Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13443

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13962
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13445

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13964
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13447

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13966
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13448

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13967
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13449

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13968
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13450

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13969
Harworth notes that while the Council suggests each of the three growth options could accommodate at least 29,000 dwellings - potentially meeting the minimum housing needs over a 15-year period according to the standard method - further evidence is needed to substantiate whether this is realistically achievable. Moreover, any of the growth options must also align with the Council’s commitment to delivering 149 hectares of employment land, as outlined in the Economic Needs Assessment. This figure is critical for ensuring that sufficient land is available to support job creation, economic development, and local businesses. However, the ability to meet both housing and employment land requirements within the chosen spatial strategy will depend on a more robust assessment of the land supply and infrastructure readiness across the Borough. At this stage, Harworth does not deem it appropriate or feasible to determine which of the proposed spatial strategy options is most suitable, as further evidence is required to evidence that CWAC claim that all three options can meet the identified need is realistically achievable. This includes detailed studies into the availability of land for development, infrastructure capacity, and the suitability of different areas to support the anticipated growth. Notwithstanding that, Harworth believes that any approach that does not involve a level of Green Belt release is unlikely to be appropriate. Such an approach is unlikely to adequately address local housing and employment needs within the Borough, and could result in an unsustainable spatial strategy. Ultimately Harworth urges the Council to ensure that whichever spatial strategy is chosen provides sufficient housing and employment sites to meet the needs housing and employment needs for the borough and that of Middlewich.

Comment

Representation ID: 13451

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13970
Harworth considers that the Council’s proposed ‘showstopper’ constraints are not considered to be appropriate or reasonable. Many of the identified ‘showstopper’ constraints are not fundamentally prohibitive to development and should not therefore be used as a means of restricting sites from consideration in the Local Plan process. Through the preparation of the emerging Local Plan, Harworth is of the view that it is entirely appropriate and feasible for the Council to reconsider existing local planning policy designations, such as Local Green Spaces, Key Settlement Gaps, Strategic Open Space and Areas of Special County Value, subject to appropriate assessments and evidence being produced, to enable land to be proposed for development. Furthermore, matters such as designated heritage assets, designated habitat sites, SSSI’s, irreplaceable habitats and flood risk are not explicitly prohibitive to new development occurring and can be appropriately mitigated, managed, or accommodated into new development as appropriate. Harworth believes that the Council should produce a Local Plan which can deliver against its housing and employment requirement. To do this it is important that a strategy is put in place which provides a sufficient range of allocated sites to provide enough outlets to enable delivery to be maintained at the required levels  throughout the Local Plan period.

Comment

Representation ID: 13453

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13972
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). Harworth’s view is that it is crucial that the Council ensures that the preparation of the emerging Local Plan, and associated planning policies and allocations are justified through robust up-to-date evidence.

Comment

Representation ID: 13457

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13976
As identified Harworth are of the view that in establishing a spatial strategy for the emerging Local Plan that CWAC should adopt an approach that focuses development around the most sustainable settlements in the Borough as well as around the most sustainable transport corridors to meet its development needs. In this response Harworth acknowledges the Council’s identification that a pragmatic approach should be taken to meet the future needs of Middlewich on land within CWAC. However, any future plan will need to go further than pragmatism; it will need to positively plan for and allocate land around Middlewich to meet the settlements development needs for the plan period. This location offers a unique opportunity in the context of CWAC authority area to deliver residential and employment development in sustainable locations with direct integration to edge of the existing settlement including the existing residential area and the employment and industrial locations of the Cheshire Fresh site, and the existing Mid-Point 18. By virtue of its relationship to Middlewich, development in this location also prioritises access to public transport, existing services, and infrastructure making it an entirely suitable residential growth opportunity. This location also maximises the only site within CWAC that benefits from a strategic relationship with the adjacent to the M6, via the A54 (Holmes Chapel Road and Junction 18). This location also benefits from immediate connectivity to the Government approach Middlewich Eastern Bypass (“MEB”) proposal which is situated to west and south within the Cheshire East authority area. The MEB proposal will deliver a new two-way single carriageway road, connecting a new roundabout off Pochin Way to a new roundabout junction with the A533 Booth Lane to the south. The bypass seeks to ease traffic pressure within the centre of Middlewich and increase safety and contribute to the delivery of housing and employment sites in Middlewich. Subject to Cheshire East’s acceptance of revised costs work on the bypass is anticipated to commence in Spring 2026. The unique location means that land adjacent to Middlewich is capable of accommodating sustainable residential and economic growth. Identification of this land as either a potential growth areas or allocation(s) would enable CWAC to meet its own housing and economic growth needs while supporting cross-boundary infrastructure investment and the wider regeneration objectives for Mid Cheshire. A proactive approach to development in this location will ensure sustainable, connected development that delivers maximum benefit to both Cheshire West and Cheshire East. The appropriateness of this location is emphasised when accounting for the advancement of a spatial strategy that seeks to focus development around the most sustainable settlements in the Borough as well as around sustainable transport corridors. Section 7 below (see attachment) provides Harworth’s further views on the role of Middlewich has to play in the emerging Local Plan, and meeting the development needs. 

