Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13371

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13890
The I&Os Document confirms that CWAC intend to prepare additional evidence to support the emerging Local Plan, including a Housing Needs Assessment, Green Belt Study, Infrastructure Delivery Plan, Strategic Viability Assessment and Land Availability Assessment. Paragraph 32 of the NPPF requires that the preparation of all policies should be underpinned by relevant and up-to-date evidence which is adequate and proportionate to justifying policies. Harworth’s view is that it is crucial that the Council ensures that the preparation of the emerging Local Plan, and associated planning policy is justified through robust up-to-date evidence. Accordingly, Harworth is of the view that the following additional evidence should be produced or updated to substantiate and justified policy proposals of the emerging Local Plan: • Site Selection Paper (to understand the methodology used to assess sites for allocation in the emerging new Local Plan); • Places Background Paper (to understand the unique characteristics of a place, identify opportunities and challenges, and inform strategic decisions about land use and development); • A robust assessment of economic needs (including for a range of manufacturing and warehouse space); • Up-to date evidence of the availability of housing and employment land supply across the borough (to ensure that the plan is based on a robust understanding of local needs and can effectively address those needs through appropriate land use allocations and policies); • Brownfield Land Register (to identify previously developed land that is potentially suitable for housing development within CWAC); • Playing Pitch Strategy (to inform planning decisions and ensure adequate provision of sports facilities); • Public Open Space Assessment (to ensure adequate provision of green spaces); and, • Duty to Cooperate Statement (to demonstrate how strategic cross boundary matters have been dealt with through the preparation of a Local Plan).

Comment

Representation ID: 13405

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13924
Harworth believes that the emerging Local Plan should include a well-defined, coherent, and robust monitoring framework. Through this framework CWAC should establish clear monitoring indicators for relevant policies to ensure and measure where or not the respective objectives and targets are being achieved. In the event that any policy objectives or targets are not being met, it is paramount that the framework is used to specify the reasons, outline the corrective actions to be taken, and establish an appropriate timeframe for addressing targets or objective failures. The framework should also specify the data sources to be used, and the reporting methods employed, and frequency of reporting. Amongst other things, the framework should ensure the frequent monitoring of housing and employment delivery against the policy requirements of the emerging Local Plan. The effective monitoring of housing delivery is critical to identify delays to housing delivery across CWAC and to take action to address under delivery as soon as possible. The Council will need to monitor the delivery of housing and publish progress against a published Housing Trajectory. Housing monitoring should be undertaken on a site-by-site basis. Likewise, the monitoring of employment delivery is paramount to quickly address any delays in the development of employment land and the impacts on employment generation and associated benefits across CWAC. The Council should track progress against a published Employment Trajectory, with monitoring conducted on a site-by-site basis. This approach will ensure clear updates on the development of employment sites and the creation of new job opportunities, enabling timely action if any issues arise.

Comment

Representation ID: 13406

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13925
The I&Os Document confirms that CWAC Council intends to plan for a period of 15 years. Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. In order to ensure a robust approach to the emerging Local Plan, reflecting the likely timescales for preparation and accounting for a 15-year plan period post-adoption in line with the NPPF (paragraph 22), Harworth considers that the Council should, as a minimum, be looking to prepare a new Local Plan that will look forward to at least 2045 to enable a 15-year plan period post-adoption. It is important to note in this regard that the adopted Local Plan applied a 20-year plan period. It may also be necessary for the Council to consider whether the scale of housing and employment need, and the strategic sites identified to meet this need, require the emerging Local Plan to extend over a longer period.

Comment

Representation ID: 13407

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13926
In accordance with paragraph 15 of the NPPF, Local Plans should provide a positive vision for the future of each area. Harworth considers that the emerging Local Plan should establish an ambitious yet realistic vision for the future of CWAC, explaining how the Council wishes to see the area grow and evolve up to the end of the Plan period. A central aspect of this vision must be a clear commitment to meeting the current and future housing needs of CWAC. While the current draft vision highlights general sustainability, it does not adequately identify the need to address and delivery the diverse housing needs of the Borough. These needs should include a mix of market housing, family homes, affordable housing, homes for older people, and homes for first-time buyers. This will ensure that the area provides homes for all stages of life and supports the Borough’s long-term demographic and economic growth. Similarly, the vision should reflect a strong commitment to fostering economic growth throughout CWAC. Paragraph 81 of the NPPF stresses the importance of supporting sustainable economic growth, which is essential for building a competitive and resilient local economy. The vision should clearly outline how the Local Plan will contribute to strengthening the local economy, creating employment opportunities, supporting local businesses, and attracting investment.

