Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 12462

Received: 29/08/2025

Respondent: Carden Group

I&O_12979
Carden support the principle of delivering a mixture of housing types, tenures and specialist housing to meet the diverse needs of the community. However, we consider that applying a rigid percentage-based requirement across all sites is overly prescriptive and could give rise to significant viability challenge Instead, we believe a more flexible, evidence-led approach is consistent with both local needs and national policy. The National Planning Policy Framework (NPPF, paragraph 61) requires local authorities to “ it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” Importantly, the NPPF does not prescribe fixed percentages but requires responsiveness to locally specific circumstances. Local demographic evidence within the Council’s Places background paper (published 2024) illustrates why a one-size-fits-all percentage approach is inappropriate. For example, over 20% of the population of Malpas is aged over 70, compared to only 13% in Ellesmere Port. This demonstrates significant variation in housing need across the district. A flexible policy approach will ensure that housing delivery is locally responsive, aligns with the latest evidence, and produces housing that is genuinely in demand. This flexibility also helps to support deliverability. Overly prescriptive policies risk constraining development, creating mismatches between local demand and supply, and undermining viability. The NPPF (paragraph 35) requires plans to ensure that policies relating to affordable housing do ‘not undermine the deliverability of the plan’. A non-prescriptive approach, guided by up-to-date housing needs evidence, ensures that new housing contributes positively to local markets without jeopardising site viability. In summary, while we fully support the objective of securing a wide choice of high-quality homes and specialist housing, this should be achieved through a flexible, evidence-based policy framework rather than rigid percentage requirements. This approach is more consistent with the NPPF and will better reflect the varying needs of communities across the borough.

Comment

Representation ID: 12463

Received: 29/08/2025

Respondent: Carden Group

I&O_12980
We support the principle of enhancing tree cover and green infrastructure, but the proposed blanket requirement to achieve 16% tree cover in every ward is neither justified nor consistent with national policy. The Issues and Options paper states that the 16% target comes from the Local Nature Recovery Strategy (LNRS), but this strategy is still only in draft form. Relying on an emerging document that has not yet been finalised or tested is unsound. Furthermore, the LNRS does not explain how this figure was calculated or why it should apply uniformly across all wards, regardless of their differing circumstances. The NPPF does encourage tree planting, but in a balanced and site-specific way. Paragraph 136 states that applicants and local planning authorities should work with highways and tree officers to ensure “the right trees are planted in the right places, and solutions are found that are compatible with highways standards and the needs of different users.” This clearly points to an individualised approach rather than a blanket percentage. Imposing arbitrary targets risk requiring tree planting in unsuitable locations, which could create practical conflicts and undermine good design. Adding excessive numbers of trees without regard to site-specific circumstances could also pose viability issues, particularly on constrained or higher-density sites where developable land is limited. A more flexible policy, proportionate to the scale and character of each site and supported by clear evidence, would be more consistent with national policy. This would still achieve meaningful increases in tree planting while avoiding unfair burdens on development and ensuring housing and employment delivery remains viable.

Comment

Representation ID: 12464

Received: 29/08/2025

Respondent: Carden Group

I&O_12981
No. Although some sites may be capable of achieving more than the mandatory 10% Biodiversity Net Gain, it would not be reasonable or justified to impose a higher blanket standard over and above the nationally prescribed requirement. Any additional provision should be considered on a case-by-case basis, reflecting the specific circumstances circumstances of the site. Where developments are able to exceed the 10% requirement, this can be taken into account as part of the overall planning balance when individual applications are assessed.

