Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 16369

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16950
The Commissioners is supportive of the suggested policy approach towards Ellesmere Port, particularly with regards to the requirement for “ all developments…to support physical and landscape improvements to the gateways, corridors and green spaces within Ellesmere Port including along the M53/Shropshire Union Canal Corridor .” As noted within the response to question OS 1, GI 1, GI 3 and MISC 3 within this representation, and within the Landscape Technical Note prepared by Bradley Murphy Design (August 2025) as submitted, the Commissioners’ Site provides an opportunity to create key landscape-led gateways along existing highways infrastructure, as well as provide a destination for canal side leisure and learning activities along the Shropshire Union Canal. As mentioned previously, if the entirety of the Site is brought forward, as part of a future Local Plan allocation, there is an opportunity for the Commissioners to collaborate and partner with both the Cheshire Wildlife Trust and the Canals & Rivers Trust, as part of future development proposals. Indeed, the Commissioners has already been in initial conversation with both parties as critical friends, to assist in the development of the Vision for the Site. Allocation of the Site in its entirety would provide the opportunity for: An enhanced and activated Canalside with development frontages, public open space and marina / moorings; improved recreational capacity and connectivity along towpath and highways assets, with an enhanced leisure route for cycling and walking celebrate and enhance the Canalside, its natural and historic assets, with the creation of a new quayside parkland destination; creation of a new tourism offer and relieve the recreational pressure along the towpath, by providing an alternative recreational route through the adjacent Commissioners land; creation of a new marina and Canalside frontages, through a leisure hub, providing a stop off point for boats between Chester and Ellesmere Port and bring a host of economic benefits to the area. Exclusion of the land to the east of the M53, from any future EP01 allocation, precludes the ability to enhance these green infrastructure initiatives, with the wider benefits and opportunities from development of the Site not fully achieved - the Shropshire Union Canal would remain enclosed on its boundaries, lacking activity and positive frontages and with ongoing limits to the recreation capacity on the towpath (due to existing narrow width of c. 1.5m and poor surfacing).

Comment

Representation ID: 16370

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16951
As noted within the Commissioners response to SS 1 and SS 4, the Commissioners consider a ‘previously developed land-first’ approach to not be an appropriate starting point when considering growth in the borough. Although the Commissioners notes the sustainability opportunities previously-developed land provides, as is noted within Paragraph 125c of the NPPF, the prioritisation of greenfield opportunities will be fundamental in not only meeting the housing needs of the borough, but also ensuring the growth and vitality of all areas in Cheshire West and Chester. The Commissioners is supportive of the use of small areas of previously developed land in proximity to the Ellesmere Port town centre in order to assist in catalysing the vibrancy and activity of the settlement, but stresses that this should be considered secondary to the allocation of large-scale greenfield sites, which provide a much greater opportunity for sustainable development, the provision of improved and additional services and facilities, affordable housing, and green infrastructure which will ultimately better assist CWCC in achieving both their wider growth and climate change aspirations.

Comment

Representation ID: 16371

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16952
The Commissioners is generally supportive of the policy approach towards Green Belt and Countryside, particularly the need to update the policy to set out the approach to grey belt and Green Belt Review evidence. The Commissioners is also supportive of including potential uses appropriate to countryside, and consider that low carbon energy should be included in these uses. Low carbon energy development such as solar and wind development often lends itself to be collocated with nature recovery. Indeed, the policy approach to solar development notes that “ the land around the structures should be used for livestock grazing, other agricultural use or another use beneficial to the environment or biodiversity ”. The Commissioners considers that, in order to ensure consistence across policies, the opportunity to provide low carbon energy development in the countryside should be referenced within the future Green Belt and Countryside policy. Land South of Ellesmere Port The Commissioners’ Site is currently designated Green Belt; however the designation precedes the highways development of the M53 and M56 motorways and as such the land between Ellesmere Port urban area and the M56 is now separated from the wider countryside north of Chester by a substantial defensible boundary. When considering the Site against the purposes of the Green Belt, it can be summarised that the Commissioners’ Site is subject to urbanising influences from substantial existing built form on the southern settlement edge of Ellesmere Port and motorway and highway infrastructure on all sides and therefore: makes limited contribution to checking unrestricted sprawl; makes no contribution to preventing towns from merging into one another, with the M56 acting as a clear and defensible southern boundary; and makes no contribution to preserving the setting and special character of historic towns. Therefore, the Commissioners considers that their Site ‘Land South of Ellesmere Port’ does not contribute positively in a material way to any of the Green Belt purposes and should be removed to allow for its sustainable development. A comprehensive Green Belt Review of the Site has been undertaken by Bradley Murphy Design, which has been submitted with this Representation. Golden Rules Paragraph 151 of the NPPF notes that “ where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ … should apply ”. The NPPF also notes at Paragraph 158 that “ a development which complies with the Golden Rules should be given significant weight in favour of the grant of permission ”. The Commissioners considers the Site could deliver a sustainable development that complies with the Golden Rules, and therefore notes its suitability for an allocation within the Local Plan in order to assist in the delivery of much needed housing and employment growth across the borough. Table 8.1 provides a summary of the opportunities the Site could provide, in accordance with the Golden Rules. [see page 28 of the attached] Further information on the justification for the removal of the Site from the Green Belt is provided within the Land at Little Stanney Lane, Ellesmere Port – Green Belt Review Technical Note (August 2025) submitted alongside this representation.

