Comment

Representation ID: 12361

Received: 28/08/2025

Respondent: Sue Hosker

I&O_12877
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12499

Received: 28/08/2025

Respondent: Nigel Taberner

I&O_13016
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12509

Received: 28/08/2025

Respondent: Benjamin J Taberner

I&O_13026
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12517

Received: 28/08/2025

Respondent: Sarah and Andy Smith

I&O_13034
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12524

Received: 28/08/2025

Respondent: Joe Taberner

I&O_13041
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12529

Received: 28/08/2025

Respondent: Amanda Taberner

I&O_13046
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12543

Received: 28/08/2025

Respondent: Jeff Horn

I&O_13060
I am strongly opposed to the proposed development of Green Belt land in Waverton and surrounding villages. My comments in relation to the consultation questions are as follows: No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12561

Received: 28/08/2025

Respondent: Jill Lowman

IN 1
I&O_13078
No. I do not believe that the evidence base is adequate. In line with the  NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A  comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 12717

Received: 29/08/2025

Respondent: Barratt Homes

Agent: Savills (UK) Limited

I&O_13235
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: 12749

Received: 28/08/2025

Respondent: Andrew Paterson

I&O_13267
I do agree that additional evidence is required and I believe work should be done to identify brownfield sites and underused/derelict properties.  There should also be a review of the local amenities and whether things such as GPs, schools, dentists are able to cope with the current community and potential future increases.

Comment

Representation ID: 13019

Received: 29/08/2025

Respondent: Peter Bulmer

IN 1
I&O_13538
I believe that a study should be undertaken to identify brownfield land suitable for housing in the urban areas and where there are good sustainable transport opportunities, way beyond one bus per hour (a very poor definition of a good bus service). There are opportunities to regenerate several communities, epically in the less deprived areas of the Borough rather than areas surrounded by green belt. I understand that Winsford is half the size it was planned to be.

Comment

Representation ID: 13055

Received: 29/08/2025

Respondent: Mr and Mrs Percy

Agent: Susan Jones Consultancy

I&O_13574
Mrs Jones has a planning career spanning more than 40 years and has operated throughout Cheshire for a large part of her career as well as other parts of the UK. She lives within the administrative boundary of Cheshire West and Chester Council (CWAC), is very familiar with the geography of the area as well as current planning policy restrictions including the boundary of the North Cheshire Green Belt, the designated Open Countryside as well as many of the borough’s conservation areas and listed buildings. She is also very familiar with up-to-date national policy and guidance (NPPF and associated NPPG) as well as the council’s deliverable housing supply position at 1/04/2025 of 1.89 years. She understands therefore that there is currently a significant shortfall of housing land supply for the borough with a 5 year supply requirement of 10,038 dwellings which equates to an annual housing requirement of 1,912 dwellings. The need to make provision for significant housing growth within the borough through this updated plan is therefore critical. However, Mrs Jones is of the professional view that the process for achieving that has to be the right one and can never be a knee jerk reaction to recent policy changes at national level. 2. These representations take the form of a stand-alone document rather than through the council’s online consultation portal. Nevertheless, throughout this document specific topics of interest to Mr and Mrs Percy will be referred to so it should be a straightforward exercise for planning officers to interpret what is being conveyed. It is noted at para 1.19 that certain additional evidence is needed to support the local plan. This includes a housing needs assessment, Green Belt study, infrastructure delivery plan and transport assessment. All of these have yet to be prepared. Mrs Jones has therefore advised Mr and Mrs Percy of her concern that at this stage significant areas of work have still to be carried out. Therefore, without that in place the value of identifying potential growth areas at this stage for members of the public to comment on is very limited, maybe misleading and also could change significantly as this plan evolves.

