Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 16379

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16960
The Commissioners agrees with the policy approach towards Open Space, Sport Recreation and Community Facilities, particularly noting the support for proposals that “ enhance public access and the recreation value of the recreational routeway network ”. As detailed within section 10 of this Representation, ‘Land South of Ellesmere Port’ presents an opportunity to provide a large-scale mixed-use development incorporating the provision of high-quality green space as well as enhancements to public access and recreation within and to the Shropshire Union Canal, an identified recreational routeway network. CWCC is aware of the importance of the provision of new active travel links, open space, schools and community facilities alongside new homes, particularly their Local Cycle and Walking Infrastructure Plan (2020-2030) which highlights where strategic improvements to the active travel network are required, such as “ improved and safer links between the Ellesmere Port Town Centre and the railway station ”. The Commissioners considers the important role large-scale development sites such as ‘Land South of Ellesmere Port’ can play in ensuring the provision of these new facilities and infrastructure elements, which will be provided in close proximity to residents, increasing accessibility to facilities through walking and cycling. These large-scale development sites are able to provide and/or connect into new infrastructure and services including new schools, community centres and doctors’ surgeries to create sustainable communities whilst supporting the existing locality. Additionally, such sites provide the opportunity for the creation of high-quality sustainable travel options i.e., walking routes, cycle routes, and bus services as well as the possibility for mobility hubs which benefit not only the new community, but existing residents within the wider locality too. Furthermore, large-scale development sites also provide the opportunity to integrate well-considered green and blue infrastructure strategies into a site masterplan from an early stage, ensuring appropriate biodiversity enhancements, open space and sustainable drainage solutions are secured, which ultimately provide opportunities to improve health and wellbeing outcomes. Provision of open space within these large-scale development sites can also ensure developments are safe, accessible and promote social interaction in keeping with paragraph 96 of the NPPF which directly relates to achieving healthy, inclusive and safe places. The Commissioners is committed to ensuring that a well-considered green and blue infrastructure strategy is incorporated into the masterplan at an early stage at their development sites.

Comment

Representation ID: 16380

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16961
The Commissioners agrees with the policy approach towards Landscape, particularly noting the support for proposals that “ take full account of the characteristics of the development site, its relationship with its surroundings and views into, over and out of the site ”. As detailed within section 10 of this Representation, ‘Land South of Ellesmere Port’ presents an opportunity to provide incorporate the provision of high-quality green space as well as enhancements to public access and recreation within and to the Shropshire Union Canal. The Proposed Development would take a landscape-led approach to masterplanning, taking full account of the Sites’ relationship with its surroundings, and would seek to provide a series of gateways and linkages from Stanney Woods to the west, to Gowy Meadows in the east, encompassing key features such as: A New Nature Recovery Network - identified the potential for a new east / west green corridor through the whole of the Site. This new corridor could be of a scale that it presents a new a Nature Recovery Network (NRN) opportunity - connecting Stanney Woods, the Shropshire Union Canal, the River Gowy Corridor and Gowy Meadows Local Wildlife site (LWS) – providing a transitional landscape corridor through the Site, grading from woodlands to wetlands; Enhancements to the function, environmental value and activation of Shropshire Union Canal; Increased conservation and enhancement of the tree, hedgerow & pond network; Enhancement and expansion Gowy Meadows and Ditches LWS and Nature Reserve, alongside opportunities for collocated renewable energy generation to maximise land efficiency and biodiversity net gain; and Ecological enhancements that align with the emerging Nature Recovery Opportunity Areas within the Cheshire and Warrington Local Nature Recovery Strategy. Further detail on the extensive landscape opportunities of ‘Land South of Ellesmere Port’ are detailed within the Land at Little Stanney Lane, Ellesmere Port – Landscape Technical Note (August 2025) submitted alongside this representation.

