Comment

Representation ID: 5623

Received: 29/08/2025

Respondent: Andrew Rowe

I&O_5995
No time to read it so no comment

Comment

Representation ID: 5799

Received: 28/08/2025

Respondent: Christine Webber

I&O_6171
I do not think the SEA has been done properley as you have earmarked FR001 and FR002 for housing development in Frodsham when the land borders an ancient woodland very rare in Cheshire and I believe there is an SSSI in this area too.

Comment

Representation ID: 5960

Received: 28/08/2025

Respondent: Andy McGovern

I&O_6349
A more realistic approach to rural development needs to be taken, public transport links, while important, are never going to serve the rural community well enough and be cost effective enough to mean providers will actual maintain them. Rural development proposals should be accepting that car use is a normal manner of commute and perhaps provision of EV charging in more rural locations is enough of a driver for improvements in air and noise quality in our countryside.

Comment

Representation ID: 6097

Received: 28/08/2025

Respondent: Councillor Lucy Sumner

I&O_6487
1 | IN 4 Do you have any comments on the initial SA/SEA that accompanies the new Local Plan Issues and Options?   🐝 Frodsham Neighbourhood Plan Evidence Base The SA/SEA must test site-specific impacts on: Hob Hey Wood (GSRL1) – irreplaceable habitat. A56 AQMA (T1) – already a major public health concern. Flooding (GBC1) – including sewer/surface water issues in areas such as Langdale Way and Manor House School. Heritage (HCH1–HCH5) – e.g. Castle Park, Bradley Hillfort, and Frodsham Conservation Area.   It must also assess cumulative impacts of proposed sites together (Dig Lane + FRO01 + FRO02), not just in isolation.   🌳 Ancient Woodland Hob Hey Wood Ancient woodland is an absolute constraint. It cannot be “mitigated.” The SA must reflect this principle, as recognised in the FNHP and national policy.   🌹 Labour Perspective Labour’s manifesto and the LSE paper stress the need to properly test brownfield-first alternatives. Unless this is done rigorously, the SA risks becoming a tick-box exercise that justifies Green Belt loss by default.   🧠 Wider Context Bourland (Gray to Green Communities) calls for embedding carbon accounting in all assessments. Colenutt (The Property Lobby) warns against developer-led bias, which often distorts evidence bases. Gallent & Eaqub highlight that equity and affordability outcomes must be assessed, not just land supply.   📌 Important Considerations The initial SA/SEA is too high-level to guide decisions of this scale. It must: Test specific impacts of FRO01 and FRO02 on woodland, flooding, air quality, and traffic. Treat ancient woodland and biodiversity as non-negotiable constraints. Incorporate historic flood data and recognise Frodsham’s real-world drainage issues. Address transport realities – hourly trains, overcrowding, poor cycling links – instead of assuming theoretical “sustainable corridors.” Assess cumulative impacts across multiple sites. Measure outcomes for health, equity, and affordability, not just housing numbers.   Unless the SA/SEA is strengthened to this level of detail, it risks failing as a genuine safeguard and becoming little more than a procedural hurdle.

Comment

Representation ID: 6443

Received: 28/08/2025

Respondent: Chloe Randall

I&O_6857
It is clearly inadequate. The area of both Parkgate and Neston and wildlife havens and precious rural area of the Wirral peninsula.  The building of 4000 homes here will have a deeply negative effect on such an area. 

Comment

Representation ID: 6473

Received: 29/08/2025

Respondent: Philip Marshall

I&O_6888
The initial SA/SEA is too high-level. It must explicitly test: - The loss of agricultural land for both housing and solar farms (food security). - The impact of cumulative major projects on transport and air quality in Northwich/Marbury. - Settlement coalescence risks, including landscape and identity impacts. - Whether infrastructure can realistically be delivered in parallel with housing.

Comment

Representation ID: 6922

Received: 29/08/2025

Respondent: Patricia Paterson

I&O_7390
The SA rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. Specifically to Guilden Sutton, and no doubt other communities within CH02, we note that bus services are even more infrequent.   For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 7229

Received: 29/08/2025

Respondent: Rob Fryer

I&O_7709
All environmental sensitive areas needs to be appraised and valued. This includes green belt and open countryside.