Comment

Representation ID: 13067

Received: 29/08/2025

Respondent: Mike Roberts

I&O_13586
I 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 fortravel, and regenerate left-behind urban communities  

Comment

Representation ID: 13110

Received: 29/08/2025

Respondent: Liverpool City Region Combined Authority

I&O_13629
Thank you for consulting Liverpool City Region Combined Authority (LCRCA) on Cheshire West and Chester’s Local Plan Issues & Options (July 2025) and providing opportunity to comment. As you may be aware, the LCRCA is preparing a Spatial Development Strategy (SDS) as part of its statutory planning functions. When adopted, the SDS will provide the strategic planning framework for the Liverpool City Region (LCR) and form part of the development plan for its six constituent local authorities. The LCR SDS remains under preparation. An initial draft version – Towards a Spatial Development Strategy – was published for engagement between Nov 2023 and Feb 2024. Work is currently underway on the next version – ‘Public Participation’ - factoring in implications of ongoing reform to the planning system (notably the revised NPPF,  Planning and Infrastructure Bill and the anticipated National Development Management Policies). Given the emerging nature of both the SDS and your Local Plan, and the longstanding relationship and connection between both areas, we would wish to continue constructive engagement with Cheshire West and Chester Council concerning strategic cross-boundary planning and other related matters within the LCRCA’s remit including transport, economic growth and the environment. Key matters we’d wish to highlight at this stage are: Meeting housing and employment needs (including Green Belt). Sustainable transport infrastructure with regards to emerging Local Transport Plans, including future expansion/improvements to the rail network serving respective areas (notably Merseyrail and Borderlands line), cross boundary bus service provision and integration of Active Travel networks. Other strategic infrastructure and preparation of respective Infrastructure Delivery Plans. Nature recovery and implementation of respective Local Nature Recovery Strategies. Waste management and minerals provision. Should you require any further information at this stage please do not hesitate to contact me. At the earliest convenience we would welcome opportunity to discuss matters in more detail.

Comment

Representation ID: 13112

Received: 29/08/2025

Respondent: Fraser Hosker

I&O_13631
No. I do not believe that the evidence base is adequate. In line with the NPPF para. 119 , the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A comprehensive urban capacity study  should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 13124

Received: 29/08/2025

Respondent: Network Rail

I&O_13643
It is noted that the new Local Plan will create a single local plan document that updates and replaces all policies in the current Local Plan (Part One) and Local Plan (Part Two) for the area. It is also identified that Cheshire West and Chester, along with Cheshire East and Warrington Councils, has been confirmed as part of the government's devolution priority programme. This means outline plans to set up a Combined Authority and hold mayoral elections in May 2026 have been accepted by government. A final decision will be made by the three councils later this year. While a combined authority would hold devolved powers related to strategic planning and have a duty to produce Spatial Development Strategy (“SDS”), the SDS will take several years to produce and cannot make allocations. Therefore, it will be important to continue to progress the new Local Plan for Cheshire West and Chester. Network Rail will engage in future consultations on the SDS as appropriate, together with subsequent consultations on the local plan.

Comment

Representation ID: 13125

Received: 29/08/2025

Respondent: Network Rail

I&O_13644
In addition to the existing / in progress evidence base documents listed above, Network Rail requests that the draft Local Plan should also identify and consider the North West and Central Regional Strategic Plan (February 2021) as part of the Plan’s evidence base. This Regional Strategic Plan, and associated delivery plans, have been developed by Network Rail to set out a strategic view of how to enhance the area’s rail network up to 2029. A copy of the Strategic Plan is provided with this consultation response. It should also be noted that more localised studies will be undertaken by Network Rail, working with others in the rail industry to develop long term service proposals as well as infrastructure priorities for the area.

Comment

Representation ID: 13371

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13890
The I&Os Document 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. Harworth’s view is that it is crucial that the Council ensures that the preparation of the emerging Local Plan, and associated planning policy is justified through robust up-to-date evidence. Accordingly, Harworth is of the view that the following additional evidence should be produced or updated to substantiate and justified policy proposals of the emerging Local Plan: • Site Selection Paper (to understand the methodology used to assess sites for allocation in the emerging new Local Plan); • Places Background Paper (to understand the unique characteristics of a place, identify opportunities and challenges, and inform strategic decisions about land use and development); • A robust assessment of economic needs (including for a range of manufacturing and warehouse space); • Up-to date evidence of the availability of housing and employment land supply across the borough (to ensure that the plan is based on a robust understanding of local needs and can effectively address those needs through appropriate land use allocations and policies); • Brownfield Land Register (to identify previously developed land that is potentially suitable for housing development within CWAC); • Playing Pitch Strategy (to inform planning decisions and ensure adequate provision of sports facilities); • Public Open Space Assessment (to ensure adequate provision of green spaces); and, • Duty to Cooperate Statement (to demonstrate how strategic cross boundary matters have been dealt with through the preparation of a Local Plan).