Comment

Representation ID: 16372

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16953
The Commissioners strongly agrees with the suggested policy approach towards transport and accessibility as set out within policy approach TA 1, particularly with regards to extending and improving access to the “ local footpath and cycle networks, including greenways, canal towpaths and the Public Rights of Way networks ” by placing new development in “ more sustainable locations ”. In this regard, the Commissioners suggests that reference to large-scale development sites be made within TA 1, specifically noting the ability such sites have in provisioning connectivity enhancements that will aid in connecting these new community to existing settlements, as well as providing enhancements to existing sustainable modes of transport. Additionally, TA 1 notes that “ developments and places should maximise any opportunities for people to be able to meet their regular day to day needs within a reasonable (10 minute/800 metres) walking distance of their homes ”. Again, the Commissioners stresses the importance of the role of large-scale development sites in this context, as the provision of services and facilities in proximity to new housing can be created through the holistic masterplanning of a new community, ensuring that day to day needs can be accommodated within walking distance of a residents home. Considering the Commissioners’ Site specifically, a detailed Transport Note (August 2025) has been prepared by Pell Frischmann which notes the opportunities sustainable development on this Site could provide, which has been submitted alongside these representations.

Comment

Representation ID: 16373

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16954
Generally, the Commissioners is supportive of the key local transport infrastructure priorities as identified. The Commissioners supports the inclusion of the Shropshire Union Canal within the strategic recreational routeways. As noted within the Commissioners’ response to question MISC3, their Site ‘Land South of Ellesmere Port’ provides an opportunity to create a destination for canal side leisure and learning activities along the Shropshire Union Canal. The Site Vision aims to utilise the canal to enhance links to the town centre by improving active travel routes along and to the Canal, whilst activating the canal-side for recreation to improve the health and wellbeing of new and existing Ellesmere Port residents. Overall, the Commissioners considers that the key local transport infrastructure priorities should be reviewed, in the context of new growth options for the borough, and supporting infrastructure needed in order to deliver such options. The Commissioners encourages this to be undertaken through the Infrastructure Delivery Plan which it understands is currently being prepared. Subsequently, these priorities should be updated in order to ensure they represent the most relevant infrastructure schemes across the borough in the context of emerging growth options, rather than reiterating those identified within the adopted Local Plan.