Comment

Representation ID: 13227

Received: 29/08/2025

Respondent: Carden Group

I&O_13746
National policy has recently acknowledged that not all Green Belt land performs the same function. The newly defined “Grey Belt” recognises land that is already compromised by development, of poor environmental quality, or with limited openness. Our site clearly falls into this category. It is entirely enclosed and contained by existing housing on the edge of Northwich, with Chester Road to the north, Whitegate Lane to the west, and the A556 to the south. In this context, the land makes no contribution to the fundamental purposes of the Green Belt as set out in paragraph 143 of the NPPF. It does not prevent unrestricted sprawl (purpose a), it does not sit within the gap between towns (purpose b), and it would not affect the setting or special character of a historic town (purpose d). Instead, the site represents a narrow strip of land hemmed in by established development and infrastructure, the release of which would have no material impact on the overall function of the Green Belt. Crucially, the original concept of the Green Belt, set out in Circular 42/55 and PPG2, stressed that Green Belts should be “at least several miles wide” to keep major settlements apart. Removing the site, along with all of the narrow land south of Chester Road shown in Figure 1, would not compromise this principle. The strategic Green Belt gap around Northwich would remain intact and comfortably above this threshold. Moreover, all of the growth areas identified around Northwich in the Local Plan are estimated to deliver in excess of 400 homes. By contrast, sites such as ours, capable of delivering approximately 100 homes, can be brought forward more quickly. Smaller sites of this scale are typically less complex in terms of land assembly, infrastructure provision, and planning negotiations, making them capable of accelerating housing delivery and contributing to meeting the Council’s short-term housing requirements. Accordingly, the land south of Chester Road, including our site outlined in red in Figure 1, should be deleted from the Green Belt. This area is a clear example of “Grey Belt” where carefully planned growth can be accommodated without undermining either the original purpose or the wider integrity of the Green Belt. It should therefore have been considered as a potential growth location for Northwich within the Local Plan.

Comment

Representation ID: 13251

Received: 29/08/2025

Respondent: Carden Group

I&O_13770
First, SO1 should be updated to reflect changes in the settlement hierarchy. This involves the inclusion of Frodsham now being recognised as a market town. The settlement already functions as service hubs and are well placed to accommodate future growth. As such, SO1 should explicitly reference the settlement and the need to promote development. Secondly, SO9 should also be revised to reflect the need for planned growth on the edges of market towns, particularly those referenced above, in addition to development around Chester and the larger towns of Ellesmere Port, Northwich, and Winsford. Lastly, SO10 should be amended to acknowledge that, in light of the significantly increased housing requirement, the limited brownfield land supply, and the necessity of directing development to the most sustainable locations, the release of land from the North Cheshire Green Belt will be required.

Comment

Representation ID: 13254

Received: 29/08/2025

Respondent: Carden Group

I&O_13773
We broadly support the principle of prioritising previously developed (brownfield) land within existing settlements. However, we must stress that the scale of available brownfield land is wholly insufficient to meet the district’s housing needs over the plan period. According to the most recent Brownfield Land Register (2021), only 96 hectares of brownfield land across the borough remain without planning permission. Based on typical brownfield densities in the UK, estimated by the CPRE State of Brownfield 2022 report at approximately 70 dwellings per hectare, this equates to a theoretical capacity for around 6,720 dwellings. However, this figure should be treated with caution. The Brownfield Land Register does not account for a range of site-specific constraints that frequently affect deliverability. These include flood risk, contamination, heritage restrictions, ecological value, and site access issues. In addition, many brownfield plots are in fragmented ownership or face significant viability challenges due to abnormal development costs. As such, the actual number of dwellings that can be delivered from these sites is likely to be substantially lower. A realistic assumption must apply a discount to reflect these limitations, reducing the notional 6,720 dwelling figure to a far more modest and deliverable total. Moreover, the most recent 2025 Housing Land Monitor Summary Report identifies a supply of 6,407 dwellings when assessed against the housing requirement. Given this context, and the need to deliver a minimum of 34,000 homes (1,914 dpa over an 18-year plan period) we urge a more balanced and realistic policy approach that acknowledges the essential role of greenfield, and specifically Green Belt, sites in delivering sustainable housing growth. Indeed, some of the most sustainable settlements in the district, including Chester, Ellesmere Port, Northwich, Neston, and Frodsham, are entirely constrained by Green Belt boundaries. Without carefully considered Green Belt release, these settlements will not be able to accommodate proportionate growth, despite their strong service base, connectivity, and employment opportunities. We therefore recommend that Policy SS3 be amended to include the following: • A clear recognition that, while brownfield sites are to be prioritised, their capacity is inherently limited and are insufficient to meet the Council’s full housing needs. • An explicit commitment to the release of greenfield sites, including within the Green Belt, where they contribute to the delivery of sustainable, well-planned urban extensions, particularly in the most sustainable settlements. Overall, a sound spatial strategy must be evidence-led, and the current housing land supply and brownfield positions clearly demonstrate the need to release greenfield and Green Belt 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: 13260