Comment

Representation ID: 13541

Received: 29/08/2025

Respondent: Mrs Catherine Richardson

I&O_14060
No it isn’t. The council should prepare a comprehensive urban study that identifies brownfield land in the urban areas that have the potential for good walking and cycling to reduce the need to travel and regenerate some of these areas.

Comment

Representation ID: 13584

Received: 29/08/2025

Respondent: Marine Management Organisation

I&O_14103
Please find attached our consultation response. As you are at the start of development, we intent to provide a fuller response at the preferred options stage, this will help align marine plan policies with your own emerging policies. In the meantime, if you wish to discuss any comments we have made today or comments we may provide going forward, I am more than happy to discuss this via email, call, or video call. I do hope you also received our standard response to your initial email. If not, please see below. Standard Consultation response - PLEASE READ Thank you for including the Marine Management Organisation (MMO) in your recent consultation submission. The MMO will review your document and respond to you directly should a bespoke response be required. If you do not receive a bespoke response from us within your deadline, please consider the following information as the MMO’s formal response. Kind regards, The Marine Management Organisation   Marine Management Organisation Functions The MMO is a non-departmental public body responsible for the management of England’s marine area on behalf of the UK government. The MMO’s delivery functions are: marine planning, marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing grants.   Marine Planning and Local Plan development Under delegation from the Secretary of State for Environment, Food and Rural Affairs (the marine planning authority), the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent, a marine plan will apply up to the Mean High Water Springs (MHWS) mark, which includes the tidal extent of any rivers. As marine plan boundaries extend up to the level of MHWS, there will be an overlap with terrestrial plans, which generally extend to the Mean Low Water Springs (MLWS) mark. To work together in this overlap, the Department of Environment, Food and Rural Affairs (Defra) created the Coastal Concordat. This is a framework enabling decision-makers to co-ordinate processes for coastal development consents. It is designed to streamline the process where multiple consents are required from numerous decision-makers, thereby saving time and resources. Defra encourage coastal authorities to sign up as it provides a road map to simplify the process of consenting a development, which may require both a terrestrial planning consent and a marine licence. Furthermore, marine plans inform and guide decision-makers on development in marine and coastal areas.   Under Section 58(3) of Marine and Coastal Access Act (MCAA) 2009 all public authorities making decisions capable of affecting the UK marine area (but which are not for authorisation or enforcement) must have regard to the relevant marine plan and the UK Marine Policy Statement. This includes local authorities developing planning documents for areas with a coastal influence. We advise that all marine plan objectives and policies are taken into consideration by local planning authorities when plan-making. It is important to note that individual marine plan policies do not work in isolation, and decision-makers should consider a whole-plan approach. Local authorities may also wish to refer to our online guidance and the Planning Advisory Service: soundness self-assessment checklist. We have also produced a guidance note aimed at local authorities who wish to consider how local plans could have regard to marine plans. For any other information please contact your local marine planning officer. You can find their details on our gov.uk page. See this map on our website to locate the marine plan areas in England. For further information on how to apply the marine plans and the subsequent policies, please visit our Explore Marine Plans online digital service. The adoption of the North East, North West, South East, and South West Marine Plans in 2021 follows the adoption of the East Marine Plans in 2014 and the South Marine Plans in 2018. All marine plans for English waters are a material consideration for public authorities with decision-making functions and provide a framework for integrated plan-led management.   Marine Licensing and consultation requests below MHWS Activities taking place below MHWS (which includes the tidal influence/limit of any river or estuary) may require a marine licence in accordance with the MCAA. Such activities include the construction, alteration or improvement of any works, dredging, or a deposit or removal of a substance or object. Activities between MHWS and MLWS may also require a local authority planning permission. Such permissions would need to be in accordance with the relevant marine plan under section 58(1) of the MCAA. Local authorities may wish to refer to our marine licensing guide for local planning authorities for more detailed information. We have produced a guidance note (worked example) on the decision-making process under S58(1) of MCAA, which decision-makers may find useful. The licensing team can be contacted at: marine.consents@marinemanagement.org.uk .   Consultation requests for development above MHWS If you are requesting a consultee response from the MMO on a planning application, which your authority considers will affect the UK marine area, please consider the following points: The UK Marine Policy Statement and relevant marine plan are material considerations for decision-making, but Local Plans may be a more relevant consideration in certain circumstances. This is because a marine plan is not a ‘development plan’ under the Planning and Compulsory Purchase Act 2004. Local planning authorities will wish to consider this when determining whether a planning application above MHWS should be referred to the MMO for a consultee response. It is for the relevant decision-maker to ensure s58 of MCAA has been considered as part of the decision-making process. If a public authority takes a decision under s58(1) of MCAA that is not in accordance with a marine plan, then the authority must state its reasons under s58(2) of the same Act. If the MMO does not respond to specific consultation requests then please use the above guidance to assist in making a determination on any planning application. Minerals and Waste Local Plans and Local Aggregate Assessments If you are consulting on a minerals and waste local plan or local aggregate assessment, the MMO recommends reference to marine aggregates, and to the documents below, to be included: The Marine Policy Statement (MPS), Section 3.5 which highlights the importance of marine aggregates and its supply to England’s (and the UK’s) construction industry. The National Planning Policy Framework (NPPF), which sets out policies for national (England) construction mineral supply. The minerals planning practice guidance which includes specific references to the role of marine aggregates in the wider portfolio of supply. The national and regional guidelines for aggregates provision in England 2005-2020 predict likely aggregate demand over this period, including marine supply.   The minerals planning practice guidance requires local mineral planning authorities to prepare Local Aggregate Assessments. These assessments must consider the opportunities and constraints of all mineral supplies into their planning regions – including marine sources. This means that even land-locked counties may have to consider the role that marine-sourced supplies (delivered by rail or river) have – particularly where land-based resources are becoming increasingly constrained. If you wish to contact the MMO regarding our response, please email us at consultations@marinemanagement.org.uk or telephone us on 0208 0265 325

