Comment

Representation ID: 12616

Received: 28/08/2025

Respondent: David Varley

I&O_13133
Future development should be focused on Brown Field and other post-industrial sites in the area.  

Comment

Representation ID: 12755

Received: 28/08/2025

Respondent: Andrew Paterson

I&O_13273
Regeneration of brownfield sites and underutilised land.

Comment

Representation ID: 13256

Received: 29/08/2025

Respondent: Carden Group

I&O_13775
While we broadly support Option B, which focuses growth in and around the largest settlements, we believe this approach should be refined in light of the proposed amendments to the settlement hierarchy. Notably, the elevation of Frodsham to Market Town status, justifies the settlement receiving a greater proportion of growth than those identified as Key Service Centres. These towns serve important sub-regional roles, offer a strong base of services and infrastructure, and are well-placed to accommodate additional development sustainably. As such, they should be prioritised for growth ahead of smaller, less well-connected settlements. Moreover, irrespective of which housing requirement or spatial option is chosen by the Council, it is our view that Frodsham could support up to 3,000 dwellings as set out by the Council in Option C and that this is the target the Council should seek to maintain for the settlement through the next draft iteration of the plan. No evidence has been provided to suggest that this level of growth cannot be sustainably accommodated under all options. We therefore broadly support a modified Option B approach, where growth is focused on the most sustainable settlements in the borough, including not just the principal urban areas, but also the Market Towns that demonstrate strong service provision and development potential. This approach also ensures alignment with NPPF which states that ‘Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes’. This emphasises the importance of focusing growth where it can be best supported and integrated.

Comment

Representation ID: 13390

Received: 29/08/2025

Respondent: Weaverham Trust

I&O_13909
Maximise the use of brownfield sites in Cheshire West and Chester.

Comment

Representation ID: 13864

Received: 29/08/2025

Respondent: Christopher Martin

I&O_14384
The  proposed options are too extreme and there should be a balance with some limited Green Belt development in an appropriate location , following the original local plan with some sustainable transport consideration .

Comment

Representation ID: 13971

Received: 29/08/2025

Respondent: Landowner (Forest Road)

Agent: Carden Group

I&O_14491
While we broadly support Option B, which focuses growth in and around the largest settlements, we believe this approach should be refined in light of the proposed amendments to the settlement hierarchy. Notably, the elevation of Neston and Parkgate, as well as Frodsham to Market Town status, and our own recommendation that Tarporley should also be classified as a Market Town, justifies these settlements receiving a greater proportion of growth than those identified as Key Service Centres. These towns serve important sub-regional roles, offer a strong base of services and infrastructure, and are well-placed to accommodate additional development sustainably. As such, they should be prioritised for growth ahead of smaller, less well-connected settlements. However, what is clear is that the proposed levels of growth for the KSCs in the Regulation 18 Local Plan do not follow the existing level of distribution of growth (see Appendix 1). The levels of growth for each KSC should be increased to reflect the correct continuation of spatial growth, but these should be adjusted to also reflect the sustainability and potential of each settlement. Tarporley is exceptionally well placed compared to the other KSC to accommodate a significantly higher proportion of the growth for the rural areas. Tarporley should be allocated at least 650 homes on the basis of the Regulation 18s proposed 29,000 home requirement, which should be increased further to 770 homes, to reflect the need for a 15 year plan period post adoption. Moreover, irrespective of which housing requirement or spatial option is chosen by the Council, it is our view that Tarporley could support up to 1,500 dwellings as set out in suggested by the Council 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. No evidence has been provided to suggest that this level of growth cannot be sustainably accommodated under all options. We therefore broadly support a modified Option B approach, where growth is focused on the most sustainable settlements in the borough, including not just the principal urban areas, but also the Market Towns that demonstrate strong service provision and development potential. This approach also ensures alignment with NPPF which states that ‘Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes’. This emphasises the importance of focusing growth where it can be best supported and integrated.

