Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14945

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15504
The Reg 18 Consultation Draft Plan confirms that CWAC Council intend to prepare additional evidence to support the emerging Local Plan, including a Housing Needs Assessment, Green Belt Study, Infrastructure Delivery Plan, Strategic Viability Assessment and Land Availability Assessment. The Council should ensure that all of their proposed policy requirements are fully justified and evidenced as the proposed evidence is likely to be necessary alongside other documents to justify the policy requirements in the emerging Local Plan. It is essential that the evidence base that informs the emerging Local Plan reflects the latest national policy as set out in the NPPF and Planning Practice Guidance (“PPG”). In particular this includes ensuring that the proposed Green Belt Study aligns with the updated Green Belt PPG published in February 20254, including consideration of grey belt opportunities. In addition to the evidence already identified by CWAC, other evidence that should be produced or updated to ensure it reflects the latest context include: Site Selection Paper Places Background Paper 2024, which should be extended to consider all identified Local Service Centres (in addition to the urban areas and Key Service Centres) and the potential for these to be ‘moved up’ the settlement hierarchy. Economic Needs Assessment 2025 Brownfield Land Register Playing Pitch Strategy 2021 Public Open Space Assessment Duty to Cooperate Statement Updated Conservation Area Appraisals and Management Plans, for all Conservation Areas in CWAC (including Christleton)

Comment

Representation ID: 14946

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15505
The emerging Local Plan should have a clearly defined monitoring framework, which establishes key monitoring indicators for each relevant policy and defines how the objectives / targets established in the Local Plan are being met and, if not, why and what actions will be taken and when to address any issues. It should also confirm the associated data sources and means of reporting. It is important that housing delivery is effectively monitored so that if annual monitoring shows delays to housing delivery across CWAC, action is taken to address this as soon as possible. The Council will need to monitor the delivery of housing and publish progress against a published Housing Trajectory, and housing monitoring should be undertaken on a site-by-site basis at least annually, in accordance with Paragraph 78 of the NPPF.

Comment

Representation ID: 14947

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15506
The Reg 18 Consultation Draft Plan confirms that CWAC Council intends to plan for a period of 15 years. Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. In order to ensure a robust approach to the emerging Local Plan, reflecting the likely timescales for preparation and accounting for a 15-year plan period post-adoption in line with the NPPF (paragraph 22), ASL considers that the Council should, as a minimum, be looking to prepare a new Local Plan that will look forward to at least 2045 to enable a 15-year plan period post-adoption. It is important to note in this regard that the adopted Local Plan applied a 20-year plan period. It may also be necessary for the Council to consider whether the scale of housing and employment need, and the strategic sites identified to meet this need, require the emerging Local Plan to extend over a longer period.

Comment

Representation ID: 14948

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15507
In accordance with paragraph 13 of the NPPF, “neighbourhood plans should support the delivery of strategic policies contained in local plans or spatial development strategies; and should shape and direct development that is outside of these strategic policies”. Footnote 17 of the NPPF confirms that “neighbourhood plans must be in general conformity with the strategic policies contained in any development plan that covers their area”. Similarly, as set out at paragraph 30 of the NPPF “neighbourhood plans should not promote less development than set out in the strategic policies for the area, or undermine those strategic policies”. Furthermore, they must meet the ‘basic conditions’ set out in paragraph 8 of Schedule 4B to the Town and Country Planning Act 1990 (as amended) (as per paragraph 38 of the NPPF). ASL recognises the value of neighbourhood planning in providing communities with an opportunity to shape a vision for their area. However, it is essential that the emerging Local Plan seeks to meet all housing (and employment) needs in CWAC by allocating sufficient land to accommodate these needs, and does not rely on any shortfall to be delivered by neighbourhood plans. ASL disagrees with the Council’s assertion at paragraph 1.27 of the Reg 18 Consultation Draft Plan that much of the content of the existing neighbourhood plans across CWAC won’t be affected by the emerging Local Plan. Many of these neighbourhood plans make direct cross references to the policies of the adopted Local Plan (and previous iterations of the NPPF and PPG), which are, or will become, out-of-date. Therefore, once the emerging Local Plan has been adopted, it will be necessary for the respective neighbourhood forums to review and update their neighbourhood plans to ensure continued consistency with the strategic policies of the Local Plan. These neighbourhood plans should not attempt to overtly restrict development where it is needed to meet local needs and should be informed by an evidence base to support all proposed policies. It may also be appropriate for neighbourhood plans to allocate small or medium-sized sites suitable for housing in their area (in addition to strategic allocations in the emerging Local Plan), consistent with paragraph 74 of the NPPF, to help support the delivery of a mix of residential opportunities and meet local needs.

Comment

Representation ID: 14949

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15508
In accordance with paragraph 15 of the NPPF, Local Plans should provide a positive vision for the future of each area. ASL considers that the emerging Local Plan should establish an ambitious yet realistic vision for the future of CWAC, explaining how the Council wishes to see the area grow and evolve up to the end of the Plan period. Central to the vision must be a commitment to meeting the current and future housing needs of the Borough, including market housing, family homes, affordable housing, homes for older people and homes for first-time buyers. Reference to meeting housing needs is absent from the current draft vision and this should be amended.

Comment

Representation ID: 14950

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15509
Subject to the inclusion of explicit reference to meeting housing (and employment) needs (see response to Question VI 1), ASL agrees that the key principles included in the proposed vision (i.e. tackling climate change, promoting wellbeing, providing infrastructure and protecting character) are necessary and show commitment to addressing key challenges facing CWAC.

Comment

Representation ID: 14951

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15510
Yes, ASL supports the proposed approach to establishing specific visions for key places within the Borough, subject to this aligning with the defined Spatial Strategy and Settlement Hierarchy, and being informed by the evidence base.

Comment

Representation ID: 14952

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15511
ASL considers that whilst the Council may take inspiration from the objectives of the current Local Plan (i.e. Option A) and the Sustainability Appraisal (i.e. Option B), that it should prepare objectives specific to the emerging Local Plan, that address the issues and challenges that are current in CWAC and which seek to support the realisation of the vision. In particular, this includes ensuring there is sufficient land available to meet local housing (and employment) needs, with a suitable range of sites to accommodate a mix of tenures, including affordable homes.

Comment

Representation ID: 14953

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15512
Please refer to response to Question OB 1.
Option A - take forward current Local Plan Objectives

Comment

Representation ID: 14954

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15513
Please refer to response to Question OB 1.