Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13298
Received: 29/08/2025
Respondent: Tony Springett
I&O_13817
I have sent in a comment recently about retaining the green belt, particularly in Upton-by-Chester, Moston area fields (Area CH01). I would like to add, although people talk about wild life corridors, endangered local wild life, green buffers, open areas, flood plains etc, I would like to comment on the most obvious, but least talked about impact of new housing development, namely the loss of agricultural land. Agricultural land grows food, we need food. Once agricultural land has gone, its gone for ever, and do you know what, no one is making any more.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13586
Received: 29/08/2025
Respondent: Marine Management Organisation
I&O_14105
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.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13705
Received: 28/07/2025
Respondent: Qair UK
Agent: Renewable Planning Consultancy Ltd
I&O_14225
The Evidence Base includes the ‘Tyndall Centre Climate Emergency Report (2019)’ within which it states: CO2 emissions in the carbon budget related to electricity use from the National Grid in Cheshire West and Chester are largely dependent upon national government policy and changes to power generation across the country. It is recommended however that Cheshire West and Chester promote the deployment of low carbon electricity generation within the region and where possible influence national policy on this issue. This acts as another reason why the LPA needs to designate suitable areas for renewable energy development taking into account the location of grid connections and should feed into an updated report on sensitivity to renewable energy development.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13745
Received: 29/08/2025
Respondent: Anthony Frampton Rawling
I&O_14265
I am concerned with the sustainable development of this project. I know this because I have studied a geography degree at Chester University and specified in sustainable development and land use. I know there is a need to build houses around the country with the government pushing County councils to build these houses, but there are much better locations to place them. There needs to be a better way or more justified plan in this area. If you would like help with this. I am happy to support, but I disagree with this consultation and hope for a new and improved one.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13793
Received: 29/08/2025
Respondent: United Utilities plc
I&O_14313
Climate Change Policy UUW wishes to highlight its support for any climate change policy. Sustainable surface water management and the efficient use of water must be critical elements of any such policy. We also encourage the policy on climate change to be intrinsically linked to wider policies in the local plan including those relating to the detailed design of new developments and the provision of green and blue infrastructure. We are keen to ensure that any climate change policy gives appropriate emphasis to green and blue infrastructure, natural flood management techniques, multi-functional sustainable drainage, designing new development so that it is resilient to the challenges of future climate change and the incorporation of water supply efficiency measures. As the LPA will be aware, green infrastructure can help to mitigate the impacts of high temperatures, combat emissions, maintain or enhance biodiversity and reduce flood risk. Green / blue infrastructure and landscape provision play an important role in managing water close to its source. If the necessary link between green/blue infrastructure, surface water management and landscape design is outlined as a strategic requirement, it will help ensure that sustainable surface water management is at the forefront of the design process.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13857
Received: 29/08/2025
Respondent: Christopher Martin
I&O_14377
Agree new developments should adopt these principles where relevant
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 13912
Received: 29/08/2025
Respondent: Canal & River Trust
I&O_14432
SUSTAINABLE DEVELOPMENT Question SD 1 - Do you agree with the suggested policy approach towards sustainable development, as set out in SD 1 'Sustainable development' above? If not please suggest how it could be amended? The Trust broadly agree with the policy approach as set out in SD 1 'Sustainable development' and would seek for the contribution that our waterway network can contribute to these provisions to be recognised. The UK Government aims to deliver Net Zero by 2050 and is focussed upon enhancing energy and water security. Our waterways and waterspace can play an important role in helping to reduce emissions and adapt to the effects of climate change in providing innovative solutions to the climate challenges we are likely to face. The canal network within Cheshire West and Chester, as a ready-made blue-green infrastructure network, has the potential to help put measures in place that can help mitigate the effects of climate change and bolster climate resilience, as outlined below. The planning system can be instrumental in helping to mitigate climate change and the Trust would seek for the potential