Comment

Representation ID: 14225

Received: 29/08/2025

Respondent: Judith Critchley

I&O_14769
No

Comment

Representation ID: 14443

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

Agent: Bidwells

I&O_14987
Spatial Alternative: Growth Hubs The Spatial Strategy should move beyond a settlement-by-settlement approach and identify how broader patterns of growth can improve transport, economic and environmental connections between existing settlements by directing growth to strategic nodes. At the same time, this would avoid over-extending existing settlements, risking coalescence or forcing existing communities to absorb yet more development. The Salt Towns will benefit from planned investment in the Middlewich bypass, the plans to reopen passenger services at Middlewich and the proposed bypass for Winsford. These investments underpin how the new Local Plan needs to get ahead of this investment and its transformative impact. There are also regeneration benefits to existing communities in taking a holistic approach to a locality, rather than a settlement-focussed approach. Paragraph 77 of the NPPF encourages a bolder approach looking at new settlements as well as extension to existing settlements and it is in this respect we put forward our alternative option for a Sustainable Growth Hub.  Specifically, our proposals for a Sustainable Growth Hub at land at Bostock Green would positively address growth around the Salt Towns, whilst improving the quality of life of these existing communities. Located equidistant between Middlewich, Winsford and Northwich/Davenham, Bostock Green has obvious and significant potential to support the emerging plan spatial strategy but was not considered as part of any the spatial options for growth in this area despite several years of active promotion by its legacy landowner. Identification of a mixed-use area for growth provides an opportunity to improve rural access to existing service centres, avoid over-extending existing settlements and improve sustainable connectivity between the three Salt Towns, without risk of coalescing, as Figure 2 (Figure 2 – Proposed Growth Hub around Bostock Green as another Option to consider. Reduction of edge of settlement and coalescence of communities in favour of a new sustainable, walkable community that improves connectivity between the three Salt Towns and provides access to greenspace for existing residents of these towns. - See attachment) Arden Enterprises Group is responsible for the management of most of the model village of Bostock Green, with over 30 buildings, rural businesses such as the Hayhurst Arms, Tilly Tots Nursery School and the working Smithy and is home to 200 residents and jobs. Arden Enterprises Group takes a long-term approach and works closely with its tenants and partners to ensure mutually beneficial and sustainable outcomes across its estate. In respect of Bostock Green, Arden Enterprises Group has worked hard to maintain the significance of the village whilst investing and supporting businesses and facilities to support village life making direct investment itself as well as securing over £2m from partners like Brunning & Price to create over 100 new jobs. The site was presented as an opportunity for CWAC and Arden Enterprises Group to pilot a new approach to using the largely rural hinterland to better link the historic Salt Towns of Northwich, Winsford and Middlewich. A copy of the response is provided at Appendix 1 (see attachment) As shown at Figure 3 (see attachment), Bostock Green could not just provide housing and employment, but also a vibrant, mixed-use walkable community as well as social infrastructure also serving the Salt Towns through new walking trails, community facilities and services, alongside environmental net gains. Meanwhile, this provides a compelling reasonable alternative to over-extending the periphery of existing communities such as Davenham, Northwich, Hartford, Winsford and Middlewich, which if realised, would effect coalescence between these various communities. Moreover, the existing strategy would only deliver “housing” and “employment” as