Comment

Representation ID: 7428

Received: 29/08/2025

Respondent: Katherine Hague

I&O_7908
Quite clearly you have no local knowledge of the special habitat of hob Hey Wood and the diversity it brings to the area. This will be destroyed when the wood is surrounded by housing.

Comment

Representation ID: 7717

Received: 22/08/2025

Respondent: Natural England

I&O_8204
Local Plan Issues and Options Sustainability Appraisal – June 2025 Natural England have provided comment on previous version of the Sustainability Appraisal under references 505871 and 511398. We are satisfied that all matters have been resolved. Please send further correspondence, marked for my attention, to consultations@naturalengland.org.uk.

Comment

Representation ID: 7868

Received: 24/08/2025

Respondent: Graham and Caroline Russell

IN 4
I&O_8357
The Sustainability Assessment (SA) identifies that the three options are the only reasonable alternatives – this is not considered to be correct. There are options that focus more on urban regeneration or include a new town that could be considered. Moreover, the SA presents no substantive evidence to support its assertions and does not provide a robust assessment of options. There is no substantive evidence presented to show that Options B and C should score better than Option A - given the location and nature of the proposed developments - in relation to infrastructure. The analysis undervalues the urban potential of sustainable travel in places like Northwich and Winsford, failing to consider improvements that could create sustainable communities. These flaws undermine the sustainability analysis. We do not believe that the SA’s conclusions are correct or sufficiently evidence based.

Comment

Representation ID: 8470

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8961
The SA rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. We do not accept the conclusions of the SA about the sustainability of the three strategic options – it fudges issues and does not come to a firm conclusion. It is non-sensical to suggest that the BAU option (B) is comparable in sustainability terms with Option A. For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 8572

Received: 26/08/2025

Respondent: Great Boughton Parish Council

IN4
I&O_9063
The Sustainability Appraisal rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. We do not accept the conclusions of the SA about the sustainability of the three strategic options – it fudges issues and does not come to a firm conclusion. It is non-sensical to suggest that the BAU option (B) is comparable in sustainability terms with Option A. For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents’ health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 8670

Received: 26/08/2025

Respondent: Carol and Daniel Morgan

IN4
I&O_9161
Question IN 4 – Do you have any comments on the initial SA/SEA? Yes. The Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) are not robust. They present only three options and ignore regeneration-led strategies or the possibility of a new town outside the Green Belt. The scoring of the options is unconvincing, with no clear justification for why Options B and C perform better than Option A in relation to infrastructure or sustainability. In particular, the analysis undervalues the potential for urban regeneration in towns like Northwich and Winsford, where improvements in active travel and public transport could deliver genuinely sustainable communities. Without stronger evidence and broader options, the SA cannot be relied upon.

Comment

Representation ID: 9942

Received: 27/08/2025

Respondent: Trish Pegg

IN4
I&O_10439
I would suggest that more hydrology research into the impact on the water table in the wider context of global warming is undertaken, perhaps in consultation with the RSPB and the local water providers. 

Comment

Representation ID: 10331

Received: 27/08/2025

Respondent: Christleton Parish Council

I&O_10828
The SA rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. We do not accept the conclusions of the SA about the sustainability of the three strategic options – it fudges issues and does not come to a firm conclusion. It is non-sensical to suggest that the BAU option (B) is comparable in sustainability terms with Option A. For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 10708

Received: 28/08/2025

Respondent: Roberts Bakery

Agent: SATPLAN Ltd

I&O_11206
The Sustainability Appraisal that accompanies the consultation acknowledges the importance of Northwich as a key settlement for future growth, with potential for both housing and employment expansion. Growth scenarios consider the town’s capacity for urban extensions and infill development, balancing land availability with environmental constraints. Gadbrook Park is identified as an established strategic employment site with a strong role in the borough’s economic framework and confirms a positive score for supporting the local economy. Its sustainability performance depends heavily on addressing transport, environmental, and infrastructure constraints associated with the area. For example, there are limited direct public transport links to this employment area, leading to higher car dependency. The SA discusses the need to balance the protection of Gadbrook Park as an employment site with other strategic land uses. It is our clients view that by encouraging some expansion of employment uses with alternative uses such as residential and mixed uses, the area and the Site at Roberts Bakery can continue to play a role in the Local Plan’s employment strategy while aligning better with sustainability goals and housing delivery. Expansion for alternative uses can be accommodated on brownfield land which avoids greenfield development when compared to other alternative sites within the Sustainability Appraisal in this location.