Comment

Representation ID: 16374

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16955
The Commissioners is generally supportive of the policy approach towards infrastructure and developer contributions insofar as it aims to set clear requirements for developers with regards to infrastructure and service provision. The Commissioners is particularly supportive of the policy approach which notes that “ where viability is a genuine issue…the Council will seek views on how infrastructure requirements could be prioritised ”, demonstrating a level of flexibility which will ensure that much needed development is not delayed or undeliverable. However, the Commissioners considers that, at present, the policy approach could risk viability issues across the borough, particularly with regards to the large-scale greenfield sites, a number of which have been highlighted as potential growth areas under the spatial strategy, and will be much needed in order for the borough to meet its significant housing need. Paragraph 15.7 within the infrastructure and developer contributions supporting text notes that “ viability arguments are unlikely to be justified especially on greenfield sites ” and “ the payment of off-site contributions will not be accepted as a solution if additional costs will fall on the Council or the funding and/or provision off site would not deliver the necessary infrastructure ”. The Commissioners considers these statements to be onerous and lack flexibility, ultimately risking delays to delivery of the large-scale greenfield sites across the borough. The Commissioners considers that, although an overarching infrastructure and developer contributions policy should be in place, it should be flexible to ensure infrastructure and service requirements can be considered on a site by site basis, and development can be flexible in reaction to wider market and political conditions. This is key for large-scale greenfield sites in particular, given the significant period of time in which new sustainable communities take to be delivered. CWCC should consider the implications of requirements around infrastructure and developer contributions in relation to location and type of site, as well as from a viability perspective. The policy should also be suitably flexible to allow for design practicality, necessity over time and suitability (including the nature of the development and physical constraints), rather than being a blanket policy that provides the same requirements to all allocations. Additionally, the Commissioners notes that developers must have the opportunity to be able to demonstrate “ whether particular circumstances justify the need for a viability assessment at the application stage ” if needed, in line with paragraph 59 of the NPPF, which should be able to be considered by the Council without bias. At present, an assumption that “ viability arguments are unlikely to be justified especially on greenfield sites ” suggests a predetermined position with regards to greenfield sites. The Commissioners suggests that reference to viability assessments should be included within the policy, with reference to these being considered by the “ decision maker, having regard to all the circumstances in the case, including whether the plan and the viability evidence underpinning it is up to date ”. Finally, the Commissioners considers the importance of both the Viability Study and the Infrastructure Delivery Plan in ensuring the viability of sites in relation to the development of essential infrastructure and services. In particular, the Infrastructure Delivery Plan should ensure alignment with new infrastructure required to support the growth of the district brough about by the new Local Plan, and provide clarity around the delivery of such infrastructure, particularly if this is to be through developer contributions. The Commissioners welcomes the ability to review and provide comment on such evidence base documents, once drafted, and stresses the importance of the robustness of these documents, in order to ensure that viable sites can be allocated through the Local Plan.

Comment

Representation ID: 16375

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16956
The Commissioners is generally supportive of the policy approach to EG 1, however suggests that greater reference be made to the role of Ellesmere Port in bolstering economic growth, employment and enterprise across the borough, particularly with reference to development opportunities that lie outside of the established Employment Areas. Additionally, the Commissioners considers that direct reference, and subsequent policy alignment should be made for the Invest 2035: The UK’s Modern Industrial Strategy (NPPF Footnote 43), which identifies priority sectors for growth. The Commissioners particularly notes that “ clean energy industries ” should be proactively encouraged, and therefore suggests that CWCC seek to “ identify strategic sites ” to accommodate such development within the Local Plan, in order to ensure the Local Plan “ proactively encourages sustainable economic growth, having regard to the national industrial strategy ”. Ellsemere Port The Employment Area Survey (2023) attributes Ellesmere Port’s large offering of flagship or strategically located sites to its “ excellent transport connectivity close to the M56, M53, Manchester Ship Canal and with rail discharge and port facilities ”. The Commissioners considers that Ellesmere Port has the unique opportunity to bolster a large proportion of the boroughs employment growth through the emerging Local Plan, and therefore it is particularly important to ensure that any established Employment Areas, as referenced within EG 1, are deliverable and capitalise on the unique strategic location of the settlement. Rather than prioritising the established Employment Area, the Commissioners considers that locations for allocations for employment land should be based on the needs of the district and ability to deliver the most sustainable developments. These allocations should “ be flexible enough to accommodate needs not anticipated in the plan ” as noted within NPPF paragraph 86d. This should include a range of both new and existing sites, which have been robustly assessed through Economic Needs Assessments and Economic Land Availability Assessments and subsequently allocated to ensure that the growth aspirations of the emerging Local Plan are achieved. It is referenced within the ‘Places Background Paper – Ellesmere Port’ (March 2024), that Ellesmere Port “ provides a major employment land resource for the borough and has become increasingly successful in attracting new employment opportunities ”. The Commissioners considers that there should be a focus of employment space within Ellesmere Port that looks to go further than the 22 established Employment Areas noted within the Employment Area Study (2023), which should be brought forward specifically through new allocations within the emerging Local Plan. These new allocations should be able to capitalise on existing connectivity infrastructure, as well as compliment the established Employment Areas, to bolster economic growth and vitality across both Ellesmere Port and the wider borough. Modern Economy The Commissioners considers that the policy wording should acknowledge the importance of supporting the needs of the modern economy, in order to align with Paragraph 86b of the NPPF which notes that policies should “ pay particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics ”. Cognisant of this, the Commissioners considers that their Site, provides an optimal location for meeting the economic needs of a modern economy. In doing so, it is considered that Policy EG1 should also make a link to the energy sector specifically recognising the potential for delivering Battery Energy Storage Systems, which are ideally located in close proximity to existing industrial and low carbon energy uses and key strategic road networks. The Commissioners’ Site provides a unique opportunity to provide BESS, which could be suitably integrated within a wider mixed-use masterplan, delivering key development to support the modern economy alongside possible complementary solar energy provision, as well as biodiversity enhancements. The Site Vision has identified land to the east of the M53 as best placed to provide such development, which would be unlocked by the delivery of the wider mixed-use development, proposing housing, employment and community uses to the west of the M53.  As noted previously within these Representations, the area of the Site to the east of the M53 is not currently identified within the draft Local Plan growth options. The Commissioners considers that their Site should be allocated wholescale, in order to maximise its potential to serve the modern economy whilst also supporting much improved green infrastructure and nature recovery.