the draft plans exclusively show. There is no mixed-use alternative that could release pressure on these communities and provide them with improved access to greenspace as well as each other’s employment and service centres. Figure 3 Bostock Green as a Sustainable Growth Hub between the surrounding communities of Winsford, Middlewich and Northwich - see attachment)  Land at Bostock Green is largely free of constraints and is not within the Green Belt. The site would therefore be a sustainable location for growth especially under spatial strategy option A (retain the Green Belt). It is our view that non-Green Belt locations near Winsford, particularly north and east of the town close to the rail station and town centre like Bostock Green, should be prioritised over development of Green Belt land around larger urban areas in other less sustainably located sites. The site would also support Sustainable Growth Hubs and Rural Clusters, delivering much needed investment in rural areas in line with our proposed additional spatial strategy options above. Bostock Green is in a sustainable location, within 6 minutes of the rail station and 4 minutes or 1.9 miles from the regionally significant and fast growing Winsford Industrial Estate. Appropriate growth on the rural hinterland can also open up opportunities for greater public access for both recreation and active travel between urban centres. For example, as part of the emerging development proposals, we are proposing circular walks along the River Dane and enhanced connectivity to nearby towns and potential links to Bostock Hall. The site has been assessed within the 2025 Land Availability Assessment as having ‘initial constraints’ with >10% of the site area within flood zone 3. However, the site submission was revised in February 2025 to exclude land to the east within the flood plain. We therefore request that the updated site submission is urgently re-assessed in the LAA. Logically, the assessment should conclude the slightly reduced site is fully ‘suitable’ for mixed-use development. Land at Bostock Green is largely free of constraints and is not within the Green Belt. The site would therefore be a sustainable location for growth especially under spatial strategy option A (retain the Green Belt). It is our view that non-Green Belt locations near Winsford, particularly north and east of the town close to the rail station and town centre like Bostock Green, should be prioritised over development of Green Belt land around larger urban areas in other less sustainably located sites. The site would also support Sustainable Growth Hubs and Rural Clusters, delivering much needed investment in rural areas in line with our proposed additional spatial strategy options above. Bostock Green is in a sustainable location, within 6 minutes of the rail station and 4 minutes or 1.9 miles from the regionally significant and fast growing Winsford Industrial Estate. Appropriate growth on the rural hinterland can also open up opportunities for greater public access for both recreation and active travel between urban centres. For example, as part of the emerging development proposals, we are proposing circular walks along the River Dane and enhanced connectivity to nearby towns and potential links to Bostock Hall. The site has been assessed within the 2025 Land Availability Assessment as having ‘initial constraints’ with >10% of the site area within flood zone 3. However, the site submission was revised in February 2025 to exclude land to the east within the flood plain. We therefore request that the updated site submission is urgently re-assessed in the LAA. Logically, the assessment should conclude the slightly reduced site is fully ‘suitable’ for mixed-use development. The principle of using new settlements in support of growth is firmly embedded in Paragraph 77 of the NPPF and represent a clear and reasonable alternative that the Council is invited to assess. Arden Enterprises Group are willing to assist the Council in this respect to ensure the Council arrives at a legally compliant as well as sound and positive spatial strategy.

