Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14439

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

I&O_14983
Arden Enterprises Group welcomes the commitment to plan for meeting the housing and other development needs of Cheshire West. However, for the plan to meet the legal compliance and the soundness tests set out in the NPPF, we have identified the need for Council to reconsider the following points before proceeding to Regulation 19: i. Options and reasonable alternatives for its spatial strategy; ii. Housing and rural investment policies related to rural areas. The Sustainability Appraisal examines the Strategic Objectives of the existing Local Plan and relates these to the spatial strategy options. These options are not meeting legal requirements as the three options are in fact just one, devoid of real alternatives: the three options all concern the expansion of the periphery of existing towns and rural service centres. Option A (Green Belt) and Option C (growth along transport corridors) appear to be variations of a single spatial strategy represented in Option B i.e. the expansion of towns and rural service centres only, which is not a positive anticipation or assessment of future needs and opportunities. Option A is a decision not to expand those centres in Green Belt areas. Option C is in effect an adjunct of site selection, it does not appear to be a strategic proposition or alternative. The table at Appendix 2 (see attachment) sets out the numbers proposed under the options by settlement. This demonstrates that there is only one decisive factor between the options, and that is whether the site is in the Green Belt or not. To meet legal requirements, the local plan must put forward some alternative objectives and spatial options which respond to the future needs and opportunities of the District, and not just those which were deemed appropriate in the previous Local Plan. In most cases, this results in significant development on the edge of existing towns which risks overextension, and in some cases coalescence of Northwich, Hartford, Leftwich, Moulton and Davenham as well as Winsford, and Middlewich. This is shown in Figure 1 below (Proposed growth as shown in the Spatial Options shows significant coalescence and over-extension of existing communities-see attachment) At paragraph 5.36 the Sustainability Appraisal states that there are no reasonable alternatives. This is not true as paragraph 5.36 the SA concedes that no alternatives have been assessed and one of the objectives of this Regulation-18 consultation exercise is to invite reasonable alternatives as stated in paragraph 2.24 of the SA. Moreover, it is difficult to formulate a strategy for this area without meaningful engagement with Cheshire East regarding the future of Middlewich. The current options do not advocate an option, but merely the absence of a Plan, which is not effective or planning positively. Therefore, on behalf of Arden Enterprises Group LLP, we put forward two positive sustainable alternative strategy for future growth which we contend would fulfil the requirement for positive planning and meet legal requirements in the SA. These two propositions are: i. Growth Hubs: Examining the distribution of settlements and economic activity to determine if new growth hubs could relieve pressure and endless expansion of existing urban communities, whilst improving transport and active travel between them and to greenspace with their rural hinterland; ii. Rural Clusters: Examining how all rural communities can benefit from new investment, not just those that are an existing service centre, to make these existing areas more sustainable and able to thrive.