Comment

Representation ID: 13585

Received: 29/08/2025

Respondent: Marine Management Organisation

I&O_14104
Marine Management Organisation Functions The MMO is a non-departmental public body responsible for the management of England’s marine area on behalf of the UK government. The MMO’s delivery functions include, marine planning and marine licensing, wildlife licensing and enforcement, marine protected area management, marine emergencies, fisheries management and issuing grants. Marine Planning As the marine planning authority for England, the MMO is responsible for preparing marine plans for English inshore and offshore waters. At its landward extent the Marine Plan boundaries extend from the mean high water spring tides mark (which includes the tidal extent of any rivers and estuary) to the inshore (up to 12nm) and offshore (12 to 200nm or the Exclusive Economic Zone) waters; there is an overlap with terrestrial plans which generally extend from the mean low water springs mark. Marine plans will inform and guide decision makers on development in marine and coastal areas. Planning documents for areas with a coastal influence may wish to make reference to the MMO’s licensing requirements and any relevant marine plans to ensure the necessary considerations are included. In the case of the document stated above, the North West Marine Plan is of relevance. The North West Marine Plan covers the area from the Solway Firth to the River Dee, including the tidal extent of any rivers within this area All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine area must do so in accordance with the Marine and Coastal Access Act 2009 and any relevant adopted Marine Plan, in this case the North West Marine Plan , or UK Marine Policy Statement (MPS) , unless relevant considerations indicate otherwise. Local authorities may also wish to refer to our online guidance , Explore Marine Plans and the Planning Advisory Service soundness self-assessment checklist .  Marine Licensing The Marine and Coastal Access Act 2009 states that a marine license is required for certain activities carried out within the UK marine area . The MMO is responsible for marine licensing in English waters and for Northern Ireland offshore waters. The marine licensing team are responsible for consenting and regulating any activity that occurs “below mean high water springs” level that would require a marine licence. These activities can range from mooring private jetties to nuclear power plants and offshore windfarms. Summary notes Please see below suggested policies from the North West Marine Plan that we feel are most relevant to your local plan. We recommend considering reference to these policy areas within the supporting policy text. These suggested policies have been identified based on the activities and content within the document entitled above. They are provided only as a recommendation, and we would suggest your own interpretation of the North West Marine Plan is completed. Infrastructure: NW-INF-1, NW-INF-2 Employment: NW-EMP-1 Seascape and Landscape: NW-SCP-1  Social Benefits: NW-SOC-1  Tourism and Recreation: NW-TR-1  Climate change: NW-CC-1, NW-CC-2, NW-CC-3  Biodiversity: NW-BIO-1, NW-BIO-2, NW-BIO-3  Ports and Shipping: NW-PS-1   Renewables: NW-REN-1, NW-REN-3 Heritage Assets: NW-HER-1  Water Quality: NW-WQ-1  Air Quality and emissions: NW-AIR-1  Cross-border co-operation: NW-CBC-1 Further points to note We would recommend you mention the adopted North West Marine Plan as a document for material consideration. Under the Marine and Coastal Access Act, any authorisation or enforcement decisions must be made in accordance with the marine plan. Any other decisions which may impact the marine area must have regard to the marine plan. We welcome the