Comment

Representation ID: 14448

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

Agent: Bidwells

I&O_14992
Having set out our positive alternative, we would like to highlight the risks and harms of the spatial strategy options proposed in the Reg-18 Consultation. In our assessment a material proportion of the areas selected are not sustainable and/or suitable locations for development. We are concerned that the Draft Plan has failed to even consider, let alone objectively assess, a number of potentially suitable sites through exclusion of land subject to constraints which are perceived as “showstoppers” to restrict future development. This includes Local Green Spaces, designated heritage assets, key settlement gaps and areas of flood risk even for just part of a site. We do not agree that sites subject to these constraints should be automatically excluded from further consideration, and in addition it seems the approach has not been applied consistently to all areas, for instance site refs NOR 8 and WIN 04 are located almost wholly within designated Conservation Areas. Bizarrely, the greenbelt and non-Greenbelt spatial options alike fails to consider opportunity areas promoted in the SHLAA outside the greenbelt (like Bostock Green) whilst including some very large sites with major constrains including Greenbelt.

Comment

Representation ID: 14521

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

Agent: Bidwells

I&O_15067
Spatial Alternative: Rural Clusters Beyond accommodating strategic growth, we have serious concerns that the direction of planning policy fails to plan positively for rural areas despite the National Planning Policy Framework being clear on more positive measures. We reproduce the key paragraphs from the NPPF below: “ 82. In rural areas, planning policies and decisions should be responsive to local circumstances  and support housing developments that reflect local needs, including proposals for  community-led development for housing. Local planning authorities should support  opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these  sites would help to facilitate this. 83. To promote sustainable development in rural areas, housing should be located where it will  enhance or maintain the vitality of rural communities. Planning policies should identify  opportunities for villages to grow and thrive, especially where this will support local services.  Where there are groups of smaller settlements, development in one village may support  services in a village nearby.” The first draft policy options are either silent on rural investment, with weak support for opportunities to deliver more affordable housing and services whilst allowing more accommodation for new families to renew and reinvigorate rural communities. In this respect, it is harder for small and medium builders to deliver investment in rural areas where thresholds to provide affordable housing is significantly lower and where there is no evidence that there is significant brownfield land is in need of recycling in accordance with paragraph 65 of the NPPF. On the other hand, proposals for a dedicated policy for community-led housing are supported. The proposed planning policy options therefore do not positively plan for the needs of rural communities, contrary to paragraph 83 of the NPPF.  This points to another Spatial Option for the SA to consider, one which in addition to making the Plan legally compliant, would also improve the quality of life, economic and environmental sustainability of rural areas. The spatial strategy needs to look beyond existing transport corridors and identify Rural Clusters where investment can be more intelligently promoted and delivered. Without consideration of these Alternatives and positive planning for Sustainable Growth Hubs and Rural Clusters, the direction of the emerging Local Plan cannot be justified as appropriate based on the evidence submitted, or consistent with national policy in enabling the delivery of sustainable development and would be unsound. We have set out the steps necessary to address that and are happy to assist in refining the spatial strategy options and supporting policies in pursuit of a sound Local Plan.  We urge the Council to consider these options as alternative strategies to strengthen connections between rural communities and urban centres through provision of new homes and other development, as well as looking for opportunities to reduce isolation and improve sustainability in rural areas.

Comment

Representation ID: 14531

Received: 29/08/2025

Respondent: Chester Nomads Football Club

I&O_15077
The Landowner is supportive of Options B and C, and believe a combined approach is most suitable to be developed for the emerging Local Plan. By pursuing this option, the spatial strategy could prioritise brownfield sites where available. As well as direct growth to those settlements where it is most appropriate. Both options will need to identify additional land, in particular in and around Chester, to meet the minimum housing requirement. The Council should consider the allocation of a range of sites, including enabling smaller sites to come forward, reducing the reliance on large urban extensions. A combined approach would enable sites to come forward that are deliverable, sustainable, balanced and defensible.

Comment

Representation ID: 14642

Received: 29/08/2025

Respondent: Andrews

I&O_15192
Some of the changes we need need to come from developers .  I am totally against land being made Leasehold - which costs are currently uncontrolled and unethical.  And against land being bought and then sold once planning permission is agreed. We are losing control of land and we shouldn’t be.

Comment

Representation ID: 14669

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

Agent: NJL Consulting

I&O_15219
We do not consider that any single option, as presented in the document, as the most appropriate spatial option and an alternative spatial option is detailed below. From a review of all options, an alternative strategy could combine the strengths of Option B (distribution development by settlement hierarchy) and Option C (focussing development at sustainable transport corridors), while avoiding too much of a focus on a large urban extension only approach. By doing so, an alternative approach would: o Prioritise brownfield and urban regeneration sites where available. o Direct growth to main towns (Chester, Ellesmere Port, Northwich, Winsford) but avoid addressing needs through a few very large urban extensions. o Support medium-scale growth at rail-served villages and key service centres (e.g. Lostock Gralam, Cuddington & Sandiway, Helsby, Frodsham, Tarporley) through targeted Green Belt releases. o Allow smaller, proportionate growth in Local Service Centres and more rural settlements (e.g. Davenham) to sustain schools, shops, and services. The benefits of an alternative proposition would be as follows: • Deliverable: it would avoid an over-reliance on a few large, infrastructure-heavy urban extensions that could result in a delay of supply. • Sustainable: it would support travel by train and bus, reducing car dependency, and strengthen smaller communities, as development would result in a subsequent improvement to infrastructure. • Balanced: it would allow growth to be distributed fairly across towns, villages, and the rural area. • Defensible: it would still allow for targeted Green Belt release particularly where a strong contribution to Green Belt purposes is not identified. Overall, the key to this approach would be to spread growth across multiple settlements to reduce risk and ensure flexibility if some sites don’t come forward as planned.