Comment

Representation ID: 13458

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13977
The emerging Local Plan seeks to continue close working and collaboration with Cheshire East (‘CE’) in relation to the future development needs and infrastructure of Middlewich. This is considered of considerable importance where the updated evidence published to date, namely the EDNA, affirms important cross-boundary relationships with regards the movement of labour. In the context of planning for subarea functional economic market areas, for example, it recommends that it will ‘ be important for the Council to continue to liaise with neighbouring Authorities on strategic planning matters and to ensure that suitable employment opportunities are planned for in unison .’ (Cheshire West and Chester Economic Development Needs Assessment (March 2025) paragraph 2.58). Harworth welcomes the identification of Middlewich within the emerging Local Plan and this intent, where it is recognised that its economic relationships span both authorities. However, Harworth is of the view that the suggested policy approach, in its current form, is insufficient as it fails to recognise the significance and importance of the opportunity that exists in this location to proactively plan to meet the development needs of both CWAC and CE for Middlewich. The I&O Document recognises that there are different timelines for local plan preparation (with the CWAC Local Plan currently ahead of preparation of a new plan for CE) and seek to understand how the future needs of Middlewich be met. Nonetheless, the future policy should positively respond to the development needs of Middlewich and must be framed in the context of the cross-boundary relationship between CWAC and CE, and the ability of both authorities to plan positively for the town’s long-term growth in the emerging Local Plan. To do so, it is first necessary to understand the scale of development sought in Middlewich through the adopted Cheshire East Local Plan and that is likely to be sought for CE’s emerging Local Plan. CE’s adopted Local Plan Strategy (‘LPS’) (2010 – 2030) (July 2017) makes provision for a minimum of 380 ha of employment land for business, general industrial, and storage and distribution uses, and 36,000 homes to meet the full, objectively assessed needs for the borough (Policy PG 1 Overall Development Strategy). For Middlewich, a defined Key Service Centre (Policy PG 2 Settlement Hierarchy), the LPS identified that it is expected to accommodate the plans largest quantum of employment land within a Settlement (75ha), as well as 1,950 new homes over the plan period. The LPS recognises that the development identified for Middlewich is of a scale, location and nature that has the greatest potential to generate economic growth and support the vitality and viability of the centre. To deliver this quantum of development the LPS allocates four strategic sites in and around Middlewich: • LPS 42 – Glebe Farm – identified for the delivery of 525 homes. • LPS 43 – Brooks Lane – identified for a mixed-use development comprising of 200 homes, leisure and community facilities, and retail facilities. • LPS 44 – Midpoint 18 – Phased delivery of 70ha of employment land within an undeveloped area of 121ha. The remaining 50ha is identified will be released for employment purposes when required. • LPS 45 – Warmingham Lane – identified for around 235 dwellings. Within CE’s Site Allocations Development Plan Document (‘SADPD’) a further five sites are allocated for employment and residential developments (which the Settlement boundary). This includes: • MID 1- East and West of Croxton Lane (50 dwellings). • MID 2 – Centurion Way (75 dwellings). • EMP 1 – Ma6nitude, Middlewich (contained within LPS 44). • EMP 2.6 - New Farm, Middlewich (7.83 ha for B2/B8 uses) (it does however no count as contributing to the employment requirement as it is a redevelopment site and is not new employment land). • EMP 2.8 - Land at British Salt, Middlewich (7.05 ha for B2/B8 uses). CE Council’s latest Annual Monitoring Report (‘AMR’) 2023/24 confirms that as of 31st March 2024 a total of 21.30 ha of employment land has been taken up in Middlewich. This constitutes the largest amount of take-up of any of the key service centres and is second only to Crewe (36.06 ha) (Cheshire East Annual Monitoring Report 2023/24, Tables 13.6 and 13.7). Most of this take-up was concentrated in Midpoint 18, located to the east of the settlement and near the border with CWAC. It is further noted that this site alone has a further 111.27 ha of committed land. This affirms the proven scale of demand for employment land within Middlewich and assuming that the remaining commitment is built out in a reasonable time will significantly exceed the amount of land expected to be delivered in the plan period within the town (75 ha). With respect of housing