contribution of our network and assets to be recognised in the Local Plan. Our network can assist in adapting to and building resilience to the effects of climate change through: The provision of high quality, interconnected and multifunctional green and blue infrastructure that provides a safe, sustainable alternative mode of travel and an interconnected walking network. Canal corridors and towpaths provide active travel routes for walking and cycling and support in reducing road network emissions in the borough through supporting a modal shift in travel and the provision of alternative, carbon-free walking and cycling routes. Towpaths can play a key role in providing sustainable transport, within Cheshire West and Chester contributing to active travel, helping to prioritise the needs of pedestrians and cyclists and provide associated health and well-being benefits. The provision of water efficiency and management measures. Our network can help respond to climate change by balancing the availability of water through water transfers, saving cost and carbon, and mitigating the impact of flooding through providing flooding relief, water storage, and surface water management. The provision of renewable sources or energy. Our network of waterways is well placed to provide ‘net zero’ solutions. Our assets can help support the provision of energy from clean, renewable sources, such as in the form of Hydro Electric Power. An example includes the installation of a hydroelectric plant at the Grade II listed sluices on the River Weaver at Dutton, Cheshire. The energy produced by the scheme is exported to the local electricity grid where it is then distributed to homes and businesses. Nationally, our network generates hydropower for around 6,200 homes, saving around 9,500 tonnes of CO₂. Our network can assist in water-sourced heating and cooling and the installation of low and zero carbon technologies in this field. For example, the Leeds & Liverpool Canal will support a district heating network supplying more than 9,000 homes and 4 million sq ft of commercial space at Liverpool Waters, and the heat pumps will save 4,200 tonnes of carbon per year. With regard to the Urban Heat Island Effect, the Trust is carrying out research to understand the extent to which canals contribute to urban cooling and whether canals in urban areas have a positive impact upon lowering local air temperatures. Our net work can support the telecommunications system, as beneath our towpaths lies a national network of fibre-optic cables carrying vital communications across the country, with over 700km of telecommunication routes / ducting. This assists in reducing emissions, and the need to travel, by connecting and servicing communities. Our network provides green/blue corridors that maintain and bolster natural habitats to support restoring natural systems. Our corridors at the same time, support biodiversity enhancement, and the provision of green/blue spaces (in support of green infrastructure provision) that provide ecological networks, alongside delivering co-benefits for climate change adaptation. Our network can support the policy provisions of mitigating and adapting to challenges of climate change by the measures outlined above. The Trust would welcome the opportunities offered by our canal networks within the borough being recognised as a means to help mitigate and adapt to effects of climate change, and for policy to identify the potential solutions offered by our green/blue network of waterways that run through Cheshire West and Chester. The Trust has prepared our Impact Report to outline the work carried out in protecting and enhancing the canal network for the benefit of current and future generations. This provides useful information with regard to how our network is an important infrastructure that helps to support energy and water security. Please find the link below for reference. Our impact | Canal & River Trust (canalrivertrust.org.uk) The policy approach also refers to ‘All new buildings should include solar panels unless it can be shown that this is impractical or not viable.’ The Canal & River Trust is a charity and the statutory undertaker with responsibility for regulating navigation on this waterway. Its primary duty, is to ‘provide services and facilities on the inland waterways owned or managed by them’. The Trust welcome the provisions outlined in SD1, and it will be important to balance the need to secure the environmental provisions of the policy with clear criteria on when this provision would have to be complied with, e.g. Clear established criteria and a cubic size threshold may be useful.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14021
Received: 29/08/2025
Respondent: Richard Deakin
I&O_14558
. You talk about sustainability. Yet you do not seem to be trying to make town centers like northwich sustainable by building closer to them. By proposing to build houses in the smaller surrounding villages does not help town centers. It just means people drive to out of town shopping centres. This causes more car journeys and more pollution.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14061
Received: 29/08/2025
Respondent: Caroline Hall
I&O_14604
