Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10677

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11175
The NPPF ¶12-14, 29-31, 239 and Glossary apply, and Neighbourhood Plans that have been approved continue to have full effect, pursuant to the listed paragraphs of the NPPF. Where a proposed allocation, or connection and/or design tests are in conflict with a made Neighbourhood Plan, the Neighbourhood Plan must take precedence, and the proposed allocation very carefully to avoid conflict. The NPPF at ¶30 emphasises, “…neighbourhood planning gives communities the power to develop a shared vision for their area…” which “…can shape, direct and help to deliver sustainable development, by influencing local planning decisions as part of the statutory development plan...”. Farndon has an approved Neighbourhood Plan and this must be taken into account when considering any proposed allocations, particularly housing allocations, especially where those proposed allocations may be at a quantum that would fundamentally change the character of the village and the surrounding area.

Comment

Representation ID: 10678

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11176
No, not entirely. The current Development Plan includes Farndon with settlements such as Cuddington, Sandiway, Helsby, Malpas, Tarporley and Tattenhall, as being said to have the same level of services as those settlements, that being a level that “…can meet the day-to-day needs of their residents…”. The level of available facilities in Farndon are at a significantly, and materially lower level than those available in the other listed settlements, and to include Farndon together with those other settlements is nonsensical and misleading. Farndon has an over-subscribed doctor’s surgery, a newsagent with a very limited volume and range of stock, a post-office, pharmacy, butchers, two hairdressers, two public houses, a gym, two coffee shops, a nursery, and a primary school. There is a limited and irregular bus service between Wrexham and Chester, with only 9 daily services to Chester, and 8 to Wrexham. For most day-to-day grocery and personal requirements most residents will use the car to travel to the general store in nearby Holt, or undertake the 7.5-mile journey to Caldy Valley Sainsburys, or the 6.5-mile journey to the various superstores in Wrexham, there being no similar adequate provision in Farndon within a sustainable travel distance. To categorise Farndon together with more sustainable settlements, particularly Cuddington, Sandiway, Helsby, Malpas, Tarporley and Tattenhall, is an incohesive approach that lacks adequate consideration, particularly when considering housing allocations. A more cohesive and appropriate approach would be to consider different tiers of minor settlements and villages, as is not uncommon elsewhere, in order to differentiate between the differing sizes of those settlements/villages and the range and adequacy of services and facilities available in those settlements/villages. In principle, housing allocations in Farndon run contrary to the national planning policy aim of reducing the reliance upon the private car for daily journeys. It is not suggested that Farndon is located in an entirely unsustainable location, but it is poorly located compared to the other settlements that it is listed alongside in the settlement hierarchy, and a more cohesive approach is suggested, properly assessing the actual level of available services and facilities, which should then be used to inform the SS5 Spatial Strategy options.

Comment

Representation ID: 10679

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11177
The location, character, identity and size of the individual settlements, and the nature and level of available services and facilities should be taken into account when considering whether further development would be appropriate in all and every settlement, particularly housing. It may well be the case that some level of development will be appropriate in almost all settlements, but not all settlements are the same and the clear and significant distinctions between settlements such as Farndon and Tarporley, or Farndon and Helsby, for example, should be reflected in the appropriate level of allocated development. Tarporley, for example, has a population of 3219 over an area of 1.1km2, whereas Farndon has a population of 2228 over an area of 0.7km2, according to the 2021 Census. The available range of services and facilities in Tarporley is significantly wider and more adequate than those available in Farndon, and it would be appropriate for any level of future housing allocation to be higher in larger and more adequately serviced settlements. A similar analysis applies to Helsby, which has a considerable and extensive range of services for its population of 5274. The balance of housing allocations cannot reasonable be made on a linear basis, it must take into account the fundamental nature of the existing settlement, as compared to other settlements.

