Comment

Representation ID: 9189

Received: 03/09/2025

Respondent: AM Littler, NJM Littler and C Leigh

Agent: J10 Planning

I&O_9682
Yes Additional evidence may usefully include an assessment of Agricultural Land Quality + Waste & Minerals capacity/resource to understand other constraints to land release.

Comment

Representation ID: 9334

Received: 27/08/2025

Respondent: Ashall Land

Agent: Marrons

I&O_9828
We welcome the additional evidence listed at 1.19, particularly the Housing Needs Assessment, Strategic Viability Assessment, Land Availability Assessment, and Infrastructure Delivery Plan. We note that a Strategic Housing Market Assessment (SHMA) and an Integrated Impact Assessment (IIA) are not listed here and suggest these additional assessments are undertaken by the Council. Additionally, we recommend a Landscape Study / Strategy, which should include the review of Key Settlement Gaps (KSG) outside of the Green Belt, is included in the evidence base for the new Local Plan. The current Landscape Strategy (Part 1 and Part 2) includes local landscape designations dating back to the Vale Royal Local Plan (2006) evidence base and is therefore in need of a comprehensive update. This will help inform the Council’s approach policies on potential growth in specific areas such as Northwich, which are currently constrained by existing policies.

Comment

Representation ID: 9381

Received: 03/09/2025

Respondent: Trustees & Beneficiaries of Ms D Bentley dec'd

Agent: J10 Planning

I&O_9876
Yes Additional evidence may usefully include an assessment of Agricultural Land Quality + Waste & Minerals capacity/resource to understand other constraints to land release.

Comment

Representation ID: 9551

Received: 03/09/2025

Respondent: C, M and R Allsop

Agent: J10 Planning

I&O_10046
Yes Additional evidence may usefully include an assessment of Agricultural Land Quality + Waste & Minerals capacity/resource to understand other constraints to land release.

Comment

Representation ID: 9665

Received: 03/09/2025

Respondent: Vistry Group and J Whittingham

Agent: J10 Planning

I&O_10161
Yes Additional evidence may usefully include an assessment of Agricultural Land Quality + Waste & Minerals capacity/resource to understand other constraints to land release.

Comment

Representation ID: 9781

Received: 03/09/2025

Respondent: SA, and SJ Arden, J C Coombs and J Hand

Agent: J10 Planning

I&O_10278
Yes Additional evidence may usefully include an assessment of Agricultural Land Quality + Waste & Minerals capacity/resource to understand other constraints to land release.

Comment

Representation ID: 9940

Received: 27/08/2025

Respondent: Trish Pegg

IN1
I&O_10437
Capacity issues in current primary and secondary schools. Capacity issues for limited number of doctors surgeries to take on new patients. Capacity issues for Dentist provision when there are already current residents who are struggling to access NHS dentists.

Comment

Representation ID: 9957

Received: 27/08/2025

Respondent: Bellway Homes Ltd (North West)

Agent: Savills (UK) Limited

I&O_10454
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation documents sets out the following list of additional evidence that is needed to support the new Plan: • Retail and Town Centres Study (in preparation) • Strategic Flood Risk Assessment (in preparation) • Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) • Housing Needs Assessment (to be prepared) • Green Belt Study (to be prepared) • Infrastructure Delivery Plan (to be prepared) • Strategic Viability Assessment (to be prepared) • Transport Assessment (to be prepared) • Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the New Local Plan. Savills is supportive of the production of a new Housing Needs Assessment, Land Availability assessment and Green Belt Study which will inform the policies that relate to housing delivery in the New Plan. It is considered that no further evidence documents are required beyond those already produced or currently being prepared to support the New Local Plan.

