Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14965

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15524
Christleton Christleton is identified as a Local Service Centre in the CWAC Local Plan Part 2 (“LPP2”) Policy R1 (Development in the rural area). This designation reflects the existing level of services within the settlement. ASL considers that the emerging Local Plan should review the settlement hierarchy and give consideration to whether some of the smaller villages should be “moved up” the hierarchy in order to reflect changing patterns in where people are choosing to live. Christleton is one of the villages that ASL considers could accommodate additional development and should be re-designated as a Key Service Centre in the emerging Local Plan. The Places Background Paper 202411 provides evidence and information on the relative sustainability of settlements within CWAC and identifies the availability of services and facilities within those settlements. This focuses on the existing urban areas and Key Services Centres as identified in Local Plan Part One (“LPP1”). Whilst ASL does not object to this approach, it is considered that as part of preparing the emerging Local Plan, a reassessment of the Key Service Centres should contain wider selection criteria. In particular, those settlements which may be accessible to a range of services and facilities within other settlements, and those which are accessible to main centres of population, should be designated as Key Service Centres, as they have the capacity to accommodate additional development in locations that are sustainable. Christleton is considered to be one such settlement. It is located on the edge of Chester and has excellent accessibility not only to Chester City Centre, but to facilities and services in the Chester suburbs located in close proximity. As people are choosing to move out of the large centres to more rural and semi-rural locations, they should be encouraged to move to settlements where there is good accessibility to the larger centres. This not only assists in maintaining the vitality of the settlement itself, but also assists in maintaining the vitality of the larger centres. In the case of Christleton, given its close proximity to Chester and its accessibility to Chester City Centre by public transport, it is considered that it is an ideal location to continue to support the vitality of Chester. Its excellent accessibility to Chester would provide the opportunity for residents of Christleton to access the services and facilities in Chester by sustainable modes of transport. ASL therefore considers that Christleton should be re-designated as a Key Service Centre in the emerging Local Plan to reflect this, and housing growth directed to the settlement as a result.

Comment

Representation ID: 14966

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15525
ASL acknowledges that the identified urban areas (including Chester) are the key drivers for the Borough’s economy and are the main centres for shopping and leisure, and therefore should be the main focus for development. However, there is also a need to deliver proportionate levels of growth in the smaller settlements in the Borough, including the identified Key Service Centres (such as Farndon and Malpas) and Local Service Centres (such as Christleton). The NPPF states that housing should be located where it will enhance or maintain the vitality of rural communities and requires planning policies to identify opportunities for villages to grow and thrive, especially where this would support local services, not just in the host settlement, but also in nearby villages. There are a number of settlements within the Borough that the existing evidence base (Places Background Paper 2024) acknowledges to contain a wide range of services and facilities, and which also serve a wider rural hinterland. These are designated in the adopted Local Plan as Key Service Centres. The spatial strategy in the adopted Local Plan only distributes a limited number of homes to these settlements. ASL considers that the emerging Local Plan should significantly increase the amount of dwellings designated to the Key Service Centres, in a proportionate manner which reflects the increased housing requirement across the Borough as a whole. This would help to support the ongoing vitality of settlements within the Borough and provide a critical mass of population to maintain and grow the service offer in these settlements. In addition, there are some settlements that, due to their location on the edge of a larger settlement, will become increasingly popular places to live due to the benefits that they have of providing access to the countryside, but also being highly accessible to the main centres within the Borough – this includes locations such as Upton-by-Chester and Christleton which are located in close proximity to Chester. Additional development within these settlements provides the opportunity to respond to the changing locational demands of a large proportion of the population in a way which will create sustainable patterns of development. Consideration should be given as to whether these settlements should be “moved-up” the settlement hierarchy in the emerging Local Plan and re-designated as a Key or Local Service Centres, with the level of housing development distributed to the settlements increased accordingly.

Comment

Representation ID: 14967

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15526
Yes. ASL supports the inclusion of place-based policies for smaller settlements, including the Key Service Centres such as Farndon and Malpas. However, this should also extend to all settlements which are proposed to accommodate further development as part of the Local Plan, including Local Centres such as Christleton.

Comment

Representation ID: 14968

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15527
Existing levels of service or infrastructure provision should not be a constraint to the expansion of settlements or their ability to accommodate growth. Where the housing needs assessment demonstrates there is a need or market for growth in these settlements, sites should be allocated for development and the proposed infrastructure strategy (to be prepared as part of the emerging Local Plan) should set out what new services or infrastructure would be required to support such growth. Policies relating to new development in these areas should clearly define expectations as to how each site should contribute to new services or infrastructure provision.