Additional identification of brown sites in the borough should be a priority undertaken by CWAC and the results publicly published. Within this assessment an understanding of the suitability for development should be included and there should be the option for the public to suggest brown sites to be considered. The council should carry out an assessment on any empty/abandoned buildings and should be given powers to force owners to develop these into homes. The council should have powers to force property owners of redundant buildings to develop these before any green belt, grey belt or open countryside is built on
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14075
Received: 29/08/2025
Respondent: Caroline Hall
I&O_14618
Who will pay for the EV chargers to be installed on public buildings such as village halls? This should not fall on local village hall committees to have to finance as accounts are often overstretched. This should not be a legal requirement/policy if the suggestion is to be included.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14094
Received: 05/09/2025
Respondent: Upton-by-Chester and District Parish Council
I&O_14637
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
Local Plan Issues and Options (Regulation 18)
Representation ID: 14133
Received: 29/08/2025
Respondent: Mrs Jennifer Crew
I&O_14677
SD1 I support the approach set out, however I would like to comment regarding transport. At the consultation stage of the Wrexham Road Development in 2017, the transport study suggested that new residents would largely rely on walking, wheeling and cycling as their preferred mode of transport. This is not the case as many of the new residents are employed many miles away from their homes. The proposed Western Relief Road has been abandoned and the infrastructure promised has not yet been delivered on time. This has resulted in many more car journeys are being made to schools and shops and no account has been taken of the proliferation of deliveries of online purchases. Realistic and properly researched transport studies should be made to assess the environmental impact of new all developments.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14207
Received: 29/08/2025
Respondent: Judith Critchley
I&O_14751
It doesn’t go far enough, only very poor agricultural land should be considered for development
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14630
Received: 29/08/2025
Respondent: Andrews
I&O_15180
PLEASE SEE ABOVE - V1 12 3
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14703
Received: 02/09/2025
Respondent: Darnhall Parish Council
I&O_15253
Darnhall Parish Council notes the following areas of policy set out for the Local Plan. • Sustainable Development – Darnhall Parish Council notes that CWAC has sustainability as a core theme of the new plan and that CWAC states that all development must help reduce carbon emissions, respond to climate change, and protect environmental quality.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 14958
Received: 29/08/2025
Respondent: Ainscough Strategic Land
Agent: Turley
I&O_15517
Overall, ASL supports the approach to ensuring all new development in the Borough is sustainable, in particular reflecting the importance of mitigating and adapting to climate change.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15016
Received: 29/08/2025
Respondent: Grosvenor's Eaton Estate
Agent: Stantec
I&O_15575
Whilst the Council’s aspiration to mitigate the impacts of climate change and provide greater energy efficiency is admirable, and Grosvenor supports the move towards greater energy efficiency and carbon reduction via a nationally consistent set of standards and timetable, policies within the Local Plan should not set local energy efficiency standards for buildings that go beyond Building Regulations. As such, we suggest that Policy SD1 provides overarching ambitions to mitigate the impacts of climate change, but does not set specific requirements which are established in the latest Building Regulations and national policy. As such, we consider such matters are addressed at a national level to avoid different approaches and standards being used at the local level. The draft Plan makes reference to the ‘Planning – Local Energy Efficiency Standards Update’ Written Ministerial Statement (13 December 2023) which seeks to constrain local authorities in setting energy efficiency standards that go beyond current building regulations, and by directing local authorities, where they do set higher standards, to express these ‘as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).’ Notwithstanding the above, Section 4 of these Representations demonstrates that Grosvenor’s land interests are sustainable locations for residential development and are capable of helping the Council meet its future housing requirement and can deliver development in a manner which mitigates against the impacts of climate change. The purpose of these Representations is to assist the Council in delivering a sound Local Plan, which is robust in tackling the Climate Change Emergency through delivery of sustainable development at its Sites to meet the future needs of the borough. Indeed, as set out above, the principal aim of the estate is the long term stewardship of its land and the communities on it which will inevitably involve building sustainably for the future and tackling climate change. Regarding the