Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13465

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13984
Harworth’s response to Question MI 1 demonstrates that the future 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. Failing to do so risks 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. In affirming the importance of cross-boundary planning in this regard consideration has been given to current commuting patterns, drawing on the results of the 2021 Census. Figure 7.1 shows that where there is a strong level of containment of residents working within the town and a further 22% working elsewhere in Cheshire, it is notable that as many as 13% – or roughly one in eight – travelled to work in CWAC. CWAC also supplied labour to fill over a quarter (26%) of all jobs based at workplaces in Middlewich, proving that the town has an important economic relationship not only with parts of Cheshire East but also CWAC. (See Figure 7.1 in attachment) Therefore, the key issues that CWAC should address to ensure the future needs of Middlewich are properly considered through the emerging Local Plan include: • The scale of development sought that is likely to be sought for CE’s emerging Local Plan for Middlewich; • The ability of CE to accommodate the identified scale of growth for Middlewich given that available land within CE is inherently limited; and, • The role that land within CWAC has to play in securing the future prosperity of Middlewich by virtue of its proximity to the M6 corridor and the ability to maximise the opportunities for new and more skilled jobs across a range of employment types. To start informing consideration of the above, analysis has been undertaken of a series of key indicators to understand the importance of sustaining the growth of Middlewich. Looking first at the town’s capacity to accommodate new employment opportunities, recognising the take-up of land referenced above, Figure 7.2 highlights the strong performance achieved over the last ten years of available data when benchmarked against Cheshire East and Cheshire. This shows that the number of jobs has increased by almost half (49%) since 2011, comfortably outpacing the growth seen over the same period across both Cheshire East and Cheshire more widely (ONS (2024) Business Register and Employment Survey). (See Figure 7.2 in attachment) Further investigation suggests that over half of the jobs created in Middlewich since 2011 have been in the transport and storage sector, indicating that the town has a growing specialism in logistics which has enabled the creation of some 945 jobs (Ibid). (See Figure 7.3 in attachment) Following recent growth, the transport and storage sector is now responsible for more than a fifth of all jobs in Middlewich, far higher than the equivalent figures for both Cheshire East (4%) and Cheshire as a whole (Ibid)  (4%). The town can also be seen to have particular strengths in business administration and support services, as well as mining, quarrying and utilities. (See Figure 7.4 in attachment) New and existing businesses will likely need to recruit if the town is to build upon this increasingly promising foundation and maximise the opportunities brought by its specialisms. There has though tended to be only a limited pool of latent labour available, with an average of only around 165 people being out of work each month over the last three years (ONS (July 2025) Claimant count by sex and age). This equates to only 1.4% of the adult population (16+) estimated prior to this period, lower than the equivalent figures for Cheshire East (1.7%) and Cheshire (1.8%) in a sign that the local labour market is relatively tight (ONS (2024) Population estimates – small area (2021 based) by single year of age – England and Wales). (See Figure 7.5 in attachment) The accommodation of a future labour-force will be dependent in large part on the parallel provision of housing. As referenced above the town has seen strong historic delivery affirming a sustained and strong demand for housing . Figure 7.6, however, shows that the pace of development is markedly slowing , with an average of only 44 homes having been completed annually over the last five reported years (2019-24). This is only half as many as were completed in the five years prior. Such a pronounced slowing contrasts with the trend throughout Cheshire and particularly in Cheshire East, where average delivery rates have respectively increased by 1% and 29% (An average of 2,552 homes per annum have reportedly been completed throughout Cheshire East since 2019, some 29% more than in the five years prior (1,971dpa). Circa 4,057 homes have been completed annually throughout Cheshire since 2019, compared to 4,013 in the five years prior). (See Figure 7.6 in attachment) The importance of ensuring a pipeline of sites to enable a return to stronger rates of delivery is important where it appears that the recent slowdown has had an impact on the town’s demographic profile. Official estimates from the Office for National Statistics (ONS (2024) Population estimates – small area (2021 based) by single year of age – England and Wales) (ONS) – available up to 2022 – suggest that Middlewich saw relatively strong population growth as housing delivery rose in the years to 2016, surpassing that seen both in Cheshire East and across the whole of Cheshire (ONS (2025) Population estimates – local authority based by single year of age). This does though now appear to have stalled, with the population reported to have since grown by less than a fifth as much in direct contrast to the acceleration seen more widely. (See Figure 7.7 in attachment) This has meant that only the older population of Middlewich, aged 65 and above, has grown since 2011. The population has otherwise been relatively stable and indeed slightly shrunk. This profile presents a challenge for sustaining the town’s local  economy and sustainably supporting the generation of new employment  opportunities which, as identified above in the context of commitments on existing employment land, would be expected to be sustained. (See Figure 7.8 in attachment) Another adverse consequence of a slowdown in delivery appears to be a rising cost of housing . This recognises that the average cost of purchasing a home in Middlewich has risen by some 61% over the last reported decade (Land Registry (2025) Price paid data, allocated to Middlewich based on the postcodes that fall within the ward) (2014-24). Prices have thus grown over a third faster than in Cheshire East or Cheshire as a whole (both 46%). (See Figure 7.9 in attachment) A continuation of this trend could jeopardise the town’s proven ability to offer more affordable housing to those working in roles that tend to be the lowest paid, at least at the regional level for which this insight is available (ONS (2024) Earnings and hours worked, region by occupation by two-digit SOC: ASHE Table 3). While increasingly few such individuals appear able to afford the cost of living in Cheshire East, or indeed anywhere in Cheshire, Middlewich has so far managed to sustain a position whereby 28% of residents work in lower-paid occupations, both in 2011 and 2021 (The lowest paid roles in the North West – based on the Standard Occupational Classification (SOC) – are elementary occupations; sales and customer service occupations; and caring, leisure and other service occupations. The highest paid roles are managers, directors, and senior officials; professional occupations; and associate professional and technical occupations). (See Figure 7.10 in attachment) The initial analysis presented above provides a compelling picture of the key issues facing Middlewich to which the Plan must respond and plan positively.