Comment

Representation ID: 13408

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13927
Harworth recognises that the proposed vision for CWAC correctly highlights essential principles, such as addressing climate change, enhancing wellbeing, ensuring adequate infrastructure, and safeguarding the character of the area. However, we believe that the vision would be strengthened by more explicitly incorporating a clear focus on meeting the housing and employment needs of the Borough.

Comment

Representation ID: 13409

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13928
Yes, Harworth supports the proposed approach to establishing specific visions for key places within the Borough, provided that these visions align with the overall Spatial Strategy and Settlement Hierarchy. However, the vision as presented in VI 1 fails to identify Middlewich as one of the places with an individual vision. It is noted that the six other places (Chester, Ellesmere Port, Northwich, Winsford, Frodsham, and Neston and Parkgate) are specifically identified, and are subject to place based chapters with the I&Os document. Chapter 12 recognises that the immediate relationship of Middlewich with CWAC, emphasising the need for continued close working and collaboration with Cheshire East Council (CEC) in relation to its future development needs and infrastructure, and seeks to take a pragmatic approach to avoid delays enabling land in CWAC to meet the future needs of Middlewich. It also recognises the concentration of existing and committed developments and infrastructure to the east of Middlewich, including Cheshire Fresh, Midpoint 18, Brooks Lane train station, and the Middlewich Eastern Bypass (“MEB”). Harworth is of the view that the future plan will need to play an important and positive role in meeting the development needs of Middlewich, and as such, Middlewich should have an individual and detailed vision with the emerging Local Plan – beyond merely the identification of a co-operative role with Cheshire East. In accordance with Paragraph 24 of the NPPF this approach will ensure the effective strategic planning across the local planning authorities’ boundaries and will play a vital and increasing role in how sustainable growth is delivered in and around Middlewich, by addressing key spatial issues including meeting housing needs, delivering strategic infrastructure and building economic and climate resilience. Harworth’s considered views on the role of Middlewich are provided within Section 7 of this response.

Comment

Representation ID: 13412

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13931
Harworth considers that whilst the Council may take inspiration from the objectives of the current Local Plan and the Sustainability Appraisal. However, objectives need to be specific to the emerging Local Plan and based on responding positively to national planning policy to grapple with the housing crisis and fostering economic grow and reflective of up-to-date evidence to respond to the specific issues and challenges facing CWAC. This will ensure that the emerging Local Plan objectives support the realisation of the vision. Harworth would seek some further evidence around the approach to the Options once further developed.

Comment

Representation ID: 13414

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13933
Harworth considers that whilst the Council may take inspiration from the objectives of the current Local Plan and the Sustainability Appraisal. However, objectives need to be specific to the emerging Local Plan and based on responding positively to national planning policy to grapple with the housing crisis and fostering economic grow and reflective of up-to-date evidence to respond to the specific issues and challenges facing CWAC. This will ensure that the emerging Local Plan objectives support the realisation of the vision. Harworth would seek some further evidence around the approach to the Options once further developed.

Comment

Representation ID: 13415

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13934
Harworth agrees that these objectives are inconsistent with national planning policy and would need to be amended or removed if the Council opted to pursue Option A to establish the objectives for the emerging Local Plan. For example, SO3 and SO9 of the current Local Plan may not reflect the chosen spatial strategy for the emerging Local Plan and thus would be rendered redundant. Likewise, SO10 does not account for the potential need to amend the defined Green Belt boundaries to meet the authorities housing and employment requirements.

Comment

Representation ID: 13416

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13935
Harworth considers that whilst the Council may take inspiration from the objectives of the current Local Plan and the Sustainability Appraisal. However, objectives need to be specific to the emerging Local Plan and based on responding positively to national planning policy to grapple with the housing crisis and fostering economic grow and reflective of up-to-date evidence to respond to the specific issues and challenges facing CWAC. This will ensure that the emerging Local Plan objectives support the realisation of the vision. Harworth would seek some further evidence around the approach to the Options once further developed.