third part of Policy SD1; ‘Additional environmental and social requirements’, Grosvenor raises concerns with the first bullet point, which seeks to encourage the use of previously developed land and minimise development on greenfield land. We do not consider the policy should ‘minimise’ development on greenfield land. As discussed later in this section of the Representations, development should be delivered in appropriate locations to meet the needs of residents, and development on previously developed land is subject to viability constraints and the challenges to meet housing needs, such as affordable housing. Therefore, whilst Grosvenor welcomes the aspiration to utilise previously developed land wherever possible, minimising greenfield development is at odds with the spatial strategy which we say will inevitably require Green Belt release and development on greenfield land to ensure housing needs can be met. Sustainable development should, instead, come forward in the right locations to support the future needs of the borough. Grosvenor is concerned that a reliance on previously developed land will be insufficient to meet the housing needs of the borough (particularly in relation to affordable housing) and a brownfield first approach should not act as a barrier to sustainable greenfield or Grey Belt development.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15050
Received: 29/08/2025
Respondent: Cheshire Garden Village Ltd
Agent: AshtonHale
I&O_15609
Yes, we broadly agree with the suggested policy approach towards sustainable development. The proposed criteria strike a strong balance between environmental responsibility, resilience to climate change, and social inclusion. However, we recommend that the policy also explicitly recognises that sustainable development can occur on well-located Green Belt sites, particularly where they are adjacent to existing urban or commercial areas, such as the site CGV’s land interests at Land off Chester Way. Sustainable development may, in some cases, include land currently within the Green Belt where clear evidence demonstrates that such development would meet long-term housing, employment, and climate objectives in a manner consistent with national and local sustainability principles
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15141
Received: 29/08/2025
Respondent: Views Holdings Limited
Agent: AshtonHale
I&O_15700
Yes, Views broadly agrees with the suggested policy approach towards sustainable development. The proposed criteria strike a strong balance between environmental responsibility, resilience to climate change, and social inclusion. However, we recommend that the policy also explicitly recognises that sustainable development can occur on well-located Open Countryside sites, particularly where they are in proximity to existing urban or commercial areas, such as the site Land off London Road, Davenham. Sustainable development may, in some cases, include land currently within the Open Countryside where clear evidence demonstrates that such development would meet long-term housing and climate objectives in a manner consistent with national and local sustainability principles.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15187
Received: 29/08/2025
Respondent: Barratt Redrow Plc
Agent: Pegasus Planning Group Ltd
I&O_15746
Barratt Redrow is supportive of the general principles of Policy SD 1, with the only comment at this stage being the importance of the need for flexible wording. At times, the current wording of Policy SD 1 reads as stringent, and it is important to recognise that there may be site-specific instances where all of the criteria cannot be met. We therefore recommend the first sentence of the policy is amended as follows: “New developments must, where feasible and relevant”
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15295
Received: 29/08/2025
Respondent: Peel NRE Limited
Agent: Turley
I&O_15854
Peel supports this policy. As recognised in the pre-lude to the proposed policy, the borough has above average carbon dioxide emission per capita, which is largely due to the very high industrial emissions in CWAC due to industrial sources such as Stanlow refinery. The borough is identified by the Government as a low carbon industrial cluster and will be host to HyNet (as described in Section 2). The HyNet development represents nationally critical infrastructure to achieve net zero. It is a low cost, highly deliverable, world-leading low carbon energy cluster aimed at removing carbon from all industrial emitters across the region. It will provide the blue print for UK’s broader strategy to achieve net zero emissions while supporting economic growth and energy security. This cluster is fundamental to the borough’s success of achieving net zero and Peel considers this should be recognised in Policy SD 1, along with the supporting infrastructure required to make the most of this opportunity, and the land required to deliver such infrastructure. In turn this will secure thousands of skilled jobs in construction and future low-carbon power generation, and in the existing industries across the borough.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15352
Received: 29/08/2025
Respondent: Peel NRE Limited
Agent: Turley
I&O_15911