Comment

Representation ID: 13468

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13987
Even though CE and CWAC plans are on different timelines, it is still feasible for CWAC to proactively and positively plan to meet the future development needs of Middlewich by safeguarding and allocating land east of the settlement. As highlighted in response to MI 1, the policy should align with the functional crossboundary connectivity of land within CWAC with Middlewich and recognise that the housing, employment, and infrastructure needs cannot be planned for in isolation. MI 1 also demonstrates that the development needs of Middlewich is unlikely to be able to be met on land within the CE. Therefore, land within CWAC has a role to play in accommodating Middlewich’s needs irrespective of the  independent Local Plan timescales and the emerging Local Plan must explicitly acknowledge and plan for the role it has to play. In accordance with Paragraph 24 of the NPPF effective strategic planning across Local Planning Authority (LPA) boundaries has a vital and increasing role in how sustainable growth is delivered. Through the duty to cooperate LPAs are able to address key spatial issues including meeting housing needs, delivering strategic infrastructure, and building economic resilience on strategic matters that cross administrative boundaries – such as is the case with meeting the development needs of Middlewich. Despite being on different trajectories for the preparation of their respective  emerging Local Plans both CWAC and CE, the NPPF (NPPF, Paragraph 25) establishes a need for the LPAs to collaborate to identify the relevant strategic matters which they need to address in their plans. The establishment of an effective cross boundary approach will be an integral part of the production of a positively prepared and justified policy approach to meeting the development needs of Middlewich on land within CWAC that cannot be met wholly within the CE plan area in accordance with NPPF Paragraph 11b. On this particular matter CWAC and CE should make sure that their plan policies for Middlewich align as closely as possible given the strategic relationship that exists. The NPPF is also clear (NPPF, Paragraph 28) that in order to demonstrate effective and on-going joint working, CWAC and CE should prepare and maintain a statement of common ground (‘SoCG’) documenting how the cross-boundary matters affecting Middlewich are being addressed. As plan-making advances the SoCG should be made available. This approach would ensure that cross-boundary needs of Middlewich can be met in full, and that the strategic opportunity at Middlewich to plan for long-term growth in the emerging CWAC Local Plan is not lost due to misaligned plan development.

Comment

Representation ID: 13469

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13988
In the event that land within CWAC is not allocated to meet the identified needs of Middlewich, then land could be safeguarded to provide flexibility to meet Middlewich’s identified and emerging development needs. Albeit, as has been evidenced through responses to MI, MI 2, and MI 3 it is highly unlikely that the anticipated scale of development needs of Middlewich can be accommodated entirely within CE’s boundary, particularly in relation to employment land. Therefore, land should be allocated for development during the plan period, and not safeguarded to meet longer-term development needs stretching well beyond the plan period. The allocation of land within CWAC would demonstrate a proactive and committed approach to addressing the likely unmet development needs of Middlewich within CE’s emerging Local Plan. It would also secure wider benefits for CWAC in terms of housing delivery, employment growth, and infrastructure investment.