advice that applicants may also require an appropriate license from the Marine Management Organisation. We would recommend the mention of the Marine and Coastal Access Act in your local plan. The UK Marine Policy Statement is the framework for the marine planning system. All public authorities taking authorisation or enforcement decisions that affect or might affect the UK marine areas must do so in accordance with the Marine and Coastal Access Act 2009 and any relevant adopted Marine Plan (your area being the North West Marine Plan) or the UK Marine Policy Statement unless relevant considerations indicate otherwise. We would also welcome reference to the need for an integrated approach between marine and terrestrial planning to address strategic cross-boundary matters in SD1 Sustainable development, FW1 Flood risk and water management and DS3 Climate adaptation, where you mention the use and green and blue infrastructure. This will help fulfil your authorities’ duties under the Duty to Cooperate and Section 58(3) of the Marine and Coastal Access Act. A general incorporation of blue infrastructure/spaces throughout, alongside green infrastructure/spaces would show recognition of the north west marine plan areas. As previously stated, these are recommendations, and we suggest that your own interpretation of the draft North West Marine Plan is completed. We would also recommend you consult Explore Marine Plans , our marine planning portal, for further information.  

Comment

Representation ID: 13637

Received: 28/07/2025

Respondent: Qair UK

Agent: Renewable Planning Consultancy Ltd

I&O_14156
The evidence base proposed does not include a new renewable energy sensitivity study. Given the change in Green Belt policy and the incorporation of Grey Belt in the NPPF this would be expected to inform any renewable energy policy. Furthermore, the previous study is almost a decade old, in which time both the technology and policy context have significantly changed. For example, the renewable energy study does not recognise the declaration of the climate change emergency by Cheshire West and Chester in 2019. Furthermore, technology has significantly progressed along with the need for renewable energy developments. A 25-hectare solar farm is not considered to be ‘very large’ in modern day solar development. Given the significant need for renewables, the declaration of a climate change emergency, the updated Green Belt policy context, it would be expected that ‘suitable’ areas for renewable energy development are identified as part of the emerging Local Plan.

Comment

Representation ID: 13655

Received: 29/08/2025

Respondent: Michael Hair

I&O_14174
No. I do not believe that the evidence base is adequate. In line with the NPPF para. 119, the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A comprehensive urban capacity study should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 13708

Received: 29/08/2025

Respondent: Guilden Sutton Parish Council

I&O_14228
Guilden Sutton Parish Council feels that 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. 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: 13764

Received: 28/08/2025

Respondent: James Hosker

I&O_14284
No. I do not believe that the evidence base is adequate. In line with the NPPF para. 119, the Council must make as much use as possible of previously-developed (brownfield) land before considering Green Belt release. A comprehensive urban capacity study should be prepared to identify brownfield land in urban areas and opportunities for intensification, especially in locations with good public transport or potential for active travel improvements. This would reduce pressure on the Green Belt and regenerate urban communities that are currently left behind.