Section 2. Strategic Context Climate Change and Net Zero Climate change is unarguably one of the biggest challenges facing the UK, and indeed the world, right now. Urgent action is needed to reduce greenhouse gas emissions and create a more sustainable future. The UK is committed to reduce the UK’s greenhouse gas emissions to ‘net-zero’ by 20501. To achieve this, the UK Government has set out its national objectives within its Clean Growth Strategy2 to grow the country’s national income while cutting greenhouse gas emissions. The use of infrastructure is recognised as being ‘critical’ in achieving the UK’s set target of being net-zero by 20503. The investment into alternative renewable and low carbon energy sources will enable the UK’s power system to be virtually carbon free and meet additional demand for energy within the future, as well as creating an economic boost within the market. The use of the Ten Point Plan for a Green Industrial Revolution4 sets out how the UK achieve can net zero by 2050. Key to this is the production and use of hydrogen5, the investment in carbon capture, utilisation and storage (CCUS), which is seen as a necessity not an option6 , and the provision of and support for renewable energy schemes, including onshore wind and solar7.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15353
Received: 29/08/2025
Respondent: Peel NRE Limited
Agent: Turley
I&O_15912
Section 2. Strategic Context Industrial Decarbonisation and ORIGIN The North West of England produces approximately thirty-eight mega-tonnes of carbon dioxide per annum. CWAC is currently one of the highest emitting boroughs of greenhouse gases in the UK. Carbon Dioxide per capita estimates for 2022 within the scope of influence of Local Authorities (including commercial, domestic, industry, transport and public sectors) were 7.3kt per capita in CWAC, compared to 4.3kt per capita for England, which is mostly from industry, buildings and road transport. The Ellesmere Port complex alone consumes c. 5% of the UK’s energy. In short CWAC has more to do, and more opportunity to make a difference, than most places across the country – the planning process has a key part to play in achieving this. CWAC has set an ambitious target to reach ‘net zero’ by 2045 or earlier. The Council aims to work with central Government and stakeholders to further economic progression through development of infrastructure which will provide environmental advantages as well as the provision of jobs and inward investment (“clean growth”). The Net Zero North West (NZNW) Cluster has been established to bring together industries, businesses and communities from across the North West to collectively drive down CO2 emissions and achieve net zero as a region by 2040. Additionally, to help achieve their own net zero emission targets by 2045, CWAC aims to establish the UK’s first low carbon industrial hub, which involves the creation of a clean growth industrial cluster around Ellesmere Port, known as “ORIGIN”. Protos (Phases 1 & 2) is a key project within the ORIGIN area - identified by CWAC amongst the major investments in the cluster. Both NZNW and ORIGIN are becoming more established, and their importance continues to grow. ORIGIN has the scale and capacity to become a global leader in energy technology, leading the UK in industrial decarbonisation, supporting the Green Industrial Revolution and delivering one of the world’s first Net Zero Carbon Industrial clusters. The Ellesmere Port Investment Prospectus8 sets the ambition for ORIGIN to be the place where solutions to climate change become reality. ORIGIN is a fundamental part of the growth of not only CWAC, but also the North West and the UK as a whole. ORIGIN is becoming known for the progress it is making in creating a decarbonised industrial cluster with security in clean energy and hydrogen to build sustainable income streams and create jobs. Key stakeholders in the area from both the private and public sector have set out a clear vision and realistic action plan to deliver the interventions needed to help unlock major private sector investment opportunities and these are outlined in a Development and Infrastructure Framework (DIIF) for the area. Invest Net Zero Cheshire, a partnership between the Cheshire and Warrington Local Enterprise Partnership (further information below) and the Cheshire Energy Hub has produced a portfolio of £1bn of viable projects that meet the aim of net zero carbon emissions, whilst satisfying the energy demands of the area. This blueprint offers long term, sustainable investment opportunities in net zero and clean growth9. The most significant project in the area is the HyNet Cluster (“HyNet”), an industry-led initiative to develop world leading Carbon Capture Usage and Storage (CCUS) and Hydrogen Power10. The HyNet development represents nationally critical infrastructure to achieve net zero. It is a low cost, highly deliverable, world-leading low carbon energy cluster aimed at removing carbon from all industrial emitters across the region. It will provide the blueprint for UK’s broader strategy to achieve net zero emissions while supporting economic growth and energy security. Vertex Hydrogen, a key part of Essar Energy Transition (EET) is planning investment of nearly £500 million building a new production plant in Ellesmere Port. This is likely to stimulate