Comment

Representation ID: 10010

Received: 27/08/2025

Respondent: Miss Helen Makin

I&O_10507
regarding the LAA stage one updated document, for the housing allocation site, why have you identified more greenfield sites than brownfield? table 4.7. Categorise brownfield sites above greenfield and stop building on our greenfield sites. There will be none left at this rate. Chester will merge with smaller districts and it will just be one urban spread. Find brownfield sites before you start finding greenfield. The number of units on greenfield sites is way larger than on brownfield, and dipropionately so, see table 7 in LAA stage one updated document. greenfield 242/19528 vs brownfield 169/3797. WHY?  Try harder to make it the other way around. para 4.19 greenbelt sites, keep housing out of the greenbelt. There can be no justification for building in the greenbelt, I don't see any justifications stated.   para 4.2 all of these sites must be removed from the local plan as housing sites. para 4.25 why does business development get removed for flood sites and yet the Council allows residential building on flood plains and no matter what the consequences are to residents eg Kings Moat and all the flooding Westminster Park has had to endure. We have also got a load of business use which is not used so why is the plan identifying more sites? Look at Chester business park, half empty. Develop those sites not the greenbelt or greenfield sites. page 40 lists the housing and economic partnership group, all of whom have an interest in building as much as possible to maximise profit without regard to anything else. Who represents the interests of the residents? Precisely no one.

Comment

Representation ID: 10072

Received: 27/08/2025

Respondent: R E, S, E and T Smith, Taylor, Cox and Carter

Agent: Savills (UK) Limited

I&O_10569
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation documents sets out the following list of additional evidence that is need to support the new Plan: • Retail and Town Centres Study (in preparation) • Strategic Flood Risk Assessment (in preparation) • Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) • Housing Needs Assessment (to be prepared) • Green Belt Study (to be prepared) • Infrastructure Delivery Plan (to be prepared) • Strategic Viability Assessment (to be prepared) • Transport Assessment (to be prepared) • Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the New Local Plan. Savills is supportive of the production of a new Housing Needs Assessment, Land Availability assessment and Green Belt Study which will inform the policies that relate to housing delivery in the New Plan. It is considered that no further evidence documents are required beyond those already produced or currently being prepared to support the New Local Plan. 

Support

Representation ID: 10103

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

Agent: Savills (UK) Limited

I&O_10600
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation documents sets out the following list of additional evidence that is need to support the new Plan: • Retail and Town Centres Study (in preparation) • Strategic Flood Risk Assessment (in preparation) • Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) • Housing Needs Assessment (to be prepared) • Green Belt Study (to be prepared) • Infrastructure Delivery Plan (to be prepared) • Strategic Viability Assessment (to be prepared) • Transport Assessment (to be prepared) • Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the New Local Plan. Savills is supportive of the production of a new Housing Needs Assessment, Land Availability assessment and Green Belt Study which will inform the policies that relate to housing delivery in the New Plan. It is considered that no further evidence documents are required beyond those already produced or currently being prepared to support the New Local Plan.

Comment

Representation ID: 10156

Received: 27/08/2025

Respondent: Northern Trust Land Limited

Agent: Savills (UK) Limited

I&O_10653
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation document sets out the following list of additional evidence that is needed to support the new Plan: ▪ Retail and Town Centres Study (in preparation) ▪ Strategic Flood Risk Assessment (in preparation) ▪ Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) ▪ Housing Needs Assessment (to be prepared) ▪ Green Belt Study (to be prepared) ▪ Infrastructure Delivery Plan (to be prepared) ▪ Strategic Viability Assessment (to be prepared) ▪ Transport Assessment (to be prepared) ▪ Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the new Local Plan. Savills is supportive of the production of a Housing Needs Assessment, Land Availability Assessment and Green Belt Study which will inform the policies that relate to housing delivery in the new Local Plan. It is not considered that there is additional evidence that is required that is not already in preparation or due to be prepared that would be necessary to support the new Local Plan.