Comment

Representation ID: 14443

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

I&O_14987
Spatial Alternative: Growth Hubs The Spatial Strategy should move beyond a settlement-by-settlement approach and identify how broader patterns of growth can improve transport, economic and environmental connections between existing settlements by directing growth to strategic nodes. At the same time, this would avoid over-extending existing settlements, risking coalescence or forcing existing communities to absorb yet more development. The Salt Towns will benefit from planned investment in the Middlewich bypass, the plans to reopen passenger services at Middlewich and the proposed bypass for Winsford. These investments underpin how the new Local Plan needs to get ahead of this investment and its transformative impact. There are also regeneration benefits to existing communities in taking a holistic approach to a locality, rather than a settlement-focussed approach. Paragraph 77 of the NPPF encourages a bolder approach looking at new settlements as well as extension to existing settlements and it is in this respect we put forward our alternative option for a Sustainable Growth Hub.  Specifically, our proposals for a Sustainable Growth Hub at land at Bostock Green would positively address growth around the Salt Towns, whilst improving the quality of life of these existing communities. Located equidistant between Middlewich, Winsford and Northwich/Davenham, Bostock Green has obvious and significant potential to support the emerging plan spatial strategy but was not considered as part of any the spatial options for growth in this area despite several years of active promotion by its legacy landowner. Identification of a mixed-use area for growth provides an opportunity to improve rural access to existing service centres, avoid over-extending existing settlements and improve sustainable connectivity between the three Salt Towns, without risk of coalescing, as Figure 2 (Figure 2 – Proposed Growth Hub around Bostock Green as another Option to consider. Reduction of edge of settlement and coalescence of communities in favour of a new sustainable, walkable community that improves connectivity between the three Salt Towns and provides access to greenspace for existing residents of these towns. - See attachment) Arden Enterprises Group is responsible for the management of most of the model village of Bostock Green, with over 30 buildings, rural businesses such as the Hayhurst Arms, Tilly Tots Nursery School and the working Smithy and is home to 200 residents and jobs. Arden Enterprises Group takes a long-term approach and works closely with its tenants and partners to ensure mutually beneficial and sustainable outcomes across its estate. In respect of Bostock Green, Arden Enterprises Group has worked hard to maintain the significance of the village whilst investing and supporting businesses and facilities to support village life making direct investment itself as well as securing over £2m from partners like Brunning & Price to create over 100 new jobs. The site was presented as an opportunity for CWAC and Arden Enterprises Group to pilot a new approach to using the largely rural hinterland to better link the historic Salt Towns of Northwich, Winsford and Middlewich. A copy of the response is provided at Appendix 1 (see attachment) As shown at Figure 3 (see attachment), Bostock Green could not just provide housing and employment, but also a vibrant, mixed-use walkable community as well as social infrastructure also serving the Salt Towns through new walking trails, community facilities and services, alongside environmental net gains. Meanwhile, this provides a compelling reasonable alternative to over-extending the periphery of existing communities such as Davenham, Northwich, Hartford, Winsford and Middlewich, which if realised, would effect coalescence between these various communities. Moreover, the existing strategy would only deliver “housing” and “employment” as the draft plans exclusively show. There is no mixed-use alternative that could release pressure on these communities and provide them with improved access to greenspace as well as each other’s employment and service centres. Figure 3 Bostock Green as a Sustainable Growth Hub between the surrounding communities of Winsford, Middlewich and Northwich - see attachment)  Land at Bostock Green is largely free of constraints and is not within the Green Belt. The site would therefore be a sustainable location for growth especially under spatial strategy option A (retain the Green Belt). It is our view that non-Green Belt locations near Winsford, particularly north and east of the town close to the rail station and town centre like Bostock Green, should be prioritised over development of Green Belt land around larger urban areas in other less sustainably located sites. The site would also support Sustainable Growth Hubs and Rural Clusters, delivering much needed investment in rural areas in line with our proposed additional spatial strategy options above. Bostock Green is in a sustainable location, within 6 minutes of the rail station and 4 minutes or 1.9 miles from the regionally significant and fast growing Winsford Industrial Estate. Appropriate growth on the rural hinterland can also open up opportunities for greater public access for both recreation and active travel between urban centres. For example, as part of the emerging development proposals, we are proposing circular walks along the River Dane and enhanced connectivity to nearby towns and potential links to Bostock Hall. The site has been assessed within the 2025 Land Availability Assessment as having ‘initial constraints’ with >10% of the site area within flood zone 3. However, the site submission was revised in February 2025 to exclude land to the east within the flood plain. We therefore request that the updated site submission is urgently re-assessed in the LAA. Logically, the assessment should conclude the slightly reduced site is fully ‘suitable’ for mixed-use development. Land at Bostock Green is largely free of constraints and is not within the Green Belt. The site would therefore be a sustainable location for growth especially under spatial strategy option A (retain the Green Belt). It is our view that non-Green Belt locations near Winsford, particularly north and east of the town close to the rail station and town centre like Bostock Green, should be prioritised over development of Green Belt land around larger urban areas in other less sustainably located sites. The site would also support Sustainable Growth Hubs and Rural Clusters, delivering much needed investment in rural areas in line with our proposed additional spatial strategy options above. Bostock Green is in a sustainable location, within 6 minutes of the rail station and 4 minutes or 1.9 miles from the regionally significant and fast growing Winsford Industrial Estate. Appropriate growth on the rural hinterland can also open up opportunities for greater public access for both recreation and active travel between urban centres. For example, as part of the emerging development proposals, we are proposing circular walks along the River Dane and enhanced connectivity to nearby towns and potential links to Bostock Hall. The site has been assessed within the 2025 Land Availability Assessment as having ‘initial constraints’ with >10% of the site area within flood zone 3. However, the site submission was revised in February 2025 to exclude land to the east within the flood plain. We therefore request that the updated site submission is urgently re-assessed in the LAA. Logically, the assessment should conclude the slightly reduced site is fully ‘suitable’ for mixed-use development. The principle of using new settlements in support of growth is firmly embedded in Paragraph 77 of the NPPF and represent a clear and reasonable alternative that the Council is invited to assess. Arden Enterprises Group are willing to assist the Council in this respect to ensure the Council arrives at a legally compliant as well as sound and positive spatial strategy.