Comment

Representation ID: 14728

Received: 29/08/2025

Respondent: Essar Energy Transition

Agent: E L G Planning

I&O_15278
For reasons outlined in the below response to question SS28, it is clear that Ellesmere Port and the village of Elton are significantly constrained by existing industry and associated COMAH zones which significantly restricts the type of development which is acceptable in such locations including the Stanlow Manufacturing Complex. Essar Energy Transition consider that the Council must therefore be mindful of this when considering the potential spatial strategy. In view of the constraints and importance of Stanlow and the wider Origin cluster, Essar Energy Transition consider that a spatial strategy which provides any significant greenfield development elsewhere in the district would be more appropriate.

Comment

Representation ID: 14753

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15303
We do not consider that any single option, as presented in the document, as the most appropriate spatial option and an alternative spatial option is detailed below. From a review of all options, an alternative strategy could combine the strengths of Option B (distribution development by settlement hierarchy) and Option C (focussing development at sustainable transport corridors), while avoiding too much of a focus on a large urban extension only approach. By doing so, an alternative approach would: o Prioritise brownfield and urban regeneration sites where available. o Direct growth to main towns (Chester, Ellesmere Port, Northwich, Winsford) but avoid addressing needs through a few very large urban extensions. o Support medium-scale growth at rail-served villages and key service centres (e.g. Lostock Gralam, Cuddington & Sandiway, Helsby, Frodsham, Tarporley) through targeted Green Belt releases. o Allow smaller, proportionate growth in Local Service Centres and more rural settlements (e.g. Kingsley) to sustain schools, shops, and services. The benefits of an alternative proposition would be as follows: • Deliverable: it would avoid an over-reliance on a few large, infrastructure-heavy urban extensions that could result in a delay of supply. • Sustainable: it would support travel by train and bus, reducing car dependency, and strengthen smaller communities, as development would result in a subsequent improvement to infrastructure. • Balanced: it would allow growth to be distributed fairly across towns, villages, and the rural area. • Defensible: it would still allow for targeted Green Belt release particularly where a strong contribution to Green Belt purposes is not identified. Overall, the key to this approach would be to spread growth across multiple settlements to reduce risk and ensure flexibility if some sites don’t come forward as planned.

Comment

Representation ID: 14841

Received: 29/08/2025

Respondent: Bolesworth Estate Co Ltd

Agent: Pegasus Planning Group Ltd

I&O_15392
Due to the significant development requirements of the borough, and the fact that a number of large settlements in the borough are surrounded by Green Belt, it is considered it will be unfeasible for the Green Belt to be retained in its entirety, as suggested under Option A. This is not considered a credible option in light of this. Instead, Bolesworth consider a blended spatial option is likely to be the appropriate/most sustainable approach in respect of the spatial distribution of development. This is likely to be a hybrid of Options B and C – which apportions growth to settlements based on an assessment of a settlement’s capacity and constraints and identifies the most suitable sites based on sustainability considerations in the round (not just on public transport corridors). As previously noted, Tattenhall has capacity to deliver up to 1,500 homes as mentioned in Option A, when pursuing a blended option of B and C. An assessment of each settlement’s capacity will be required as part of the preparation of the Local Plans supporting evidence. This test is required in light of NPPF paragraph 147, which notes how before concluding that exceptional circumstances exist to justify changes in Green Belt boundaries, local planning authorities should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. As part of this, the Council will need to undertake a similar level of consideration to determine what can be accommodated in other settlements, including sites currently located outside of existing settlement boundaries. The spatial strategy also needs to consider opportunities for additional growth in settlements where infrastructure enhancements can be provided, as previously explained at paragraph 4.13.