Comment

Representation ID: 10917

Received: 28/08/2025

Respondent: Weaverham Parish Council

I&O_11415
We would like to see more detailed information regarding the SA/SEA assessments.

Comment

Representation ID: 11250

Received: 28/08/2025

Respondent: Frodsham Town Council

I&O_11748
Difficult to comment as it has to many IFS and MAYBES. Layout of the final pages in colour and landscape are impossible to read on line

Comment

Representation ID: 11486

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11984
We commend the fact that the Sustainability Appraisal has been rural proofed and trust that the Local Plan itself will be also. Our main criticism would be around the very large number of local evidential reports that are “in preparation” and which therefore are not yet available for scrutiny and analysis. Regarding health, as paragraph 2.16 in the Sustainability Appraisal (page 73) points out “ The Ellesmere Port area policy approach (EP 2) is the only policy from the SA that scored negatively on impacts to health” . The reasons for this are identified (the need to deal with hazardous installations) but there is no solid reassurance that this is likely to happen quickly.

Comment

Representation ID: 11787

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12285
While the SA includes broad sustainability themes such as infrastructure and economic growth, there is currently no clear reference to the Manchester Ship Canal as a strategic freight corridor within the appraisal criteria. It is therefore recommended that the document includes a specific SA sub-objective such as: “Support for safeguarding and enhancing strategic freight water corridors (specifically the Manchester Ship Canal) to provide a resilient, low-carbon freight network and economic infrastructure.” This addition would ensure the Canal’s multifunctional value is systematically assessed across all options and policies. In the appraisal of Spatial Strategy Options A–C, it is suggested that the Council explicitly evaluates how each spatial approach supports the Canal’s modal shift potential and contributes to sustainable freight movement. Option C (focused on sustainable transport corridors) should be appraised positively in this regard. It is also suggested that policy approaches—particularly those related to transport, employment allocations, and canal-side development—be appraised for their alignment with safeguarding canal operations and promoting waterborne freight. This would reinforce the strategic status of the Manchester Ship Canal across multiple Local Plan themes.

Comment

Representation ID: 13021

Received: 29/08/2025

Respondent: Peter Bulmer

IN 4
I&O_13540
In our area, in the centre of CH02, the major roads and their junction are already at capacity and some beyond this. These are the A41, A51 and A56 and therefore more local traffic from housing in CH02, using the rural roads of Pearl Lane, Station Lane and Hare Lane will substantially increase congestion and air pollution, without major improvements of this road network. This should be undertaken first before any release of green belt to housing.

Comment

Representation ID: 13714

Received: 29/08/2025

Respondent: Guilden Sutton Parish Council

I&O_14234
The SA rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. Specifically to Guilden Sutton, and no doubt other communities within CH02, we note that bus services are even more infrequent.   For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 14071

Received: 29/08/2025

Respondent: Caroline Hall

I&O_14614
As part of the SA is CWAC looking to reinstate public transport that has previously been removed? How will CWAC assess the need for reinstated/new public transport services and how will the council encourage people to use it e.g. affordable tickets (a willingness to pay project should be performed to decide prices and not driven by commercial desire of transport companies), regular and suitable timetables etc. Will the outputs from the current transport consultation be integrated with the consultation for the local plan? To ensure elements such as water efficiency when new planning projects are considered, will the council have the powers to ensure the water company is upgrading drain systems etc to cope with the additional housing? The SA seems to contain conflicting messages. It wants to reduce the risk of flooding and yet the local plan suggests building on open countryside/greenbelt/grey belt. These areas should be left undeveloped.