Comment

Representation ID: 16381

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16962
The Commissioners does not consider that new settlement gaps should be identified within the Green Belt to protect the character of settlements, as this would duplicate a function already covered through a Green Belt designation. As noted within NPPF Paragraph 143, the Green Belt serves five purposes, one of which is to “ prevent neighbouring towns merging into one another ”, another to “ preserve the setting and special character of historic towns ”. Therefore, the Commissioners considers it unnecessary to identify any settlement gaps within the Green Belt across the borough, as such protective functions are already established by virtue of a Green Belt designation.

Comment

Representation ID: 16382

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16963
The Commissioners is generally supportive of the suggested policy approach towards green infrastructure, biodiversity and geodiversity, however, in order to ensure that sustainable growth is bolstered across the borough, elements of the policy criteria should be altered. The Commissioners understands the increasing importance of nature recovery, and support the integration of Local Nature Recovery Strategy’s within both plan-making and subsequently, decision-making. However, as noted within the Commissioners’ response to the Cheshire and Warrington Local Nature Recovery Strategy Consultation, which took place in March 2025, in order to ensure sustainable development can continue to be brought forward effectively to meet the housing and employment needs, development should not be unnecessarily impacted at site promotion, planning application or delivery stage, by LNRS targets and priorities. Given this, the Commissioners supports that “ developers will need to look at opportunities for nature recovery in line with the LNRS ” if they are “within or adjacent to either areas of opportunity or designated areas identified in the LNRS” however stresses that there should be no obligation to deliver such targets and priorities within the policy. Of course, the protection and enhancement of sites, habitats and species should be supported, however this should not come at a cost of delivering much needed sustainable development across Cheshire West and Chester.

Comment

Representation ID: 16383

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16964
The Commissioners considers that Local Plan policy should not exceed the 10% mandatory biodiversity net gain set out nationally. Instead, the Local Plan should direct development to areas in which “ net gains for biodiversity, including by establishing coherent ecological networks ” can be viably delivered, in line with Paragraph 187d of the NPPF. The Commissioners considers that the best opportunity in which to deliver such biodiversity gains and ecological networks is through their integration within large-scale mixed-use developments. The Commissioners considers that their Site provides a significant and unique opportunity to create high-quality nature recovery areas, in proximity to existing green infrastructure assets Gowy Meadows and Stanney Woods. The Vision for the Site includes the potential to extend Gowy Meadows nature reserve, creating a large-scale wetland destination that would transform existing farmland to a biodiverse habitat mosaic. This nature recovery area would link into a wider landscape corridor strategy that spans coherently across the Site, enhancing ecological connectivity and biodiversity from Stanney Woods through to Gowy Meadows. In developing this Vision, the Commissioners has had initial conversations with Cheshire Wildlife Trust (“CWT”) in order to understand the potential opportunities that a large-scale mixed-use development could provide in terms of biodiversity enhancements in proximity to the existing assets to the south of Ellesmere Port, and how these could best align to the wider aspirations of the CWT. As the Vision for the Site progresses, the Commissioners will continue to collaborate with the CWT, as well as Mersey Forest, to further establish the nature recovery and ecological connectivity opportunities across the Site. Cognisant of the above, the Commissioners stresses the importance of ensuring the allocation of Site is brought forward wholescale in order to ensure that the aforementioned nature recovery and ecological connectivity opportunities can be fully unlocked and subsequently delivered on Site, as these significant interventions would require integration within a wider proposed development in order to be delivered.