significant further growth locally, with opportunities for other businesses to locate in close proximity to the hydrogen plant to decarbonise their operations. This will be most important for heavy industry/waste management who create significant carbon emissions. Additionally, and very recently (5th August 2025), the Government announced additional projects associated with the HyNet Cluster which will support a total of 2,800 direct skilled jobs across Cheshire (and also Flintshire)11. This includes the Connah’s Quay Low Carbon project in North Wales, and the Ince Bioenergy with Carbon Capture and Storage at Protos. These projects are added to the existing projects identified for priority negotiations, including: Protos Energy Recovery Facility, Encyclis, Protos, Ellesmere Port (Cheshire); Hanson Padeswood Cement Works Carbon Capture Project, Heidelberg Materials, Padeswood (North Wales); and Hydrogen Production Plant 1 (HPP1), EET Hydrogen, Stanlow (Cheshire). There are also an additional five “standby” projects to provide contingency, including: Silver Birch, Climeworks UK Ltd , Stanlow (Cheshire); Essar Energy Transition Industrial Carbon Capture (EET ICC), EET Fuels, Stanlow (Cheshire); Hydrogen Production Plant 2 (HPP2), EET Hydrogen / Progressive Energy, Stanlow (Cheshire); Parc Adfer Energy from Waste Industrial Carbon Capture Project, Enfinium Group Ltd, Deeside (North Wales); and Runcorn Carbon Capture Project, Viridor, Runcorn (Cheshire). These projects are focussed within CWAC and (largely) in and around the Ellsemere Port and ORIGIN area, demonstrating the strategic importance and the focal point of this area to support clean growth and the movement towards net zero. As demonstrated with the projects above, Protos is already acting as a catalyst for industrial decarbonisation. Protos is placed within ORIGIN (known as the “Eastern Growth District”), recognising its importance in enabling HyNet and serving industrial users. Protos is uniquely positioned to HyNet, with the main infrastructure pipelines and other above ground components being located approximately 1km south of Protos and therefore provides the opportunity to be able to host projects which are able to utilise the HyNet infrastructure (subject to securing planning permission). The land surrounding Protos, which is promoted through these representations, also benefits from the same adjacency. This land sits to the east and south of ORIGIN’s Eastern Growth District. As is detailed further at Sections 5 - 12, this land has unique characteristics being large-scale, flat, and in close proximity to established and planned essential infrastructure (HyNet, gas and electricity connections, canal and rail, strategic highway) – as well as proximity to the existing Protos development and other significant industrial and employment uses in the area. This provides an opportunity to create synergies and utilise infrastructure provision to cluster developments associated with decarbonisation and clean growth.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15354
Received: 29/08/2025
Respondent: Peel NRE Limited
Agent: Turley
I&O_15913
Section 2. Strategic Context Infrastructure, Economic Growth and Job Creation National The Government recently published the ‘UK’s Modern Industrial Strategy’12. This sets out a ten-year plan to deliver long term sustainable growth and investment in high growth sectors. The strategy focuses on tackling barriers to growth in the highest potential growth-driving “frontier” sectors and firms, creating the right conditions for increased investment, high-quality jobs and ensuring tangible impact in communities across the UK. Spatially, the strategy focusses on promoting city regions outside of London and the South-East, where economic performance has historically been focused. Tackling this comparative underperformance is identified as being key to economic growth and reducing inequality across the regions. The revised National Planning Policy Framework (NPPF) published in December 2024 establishes the Governments vision for sustained economic growth. Since its election in July 2024, the Government has been clear in its view that “sustained economic growth is the only route to improving the prosperity of our country and the living standards of working people”13. It has stated that its “central mission” is to “restore economic growth” and it also aims to deliver the infrastructure that the country needs14. The updated NPPF (December 2024) provides a policy framework to facilitate the Government’s commitment to aim for the highest sustained growth in the G7, with more people in good jobs, higher living standards and productivity growth across the country. It recognises that growth can only be achieved in partnership with businesses. It establishes the intention for the planning system to “help create the conditions in which businesses can invest, expand and adapt”. In this context it confirms that: “Significant weight should be placed on the need to support economic growth and productivity.”15 In order that sustainable development is pursued in a positive way, the NPPF retains the “presumption in favour of sustainable development”16, which requires local authorities – in the development of their Local Plans – to “meet the development needs of their area”17. NPPF requires