warrington which have densities not underpinned by robust evidence and raises issues of market delivery; the past failure of sites with the town centre and the urban area to deliver has led to significant shortfalls in the deliver of housing; the Council?s own evidence on viability indicates that much of the SHLAA supply is not viable. Notwithstanding our concerns in relation to the identified housing land supply, we consider the flexibility factor of 10% is insufficient given past under delivery and lack of any safeguarded land. Only once the Council has a clear understanding of its deliverable supply can the appropriate strategic policy response be made. But from the evidence available, it is very clear that the plan would not provide a 5-year housing land supply on adoption and the supply needs to be boosted significantly by further site allocations.

We object to this approach for the following reasons: There is no evidence to suggest that the need will be less in the early years of the plan; the proposed phased approach is contrary to paragraph 60 of the Framework, which requires the Council to support the Government?s objective of ?significantly boosting? the supply of homes by bringing forward a sufficient amount and variety of land where it is needed; the Secretary of State can have no confidence that the higher levels of delivery in later years will ever be applied as a housing requirement.

National policy is clear on the need to ensure that Green Belt boundaries will not need to be altered at the end of the plan period (currently 2038). This is a critical aspect to achieving the intended permanence in the long term. The appropriate mechanism for achieving this is through the provision of safeguarded land. Based on the Cheshire East EIP sufficient safeguarded land should be provided to ensure that the current requirement could be carried forward to the next plan period (i.e., 2038 to 2053 based on the current plan period in the UPSVLP) without the need for Green Belt release. In practice the minimum requirement is to provide a similar amount of safeguarded land to the amount of Green Belt being released for development in this plan period. Ideally more should be provided, to allow flexibility for higher growth and to increase the permanence of the Green Belt. In considering development beyond the Plan Period, the Council has considered too short a period; has not used the minimum local housing need figure to consider future need; incorrectly incorporates the Plan's flexibility factor into supply; overestimates urban capacity beyond the Plan Period. Furthermore, the UPSVLP does not provide any safeguarded land within the outlying settlements, despite the Council simultaneously determining that there are exceptional circumstances to justify Green Belt release to allocate sites in those settlements to meet needs during this plan period.

In terms of lead-in times, the Council?s evidence should address: how long a planning application will take to prepare, submit and be determined; how long it will take for the s106 agreement to be negotiated and agreed; whether an allowance needs to be made for the site to be sold to a developer/housebuilder; how long it will take for applications for reserved matters and discharge of conditions to be made, considered and approved; whether there is infrastructure that needs to be put in place before the site can start delivering dwellings and how long this will take; and whether there are any other site-specific considerations which would affect a start on site. The lead-in times are particularly important for the very large allocations such as this, which by their nature will have a range of issues to be addressed through applications and will need sufficient time for section 106 agreements to be executed, a start to be made and infrastructure put in place. Whilst the early phases may be further progressed, the remainder of the site to be released from the Green Belt is not part of that site and the above considerations all still apply. Having regard to the above, the proposed build rates are not justified. It is not clear how these could be achieved within a realistic phasing plan and the land ownership across the site.

The site allocation proposes the release of an area of Green Belt within an extremely narrow and sensitive gap between two towns. The Council?s own Green Belt assessment indicates that this land makes a ?strong? contribution to the Green Belt purposes. The greenfield parts of the site are not sustainable locations. They are isolated pockets of land which are distant from existing services and facilities. there are significant contamination and remediation issues which mean that 1,300 dwellings are unlikely to be realised during the plan period. There is a clear lack of evidence in relation to the true scale of remediation required. it is not clear if the site is viable. The Council?s viability assessment indicates that the site is of marginal viability based on the full policy requirements, but there are very significant uncertainties around the scale and cost of remediation needed at this site. It is also not clear what costs would be associated with providing a suitable vehicular access the railway to the land to the south (including the need for any emergency access points). These costs do not appear to have been factored into the Council?s viability assessment, and we are not aware of any study which seeks to quantify the costs of remediation or railway crossings. The Council has also failed to provide sufficient evidence as to how the proposed lead-in times and build rates can be achieved across such a complex site. For the reasons given above, we do not consider that it is realistic to assume 1,300 dwellings from this site during the plan period.

The document states that all sites in the outlying settlements making a strong contribution to the Green Belt have been discounted. It is not clear why all such sites have been discounted in principle. This is just one of many factors that should be weighed in the balance when considering whether to allocation a site for development and release it from the Green Belt. The Council has identified the site allocation at Fiddlers Ferry, which relates to land that partly makes a strong contribution to the Green Belt as per the assessments carried out for the local plan evidence base. We consider that further consideration should be given to the impact of potential alternative on the Green Belt and what mitigation may be possible through landscape planting and buffers for instance. The same approach set out by the Council through the Implications of Green Belt Release Report (2021) should be adopted for potential alternative site allocations. It is considered the Council's site selection process falls short of what is required to ensure a fair and transparent site selection process that contributes to the emerging local plan overall vision and objectives. It is contrary to the PPG, which advises that all land should be assessed together as part of plan reparation to identify which sites are the most suitable and deliverable for a particular use (paragraph 3-001).

Wain Homes have carried out their own Green Belt assessment of the site, which concludes the sites makes a 'weak' contribution as opposed to 'moderate' in the Council's assessment. The site is not assessed in the through the updated Development Options and Site Assessment Technical Report & Site Assessment Proformas. We presume that this is because of the Council?s erroneous decision not to allocate any sites in Burtonwood due to alleged highways constraints. The position in Burtonwood must be reconsidered and the sites properly assessed, with a view to allocating sites and providing safeguarded land to meet current and future development needs. Wain Homes disagrees with the previous assessment carried out in the Development Options and Site Assessment Technical Report (March 2019) in respect of the inability to provide pedestrian footways and disagree with the authority?s conclusion that the site could not come forward as part of a wider allocation due to the resulting development being beyond the housing requirement for Burtonwood. Wain Homes consider there is a need to allocate additional sites if the Council is going to meet its housing requirement. Detailed information in submitted by Wain Homes to demonstrate the site's suitability and deliverability.

The evidence base clearly demonstrates that both the wider parcel, and our client?s land specifically, do not make a ?strong? contribution to the Green Belt purposes, and its development would not result in the towns of Warrington and Runcorn merging. The Council?s decision to delete the South Western Warrington Urban Extension, including our client?s land, therefore conflicts with the Council?s own evidence on the Green Belt. As set out above, the site is considered capable of being developed as part of a South Western Warrington Urban Extension without resulting in unrestricted urban sprawl or coalescence of urban areas and with respect to landscape and visual matters. This is further supported by the previous proposal to allocate the South Western Warrington Urban Extension in the 2017 version of the plan, and also the proposed allocation of the South Western Warrington Urban Extension under Policy MD3 of the 2019 Regulation 19 version. The inclusion of our client?s site within the South Western Warrington Urban Extension would result in clearly defined, strong defensible boundaries that would contain development and would not encourage future sprawl. Wain Homes have confirmed the site is deliverable as part of the wider urban extension or as a stand alone development. The provision of developer contributions to local services such as education and health facilities could be secured at the planning application stage. A wider South Western Warrington Urban Extension could deliver new infrastructure on site as part of a comprehensive masterplan