Comment

Representation ID: 10194

Received: 26/08/2025

Respondent: Education and Skills Funding Agency

I&O_10691
The Department for Education’s Securing Developer Contributions for Education (2023) (https://assets.publishing.service.gov.uk/media/64d0f70d7a5708001314485f/Securing_Developer_Contributions_for_Education.pdf)  guidance sets out a clear and consistent method for assessing the impact of housing growth on education provision. It explains how to calculate the funding and land required to meet the demand for school places generated by new development. Using this guidance to inform the next iteration of the Local Plan will improve transparency, provide a robust evidence base for securing developer contributions, and support the timely delivery of education infrastructure where it is needed.

Comment

Representation ID: 10329

Received: 27/08/2025

Respondent: Christleton Parish Council

I&O_10826
We think the borough should prepare a comprehensive urban capacity study that would identify brownfield land in the urban areas and opportunities for intensification, particularly in areas with good public transport or the potential to provide good walking and cycling to reduce the need for travel, and regenerate left-behind urban communities in CWaC where life expectancies are 10 years less in in deprived areas of the Borough rather than areas surrounded by green belt. Our evidence for this is: We know standard LPA brownfield registers are almost all out of date and of little use in identifying either developable or deliverable housing sites. In 2022 the CPRE 'State of brownfield report’ showed that over 1.2 million homes could be built over 23,000 sites nationally covering more than 27,000 hectares of brownfield, including a minimum of 165,919 dwellings in the north west. This evidence suggests that there is a lot of extra developable brownfield land that has not yet been identified in the CWaC area. Local communities in the Chester Green Belt Alliance have started the process of identifying additional housing land using the CPRE brownfield register toolkit. It is expected to demonstrate additional sites. We are keen to, and expect that CWaC will engage with us in this exercise. Wirral MBC has just adopted a local plan without the need to allocate Green Belt or greenfields for development, and with a high degree of political consensus.

Comment

Representation ID: 10631

Received: 28/08/2025

Respondent: Sandra Stonham

Agent: Marrons

I&O_11129
We welcome the additional evidence listed at 1.19, particularly the Housing Needs Assessment, Strategic Viability Assessment, Land Availability Assessment, and Infrastructure Delivery Plan. We note that a Strategic Housing Market Assessment (SHMA) and an Integrated Impact Assessment are not listed here and suggest the value of these additional assessments are considered by the Council. In reference to questions and commentary in Section 24 Landscape, we suggest a Landscape Study or Strategy, which should include the review of Key Settlement Gaps, is included in the evidence base for the new Local Plan. The current Landscape Strategy (Part 1 and Part 2) includes designations dating back to the Vale Royal Local Plan (2006) evidence base, as does the Local Landscape Designation Review, which identifies KSGs outside of the Green Belt in CW&C. Updating information on Local Landscape Designations will help inform the Council’s approach policies around potential growth in specific areas such as Northwich, as well objectives for local green spaces, landscapes and designated sites.

Comment

Representation ID: 10842

Received: 28/08/2025

Respondent: Mr and Mrs . Hall

Agent: Urban Imprint Limited

I&O_11340
Having considered the evidence that the LPA seeks to collate in order to support the decisions on the emerging Local Plan (listed under paragraph 1.19 of the document) it seems that the breadth of evidence is appropriate. It is assumed that the second stage of the land availability assessment may seek to consider sites in a much more robust manner than a typical SHLAA or SHMA and would sensibly include an assessment based on the design, landscape and character impact of any sites. It would not be considered appropriate for the evidence to conflate these important matters with the Green Belt and the assessment that would be undertaken for that study. There is also likely to be a number of available sites which have a significant townscape or visual impact, however, the evidence base currently lacks the requisite depth which would enable such matters to be appropriately considered. In this respect we note that there is reference to the Cheshire West and Chester heritage strategy which does not appear in the list of 1.19 and should form part of any holistic assessment of potential allocations. Looking forward, many of the questions posed relate to the provision and capacity of local services and local character (assuming this is townscape / landscape). In that respect it is recommended that additional work looking at the attributes of all settlements is undertaken to help underpin decision making.