Comment

Representation ID: 16384

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16965
The Commissioners is generally supportive of the policy approach towards energy supplies and energy related development, however, considers some amendments should be made to highlight the role that large-scale developments can play in providing low carbon energy as part of wider mixed-use proposals, and to ensure that low carbon energy development and energy supplies can be delivered without restrictive policy requirements. From a national policy perspective, Paragraph 165 of the NPPF notes that Local Plans should “ maximise the potential for suitable [renewable and low carbon] development ”, including “ identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development ”. The borough of Cheshire West and Chester has the fifth highest carbon emissions of any local authority area in England (with the Ellesmere Port Industrial Estate alone consuming 5% of UK energy for industrial processes, heat and transport). Therefore, as noted within the CWCC Inclusive Economy Strategy (2022), “ moving to green energy and the transition to net zero is both a major challenge and a top priority ” for the borough. Therefore, the policy criteria should go further to consider the opportunities that large-scale mixed-use developments can provide in delivering low carbon energy and energy supplies. It is noted that the EN 1 criteria states that “ wherever possible, schemes should be located on previously developed land and/or in industrial areas and in areas close to existing users/demand or supplier of the energy, fuel and/or heat ”. The Commissioners considers that this should be amended to remove the prioritisation for low carbon energy development to be provided on previously developed land, and include reference to large-scale mixed-use allocations, which will ultimately be provided as part of the Local Plan, which should be considered as equally viable and deliverable as “ previously developed land and/or in industrial areas ” within the policy.

Comment

Representation ID: 16385

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16966
The Commissioners is generally supportive of the policy approach towards solar energy provision, however, considers some amendments should be made to highlight the role that large-scale developments can play in providing solar energy as part of wider mixed-use proposals, and to ensure that much needed solar development can be delivered without onerous policy requirements. From a national policy perspective, Paragraph 165 of the NPPF notes that Local Plans should “ maximise the potential for suitable [renewable and low carbon] development ”, including “ identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development ”. Additionally, the CWCC Climate Emergency Response Plan (2020) notes that, to provide sufficient solar power to support the decarbonisation of the grid, “ a 25x increase in installed capacity ” is needed by 2050. The Commissioners considers that this clearly illustrates a demonstrable need for solar energy developments to be prioritised through the policies of the emerging Local Plan, without which, a transition to net zero will not be possible across Cheshire West and Chester. Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Development (2016) Cognisant of the above national and local position, the Commissioners considers that local policy should ensure solar developments can be delivered without delay. The Commissioners is concerned that solar proposals will be impacted by requiring such developments to be located in areas of least impact, as noted within the currently drafted Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Development (2016). This document was prepared prior to CWCC declaring a Climate Emergency in 2019, which the Commissioners considers has changed the context and need for low carbon energy sources. The Commissioners supports the context set out in the Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Development (2016), insofar as it details the potential impacts development can have on the landscape, in line with Paragraph 165a of the NPPF. However, the Commissioners stresses that, if this is to be listed within policy, it should be updated to reflect the pressing need for low carbon energy in the borough. Furthermore, the Commissioners considers that, as currently drafted, the Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Development (2016) does not currently align with the emerging growth options of the borough, or wider CWCC documents such as the CWCC Inclusive Economy Strategy (2022) and the Climate Emergency Response Plan (2020) which again highlights the need for the document to be updated. The Commissioners particularly disagrees with the onerous assessment of the Landscape Character 9 – Cheshire Plain West, which covers a significant area of land between Ellesmere Port and Malpas. As currently drafted, the Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Development (2016) notes that the Landscape Character Area (“LCA”) would be particularly sensitive to a medium, large or very large solar farms, and somewhat sensitive to small solar farms. The Commissioners considers that rendering this large area as unsuitable for solar development would significantly hinder the opportunity to “ maximise the potential for suitable [renewable and low carbon] development ” in line with national policy, and ultimately limit CWCC from meeting their net zero ambitions. Furthermore, the Commissioners notes that areas within this LCA, such as their Site ‘Land South of Ellesmere Port’ have been included as the growth options within the emerging Local Plan, and