Comment

Representation ID: 13470

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13989
Harworth has submitted a standalone representation to the Regulation 18 Consultation which promotes land at Holmes Chapel Road, east of Middlewich as an allocation for employment and residential development in the new CWAC Local Plan. For the reasons set out in the standalone representation, and as detailed in response to Question SS22, MI 1 there is a compelling case for CWAC to identify this broad location as a potential growth option, or allocated land for both residential and employment development.

Comment

Representation ID: 13471

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13990
The new Local Plan must reflect the latest national policy context with respect to Green Belt, as set out in the revised NPPF (December 2024) and updated Green Belt PPG (February 2025). This includes the introduction of grey belt land and the role this has to play in delivering housing (and employment) growth. The policy should also have due regard to the emerging Green Belt review evidence (once completed). The Council should consult on its proposed methodology and approach for the Green Belt Assessment as soon as possible and prior to the work being undertaken. The countryside boundaries will need to be amended to reflect the spatial strategy, revised settlement boundaries and site allocations to meet housing (and employment) needs as identified in the emerging Local Plan.

Comment

Representation ID: 13472

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13991
Paragraph 35 of the NPPF makes clear that Local Plans should set out the contributions expected from development and that such policies should not undermine the deliverability of the Local Plan. To ensure it is deliverable, the emerging Local Plan should be supported by a Viability Appraisal which demonstrates that the infrastructure needed to support the amount of new development proposed is viable. It will also be important to ensure that any increase in viability pressures do not place too high a burden on developer contributions which may serve to undermine the deliverability of the emerging Local Plan policies and the associated Infrastructure Development Plan (IDP) (once produced). Development can only be required to mitigate its own impact and cannot be required to address existing deficiencies in infrastructure or services. It is therefore essential for the IDP to clearly show the existing and known deficiencies in current infrastructure provision, before reaching any conclusion on the cumulative effects of new development, and any contribution that is needed from new development to mitigate any additional individual and/or cumulative impacts.

Comment

Representation ID: 13473

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13992
No. All development should contribute to infrastructure provision required to enable its delivery, in a proportionate way (subject to viability). Major development should be defined in accordance with the definition established in the NPPF (Glossary) to ensure consistency with other policy requirements: “For  housing, development where 10 or more homes will be provided, or the site has an area  of 0.5 hectares or more. For non-residential development it means additional floorspace  of 1,000m2 or more, or a site of 1 hectare or more, or as otherwise provided in the  Town and Country Planning (Development Management Procedure) (England) Order  2015”.

Comment

Representation ID: 13474

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13993
No. The funding of infrastructure requirements should be determined on a case-by-case basis, informed by the Local Plan IDP, reflecting the scale of development which would benefit from that investment. Where infrastructure is required to support multiple sites, possibly delivered in phases, with different developers/applicants, this should be shared by all parties. Similarly, infrastructure delivered by development may also have wider benefits associated with Council / others strategic priorities, which could benefit from funding streams available to the Council / others but not the developer / applicant.

Comment

Representation ID: 13475

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13994
Harworth supports the policy’s broad goals of promoting sustainable economic growth; however, we believe the Council should adopt a more ambitious stance towards employment development. To support long-term prosperity, we advocate for an expanded provision of employment land, particularly for emerging sectors like digital, technology, and knowledge-based industries as well as B2 (General Industrial) and B8 (Storage and Distribution) uses support economic growth and employment opportunities. The policy should incorporate a flexible, diverse approach to land use, accommodating both large-scale industrial requirements and small-scale business hubs. We encourage a review of current allocations to ensure an adequate supply of employment space and the identification of a sufficient supply of employment land to enable the borough to stay competitive, attract inward investment, and support local business growth.

Comment

Representation ID: 13476

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13995
The strategic locations identified (e.g., Chester Business Park, Gadbrook Business Park, and Cheshire Oaks Business Park) are well-established and critical for the area’s economic development. However, it may be beneficial to consider additional locations, particularly those on the periphery of key growth areas, where demand for larger-scale industrial and logistical operations are already in operation and where the intensification of use is likely to increase for example, on land within the CWAC authority area that abuts the establish employment location of Midpoint 18 in Middlewich.