Comment

Representation ID: 13769

Received: 29/08/2025

Respondent: Mr C Stubbs

Agent: Susan Jones Consultancy

LAA Ref 2062
I&O_14289
Land off Webbs Court, Northwich, also known as land at the rear of London Road, Northwich [LAA 2062] It is noted at para 1.19 of the Issues and Options document that certain additional evidence is needed to support the local plan. This includes a housing needs assessment, Green Belt study, infrastructure delivery plan and transport assessment. All of these have yet to be prepared. However, it is confirmed that a Strategic flood Risk Assessment is currently under preparation. Mrs Jones has therefore advised Mr Stubbs of her concern that at this stage significant areas of work have still to be carried out/ completed. Therefore, without that evidence base in place the value of identifying potential growth areas at this stage for members of the public to comment on is very limited, maybe misleading and could change significantly as this plan evolves. Furthermore, later on in the Regulation 18 document at paragraph 5.12 it is confirmed that the exercise of identifying potential growth areas has excluded areas of land which are subject to constraints including areas of flood risk. Flood risk is a material consideration but as demonstrated below, there are significant parts of the subject site which have a low risk to flooding when last reviewed and therefore the development of the site is feasible. Planning History The existing development immediately adjoining the subject site was approved on appeal (see Inspector’s decision letter – Appendix A) in relation to planning application APP/2001/0033. Susan Jones was involved in that scheme and at the time Mr Stubbs owned both sites. As is evident from the application documents on the council’s website part of the subject site originally included a building which was subsequently demolished. 6. The subject site was the subject of a planning application in 2004 (LPA ref: APP/2004/0313). That application was refused consent on 17/05/2004. The application proposed the erection of 12 one- and two-bedroom apartments, and the proposed scheme included appropriate flood risk measures (see Appendix B). The reasons for refusal as a result did not include any objection on the basis of flood risk. At that time the former council were well placed with respect to housing land provision on brown field sites within the urban area. The situation now is quite different. Flooding The most recent flooding assessment of the subject site was in 2014 and was carried out by Enzygo. A copy of the Flood risk notes at the time recommended a proposed scheme involving sequential development would be appropriate (see Appendix C). Therefore, on the basis of what has occurred previously and the position the council finds itself in now concerning housing land supply Mrs Jones can see no reason why this site should not now be considered for future growth.

Comment

Representation ID: 13785

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14305
Thank you for your consultation seeking the views of United Utilities Water Limited (UUW) as part of the Local Plan process. UUW wishes to build a strong partnership with all local planning authorities (LPAs) to aid sustainable development and growth within its area of operation. We aim to proactively identify future development needs and share our information. This helps: - ensure a strong connection between development and infrastructure planning; - deliver sound planning strategies; and - inform our future infrastructure investment submissions for determination by our regulator. UUW wishes to highlight the benefit of early, constructive communication with the Council and site promoters to ensure a co-ordinated approach to the delivery of sustainable growth in sustainable locations. When preparing the local plan, new development should be focused in sustainable locations which are accessible to local services and infrastructure. We can most appropriately manage the impact of development on our infrastructure if development is identified in locations where infrastructure is available with existing capacity. We encourage you to direct future developers to our pre-application service to discuss their schemes and highlight any potential issues by contacting: Developer Services – Wastewater Tel: 03456 723 723 Email: SewerAdoptions@uuplc.co.uk Developer Services – Water Tel: 0345 072 6067 Email: DeveloperServicesWater@uuplc.co.uk To supplement this response, we have enclosed an appendix that provides supporting information and example policy wording for you to consider when preparing your new local plan. We have also enclosed evidence to support the implementation of the tighter standard for water efficiency. We would welcome the opportunity to provide our comments on any sites that are suggested to you as potential development sites when available. We are keen to undertake an initial assessment so that this can be fed into your site assessment process and to ensure that any flood risks from our assets are reflected in your Strategic Flood Risk Assessment. Please ensure that you have regard to the main body of the letter and the associated supporting information, which includes recommended policies. Moving forward, we respectfully request that the Council continues to consult with UUW for all future planning documents.