Comment

Representation ID: 16376

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16957
The Commissioners agrees with the policy approach towards the visitor economy, particularly noting that “ the creation of new tourism opportunities will be supported where this would enhance the existing tourism offer, benefit the local economy and be of a suitable design, scale and type for its location .” In developing the ‘Land South of Ellesmere Port’ Vision, the Commissioners has been in discussion with the Canals and Rivers Trust (“CRT”), CWCC Regeneration Officers, and neighbours at Cheshire Oaks Designer Outlet which have detailed the existing visitor economy offerings around Ellesmere Port. The Commissioners’ Site presents an opportunity to provide complementary “ cultural attractions and visitor accommodation ” in proximity to Ellesmere Port to support the vitality of the town, in line with the policy approach. At present, the Vision notes the following opportunities that could be provided as part of a large-scale mixed-use development at in proximity to Ellesmere Port: A hotel with conference facilities to complement the existing cultural attractions of Ellesmere Port; Provision of outdoor activities along the Shropshire Union Canal to activate the existing waterways asset, and the improvement of key active travel routes along the towpath to improve connections to and from Ellesmere Port; Provision of a leisure hub comprising indoor and outdoor sport facilities; and Outdoor recreational offers in the form of a new park and nature reserve. As the Vision for the Site progresses, the Commissioners will continue to collaborate with local neighbours and key stakeholders to identify key visitor economy opportunities that could be successfully implemented within the proposed development.

Comment

Representation ID: 16377

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16958
The Commissioners is supportive of the policy approach towards delivering affordable housing within Cheshire West and Chester. The Commissioners supports the need for an affordable housing policy within the Local Plan which will deliver the level of provision required to support the needs of the borough. At this early stage in the Plan-making process, the Commissioners considers that further work regarding the Plan’s viability is required in order to establish the affordable housing requirement, particularly if there are variations proposed on a sub area basis or indeed between Green Belt and non-Green Belt sites. Should the Council seek to propose a significantly higher affordable housing requirement on sites released from the Green Belt than non-Green Belt sites, it is critical that the Council considers carefully whether there are any viability implications, taking into account different housing market areas, and the requirements that are more frequently placed upon large-scale development sites such as provision of supportive infrastructure and additional services and facilities. In order to ensure that the borough’s significant housing need can be met, the Commissioners considers that CWCC should look to prevent any delay to the delivery of large-scale development sites that have been released from the Green Belt, which could be brought about by a significantly higher affordable housing requirement.

Comment

Representation ID: 16378

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16959
The Commissioners agrees with the policy approach towards health and wellbeing, particularly noting the support for proposals that “ aim to promote high quality access to green space across the borough that will support opportunities to widen and strengthen the boroughs cultural, sport, recreation and leisure offer ”. As detailed within section 12 of this Representation, ‘Land South of Ellesmere Port’ presents a unique opportunity to provide a large-scale mixed-use development incorporating the provision of considerable levels of high-quality green space and opportunities to strength the cultural, sport, recreation and leisure offer across the borough. The Commissioners considers that CWCC should ensure their spatial strategy supports large-scale developments that are able to create vibrant and healthy communities across Cheshire West and Chester which will provide an opportunity to promote active and healthy lifestyles across the borough.