therefore have been considered as potentially appropriate for development. Given this, the Commissioners stresses that the approach to the LCA’s should be revisited, in a current policy context, to ensure that any much-needed solar development is not precluded. Solar Development on Greenfield Land EN 3 notes that “ where development is proposed on greenfield land, the land around the structures should be used for livestock grazing, other agricultural use or another use beneficial to the environment or biodiversity. Use of agri-voltaics will be supported ”. The Commissioners is largely supportive of ensuring that solar development is provided in proximity to complementary green infrastructure uses, however given the increasing need to provide solar development, considers that this requirement should be amended to include the text “ where possible ”, which is used elsewhere within the criteria of EN 3. This will ensure that the Local Plan is “ maximis[ing] the potential for suitable [renewable and low carbon] development ” in line with national policy. Additionally, the Commissioners notes the key role large-scale mixed-use developments can play in unlocking low carbon energy development within wider proposals, particularly on large greenfield sites such as the Commissioners’ Site ‘Land South of Ellesmere Port’, is currently not referenced within the EN 3 criteria. Therefore, the Commissioners considers that text should be included within the solar development policy to highlight that support will be given to large-scale mixed-use developments that can provide low carbon energy, particularly where such developments can ensure solar development is co-located with “ uses beneficial to the environment or biodiversity ” such as high-quality green space and nature recovery areas. Land South of Ellesmere Port The Commissioners’ Site provides a significant opportunity to provide much needed solar energy development and energy supplies as part of a wider large-scale mixed-use development, which is proposed within the Site Vision to be co-located with “ another use beneficial to the environment or biodiversity ”. An area of the Site has been identified under growth options 2 and 3 within the draft Local Plan, for a mixed-use development, and therefore is already considered potentially suitable for development. By providing low carbon energy in this strategic location as part of a wider mixed-use development, renewable energy could be provided to neighbours such as ORIGIN, Ellesmere Port Waste Water Treatment Works, HyNet, Stanlow, Cheshire Oaks and others. As mentioned previously, the Commissioners has been in conversation with such neighbours around the possibility of providing renewable energy in order to assist them in meeting their own net zero ambitions. Furthermore, as the Ellesmere Port Industrial Estate alone consumes 5% of UK energy for industrial processes, heat and transport, the Commissioners considers that the development of any low carbon energy in this location should be prioritised. The Commissioners commissioned a Solar Energy Capacity Study for an area of their Site, to the east of the M53 in close proximity to the aforementioned neighbours, a layout plan is submitted in support of this submission detailing the possible location if the low carbon energy development. It is suggested that solar energy would be delivered as part of a wider mixed-use development on the Site, and would be co-located alongside nature recovery areas and improved green infrastructure. 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 Commissioner considers that their Site should be allocated wholescale, in order to ensure that any proposed development can unlock and provide much needed solar energy and collocated nature recovery and green infrastructure in an optimally located area which could assist in meeting “ a 25x increase in installed capacity ” to assist in decarbonising the grid, as well industrial neighbours in proximity meet their own net zero ambitions.

Comment

Representation ID: 16386

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16967
The Commissioners is supportive of the suggested policy approach towards waterways and mooring facilities, particularly the suggestion of supporting “ development proposals adjacent to waterways that can provide positive regeneration benefits… in Ellesmere Port” as well as improved “public access and recreational use of the waterways ”. The Commissioners agrees with the Ellesmere Port Places Background Paper (2024) insofar as it considers the presence of the Manchester Ship Canal as a considerable opportunity for improving the economy of the town, as well as the borough as a whole. The Shropshire Union Canal, which links the canal systems of the West Midlands with the River Mersey and the Manchester Ship Canal, runs north to south through the Commissioners’ Site. As detailed through the Vision Document submitted alongside this Representation, the Site provides an opportunity to create a destination for canal side leisure and learning activities along a currently underutilised waterway asset. In addition, the Vision aims to utilise the canal to improve the links to the town centre by improving active travel routes along and to the Shropshire Union Canal. The Vision looks to activate the canal from the early stages of development, unlocking access to blue infrastructure in the area, and ultimately improving the health and wellbeing of new and existing Ellesmere Port residents. As the Vision for the Site progresses, the Commissioners will continue to collaborate with the CRT to identify key interventions that could be successfully implemented along the Shropshire Union Canal.