Comment

Representation ID: 11060

Received: 28/08/2025

Respondent: Tata Chemicals Europe Limited

Agent: Axis

I&O_11558
TCEL do not disagree with the evidence referenced at Paragraph 1.19 of the I&O; however, it is considered that further evidence will be necessary prior to Regulation 19 and adoption. This should include a Landscape Character Assessment and a review of both existing and potential Conservation Areas within the plan area. This will help provide an appropriate baseline for assessment, demonstrate the Council’s justifications in terms of designations and allocations, and ensure consistency of approach in decision making. In addition, Paragraph 165(b) of the National Planning Policy Framework 2024 (NPPF) highlights that plans should identify suitable areas for renewable and low-carbon energy sources. Accordingly, it is recommended that the evidence base for the new Local Plan also includes an assessment of potential sites for renewable energy development to ensure that opportunities to support the transition to net zero are fully considered.

Comment

Representation ID: 11168

Received: 22/08/2025

Respondent: Heine Planning

I&O_11666
1.18-Concern that the Reg18 consultation has proceeded ahead of all the Evidence required and the Evidence Base is incomplete. In particular the Council has launched this consultation in advance of an updated Gypsy Traveller Accommodation Assessment to replace the 2018 Study which relied on data gathered in 2017. Having contacted current clients and other agents, I know of no household in CWAC that has been approached by RRR to date and I have contacted RRR to offer to put them in touch with clients. In addition there has been no Green Belt Area Assessment following guidance in the PPG published February 2025. It is far from clear how the Council can be recommending that land in the Green Belt be released for new development when this is not informed by a district wide Green Belt study .

Comment

Representation ID: 11169

Received: 28/08/2025

Respondent: Mineral Products Association Ltd

IN 1
I&O_11667
We partially agree, however, the Evidence Base list should also include the Local Aggregates Assessment and the North West Aggregate Working Party Annual Report as well publications which report on Industrial Sand production and use such as the BGS Annual Minerals Yearbook.

Comment

Representation ID: 11216

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

Agent: Turley

I&O_11714
The R18 LP confirms that CWAC intend to prepare additional evidence to support the emerging Local Plan, including a Housing Needs Assessment, Green Belt Study, Infrastructure Delivery Plan, Strategic Viability Assessment and Land Availability Assessment. Paragraph 32 of the NPPF requires that the preparation of all policies should be underpinned by relevant and up-to-date evidence which is adequate and proportionate to justifying policies. To this extent and, principally with regard to the proposed allocation of Chester Business Quarter, it is considered imperative that the Council produces the evidence it has outlined as soon as possible to inform its new Local Plan. This must include an up-to-date Housing Needs Assessment which includes a detailed consideration of the need for different tenures of affordable housing and recognises the different local housing markets in operation across the authority and the needs of different segments of the housing market. Similarly, whilst an Economic Development Needs Assessment (EDNA) has been recently published as we refer in subsequent questions several deficiencies of this study have been identified, and it should be updated accordingly to support the next draft of the Local Plan. Furthermore, the Council will need to complement these assessments with up-to-date evidence of the availability of housing and employment land to ensure that calculated needs can be  accommodated through appropriate land allocations and policies.

Comment

Representation ID: 11220

Received: 28/08/2025

Respondent: Ella Magnuszewska

CUD01, CUD04 and CUD05
I&O_11718
It seems to me that the council should first look at brownfield sites in the borough rather than at any green belt land. Brownfield sites will already have some degree of infrastructure which could be utilised as building blocks for housing development. 

Comment

Representation ID: 11242

Received: 28/08/2025

Respondent: Frodsham Town Council

I&O_11740
Yes: Transport assessment – what does it include – needs to cover travel from the home to rail/bus starting point and adequate public transport services

Comment

Representation ID: 11245

Received: 28/08/2025

Respondent: Alan Shaw

I&O_11743
It seems to me that the council should first look at brownfield sites in the borough rather than at any green belt land. Brownfield sites will already have some degree of infrastructure which could be utilised as building blocks for housing development. 

