Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 8467

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8958
We think the borough should prepare a comprehensive urban capacity study that would identify brownfield land in the urban areas and opportunities for intensification, particularly in areas with good public transport or the potential to provide good walking and cycling to reduce the need for travel, and regenerate left-behind urban communities in CWaC where life expectancies are 10 years less in in deprived areas of the Borough rather than areas surrounded by green belt. Our evidence for this is: We know standard LPA brownfield registers are almost all out of date and of little use in identifying either developable or deliverable housing sites. In 2022 the CPRE 'State of brownfield report’ showed that over 1.2 million homes could be built over 23,000 sites nationally covering more than 27,000 hectares of brownfield, including a minimum of 165,919 dwellings in the north west. This evidence suggests that there is a lot of extra developable brownfield land that has not yet been identified in the CWaC area. Local communities in the Chester Green Belt Alliance have started the process of identifying additional housing land using the CPRE brownfield register toolkit. It is expected to demonstrate additional sites. We are keen to, and expect that CWaC will engage with us in this exercise. Wirral MBC has just adopted a local plan without the need to allocate Green Belt or greenfields for development, and with a high degree of political consensus.

Comment

Representation ID: 8468

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8959
We agree that 15 years is a reasonable period. Any more would increase pressure to allocate greenfield or Green Belt sites. These would inevitably be developed first, and use of brownfield land and urban regeneration would stall. It is almost impossible to see what economic or social factors will apply more than ten years ahead, so while significant strategic issues can be guessed at, it is not sensible to make tactical allocation decisions more than 15 years ahead.

Comment

Representation ID: 8470

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8961
The SA rates current active travel accessibility is poor in some urban areas (Northwich, etc.) which downplays their potential to create sustainable communities should walking and cycling conditions be improved. Also, the SA appears to regard a bus service of 1ph as ‘frequent’. These anomalies lead to some odd results in defining sustainable communities suitable for development. We do not accept the conclusions of the SA about the sustainability of the three strategic options – it fudges issues and does not come to a firm conclusion. It is non-sensical to suggest that the BAU option (B) is comparable in sustainability terms with Option A. For the avoidance of doubt the A41, A51 and A56 do not have the capacity or the capacity to be configured to cope with the additional traffic and access points required. PM2.5 represents the next major ‘buried health problem’ following asbestos and smoking with residents health already compromised by the presence of particles throughout their bodies. The suggestions that firstly either electric cars which are heavier and cause more road damage, and that increase PM2.5 particles from brakes and tyres, or that secondly bus use will solve the congestion, queueing and cut through traffic is misleading and will not meet the legal obligations on the Council to ensure that local air quality meets statutory standards.

Comment

Representation ID: 8474

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8965
Neighbourhood Plans provide an opportunity to commission a local housing needs study which operates at a detailed level using local knowledge and expertise and can identify housing needs for residents and those with a local connection as well as identify site that are acceptable to the local community. Christleton and Littleton PC has just done this through their Neighbourhood Plan process. Once the level of genuine local need has been determined, the local community can allocate sites to meet this need through the NP process. We note that national funding for NPs has ceased, and this means that CWaC will need to allocate resources should it be intended that NPs play a significant role. Where existing NPs have been adopted or are at an advanced stage, then there should be a strong presumption that the policies and allocation are incorporated in the new local plan.

Comment

Representation ID: 8475

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8966
No. Part One included a detailed examination of Green Belt boundaries around Chester and concluded that the extent of the Green Belt was justified (apart from the release of one site - land at Wrexham Road) and that all parcels of land in the current Green Belt contribute to the purposes of the Green Belt. This assessment remains valid. While Government planning policy has evolved and new housing figures proposed, the thrust of the planning system is still heavily tilted towards urban regeneration and countryside protection. We believe that the additional housing to meet specific identified local need ,and limited by highway capacity can be provided in existing communities to improve the quality of life and regenerate those communities.

Comment

Representation ID: 8477

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8968
Option A - Retain the Green Belt.

Option A - Retain the Green Belt

Comment

Representation ID: 8478

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8969
Yes. Chester Green Belt Alliance welcomes the Council’s commitment to consultation and planning for sustainable growth. We support the value of the Green Belt in retaining the separate identity of villages to the east of Chester, environmental quality, heritage, community character and preserving the setting of the historic City of Chester as well as encouraging urban regeneration in some of the boroughs less favoured urban areas where life expectancy is around ten years less than the rural villages. The detailed boundary of the Green Belt around Chester was defined in 1983 in the Greater Chester Local Plan. For 40 years, it has been under intense pressure from developers at every stage of the planning process. The last examination (Local Plan Part One) concluded that further Green Belt release around Chester would have “a significant adverse effect on the purposes of including land within the Green Belt.” The Chester Green Belt provides a valuable escape from city life, mental health benefits and opportunities for outdoor recreation opportunities. Green Belt is the single best understood planning policy which retains almost universal support (apart from people who would make profits out of its development). Green Belt also contributes to the borough’s quality of life and attractiveness for residents and businesses. Cheshire West and Chester benefits economically from its rural character and proximity to green space, which underpin tourism, recreation, and wellbeing. Put simply, without the Green Belt, Chester and Cheshire would not be the Chester and Cheshire we know and love today. We are concerned that the Council may select a ‘hybrid’ option of ‘A’ plus elements of the other options. To be clear, this would NOT be ‘Option A’ and we and completely opposed to a compromise that would actually mean significant development in the Green Belt.

