UPSVLP 2473
To be sound, the Plan needs to be Positively Prepared. The guidelines state the strategy must, as a minimum, seek to meet the area's OBJECTIVELY ASSESSED NEEDS.
1.The Warrington Local Plan fails to comply with this requirement, as it has completely failed to assess or take into consideration the needs of a large sector of local needs, namely the equestrian sector. The needs of horse riders and carriage drivers have not been taken into account throughout the plan. The Statement of Community Involvement requires consultation with a wide range of people and organisations, but the list of consultees provided in Appendix A to the document does not include any representative body for equestrian interests, whether national or local, whereas it does include bodies representing other active travel and recreational interests, for example a local cycling body and inland waterway users.
2. The need for improvement to the Rights of Way provision in Warrington is clear from 2.1.56, which clearly reveals a serious shortfall in provision of Rights of Way usable by equestrians. However, the Plan completely fails to address the need for Rights of Way provision for equestrian users, mentioning it only in the context of cycling and walking. There is no reference to the Council's Rights of Way Improvement Plan (ROWIP) in the document. NPPF paragraph 100 states that planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users
1. Consultation with those representing equestrian interests should be undertaken to objectively assess the needs of horse riders and carriage drivers. The needs thus identified should be taken into consideration throughout the plan, with particular emphasis on issues relating to travel and transport, active travel, recreational facility provision and green infrastructure.
2. The Plan should include specific commitments relating to the improvement of Rights of Way provision for all users, including equestrians (both horse riders and carriage drivers)
I have made specific recommendations for modifications in other representation forms included in this response.
The policy fails to recognise that horse riding is a form of active and sustainable travel. The principles in 1(b) and (e) risk exclusion of or harm to equestrians, who are a legitimate road user class. Similarly, the policy in 2(a) and (c) is unsound in that it excludes a significant user category and specifically speaks of Rights of Way only in the context of walking and cycling. Thus it fails to objectively assess and meet the area's needs as there is a substantial equestrian user community. NPPF para 100 speaks of enhancing rights of way for users and does not constrain this to just cyclists and walkers as the Draft Local Plan does.
In all the following, the wording should be amended by adding the relevant equestrian designations to the existing references to cycling and walking:
7.1.2 should incorporate horse riding as an alternative travel mode
INF1 1(b) should include horse riding to avoid exclusion
INF1 1(e) should include horse riders and carriage drivers
INF1 2(a) should include horse riders and refer to Multi-User, rather than cycling and walking networks to avoid exclusion
INF1 2(c) should include horse riding to ensure the safety and inclusion of equestrians
These amendments would ensure that the Plan is inclusive of all user groups and therefore meets the area's needs
Paragraph 7.1.2. Policy INF1 part 1(b) and (e), 2(a) and (c)
The policy fails to recognise that horse riding is a form of active and sustainable travel. It risks exclusion of or harm to equestrians, and is therefore unsound through failing to assess and meet the area's needs as there is a substantial local equestrian base.
To make the plan sound, it must assess and meet the area's needs and those needs include the needs of equestrians. In order to achieve this, the following amendments are required within MD3:
10.3.1 Horse riding must be added to the community infrastructure requirements
10.3.8 Facilities alongside the A562 must also include equestrian needs to avoid risk of excluding equestrians from connections
MD3.3 29(b) should be changed to walking, cycling and horse riding routes
30 'footpaths and cycleways' should be changed to 'footpaths and bridleways/byways' or otherwise be made inclusive of equestrians
33 The Council's aspirations for the enhancement of the TPT and St Helens Canal should extend to the inclusion of equestrians
The above would enable the Plan to meet the area's needs in relation to MD3
paragraphs 10.3.1 and 10.3.8.
Equine sector is very substantial in the Warrington area and should be taken into consideration in the creation of the Local Plan. Important value to the local economy. As legitimate road users equestrians desperately need safe routes because the accident statistics in respect of horse on the roads are horrific. There have been 4,140 incidents reported to the British Horse Society since 2010; 89% of these incidents involved vehicles passing too close to the horse and/or too fast. Nationally equestrians have just 22% of the rights of way network which is increasingly fragmented by roads, which were once safe rural routes, that have become busy thoroughfares. In Warrington, according to the figures provided in paragraph 2.1.56 of the Local Plan, this figure is just 5% (7 miles out of a total of 136 miles of public rights of way). It is therefore even more important that any infrastructure relating to non-motorised users must consider equestrians in addition to walkers and cyclists.