Comment

Representation ID: 11483

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11981
Whilst the brownfield land register is listed in the evidence base, this crucial data set does not appear to have been fully updated. It is essential that it is updated in full if the new Local Plan is to comply with the National Planning Policy Framework (NPPF) and with the Town and Country Planning (Brownfield Land Register) Regulations 2017. CPRE’s ‘State of brownfield report’ (published in 2022) showed that, nationally, over 1.2 million homes could be built over 23,000 sites covering more than 27,000 hectares of brownfield. Our estimate, based on the available evidence, was that the minimum brownfield housing capacity in the north west was 165,919 (https://www.cpre.org.uk/resources/state-of-brownfield-report-2022/). CPRE national has also developed a brownfield register toolkit to help local CPRE branches to interrogate local brownfield registers to ensure they are sufficiently comprehensive. CPRE Cheshire branch has recently recruited a brownfield volunteer and we will be keen to engage with the Council on this important issue as the Local Plan progresses through its next steps.

Comment

Representation ID: 11660

Received: 28/08/2025

Respondent: Beck Homes Limited

Agent: NJL Consulting

I&O_12158
Beck Homes agree that the listed evidence base is appropriate, however the Green Belt Study should include a detailed parcel-by-parcel assessment of land around Guilden Sutton as with all settlements, explicitly considering: • The relative contribution of each parcel to Green Belt purposes (as set out in NPPF para 143). • Accessibility to sustainable transport. • Capacity to deliver housing without causing coalescence of settlements.

Comment

Representation ID: 11752

Received: 28/08/2025

Respondent: Beck Homes Limited

Agent: NJL Consulting

I&O_12250
We agree with the evidence base proposed, however there is a clear need for the evidence base to include an up-to-date Open Space Assessment, to support Policy OS 1. Furthermore, we would expect that the Green Belt Study to be prepared include a parcel-by-parcel assessment of land around Guilden Sutton, establishing the sites contribution to the Green Belt in accordance with the purposes as defined within paragraph 143 of the NPPF. Each assessment should also consider constraints and opportunities of each parcel, such as capacity, sustainable transport and ecological designations.

Comment

Representation ID: 11786

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12284
MSCC is generally supportive of CWaCC’s existing development plan and acknowledges the work that has gone into producing the latest documents for consultation. MSCC provided separate comments relating to the evidence base in March 2024, including the Employment Land Survey, Places Background Paper, and Land Availability Assessment and Call for Site. This consultation response builds upon previous comments and therefore should be read alongside the previously submitted representations. The previous consultation response was generally supportive and sought to ensure the strategic economic importance for MSCCs assets was recognised within the new Local Plan. In summary, previous comments suggested that for the Local Plan to align with national policy requirements, it should: • Safeguard existing and potential wharves and canal-side land for freight and port-related activity. • Resist proposals for non-port-related or incompatible development which could prejudice current or future operational capacity of the Canal, being mindful of the agents of change principle. • Support investment in canal-related infrastructure to enable greater use of waterborne freight and enhance multi-modal connectivity. • Promote modal shift and decarbonisation by recognising the Canal’s role in reducing HGV movements and cutting carbon emissions. • Embed the Canal within strategic growth and employment policies, ensuring its contribution to the borough’s economy and inward investment offer is fully recognised. • Work proactively with the Manchester Ship Canal Company and wider stakeholders to maximise the economic, environmental and sustainability benefits of the Canal. The purpose of these representations is to ensure the ongoing operational activities and future ambitions of MSCC’s interests are safeguarded as part of any future development plan preparation. On this basis, and due to the significant port interests within the Borough, it was also recommended that CWaCC should include reference to the National Policy Statement for Ports (2012) as a material consideration when undertaking the Local Plan review, in addition to the government guidance already referenced in the consultation documents. Neither the Local Plan Issues and Options (Regulation 18) document nor the Sustainability Appraisal reference the National Policy Statement for Ports.