Comment

Representation ID: 14969

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15528
Yes. There have been significant changes since adoption of the current Local Plan that would now justify Green Belt release; including planning reforms and updated national policy. This has been recognised by the Council in their decision to prepare a new Local Plan, as set out in the January 2025 Report to Cabinet12. As set out in ASL’s response to Question SS 1, CWAC’s housing need, as defined by the standard methodology, requires a minimum of 1,928 dwellings per annum to be delivered, which equates to a total of 28,920 dwellings over a 15-year plan period or 38,560 dwellings over a 20-year plan period. The Council suggests that the latest housing land monitoring data identifies undeveloped planning permissions for almost 6,000 homes and that there are sites on previously developed land without permission within the main urban areas and Key Service Centres with a potential capacity of just over 5,000 homes – a total of 11,000 homes. Therefore, there are not enough homes within the urban area to accommodate the minimum requirement over a 15-year (or 20-year) plan period, and therefore this must be accommodated outside of the settlement boundary, on land within the countryside or the Green Belt. Green Belt covers almost half of the Borough and presents a significant constraint to the growth of settlements within the northern part of the Borough. Reflecting the extent of housing and employment need to be accommodated will require a detailed appraisal of the contribution that land surrounding sustainable settlements makes to the purposes of including land in the Green Belt, including identifying grey belt land in accordance with the February 2025 PPG. The NPPF (paragraph 146) is clear that the exceptional circumstances required for Green Belt release may include circumstances where a Local Authority cannot meet its identified housing need through other means.

Comment

Representation ID: 14970

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15529
Yes. As referred to throughout these representations, national policy relating to Green Belt has been refined and updated within the revised NPPF (December 2024) and updated Green Belt PPG (February 2025). In particular, the principle of ‘grey belt’ has been introduced (as defined in the NPPF Glossary). Paragraph 148 of the NPPF confirms that “where it is necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations”. On this basis, the emerging Local Plan must have full regard to the latest NPPF policy on Green Belt and the evidence base must include an assessment of whether land parcels within the Green Belt meet the definition of ‘grey belt’. The Council should also consider the potential requirement for and benefits of identifying safeguarded land in order to meet longer-term development needs beyond the Local Plan period, as per NPPF paragraph 149.

Comment

Representation ID: 14971

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15530
The Reg 18 Consultation Draft Plan sets out three Spatial Strategy Options, all of which the Council suggests are capable of accommodating at least 29,000 dwellings, which in theory would meet the minimum housing needs over a 15-year plan period in accordance with the standard method – however, further evidence will be required to demonstrate this is achievable. ASL’s view on each option is as follows: Option A: ASL considers that an approach which does not include a level of Green Belt release is unlikely to be appropriate, as this would be unlikely to meet the local housing needs across the Borough, and could lead to an unsustainable spatial strategy. Assuming that, as proposed, c.16,000 homes would be delivered around Northwich and Winsford, there would be a requirement for a further c.12,920 dwellings in other parts of the Borough. ASL does not consider that this would be a sustainable spatial strategy and there is a lack of evidence presented to confirm whether Northwich and Winsford could accommodate the scale of development proposed. On this basis, this option is not supported. Option B: ASL considers that Option B is the most appropriate of the three options presented, proposing growth in all existing urban centres and Key Service Centres reflecting their role within their settlement hierarchy and range of services and facilities on offer. These are the most sustainable settlements in the Borough and already benefit from a range of services and facilities to support residential populations. Maintaining the distribution of growth across the Borough would help to continue the positive approach to new development within these settlements which has been delivered by the adopted Local Plan. This option would also enable growth to be accommodated where it is shown to be needed, regardless of existing policy or Green Belt constraints – for example the emerging evidence base is likely to identify housing needs in Chester (and other Green Belt constrained settlements), which wouldn’t be met by the allocation of land for housing in Winsford or other settlements. Option C: In this option, the majority of growth would be directed to settlements with a train station or on main bus route corridors. ASL does not consider this to be an appropriate strategy as the presence of a public transport connection alone is not a definitive proxy for sustainability – consideration of a full range of services, including retail, community and education provision, as well as employment opportunities, should also be taken into account. The majority of the Borough’s existing Key Service Centres, recognised for their sustainability and providing services and facilities to support their surrounding population, do not have train stations and therefore should not be overlooked for growth. For the reasons set out above, ASL considers that the most appropriate spatial strategy for CWAC is Option B, which reflects that the distribution of development will be informed by the relative sustainability of the settlement with a proportionate level of new housing (and employment) growth located within each.
Option B - use the Sustainability Appraisal objectives

Comment

Representation ID: 14973

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15532
Yes, residential development should be supported in all settlements to enable sustainable development and growth, meeting all local housing needs. Alongside the urban centres and Key Services Centres referenced in the Reg 18 Consultation Draft Plan, the emerging Local Plan should also consider how housing growth could be accommodated within the Local Service Centres identified in LPP2 Policy R1 (Development in the rural area), including Christleton. These settlements provide a range of services and facilities to support their communities, which could be enhanced and improved by expanding the population. New development, particularly that which attracts younger residents, can play a significant role in maintaining the viability of smaller, rural settlements.

Comment

Representation ID: 14974

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15533
No. Please refer to response to Question SS 11.

Comment

Representation ID: 14975

Received: 29/08/2025

Respondent: Ainscough Group

Agent: Turley

I&O_15534
No. Please refer to response to Question SS 11.