Comment

Representation ID: 14090

Received: 05/09/2025

Respondent: Upton-by-Chester and District Parish Council

I&O_14633
Yes the Upton-by-Chester & District Neighbourhood Plan 2020-2030 (UNP) strongly supports the principles of Sustainable development as set out in SD1. We would refer in particular to the UNP Policies S1, S2, H1, H2, H3, PC3, PC4, T1-T6, D1. It should be noted that all these Policies go beyond the CW&CC Local Plan Parts 1 and 2, as the UNP was adopted in 2022 which was after the adoption of the Local Plan.

Comment

Representation ID: 14192

Received: 29/08/2025

Respondent: Judith Critchley

I&O_14736
Difficult to comment as it has to many IFS and MAYBES. Layout of the final pages in colour and landscape are impossible to read on line

Comment

Representation ID: 14439

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

Agent: Bidwells

I&O_14983
Arden Enterprises Group welcomes the commitment to plan for meeting the housing and other development needs of Cheshire West. However, for the plan to meet the legal compliance and the soundness tests set out in the NPPF, we have identified the need for Council to reconsider the following points before proceeding to Regulation 19: i. Options and reasonable alternatives for its spatial strategy; ii. Housing and rural investment policies related to rural areas. The Sustainability Appraisal examines the Strategic Objectives of the existing Local Plan and relates these to the spatial strategy options. These options are not meeting legal requirements as the three options are in fact just one, devoid of real alternatives: the three options all concern the expansion of the periphery of existing towns and rural service centres. Option A (Green Belt) and Option C (growth along transport corridors) appear to be variations of a single spatial strategy represented in Option B i.e. the expansion of towns and rural service centres only, which is not a positive anticipation or assessment of future needs and opportunities. Option A is a decision not to expand those centres in Green Belt areas. Option C is in effect an adjunct of site selection, it does not appear to be a strategic proposition or alternative. The table at Appendix 2 (see attachment) sets out the numbers proposed under the options by settlement. This demonstrates that there is only one decisive factor between the options, and that is whether the site is in the Green Belt or not. To meet legal requirements, the local plan must put forward some alternative objectives and spatial options which respond to the future needs and opportunities of the District, and not just those which were deemed appropriate in the previous Local Plan. In most cases, this results in significant development on the edge of existing towns which risks overextension, and in some cases coalescence of Northwich, Hartford, Leftwich, Moulton and Davenham as well as Winsford, and Middlewich. This is shown in Figure 1 below (Proposed growth as shown in the Spatial Options shows significant coalescence and over-extension of existing communities-see attachment) At paragraph 5.36 the Sustainability Appraisal states that there are no reasonable alternatives. This is not true as paragraph 5.36 the SA concedes that no alternatives have been assessed and one of the objectives of this Regulation-18 consultation exercise is to invite reasonable alternatives as stated in paragraph 2.24 of the SA. Moreover, it is difficult to formulate a strategy for this area without meaningful engagement with Cheshire East regarding the future of Middlewich. The current options do not advocate an option, but merely the absence of a Plan, which is not effective or planning positively. Therefore, on behalf of Arden Enterprises Group LLP, we put forward two positive sustainable alternative strategy for future growth which we contend would fulfil the requirement for positive planning and meet legal requirements in the SA. These two propositions are: i. Growth Hubs: Examining the distribution of settlements and economic activity to determine if new growth hubs could relieve pressure and endless expansion of existing urban communities, whilst improving transport and active travel between them and to greenspace with their rural hinterland; ii. Rural Clusters: Examining how all rural communities can benefit from new investment, not just those that are an existing service centre, to make these existing areas more sustainable and able to thrive.