Comment

Representation ID: 13806

Received: 29/08/2025

Respondent: United Utilities plc

I&O_14326
Property Interests of UUW We would wish to assess any possible future development sites to determine whether we have any land interests such as easements and rights of access which are in addition to our statutory rights for inspection, maintenance and repair. These land interests may have restrictions that must be adhered to. It is the responsibility of the developer to obtain a copy of the associated legal document, available from our Legal Services department or Land Registry and to comply with the provisions stated within the document. We would request that these matters are addressed in site-specific policy / development considerations if you allocate the sites. We recommend that landowners/developers contact our Property Services team at PropertyGeneralEnquiries@uuplc.co.uk to discuss how any proposals may interact with our land interests. Our easements, pipe structures and access rights should not be affected by the design and construction of new development.

Comment

Representation ID: 13830

Received: 04/09/2025

Respondent: Progressive Energy Ltd

I&O_14350
We recommend that the Infrastructure Delivery Plan and Economic Needs Assessment include explicit recognition of the role of nationally significant decarbonisation projects in shaping employment and infrastructure requirements. The construction of HyNet and its related projects is estimated to create 16,000 jobs, averaging around 6,000 per year, depending on the pace of delivery. Additional ongoing operational jobs will number in the hundreds, with institutions such as TTE and Cheshire College South & West in Ellesmere Port well suited to train local apprentices for these forthcoming roles. Future HyNet infrastructure is already attracting investment in new sectors to the county. The Department for Energy Security & Net Zero’s recent Track 1 Expansion process to allocate HyNet’s carbon dioxide pipeline capacity was oversubscribed, with successful projects seeking to connect to points at Stanlow and Protos across hydrogen production, manufacturing, bioenergy carbon capture and direct air capture. This follows £9.4bn of investment announced at June’s Spending Review to deliver projects in HyNet and on Teesside. Low carbon hydrogen could be used for making glass or green steel, whilst electricity from EET’s planned hydrogenfired Combined Heat & Power plant could attract hyperscale data centres. In August, the Department for Transport awarded £4.5 million to two Sustainable Aviation Fuel projects, including Stanlow Methanol-to-Jet. These figures illustrate the scale of opportunity for Cheshire West and Chester, if infrastructure delivery is embedded in the evidence base. Policies supportive of all these sectors will ensure Cheshire West & Chester is a world-leader in clean energy.

Comment

Representation ID: 13939

Received: 29/08/2025

Respondent: Landowner (Forest Road)

Agent: Carden Group

I&O_14459
The length of the Local Plan period is critical. While the Council proposes a 15-year plan period, in accordance with paragraph 22 of the NPPF, this must be measured from the anticipated date of adoption, not from the plan’s base year. Given that adoption is unlikely before late 2027, or potentially early 2028, the plan period should extend to at least 2043 as a minimum. Furthermore, paragraph 22 of the NPPF states: “Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” This is particularly applicable to the emerging CWaC Local Plan, which includes several significant strategic growth locations. For example: • CH02: Chester East- Piper’s Ash, with an estimated capacity of 4,316 dwellings, and • EP02: Ellesmere Port South, with an estimated capacity of 5,517 dwellings, and • WIN05: Winsford West- Hebden Green, with an estimated capacity of 6,376 dwellings. According to Lichfields’ Start to Finish (2024) report, large-scale sites of over 2,000 homes typically deliver an average of 150 dwellings per year. Even assuming two major housebuilders operate concurrently, potentially doubling delivery to 300 dwellings per year, the build-out period for some of these larger sites would still extend to over 20 years, particularly when accounting for a typical six-year lead-in time before the first completions, as also noted by Lichfields. This highlights the long-term nature of strategic site delivery and reinforces the need for a sufficiently long plan period. In summary, to ensure the Local Plan provides at least 15 years of housing supply from the point of adoption, the Council should, as a minimum, plan for an 18-year period between 2025 to 2043. However, given the likely inclusion of several strategic sites, many of which will continue delivering housing well beyond 20 years, a 30-year plan period (2025 to 2055) represents a more robust and appropriate approach. Extending the plan horizon allows for realistic, phased development of strategic sites, facilitates coordinated infrastructure planning, and helps maintain the relevance and deliverability of the Local Plan over the long term. This approach reduces the risk of policy gaps or early obsolescence.