Comment

Representation ID: 10680

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11178
Yes, for the reasons set out in answer to questions SS5, SS6, and GB1. Each of these settlements is unique and fundamentally different, particularly in the context of size, area, character and availability of services and facilities (2021 Census – Helsby population 5274, over an area of 2km2 , Farndon population 2228 over an area of 0.7km2 ). It is neither appropriate nor sound to continue to treat all of these settlements as being the same. Settlement specific polices would address these material differences, and be reflective of any Neighbourhood Plan that is in place, ensuring suitable and sound settlement specific allocations and plan policies.

Comment

Representation ID: 10681

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11179
Yes, to do otherwise would be entirely contrary to the national planning policies set out in the December 2024 NPPF (see also the responses provided to questions SS5, SS6, SS7 and GB1). For example, Farndon with a population of 2228 (2021 Census) across approximately 900 dwellings would be entirely overwhelmed in character and demand by anything near a housing allocation of 500 units, and 1500 units would be entirely irrational, whereas the impact of an allocation of 500 dwellings upon larger settlements such as Helsby and Tarporley would be more sustainable and less harmful. Demand on the limited range of services in Farndon from an increase of over 50% of dwellings would be overwhelming for those services, for the road network (parking and traffic movement), compromising highway safety and be contrary to all of the national planning policies relating to the sustainability of development, the fundamental driver of national planning policy. Farndon Parish Council do not advance an argument that the village should not necessarily have any future housing allocations, in light of the current Government’s change in housing policy, but any such allocations should be proportionate to the existing village, with an allocation of anything near 500 units being entirely disproportionate and unsustainable. Any housing allocation for Farndon (no other allocation is proposed) should be set at a level that reflects, protects, and preserves the historic character of the 900 dwelling village, which is already developed up to the Settlement Boundary, at a level that respects the capacity of the existing services and facilities.

Comment

Representation ID: 10682

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11180
Yes – see the response provided to question GB1. National Green Belt policy was fundamentally changed and relaxed in December 2024, necessitating a change in local Green Belt policy. Further, with such a substantial and unexpected increase in the Borough’s housing needs requirement, a more cohesive and realistic examination of the Borough’s Green Belt is necessary, particularly as it washes over the most sustainable areas of the Borough. In a Borough that is highly constrained with 42% of Green Belt, the Council will need to properly assess the current extent of Green Belt in order for the emerging Development Plan to be found sound. The release of land from the Green Belt where it is found to be Grey Belt and sustainably located will release development pressures from the less sustainably located areas, particularly the more isolated areas to the south of the Borough such as Farndon, where large housing allocations will leave residents remote from the bulk of necessary services and facilities, and which in the case of Farndon would overwhelm the character of the village and the existing limited services. There is no Green Belt around Farndon, it is either agricultural land or flood plain.

Comment

Representation ID: 10683

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11181
(d) – none of these, on their own and as reflected in the current Development Plan. Options A to C all represent a rather lax approach to a complex problem, with a failure to properly engage with the burden upon the Council to prepare a Development Plan consistent with current national planning policy, although Option B presents the most logical and lawful starting point. The Green Belt clearly cannot be retained in its current context or extent, given the relaxation in approach to inappropriate development introduced in the December 2024 NPPF (see also answers by Farndon Parish Council to questions SS9 and GB1). Significant areas of current Green Belt are highly likely to now fall within the NPPF/PPG definition of Grey Belt, which in itself militates against maintaining the `Green Belt in its current form and extent. That will result in increased levels of Green Belt release, in the inherently more sustainable areas of the Borough, and a consequential reduction in the levels of allocations required in the more remote and less sustainable areas of the Borough (i.e. the current suggestion of a total of 3000 dwellings across the lower tier settlements will inevitably reduce with greater levels of Green Belt release).   Similarly, in respect of options B and C, the current local plan was drafted in a different national planning policy context, and in a Borough where the current Green Belt comprises at least 42% of land, and where some of that land will now be considered to be suitable for development, particularly housing development, the current Local Plan level and distribution of development will no longer be defensible or sound, without amendment.   The current form and extent of Green Belt must be re-examined, land must and will be released from the Green Belt where it falls within the definition of Grey Belt, or at least identified as being Grey Belt, and the current Local Plan level and distribution of development needs to be reassessed in the context of that land release, resulting in increased levels of housing land being allocated in the more sustainable northern areas of the Borough, and the burden on the more remote southern areas being eased.

