Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15860

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16419
BDW reaffirm that the concept of grey belt, as introduced in the December 2024 iteration of the NPPF, with supplementary guidance provided in the February 2025 updates to Green Belt PPG, is an important consideration that should be taken into account. The emerging Local Plan must have full regard to the latest NPPF policy and the evidence base must include an assessment of whether land parcels within the Green Belt meet the definition of grey belt.

Comment

Representation ID: 15861

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16420
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: 15862

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16421
BDW consider that growth option FRO03 is the most suitable, as demonstrated throughout these representations. The area is located adjacent to the existing settlement of Frodsham, and benefits from existing natural boundaries including the A56 Chester Road to the east, the railway line to the north, and residential development to the south. The Site is sustainably located to make best use of existing sustainable transport provision; and is located within proximity to a number of facilities and services, which are accessible via a number of sustainable non-car modes including walking and cycling. The existing public transport provides a wide range of connections to key locations such as Manchester, Liverpool and is of high frequency. The planning application for Dig Lane is supported by a range of technical assessments, which confirm that the Site is a suitable location for housing development. In particular, and as noted above, the submitted Green and Grey Belt Appraisal confirms that the Site meets the definition of grey belt, and that the Proposed Development meets the criterion in paragraph 155 of the NPPF and can be regarded as appropriate development. The application also confirms that the Proposed Development will follow the Golden Rules in accordance with paragraph 151 of the NPPF, which states: “where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 should apply.” The application demonstrates that the Proposed Development is underpinned by a high-quality approach to design, layout and landscape which respects and responds to the evidenced Site constraints and the wider environment. The application was accompanied by an Environmental Impact Assessment Screening Request (LPA ref. 25/02187/SCR), which includes a detailed appraisal of the construction and operational stage effects associated with the Proposed Development, and confirms that no likely significant effects have been identified. BDW encourages the Council to consider the submitted application materials as part of the process for selecting growth locations and residential allocations within the emerging Local Plan. The work undertaken to date clearly demonstrates that the Site is both suitable and sustainable for development.

Comment

Representation ID: 15863

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16422
BDW supports accommodating sufficient growth in Frodsham to meet identified needs. This may necessitate the allocation of more than one growth option. As aforementioned, the Site forms the northernmost part of the identified Frodsham growth area FRO03 (i.e. directly adjacent to the settlement boundary). The remainder of the land within FRO03 therefore represents a logical and coherent extension for accommodating future growth beyond BDW’s land interests at Dig Lane. In this context, it is recommended that the entirety of the FRO03 growth location be allocated for development within the new Local Plan. Whilst BDW is generally supportive of all sustainable growth in Frodsham, it is noted that the potential growth locations FRO01 and FRO02—both situated to the east of the town—lack the strong natural boundaries that define FRO03. As a result, these sites present a greater risk of contributing to urban sprawl. Furthermore, FRO03 benefits from direct access to the A56 Chester Road, a key arterial route offering strategic connections to Runcorn, Widnes, Chester, Speke, and Liverpool. In contrast, FRO01 and FRO02 are accessed via smaller local roads, such as Townfield Lane. The capacity of these routes to accommodate development of the scale proposed should therefore be robustly assessed. In summary, it is strongly recommended that growth location FRO03 be allocated for development within the new Local Plan. The land offers a more suitable and sustainable location for growth, with BDW well-positioned to deliver development on part of the site in the short term. Development at Dig Lane could also facilitate infrastructure improvements, supporting the delivery of the wider FRO03 area in a sustainable and coordinated manner. The allocation of any growth areas should also be supported by sufficient and robust evidence demonstrating that the sites are suitable to accommodate development. 

Comment

Representation ID: 15864

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16423
The Places Background Paper 2024 highlights the availability of services and facilities in Frodsham, as outlined in paragraph 3.34 above. It confirms that Frodsham benefits from a broad range of existing services and infrastructure. Accommodating new housing growth in the settlement would support the long-term viability of these existing facilities and could be aligned with infrastructure improvements, to be identified by the Infrastructure Delivery Strategy, which will form part of the evidence base.

Comment

Representation ID: 15865

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16424
FR 1 identifies Frodsham as a market town within the settlement hierarchy of the emerging Local Plan. BDW supports the elevation of Frodsham within this hierarchy and encourages the Council to recognise the town as a sustainable location capable of accommodating a proportionate level of future growth. It is noted that the proposed policy approach seeks to align with the objectives and projects identified in the FNP. However, it is reiterated that the FNP was prepared under the provisions of LPP1—albeit nine years after its adoption—and is therefore based on policies that are now considered out of date. As set out in paragraph 3.11 above, following the adoption of the new Local Plan, it will be necessary for the FNP Group to undertake a review and update of the neighbourhood plan to ensure continued alignment with the strategic policies of the NPPF and the new Local Plan, in accordance with paragraph 30 of the NPPF. To support the continued vitality of Frodsham as a market town, additional site allocations beyond those identified in the FNP will be required. As outlined throughout these representations, this will necessitate the allocation of land beyond the existing settlement boundary, including sites within the Green Belt. BDW therefore reiterates its view that FRO03 represents a prime opportunity for sustainable growth and would make a valuable contribution to meeting identified housing needs. Otherwise, BDW supports the overarching principles of the proposed policy approach, particularly the emphasis on delivering a mix of housing, including affordable homes for young people and families, starter homes, and smaller properties to support downsizing, as well as homes that meet the needs of older residents.  As part of the preparation of the planning application at Dig Lane, BDW undertook public engagement to provide local residents and stakeholders with the opportunity to share their views. Feedback was invited through a range of channels, including a dedicated website, phone line, email, and Freepost. Most notably, there has been overwhelming support for the provision of 3 / 4-bedroom family homes, affordable housing, and the enhanced pedestrian and cycle links. Out of the 243 responses received, 51 respondents expressed an interest in purchasing a home on the Site. This equates to over 20% of the total respondents. This reflects the clear need for family and affordable housing in the locality and CWACC generally. As such, it is recommended that the Local Plan be informed by a robust and up-to-date Housing Needs Assessment (HNA). It is also important that the policy remains flexible and not overly prescriptive, to avoid constraining or delaying housing delivery. To ensure the Council’s requested housing mix remains accurate and effective, the HNA should be reviewed and updated regularly to reflect evolving market conditions and local needs. This will help maintain a responsive and evidence-based housing strategy over the lifetime of the Plan.