Received: 29/08/2025

Respondent: Carden Group

I&O_13779
As stated in response to Question SS 12, we broadly support the principle of Option B’s settlement hierarchy, which aligns with NPPF paragraph 77 by focusing development in the most sustainable locations with good access to jobs, services, and public transport. However, it is important to note that in the current Local Plan, the distribution of housing across the settlement tiers ultimately reflected residual need at the point of adoption, rather than an initial strategic target. By that stage, a significant proportion of the overall requirement had already been permitted in the Key Service Centres, which artificially reduced the scale of allocations in those locations. It is essential that the new Local Plan avoids repeating this approach and instead bases its distribution on the actual capacity and sustainability of each settlement tier from the outset. This is further evidenced by virtue of the fact that the Part 2 Local Plan made no allocations for development to meet the needs of the KSCs. In light of this, while we agree with Option B’s general settlement hierarchy, we believe the proposed housing numbers are insufficient to meet identified needs. As outlined in our earlier response to Policy SS4, the Local Plan should plan for at least 34,000 dwellings over the plan period, consistent with NPPF paragraph 16, to ensure the plan is positively prepared and meets needs in full. Within Option B, this would require redistributing growth to fully utilise the capacity of the Borough’s most sustainable locations, avoiding over-reliance on windfall or urban intensification, which is unlikely to be deliverable at scale.

Comment

Representation ID: 13261

Received: 29/08/2025

Respondent: Carden Group

I&O_13780
If the Council intends to follow a spatial strategy similar to that used in the current Local Plan, it is important to remember that the housing numbers allocated to different settlement tiers last time were not an initial policy target but instead reflected the residual need remaining by the time the plan reached adoption. This was because a substantial amount of the overall housing requirement had already been permitted in the Key Service Centres earlier in the plan period, meaning that the Local Plan allocations in those locations were significantly reduced. In determining an appropriate distribution for this plan period, the Council should also take account of the findings of the Rural Regeneration Strategy and Action Plan (September 2011), which concluded: “ Based on this analysis it would seem reasonable to conclude that growth of between 11% and 13% in the number of dwellings and households in the rural area is the minimum necessary to address the challenges identified. It is reasonable to add some contingency to this figure – to account for exacerbation of trends and to provide some slippage. A growth target of 15%, which equates to 8,000 new homes, is therefore considered to be appropriate.” This evidence demonstrates that a meaningful proportion of growth in what were at the time considered rural areas but now include the proposed Market Towns and Key Service Centres, is essential to maintaining rural vitality, supporting services and employment, and addressing identified challenges. The existing local plan allocated only one third of the need for 8,000 homes. Rural housing needs were not met by the existing local plan strategy. A distribution strategy should therefore ensure that allocations are not artificially constrained by relying on historic residual figures but instead reflect the full potential and sustainability of each settlement tier in delivering the overall housing requirement.

Comment

Representation ID: 13262

Received: 29/08/2025

Respondent: Carden Group

I&O_13781
The growth area identified as FRO01, on the eastern edge of Frodsham, is in our view the most suitable of the three potential options. This is primarily due to its high level of accessibility. For example from the centre of the site, all three primary schools in Frodsham, Manor House, St Luke’s, and Frodsham CofE, are all located within one mile, offering shorter walking distances than the other 2 identified growth areas. The site is also less than a mile from key town-centre services, including the train station and Morrisons supermarket. The site also provides the greatest opportunity to strengthen connections to a wide range of existing community assets, including Top Park Playground, the Community Orchard, and Hob Hey Wood. These assets would themselves be enhanced through the delivery of an integrated open space network. From a Green Belt perspective, FRO01 also represents one of the more logical green belt release opportunities, as it is naturally bounded to the east by Hob Hey Wood. By contrast, development of the full extent of FRO03 would significantly reduce the separation between Frodsham and neighbouring Helsby, increasing the risk of coalescence between the two settlements.