There is a very significant lack of evidence underpinning the delivery of sites identified within the SHLAA. A significant 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 and the past failure of sites with the town centre and the urban area to deliver has led to significant shortfalls in the delivery of housing. There is insufficient flexibility in the supply to allow for the Council to adapt to changing circumstances. Many sites included by the Council do not meet definition of ?deliverable? for the purposes of the Framework.

it is considered that there is a need to allocate additional sites for housing to boost the supply of housing and meet identified housing needs for reasons discussed elsewhere in this Statement. Emery Planning have put forward two omission sites on behalf of their client for release from the Green Belt.

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).

Emery Planning have carried out their own Green Belt assessment of the site, which concludes the sites makes a 'weak' contribution as opposed to 'strong' in the Council's assessment. The site is located to the edge of the built-up area of Lymm and is influenced by surrounding urban features e.g. Bridgewater Canal to the north, the built-up area to the west and Sutch Lane to the south with a caravan site beyond. The boundaries are readily defensible by physical barriers such that urban encroachment would not be an issue for this site. The site is unremarkable in landscape terms, and is not subject to any heritage, arboriculture or ecology constraints. The release of the site on a standalone basis would not undermine highway safety or the local road network. There is potential for a new car park/drop-off zone within the site for Ravenbank Community Primary School, and this would comprise a significant community benefit in favour of the allocation in terms of highways safety and the operation of the school. There is potential for a new road link to Oughtrington Lane as part of a wider site allocation with Land to the South of Sutch Lane, which is also being promoted for housing. All of the recommended measures to facilitate appropriate access relate to land within the applicant?s control, and the site is locationally sustainable in terms of local services and public transport provision. The release of this site would contribute to meeting the identified development needs of Lymm in a sustainable manner. Detailed information in submitted by Mr Waheed to demonstrate the site's suitability and deliverability.

Emery Planning have carried out their own Green Belt assessment of the site, and concluded the site could not make a strong contribution to the purposes of the Green Belt. The site is located to the edge of the built-up area of Lymm and is influenced by its proximity at the western and eastern edges to existing built development. The site is unremarkable in landscape terms and comprises a single field with no hedgerows or trees within the site itself. The development of the site could comprise a logical urban extension to Lymm in Green Belt terms, and would deliver a large proportion of the identified housing needs for Lymm in a sustainable manner. The site is suitable for residential development in highways terms. There is potential for a new road link to Oughtrington Lane as part of a wider site allocation with Land off Pepper Street and Sutch Lane, which is also being promoted by the same land owner for housing. This would represent a significant benefit of the development that could only be achieved through the wider allocation of Mr Waheed?s site interests. Detailed information in submitted by Mr Waheed to demonstrate the site's suitability and deliverability.