planning policies to “set out a clear economic vision that positively and proactively encourages sustainable economic growth having regard to the national industrial strategy” (paragraph 86a) and “pay particular regard to facilitating development to meet the needs of a modern economy” (paragraph 86c). It notes that “the UK’s Modern Industrial Strategy identifies priority sectors for growth and support as: advanced manufacturing; clean energy industries [emphasis added]; creative industries; defence industries; digital and technology businesses; financial services; life sciences; and professional and business services” (Footnote 43). In this context it also requires planning policies to “be flexible enough accommodate needs not anticipated in the plan” (paragraph 86e). The updated NPPF expects the planning system to recognise and address the specific locational requirements of different sectors. It specifically identifies that this should include making provision for: a) clusters or networks of knowledge and data-driven, creative or high technology industries; and for new, expanded or upgraded facilities and infrastructure that are needed to support the growth of these industries (including data centres and grid connections); b) storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially where this is needed to support the supply chain, transport innovation and decarbonisation [emphasis added]; and c) the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience18. The Clean Energy Industries Sector Plan (updated on 5th August 2025)19 sets the ambition to make the UK a global leader in the clean energy industry by 2035, doubling investment levels across in the industries to over £30 billion per year and creating jobs across the country. This Plan builds on the UK’s Modern Industrial Strategy. This vision is supported by the following aspirations: • Be the most attractive place in Europe to invest in Clean Energy Industries. • Have grown exports in all frontier Clean Energy Industries. • Have created hundreds of thousands of good quality jobs across the country. • Have driven higher domestic commercialisation of evolving clean energy technologies. • Have secured more resilient and robust supply chains. This Plan confirms that across the UK in 2022 there were already approximately 450,000 jobs in low carbon and renewable energy jobs or in the wider supply chains, and suggests hundreds of thousands of jobs could be supported by 2030. Carbon capture will help to decarbonise heavy industry as the country accelerates to net zero, whilst protecting skilled, manufacturing jobs and creating new export opportunities for British business in new technologies. Carbon capture alone is expected to add around £5 billion per year to the UK economy by 2050. Regional Cheshire and Warrington are home to a strong, educated, and entrepreneurial labour market. The Cheshire and Warrington LEP covers Cheshire West, Cheshire East and Warrington (now known as Enterprise Cheshire and Warrington). The LEP’s ambition is to be the healthiest, most sustainable, inclusive, and fastest-growing place in the UK by 2045, set out in their Sustainable and Inclusive Economic Strategy21. This Strategy recognises the areas considerable sector strengths to unlock growth from decarbonisation and the transition to clean energy. This also means supporting other significant sectors, including manufacturing; business and finance; and logistics and distribution. The LEP’s Local Industrial Strategy (2019)22 identifies the Stanlow refinery in Ellesmere Port which has historically been at the heart of the traditional carbon economy, but also highlights the emerging strengths in hydrogen production and storage and nuclear engineering. The Cheshire and Warrington Sustainable and Inclusive Growth Commission was set up by the Subregional Leaders’ Board in November 2020, with the aim of building on progress to date to help realise Cheshire and Warrington’s ambition of becoming the most sustainable and inclusive subregion in the UK. One of their recommendations is to build the UK’s First Net Zero industrial cluster around the area’s large hydrogen and net zero projects – i.e. the HyNet Cluster. The current number employed in the ‘Low Carbon and Renewable Energy Economy’ (LCREE) in Cheshire and Warrington is estimated to be about 4,000. These numbers are set to grow. Ecuity has forecast a fourfold growth to 15,000 employed in the LCREE in Cheshire and Warrington by 203023. However, this growth could be more significant if the project portfolio developed by Net Zero North West is delivered (as described above). In July 2021, NZNW published an Economic Investment Prospectus designed to stimulate over £200 billion of investment in the region in eighteen key projects. The prospectus proposes to deliver a 38.5 MtCO₂ emissions reduction to meet the North West’s decarbonisation net zero goal by 2040 through £206.9 billion of investment, which, it says, will help support 660,000 jobs to be secured or created and grow the economy by £285 billion GVA. The growth of the Low Carbon and Renewable Energy Economy will be driven, in the first instance, by the reskilling of the existing workforce. For example, car manufacturers will transition from the assembly of cars with internal combustion engines to the assembly of cars with batteries. Industries will need to reshape how they operate to reduce carbon emissions and help the area to become net zero including what they produce, how they consume energy, and how they mitigate emissions. This shift will lead to changes to the nature of work in these industries. This will need new skills, and for the existing workforce to reskill. The decarbonisation industry will not only help the UK meet the zero carbon goals, but it will also help to protect and grow the high value local manufacturing jobs. High-value jobs within low carbon sectors directly aligns with the UK’s Industrial and Clean Growth Strategies.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15410