Comment

Representation ID: 15061

Received: 29/08/2025

Respondent: Cheshire Garden Village Ltd

Agent: AshtonHale

I&O_15620
To further the strategy outlined in Option B, further emphasis should be given to sustainable expansion of employment sites adjacent to established settlements, including targeted release of Green Belt land where it directly adjoins existing employment areas or settlement boundaries. Taking forward this approach would allow strategically positioned sites to deliver employment provisions, strategic regeneration, and infrastructure delivery. This spatial strategy would support the Local Plan’s objective of economic growth, while allowing flexibility to meet the increasing housing and employment land needs.

Comment

Representation ID: 15112

Received: 29/08/2025

Respondent: StanleyRed Developments Ltd

Agent: AshtonHale

I&O_15671
To further the strategy outlined in Option C, further emphasis should be given the release of Green Belt land along sustainable transport corridors and at sites that adjoin established settlement boundaries Taking forward this approach would allow strategically positioned sites to deliver required housing provisions across the borough. These sites would have existing infrastructure provisions and be located in areas with strong services and facilities for future development.

Comment

Representation ID: 15199

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15758
Barratt Redrow consider a hybrid of Options B and C will provide the most appropriate/ sustainable approach in respect of the spatial distribution of development. We have already noted under question SS 9 that Option A is not appropriate. Barratt Redrow advocate a hybrid option which would follow the general distribution from the current Local Plan but also take account of the revised settlement hierarchy – as set out at Policy SS 4. It would also incorporate the general ethos of Option C, however; should be site-led and widened to focus on sustainability and accessibility in the round, including Active Travel, instead of being solely focused on sustainable transport corridors. Indeed, the Planning Inspectorate recently hosted a webinar6 entitled ‘what is meant by a sustainable location?’. Key points of note include reiterating the fact that walking and cycling are at the top of the sustainable transport hierarchy, followed by public transport. Whilst public transport connectivity/corridors are clearly important, it should not be the sole focus. Instead, the site selection process for each settlement should also heavily focus on a site’s location and it’s pedestrian and cycle connectivity to existing local amenities (shops, schools etc), which all reduce car trips on a day to day basis. Public transport is clearly helpful for longer distance trips, but has to be considered alongside the aim to reduce day to day trips to local facilities. This highlights the issue with Option C’s overreliance/focus on public transport, as although places like Delamere and Mouldsworth have train stations, they do not have primary schools which are a key focus of day to day trips. This therefore does not represent a balanced approach to sustainability, which is more nuanced and multi-faceted. It is considered a hybrid option of Option B and C is the most appropriate spatial strategy because: It would still facilitate the brownfield first approach to development, as enshrined in national policy, across the authority area; It would deliver both non Green Belt and Green Belt sites in the most sustainable locations; It would result in a more even spatial distribution across settlements, and not lead to an over-concentration of development in certain locations. This will deliver a number of benefits, including variety of choice and tackling affordability issues across the Borough; Would reflect recent changes in Green Belt policy, specifically Grey Belt, and the key role Green Belt sites will play in delivering development requirements; and Is settlement capacity and site led, which will provide the most sustainable and suitable spatial distribution of development for the Borough. 6 https://www.youtube.com/watch?v=yTKYHTffS80

Comment

Representation ID: 15242

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

I&O_15801
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably Chester, in the first tier of the settlement hierarchy, which is completely enveloped by Green Belt designation. Therefore, Chester Zoo are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Chester Zoo would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt.  Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Chester Zoo would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. It is paramount to allow small scale extension of the Chester settlement boundary, including site-specific Green Belt release. This is opposed to any largescale release of Green Belt, which will only go to compromising the value of the wider Green Belt and weaken its protection. The previous Green Belt Study and its conclusions is a good starting point.

