Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11483

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

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

Comment

Representation ID: 11484

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11982
The monitoring framework should include air quality and river quality. This would be consistent with the CWaC Climate Energy Response Plan for 2025-30, which recognises ‘cleaner water’ and ‘improved air quality’ as key benefits/opportunities of acting on climate change (para. 2.3, page 5).

Comment

Representation ID: 11485

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11983
It is appropriate that the new Local Plan should look ahead for 15 years. That said, in view of the fact that it is now mandatory for all Local Plans to be reviewed every five years, we assume the Plan may change if necessary, for example to address any changes of circumstances. Whilst the 5-year reviews may be challenging for local authorities to resource, and may lead to some reduced certainty, CPRE Cheshire is broadly happy with this approach.

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: 11487

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11985
We note that 21 policies, growth areas and growth strategies have been screened in for further investigation under the Habitats Regulation Assessment and are left wondering when these further assessments will be available.

Comment

Representation ID: 11488

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11986
Cheshire West and Chester Council is more familiar than many local authorities with what can be achieved through Neighbourhood Plans. Its Local Development Scheme (May 2025) lists 27 Neighbourhood Development Plans that have been supported at referendum or ‘made’ and 20 that are in preparation, including four which are revisions to previous plans. As neighbourhood planning has developed over the 14 years since being brought in by the Localism Act, the understanding of its potential has increased and so has the quality of the outputs. CPRE, along with the National Association of Local Councils (NALC) is very concerned about the removal of government funding for Neighbourhood Plans. We feel it is a decision at odds with the government’s expressed desire in the English Devolution and Community Engagement Bill to see more meaningful community involvement in decision-making in future. However, Neighbourhood Development Plans still stand as statutory documents alongside Local Plans and the community desires they represent must be taken account of, whether this be on housing need and distribution, building design, important open spaces and the countryside, landscape or climate change.

Comment

Representation ID: 11489

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11987
We suggest the following addition to the opening paragraph: “T he vision for Cheshire West and Chester is for it to be a desirable, healthy and attractive place ….. ”.

Comment

Representation ID: 11490

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11988
Yes, it is appropriate that a set of principles is included and we support the 4 principles identified.

Comment

Representation ID: 11491

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11989
Individual ‘place’ visions need to be different from the over-arching vision, and be defined in line with best practice e.g. the Design Council’s ‘Best Practice Guide to Place Visioning’: https://people-places.net/best-practice-guide-to-place-visioning/.

Comment

Representation ID: 11492

Received: 28/08/2025

Respondent: CPRE Cheshire Branch

I&O_11990
Option B – Use the Sustainability Appraisal objectives.
Option B - use the Sustainability Appraisal objectives