Received: 29/08/2025
Respondent: Consilio Bono
Agent: PWA Planning
I&O_15969
Any policy which attempts to be over prescriptive or does not accept that technological changes will occur and cannot necessarily be foreseen at this stage will ultimately carry little or no ultimate weight and will simply be worked around and will reduce the importance and impact of the policy. Policies in the plan ought not to repeat or rework guidance which exists in the Framework or national guidance; the best solution is that the plan remains silent on matters which are adequately covered in national guidance. Perhaps more importantly, the plan should not seek to go behind national guidance and seek to apply more onerous restrictions on development than might otherwise apply. For example, in respect of the “additional environmental and social requirements” being considered, national guidance does not seek to “avoid development in locations of high environmental value and on high grade agricultural land”. National guidance is more nuanced and acknowledges that meetingdevelopment needs is vital whilst recognising the intrinsic character and beauty of the countryside and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland (NPPF 187 b). Importing greater level of controls using words such as avoid / reject / refuse is simply inconsistent with most of the national guidance and should not be the approach taken if the plan is to be shown to be consistent with national guidance and hence sound. It should then be considered whether the plan needs to provide additional guidance, particularly where this seeks to require adherence to certain specific technologies, e.g. district heat networks, beyond that in national guidance. Simplicity in the plan making process and avoidance of conflicts with national guidance remains crucial to local plans being vital land use planning tools.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15433
Received: 29/08/2025
Respondent: Shropshire Homes
Agent: Pegasus Planning Group Ltd
I&O_15992
Shropshire Homes are supportive of the general principles of Policy SD 1, with the only comment at this stage being the importance of the need for flexible wording. At times, the current wording of Policy SD 1 reads as stringent – and it is important to recognise that there may be site-specific instances where all of the criteria cannot be met. We therefore recommend the first sentence of the policy is amended as follows: “New developments must, where possible, feasible and relevant”
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15441
Received: 21/10/2025
Respondent: Wirral Borough Council
I&O_16000
No comments at this stage
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15742
Received: 29/08/2025
Respondent: Northern Powerhouse Land Ltd
Agent: Asteer Planning
I&O_16301
NPL supports the Council’s commitment to mitigating and adapting to climate change. Nevertheless, where the new Local Plan seeks to introduce additional policy requirements that could threaten the viability and/or delivery of development, there must be a robust and flexible mechanism whereby these additional requirements and/or other requirements (such as affordable housing or other developer contributions) can be relaxed if viability is threatened. Therefore, NPL supports the use of words such as “maximise” and “minimise” within SD 1, which acknowledge that there is flexibility in the delivery of the stated measures to mitigate and/or adapt to climate change and should be incorporated within any prospective planning policy relating to sustainable development.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15808
Received: 01/09/2025
Respondent: Central & Country Developments Ltd
Agent: HK Planning
I&O_16367
A tail piece should be added to 'avoid development in locations of high environmental value and on high grade agricultural land' that reads 'unless allocated in the Local Plan' as these are expected to be factors considered in allocating land for development, and should not have be re-iterated at application stage.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 15830
Received: 29/08/2025
Respondent: West Midlands Pension Fund
Agent: Knight Frank
I&O_16389
Whilst ensuring sustainable development is the ‘golden thread’ running through the National Planning Policy Framework, as written this policy includes detailed subsections relating to climate change mitigation and adaption and additional environmental and social requirements. It is suggested that they are removed from SD 1 and included elsewhere in the Local Plan as separate policies or combined with other relevant policies.