Comment

Representation ID: 15301

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15860
Peel considers the most appropriate spatial strategy for CWAC will be a combination of all options, recognising that Green Belt release will very likely be required to meet the development needs of the borough and for development to be in the right locations to take advantage of existing and planned infrastructure, and be capable of accommodating development needs in a sustainable manner. All of the options represent very strict choices, which do not reflect a considered approach to plan-making. Option A does not recognise the evolved needs (and altered supply) or the wider policy context; as noted, we consider it very likely that Green Belt will need to be released in order to meet the needs of the borough in a sustainable manner. This will represent exceptional circumstances (as noted in response to question SS 9); Green Belt should not be regarded as an overriding constraint justifying unmet needs or unsustainable patterns of development. Option B warrants detailed consideration, as it was clearly justified in the preparation of the adopted Plan, but this needs to be appraised and developed in the context of evolved circumstances (needs, supply, policy drivers etc., for the respective uses the Plan needs to cater for). Option C has some merit in its focus on sustainable transport but it is a crude option on its own – this consideration of sustainability should be balanced against all others. A tailored strategy should be developed, based on a comprehensive evidence base. In respect of employment needs Peel considers this should comprise the following considerations: The availability of land (within the Plan period) within and surrounding key employment areas, which is (in priority order): ‒ Realistically deliverable (i.e. viable) brownfield / PDL land. ‒ non-Green Belt greenfield land. ‒ grey belt land. ‒ Other land within the Green Belt. The suitability of land to cater for a range of employment needs (traditional and non-traditional) needs. The proximity to existing and planned infrastructure for sustainable and clustering development opportunities.

Comment

Representation ID: 15454

Received: 21/10/2025

Respondent: Wirral Borough Council

I&O_16013
No comments at this stage

Comment

Representation ID: 15553

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16112
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably the first and second tiers of the settlement hierarchy, so including Northwich, but also the key service centres well related to and benefitting from shared service and facilities to such areas, e.g. Cuddington & Sandiway. Therefore, Liberty Properties are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Liberty Properties would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. However, unlike the previous Study, which only assessed Green Belt around the settlement boundary of Chester, any new Study is now required to include assessment of Green Belt around all Tier 1 & Tier 2 settlements and the key service centres (where Green Belt id applicable) – Cuddington & Sandiway specifically included. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt. Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Liberty Properties would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. This can include Chester to a certain degree, but priority should be given to the second tier settlements and the key service centres where Green Belt is applicable, such as Cuddington & Sandiway.

Comment

Representation ID: 15598

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16157
Due to the significant development requirements of the borough, and the fact that a number of large settlements in the borough are surrounded by Green Belt, it is considered it will be unfeasible for the Green Belt to be retained in its entirety, as suggested under Option A. This is not considered a credible option in light of this. Instead, Shropshire Homes consider a blended spatial option is likely to be the appropriate/most sustainable approach in respect of the spatial distribution of development. This is likely to be a hybrid of Options B and C – which apportions growth to settlements based on an assessment of a settlement’s capacity and constraints and identifies the most suitable sites based on sustainability considerations in the round (not just on public transport corridors). As previously noted, Malpas has capacity to deliver up to 1,500 homes as mentioned in Option A, when pursuing a blended Option of B and C. An assessment of each settlement’s capacity will be required as part of the preparation of the Local Plans supporting evidence. This test is required in light of NPPF paragraph 147, which notes how before concluding that exceptional circumstances exist to justify changes in Green Belt boundaries, local planning authorities should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development. As part of this, the Council will need to undertake a similar level of consideration to determine what can be accommodated in other settlements, including sites currently located outside of existing settlement boundaries.

Comment

Representation ID: 15751

Received: 29/08/2025

Respondent: Northern Powerhouse Land Ltd

Agent: Asteer Planning

I&O_16310
As detailed earlier within these representations, Middlewich has strong links to Cheshire West and Chester and, thus, it is important that development adjacent to the settlement of Middlewich is supported. The site that is the subject of these representations is adjacent to the urban area of Middlewich and, thus, presents a logical and appropriate location for residential-led, mixed-use development.