None of these

Comment

Representation ID: 10684

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11182
No – see answer on behalf of Farndon Parish Council to question SS11. Option A assumes that housing and other development is not appropriate in the Green Belt and that the Green Belt boundaries cannot be altered, and therefore housing land must be allocated elsewhere. That is an entirely false premise. The NPPF at ¶155 makes it clear that the development of homes, commercial and other development in the Green Belt is not inappropriate, provided the criteria at ¶155(a)-(d) are met. Inherent in that national policy is that land that is identified as being Grey Belt (¶155(a)), which is sustainably located (¶155(c)) and where there is a demonstrable need, which now flows from the current level of housing need (¶155(b)), can either be allocated for housing development or can be removed from the Green Belt. It follows that merely maintaining the current Green Belt spatial strategy would not be a sound approach. Option A is fundamentally unsound, in light of the December 2024 changes to the NPPF and subsequent changes to the PPG.

Comment

Representation ID: 10685

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11183
For the reasons set out in the answers provided by Farndon Parish Council to questions GB1, SS9, SS11 and SS14, the Council must undertake a comprehensive Green Belt review to identify land that will fall within the definition of Grey Belt, and which is appropriate either for allocation or release from the Green Belt. Option A would be an unsound approach.

Comment

Representation ID: 10686

Received: 28/08/2025

Respondent: Farndon Parish Council

I&O_11184
Please see the response on behalf of Farndon Parish Council to question SS11. It is agreed that the principles of the current approach (Option B) are not inappropriate, in that the largest number of allocations should be in the northern areas of the Borough, which are inherently more sustainable, and that the smaller settlements, such as Farndon should be at the lowest end of the allocation hierarchy. Any allocations at that lower end should be assessed in the context of the existing level of population, and the available services and facilities, and seek to protect and conserve the character, services and facilities, and highway safety of those settlements. Option B anticipates 3000 housing allocations over the settlements at the lower end of the settlement hierarchy, but that number will and should reduce once the Council properly assess the extent of Grey Belt land across the Borough. A failure to properly assess the extent of Grey Belt land will almost certainly result in housing developers succeeding on appeal for speculative development in Green Belt areas. There is a clear distinction to be drawn between the lower tier settlements which include Neston and Parkgate (population 14712); Frodsham (population 8908); Helsby (population 5274); Cuddington and Sandiway (population 5223); Tarporley (population 2634); Kelsall (population 2520); Tarvin (population 2307); Farndon (population 2229); Tattenhall (population 1860); and Malpas (population 1184). The division of the currently proposed 3000 dwellings cannot simply be split equally between those 10 or more settlements/villages given their entirely differing natures. A more strategic and cohesive approach must be adopted, taking into account the location, size, and nature of each settlement/village. Clearly an allocation of 500 dwellings to Farndon (17% of the currently proposed total distribution to the lesser settlements) would not be a sound or sustainable approach. The population of Farndon represents a maximum of approximately 5% of the total population of the settlements at the lower end of the hierarchy, and the village has a substantially lower level of services and facilities as compared with Neston and Parkgate, Frodsham, Helsby, and Tarporley, for example. Farndon is also located in the least sustainable area of the Borough, with the settlements in the northern area being significantly more sustainable. These clear and important differences should be reflected in any final allocations to these settlements/villages, in order for the plan to be found sound. In principle, Option B as a starting point, is likely to result in a more sound approach than options A and C, but a more cohesive and integrated process is required in light of recent national planning policy changes. An adequate and through assessment of the current Green Belt should result in further Green Belt release to provide for more than the currently anticipated 11,000 units, resulting in a lesser allocation requirement than 3000 units to the lower hierarchy settlements. Any allocation for Farndon should be at the very lowest level of the resultant net requirement, and significantly less than 500 units, which would be an entirely disproportionate and unsustainable increase in the level of housing in the village by over 55%.