provision, the AMR identifies a comparatively positive story with regards to delivery within Middlewich. It identifies that completions and commitments to 31st March 2024 comprise of 844 dwellings and 853 dwellings respectively, and totalling 1,697 dwellings. The total quantum of residential development completed and committed within the plan period to 31st March 2024 equates to 121 dwellings per annum (over the 14-yearperiod 2010 – 2014). LPS Table 8.4 forecast that residential dwellings will be delivered in Middlewich at an average of 98 dwellings over the plan period. This again affirms that the town is expected to deliver strongly against the Plan’s expected level of delivery (1,950 dwellings), whilst recognising that there are a number of years remaining until the end of the plan period. On the basis of CE’s adopted LPS development needs for Middlewich, evidence  demonstrates and indicates that the anticipated figures of Policy PG1 over the plan  period can be expected to be exceeded. Therefore, both CWAC and CEC should continue to plan, as a minimum, for the same scale of development identified as was set out in the CE adopted Local Plan for Middlewich. The level of growth experienced within the current plan period is reflective of the established role of Middlewich as a Key Service Centre and its strategic position on the M6  corridor. Maintaining this scale of development throughout the emerging Plan period is essential to meeting both the housing and employment needs of the town, supporting the delivery of the Government-approved Middlewich Eastern Bypass, and ensuring that Middlewich can continue to play its full role in supporting economic growth and regeneration across Mid Cheshire. Any reduction in the planned scale of development could risk undermining the town’s long-term sustainability, its infrastructure-led growth potential, and the opportunity to secure new and more skilled employment opportunities in this strategically important location. The ability of CE to accommodate the identified scale of growth for Middlewich is, however, severely constrained. The current spatial distribution of strategic allocations places most of the employment land to the east of the town, with expansion only possible to the south of Midpoint 18 or east into CWAC. The AMR indicates that within this site only circa 25 ha remains without permission (Cheshire East Annual Monitoring Report 2023/24, Table 13.7). To the north, there is very limited available land within CE’s administrative boundary capable of delivering new residential development. To the west, land within CE’s administrative boundary is limited and further constrained by insufficient infrastructure capacity to support development of a strategic scale. As a result, Middlewich has very limited opportunities to grow sustainably within Cheshire East’s boundary. This makes expansion into land immediately east of Middlewich, within CWAC, one of the only realistic options to deliver new  development - particularly for employment land - at the strategic scale required to meet the town’s anticipated level of growth over the new plan period given its role as a Key Service Centre and its strategic position on the M6 corridor. In this context, it is essential that the emerging Local Plan recognises the shared functional role of Middlewich and proactively identifies opportunities to accommodate growth within its boundary. The land immediately east of  Middlewich, lying within CWAC, represents a unique opportunity to define a strategic growth area and/or residential and employment allocations. The suitability of which is evidenced within Harworth’s standalone representation to the I&O Document which promotes land at Holmes Chapel Road, east of Middlewich as an allocation for employment and residential development in the new CWAC Local Plan. Development in this location would: • Help meet development needs for Middlewich, especially the significant requirement for employment land, in a location directly integrated with the Key Service Centres established employment and industrial area (Mid-Point 18 (CE Allocation LPS 44) and Cheshire Fresh and associated infrastructure. • Deliver development in a strategic location that maximises its locational advantages and proximity to the M6 corridor (as the only site in CWAC that benefits from such a location), the A54, and the Government-approved Middlewich Eastern Bypass, ensuring that growth is infrastructure-led and sustainable. • Contributes to CWAC’s own housing and economic growth objectives, making use of land adjacent to an identified Key Service Centre in CE that is not subject to Green Belt constraints. • Supports long-term economic transformation, enabling the delivery of new and more skilled jobs across a range of employment sectors, encouraging inward investment, and sustaining the vitality and vibrancy of Middlewich as a whole.