Comment

Representation ID: 14831

Received: 29/08/2025

Respondent: Bolesworth Estate Co Ltd

Agent: Pegasus Planning Group Ltd

I&O_15382
At Table 5.2, the SA contains a high-level assessment of spatial options A,B and C against key objectives – which score the same against all objectives, with the following (not all) notable exceptions: • Option A (Retain the Green Belt) scores worse (amber) than the other two options in respect of infrastructure – reducing the need to travel and encouraging sustainable modes of transport. • Options B (current LP level and distribution) and C (sustainable transport corridors) score worse (red) in respect of conserving and enhancing the historic environment objective. • Options B & C score better than option A under climate change and reduction of air pollution objectives. As we explain throughout these Representations, it is considered that a blended spatial option/approach will be required in order to sustainably meet housing requirements. No spatial option in isolation will be sufficient. Clearly, the SA also takes a very high-level approach – when in reality, development and allocations should be settlement capacity and site-led, to deliver the best and most suitable options for development across the plan area. Due to the early stage of the Local Plan making process, we note the SA (and Consultation Paper) at this stage only refer to delivery of a minimum of 1,914 dwellings per annum. As required at NPPF paragraph 36, Local Plans must be justified – taking into account reasonable alternatives. One such alternative will be to explore a higher growth option which is higher than the standard method figure, which is a minimum starting point2.  Regardless of what spatial option is ultimately chosen by the Council, it is our view that Tattenhall could support up to 1,500 dwellings as set out in Option A and that this is the target the Council should seek to maintain for the settlement through the next draft iteration of the plan. Indeed, what is evident is that Tattenhall comprises of a range of key local services that make it a sustainable location to accommodate new family housing and affordable housing. This includes local shops, a GP/Medical Practice, a two-form primary school, sports grounds and facilities, a community hall and employment areas (including Chowley Business Park located to the south). There is capacity at the local primary school (which operates at circa 70-75% capacity). More generally, there is a need to invest in the settlement to ensure that its existing services are well supported and utilised so they can continue to provide a benefit to existing and new residents. Housing growth will aid this objective. Whilst we note that there are capacity issues in relation to the GP/Medical Practice, Bolseworth Estate has various property options that could facilitate their relocation and growth. The release of developable land at Frog Lane would assist in ensuring that a solution for the medical practice could be delivered (either through delivery on site or better still, through the linked provision of a facility within/adjacent to the town centre that would make use of existing buildings that could be captured by any future Section 106 agreement relating to the Frog Lane site).

Comment

Representation ID: 15180

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15739
At Table 5.2, the SA contains a high-level assessment of spatial options A, B and C against key objectives – which score the same against all objectives, with the following (not all) notable exceptions: Option A (Retain the Green Belt) scores worse (amber) than the other two options (green) in respect of ‘infrastructure – reducing the need to travel and encouraging sustainable modes of transport’. Options B (current LP level and distribution) and C (sustainable transport corridors) score worse (red) in respect of conserving and enhancing the historic environment objective. The red scoring relates to Green Belt release in Chester – which we respond to in more detail under Question SS 10. Options B & C score better than option A under climate change and reduction of air pollution objectives. As we explain throughout these representations, it is considered that a hybrid approach will be required in order to sustainably meet housing requirements. No spatial option in isolation will be sufficient, and a dispersed spatial strategy (both Green Belt and non-Green Belt options) will be required across the Borough. Clearly, the SA also takes a very high-level approach, when in reality, development and allocations should be settlement capacity and site-led, to deliver the best and most suitable options for development across the plan area. In respect of the settlement specific policies (Chester - CH 1, Northwich - NO 1 etc) assessed in the SA, we do not have any particular comments to make at this stage, given  allocations have not yet been formally identified or assessed. Due to the early stage of the Local Plan making process, we note the SA (and Consultation Paper) at this stage only refer to delivery of a minimum of 1,914 dwellings per annum. As required at NPPF paragraph 36, Local Plans must be justified – taking into account reasonable alternatives. One such alternative will be to explore a higher growth option which is higher than the standard method figure, which is a minimum starting point 2. 2 NPPF paragraph 62 states: To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.

Comment

Representation ID: 15424

Received: 21/10/2025

Respondent: Wirral Borough Council

I&O_15983
No comments at this stage other than to note the commissioning of AECOM to undertake the HRA who will be aware of cross-boundary and wider issues having prepared the HRA for Wirral’s Local Plan