Comment

Representation ID: 8479

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8970
No. Option B might appear familiar, but this should not be mistaken for sustainability. Continuing the current distribution pattern requires release of Green Belt for around 11,000 homes and would repeat the weaknesses of the existing spatial strategy without responding to new environmental, economic, and demographic realities including the climate crisis. Option B entrenches a development pattern that disproportionately targets peripheral sites, often on high-value agricultural or biodiverse land, rather than focusing on the regeneration potential within the urban area. By doing so, it misses the opportunity to reinvest in struggling town centres and risks accelerating their decline. For example, under-occupied retail areas in Ellesmere Port and vacant industrial estates in Winsford could be developed as compact, sustainable communities that avoid car-dependence. Otherwise, they will continue to struggle. Option B weakens the borough’s ability to defend against speculative applications. Once a precedent for Green Belt release is established, it becomes harder to resist further encroachment. The incremental erosion of Green Belt is often the result. From a climate change perspective, Option B’s pattern of dispersed development results in higher car dependency. Most peripheral sites listed in option B lack frequent public transport and are too far from employment hubs to support walking or cycling as primary modes. For instance, the service on the Mid-Cheshire Line is painfully slow and infrequent and of little use in journeys east towards Greater Manchester and the Airport. Chester station is poorly located with respect to the City centre. This undermines the Council’s carbon reduction targets and increases congestion on radial road routes into Chester, Ellesmere Port, and Northwich. This is particularly acute to the east of Chester with systemic congestion on the A41/51, air quality that fails WHO standards, no rail stations and no prospect that bus routes will be given meaningful priority. The conditions on these roads are uniformly hostile to walking or cycling. Option B also spreads limited developer contributions thinly across multiple areas, resulting in “half-measures” for schools, GP surgeries, and road capacity improvements rather than fully funded facilities. This leaves communities with enduring service gaps and undermines public support for new development. Economically, the option risks creating new dormitory suburbs without adequate local employment, retail or social provision. Jobs tend to remain concentrated in larger centres or industrial zones, forcing new residents to commute long distances and adding pressure to transport networks. The Sustainability Appraisal does not sufficiently address these issues. Finally, Option B does little to address the borough’s brownfield land supply challenge. By relying heavily on peripheral release, it reduces the incentive for developers to tackle more complex urban regeneration projects. This is contrary to both national guidance and the Council’s own ambitions for revitalised, vibrant town centres.

Comment

Representation ID: 8481

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8972
No. Option C sounds progressive—linking growth to sustainable transport—but in practice it represents the most aggressive Green Belt release of all three options, over 12,000 homes. This undermines the very sustainability it claims to promote. The logic of Option C assumes that building along rail or bus corridors will automatically reduce car dependency. In reality, many proposed sites along these corridors are still distant from stations, lack safe walking and cycling routes, and have limited public transport frequency especially outside peak hours. Without guaranteed and sustained investment in service improvements, such developments risk becoming car-dependent despite their “corridor” label. The scale and dispersal of development under Option C is also problematic. By spreading growth across multiple settlements, it dilutes the capacity to fund and deliver infrastructure upgrades. Large-scale growth in fewer locations allows economies of scale in infrastructure provision; corridor-based dispersal does not. Communities along these corridors could experience population growth without service improvements, undermining social cohesion. Option C risks “ribbon development” along transport routes, leading to gradual merging of distinct settlements. This directly contravenes one of the core purposes of Green Belt: preventing neighbouring towns and villages from coalescing. The visual and landscape impacts of linear sprawl can be particularly severe, eroding rural character over long distances. Environmental impacts would be extensive. It would exacerbate flood risk, fragment wildlife habitats, and permanently develop high-value agricultural land compromise. Economically, Option C risks undermining town centre regeneration. If new housing is concentrated along corridors but outside main centres, residents may commute out of the borough entirely, increasing car commuting, reducing local spending and weakening urban areas in the borough. Lastly, the viability of Option C depends on aligning housing delivery with significant public transport, cycling and walking investment – something that rarely happens. The result could be isolated developments poorly served by sustainable travel options, effectively locking in car dependency for decades. Overall option C presents high environmental costs, questionable transport benefits, and serious risks to community and landscape integrity. It is the least defensible option when measured against the Council’s sustainability and climate objectives.

Comment

Representation ID: 8482

Received: 26/08/2025

Respondent: Chester Green Belt Alliance

I&O_8973
The draft plan does not suggest an approach to Grey Belt. Landowners and developers will always make the self-serving case that their piece of land is Grey Belt and therefore should be allocated for development. For plan-making, the point about Grey Belt is that authorities must release it first in sequence before they release non-grey Green Belt land. If land is Grey Belt it does not meant that it must be removed from Green Belt or that it should be allocated for development – just that if needed it should be in the first tranche to be considered. We are confident that firstly, there is sufficient brownfield and other land in urban areas, and potential for urban regeneration and intensification that means that any release of Green Belt (whether Grey or not) is unnecessary. Identifying this supply may require additional work from CWaC and local communities, including using the CPRE Brownfield Toolkit which has successfully been used nationally in many local areas to identify significant areas of brownfield land additional to that which the LPA had already identified. It is also clear from the recently adopted Wirral Local Plan (in an adjacent local authority that has significant and restrictive Green Belt) that this strategy is feasible and defensible at a local plan inquiry. This approach is also more sustainable than the current CWaC approach and directly addresses the significant economic and social inequalities in the borough by directing development and investment to areas that need it.