Comment

Representation ID: 15816

Received: 01/09/2025

Respondent: Central & Country Developments Ltd

Agent: HK Planning

I&O_16375
It is anticipated that as detailed assessments are undertaken, including housing needs assessment (to ascertain the scale of housing need in the Borough), review of local services and facilities in Key Services and rural settlements and a Green Belt Assessment that a hybrid of options B and C is likely to be the most appropriate approach to ensure that new development is sustainable in the emerging Local Plan.

Comment

Representation ID: 15874

Received: 29/08/2025

Respondent: Barratt David Wilson Homes North West

Agent: Turley

I&O_16433
As explained above, BDW does not consider Option A to be an appropriate spatial strategy, as it fails to include any release of Green Belt land. Such release is a necessary component to meet the borough’s housing needs. This is supported by the Council’s own evidence base on land availability, which identifies a potential capacity of approximately 11,000 homes. As noted above (paragraph 3.25), there is insufficient land within the urban area to accommodate the minimum requirement of 28,290 dwellings over a 15-year plan period, or 38,560 dwellings over a 20-year period. Consequently, additional housing land must be identified beyond the existing settlement boundary, including land currently designated as countryside or Green Belt. While BDW are generally supportive of Option B, which identifies significant Green Belt release around Ellesmere Port, Northwich and Chester, it is noted that larger settlements such as Neston and Frodsham will have a relatively limited level of new development compared to their size, transport connections and services. In particular, as Frodsham now has an elevated status in the settlement hierarchy as a ‘market town’, a proportionate level of growth should be assigned to Frodsham, as opposed to relying upon the previous level of distribution. Option C seeks to direct development in and around locations which offer sustainable transport connections. This will require Green Belt release around more settlements and would introduce more development in some of the smaller settlements including Hooton, Capenhurst, Elton, Acton Bridge and Mouldsworth. A review the approach to locations for development in Option C identifies that, whilst the sites may be sustainable in respect of their proximity to a rural train station, many of the proposed locations are limited in terms of their access to essential services and facilities such as schools and healthcare. BDW therefore urges the Council to exercise caution in prioritising transport hubs as the primary basis for new development. A more balanced, holistic approach to assessing site sustainability is recommended. Under Option A/B, Frodsham is identified to accommodate up to 500 homes, whereas Option C proposes a significantly higher level of growth, ranging from 1,500 to 3,000 homes. The Dig Lane site (ref. FRO03) is included as a potential growth option for housing development in Frodsham in both Options B and C. Option A involves no Green Belt release around Frodsham. 3.50 As such, BDW recommend that the Council adopt a hybrid approach between Options B and C; one that recognises the strategic role of larger settlements such as Frodsham, while ensuring that sustainable considerations extend beyond transport accessibility alone. Further detail on this approach is outlined within Chapter 6 of the Pegasus representations.

Comment

Representation ID: 15930

Received: 29/08/2025

Respondent: Lexwood Developments

Agent: HK Planning

I&O_16489
It is anticipated that as detailed assessments are undertaken, including housing needs assessment (to ascertain the scale of housing need in the Borough), review of local services and facilities in Key Services and rural settlements and a Green Belt Assessment that a hybrid of options B and C is likely to be the most appropriate approach to ensure that new development is sustainable in the emerging Local Plan.

Support

Representation ID: 16426

Received: 04/12/2025

Respondent: Urenco

Agent: Axis P.E.D Ltd

I&O_12374
UUK’s responses to the above topic questions are interlinked, so these have been answered in single response below.
The Complex is in a sustainable location, being adjacent to Ellesmere Port and located adjacent to an existing train station (Capenhurst). Therefore, a local plan strategy that combines Option B and Option C would more closely align with UUK’s development ambitions.
If the Council was to remove the Complex from the Green Belt, the agreed option must ensure the Complex is not referenced as a commercial site in the Green Belt.