Comment

Representation ID: 11788

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12286
National Policy Statement for Ports (January 2012) In March 2023, the government announced a review of the National Policy Statement for Ports under the provisions of the Planning Act 2008. This review will include a thorough examination of the modelling and forecasts that support the statement of need for development, and the environmental, safety, resilience, and local community considerations that planning decisions must take into account. Consultations took place in June and July 2025, but the review has yet to conclude and therefore the National Policy Statement for Ports (DfT 2012) (NPS) remains in place and carries full weight. It is part of the planning system established under the 2008 Act to deal with nationally significant infrastructure proposals. It provides the framework for decisions on proposals for new port development. It emphasises the essential role of ports in the UK economy. It notes that for an island economy, there are limited alternatives available to the use of sea transport for the movement of freight and bulk commodities and that shipping will continue to provide the only effective way to move the vast majority of freight in and out of the UK, and the provision of sufficient seaport capacity will remain an essential element in ensuring sustainable growth in the UK economy. The strategic importance of port facilities, such as the Manchester Ship Canal, is recognised at a national and regional level. This strategic importance must also be recognised at a local level through the development plan. Accordingly, MSCC wish to emphasise and repeat the request for reference to be made to the NPS as the new Local Plan progresses.

Comment

Representation ID: 11988

Received: 29/08/2025

Respondent: Mr and Mrs R Basford

Agent: Grimster Planning

I&O_12502
The evidence base documents listed at paragraph 1.19 of the I&O, and within the evidence base section of the planning policy webpages, are considered to form a strong basis to inform and shape the new Local Plan. It is considered that a Settlement Hierarchy assessment should be undertaken with clear criteria established to determine where settlements sit within the hierarchy, based on access to services, education and public transport amongst others. A Settlement Limits Review should also be undertaken, demonstrating how settlement boundaries within each of the settlements identified for growth within the new Local Plan (to be confirmed as part of the Local Plan process) will be adjusted to accommodate new housing and (where appropriate) economic growth. This includes any existing housing commitments which remain extant and where a lawful material start has been made, and any new housing commitments that may be granted during the Local Plan preparation process.

Comment

Representation ID: 12044

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

Agent: Grimster Planning

I&O_12558
The evidence base documents listed at paragraph 1.19 of the I&O, and within the evidence base section of the planning policy webpages, are considered to form a strong basis to inform and shape the new Local Plan. The Green Belt Study should be a Borough-wide assessment of the Green Belt, as opposed to simply focusing on an assessment of Green Belt land around Chester, as was the case in the preparation of the 2015 Part One Local Plan. This aligns with our comments later in this representation on Green Belt release across the Borough. Furthermore, the Green Belt assessment should include a specific assessment of those sites in the Green Belt that have been submitted to the Council as part of its Call for Sites, rather than those sites simply being assessed as part of a wider “parcel’ of land. This will ensure that individual sites are not identified as making a strong contribution to the Green Belt purposes as a consequence of the inclusion of additional land within a “parcel” that might not have been put forward for development and would not be suitable for development (for example, a brownfield parcel of land being assessed as part of a wider greenfield land parcel). It is considered that a Settlement Hierarchy assessment should be undertaken with clear criteria established to determine where settlements sit within the hierarchy, based on access to services, education and public transport amongst others.  A Settlement Limits Review should also be undertaken, demonstrating how settlement boundaries within each of the settlements identified for growth within the new Local Plan (to be confirmed as part of the Local Plan process) will be adjusted to accommodate new housing and (where appropriate) economic growth. This includes any existing housing commitments which remain extant and where a lawful material start has been made, and any new housing commitments that may be granted during the Local Plan preparation process.