Comment

Representation ID: 15866

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16425
BDW are in general agreement with the suggested policy approach towards Green Belt and countryside. In particular, the relevant Green Belt policy must align with the latest national policy context regarding the Green Belt, as set out in the revised NPPF (December 2024) and the updated PPG on Green Belt (February 2025). This includes recognising the introduction of 'grey belt' land and its potential role in supporting housing and employment growth. The Council should also give due consideration to the findings of the emerging Green Belt Review, once this evidence becomes available. It is essential that the Council consults on the proposed methodology and approach to the Green Belt Assessment in advance of undertaking the work, to ensure transparency and allow for stakeholder input. In addition, the existing countryside boundaries will need to be amended to reflect the spatial strategy, revised settlement boundaries, and proposed site allocations necessary to meet the borough’s identified housing and employment needs within the emerging Local Plan.

Comment

Representation ID: 15867

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16426
BDW advises that the general provisions set out in LPP1 STRAT11 are appropriate and accepts the approach to amend the policy to ensure educational needs are included. Specific comments are provided below in relation to the identified topics for infrastructure and developer contributions: Net Zero objectives – BDW advises caution in seeking to secure these outcomes solely through developer contributions. National regulations and planning policy already seek to achieve net zero goals, and duplicating such requirements at the local level risks creating unnecessary complexity and restriction. It is important that any local policy complements, rather than duplicates, existing frameworks.  Digital Infrastructure – The policy should provide for a degree of flexibility, particularly in relation to the delivery of digital infrastructure such as electronic communications networks and high-speed broadband. Delivery of such infrastructure may be constrained by technical or viability issues, and the policy should recognise that such requirements should only be applied where demonstrably feasible and deliverable, without prejudicing the acceptability of a proposed development. The requirement on developers should not go beyond that set out in Building Regulations, as set out by the HBF. Public Art – BDW does not support the inclusion of public art as a requirement for developer contributions, as it does not constitute essential infrastructure necessary to make development acceptable in planning terms. Maximising employment opportunities for residents – BDW endorses Home Builders Federation (‘HBF’) position that the approach to this should be developed in dialogue with the HBF and wider industry. The costs associated with this should also be tested within the emerging Viability Assessment.  The policy should emphasise the importance of a collaborative and transparent relationship between the local authority and developers, ensuring that infrastructure delivery is effectively coordinated and proportionate to the development proposed. Furthermore, the Viability Assessment and Infrastructure Delivery Plan should test all of these costs, ensuring the delivery of the plan is not compromised, in accordance with paragraph 35 of the NPPF.

Comment

Representation ID: 15868

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16427
BDW considers that developer contributions should be proportionate and directly related to the scale and type of development proposed. While it is appropriate for the majority of infrastructure contributions to be secured from major developments, there may be circumstances where smaller developments have a cumulative impact on infrastructure and should contribute accordingly—provided this is justified, reasonable, and does not undermine viability. The definition of 'major development' should align with the existing national definition set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015. This provides clarity and consistency across local authorities. Any local variation to this definition should be clearly justified by evidence and tested through the Local Plan process. Flexibility should also be retained to ensure that contributions are only sought where they meet the statutory tests set out in Regulation 122 of the Community Infrastructure Levy (‘CIL’) Regulations 2010 (as amended), particularly in terms of necessity, and direct relationship to the development.

Comment

Representation ID: 15869

Received: 29/08/2025

Respondent: Barratt & David Wilson Homes

Agent: Turley

I&O_16428
BDW acknowledges that it is appropriate for developers to contribute to the infrastructure necessary to make their developments acceptable in planning terms. However, such contributions must be fair, proportionate, and aligned with the statutory tests set out in Regulation 122 of the CIL Regulations 2010 (as amended), and paragraph 58 of the NPPF. BDW emphasises the importance of a collaborative and coordinated approach between the Council and developers. Infrastructure planning should be based on an understanding of the cumulative impact of committed and planned development across the area, rather than being addressed in isolation on a site-by-site basis. This ensures that infrastructure is strategically planned, appropriately phased, and capable of supporting both current and future needs. Requiring individual developers to meet the full cost of infrastructure in isolation risks undermining the viability and deliverability of schemes, particularly where the infrastructure serves a wider area or multiple developments. In such cases, the cost burden should be shared equitably, with consideration given to funding mechanisms such as Section 106 agreements, the CIL, or other public funding sources where appropriate.