Comment

Representation ID: 14448

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

I&O_14992
Having set out our positive alternative, we would like to highlight the risks and harms of the spatial strategy options proposed in the Reg-18 Consultation. In our assessment a material proportion of the areas selected are not sustainable and/or suitable locations for development. We are concerned that the Draft Plan has failed to even consider, let alone objectively assess, a number of potentially suitable sites through exclusion of land subject to constraints which are perceived as “showstoppers” to restrict future development. This includes Local Green Spaces, designated heritage assets, key settlement gaps and areas of flood risk even for just part of a site. We do not agree that sites subject to these constraints should be automatically excluded from further consideration, and in addition it seems the approach has not been applied consistently to all areas, for instance site refs NOR 8 and WIN 04 are located almost wholly within designated Conservation Areas. Bizarrely, the greenbelt and non-Greenbelt spatial options alike fails to consider opportunity areas promoted in the SHLAA outside the greenbelt (like Bostock Green) whilst including some very large sites with major constrains including Greenbelt.

Comment

Representation ID: 14514

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

NOR 08
I&O_15060
The site is identified as having capacity for c. 901 dwellings across a gross area of c. 43 hectares. Potential development of the land west of the railway line would rely on forming a new access of the A556. Both the west and east parcels have extensive coverage by mature trees which as well as being along established tree belts are also dispersed across the site. The east parcel contains a Local Wildlife Site and is mostly within a mineral safeguarding zone. Furthermore, the noise impact of the A556 is likely to sterilise the development potential allowing for likely noise buffers. The A-road also limits the ability to deliver sustainable transport connections back to the existing town. Having regard to the identified constraints, we consider the developable parts of the site are no greater than c. 29 hectares before other potential constraints are accounted for. However, even that smaller area for the above reasons - in particular the physical separation from the existing town caused by the A-road- is in our professional opinion not a sustainable option.

Comment

Representation ID: 14515

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

NOR 06
I&O_15061
Almost all of the proposed growth area is within the designated Davenham Conservation Area boundary and also Neighbourhood Plan policy protections. The main facet of the conservation area is focused on land surrounding the Grade II listed building of Davenham Hall. As noted in the Davenham and Moulton Neighbourhood Plan, the meadow and mature trees that surround the listed building form an important part of the significance of the conservation area and the land is currently protected via an established Article 4 direction which removes agricultural permitted development rights. Much of the land is also identified as medium to high distinctiveness ecology habitat which the Neighbourhood Plan seeks to protect. We are therefore of the opinion that this is not a sustainable location for strategic housing development or policy compliant and the growth area should be removed.

Comment

Representation ID: 14516

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

NOR 07
I&O_15062
The site is identified as having a gross area of c. 21 hectares with capacity to provide c. 443 dwellings. The site has flood and ecology constraints associated with River Weaver and its habitats (with areas around the river designated local wildlife sites), and there is an extensive tree belt along either side of the river in this location which limits land available for development. We also note that a significant portion of the site falls within the draft order limits of the Hynet Hydrogen Pipeline. Following Cadent’s Stage 2 consultation the route of the pipe has shifted east which is likely to impact the site’s developable area particularly accounting for likely development stand-off distances. The consultation is also now well advanced with an application expected to come forward in Autumn 2025, such that the route is unlikely to be amended at this late stage in the process. Once these constraints are accounted for, the developable area is likely to be reduced to c. 15 hectares, which applying the density assumptions in the draft plan reduces the housing estimate by almost 150 units, before other potential constraints are accounted for.

Comment

Representation ID: 14517

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

I&O_15063
Winsford has a number of non-Green Belt opportunities in sustainable locations which should be leveraged. However, land to the north and east of the town is generally better connected to existing services than the west. This is reinforced by the Sustainability Appraisal in the Winsford examined and adopted neighbourhood plan which found that potential growth areas to the west of the town score lower in terms of sustainability when compared to growth areas north and east which have better connections to the rail station and the town centre. As noted in the Neighbourhood Plan, while the land to the west of the town may be less constrained once the west ‘edges’ have been developed, in the long-term further edge development is more likely than the heart of the town being developed. This is not considered a  sustainable long-term strategy.

Comment

Representation ID: 14518

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

WIN 04
I&O_15064
This site is identified as having capacity for c. 1,672 dwellings across a gross area of c. 79 hectares. The site is located within the St Chad’s (Winsford) Conservation Area and contains a scheduled ancient monument. The east part of the site is also within a ‘highly visible area’ as defined in the Landscape Character Assessment. Overall, this site is subject to a number of significant constraints is not considered a suitable location for growth for anything like that level of housing. 

Comment

Representation ID: 14519

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

WIN 05
I&O_15065
Parts of the site are within Flood Zone 2 and 3 and as such are at high risk of flooding. While these sites are generally less constrained than WIN 04, for the above reasons growth to the west of the town is considered less sustainable in the long term with these sites being far more removed from the existing population and services.

Comment

Representation ID: 14520

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

I&O_15066
Although not expressly presented, comments are sought on allocations adjoining Middlewich. We disagree with the Council that it is not possible to cooperate effectively with Chesire East on the future of Middlewich. Indeed, this question reinforces the need for a positive growth option for the three Salt Towns that sees them as an interconnected entity with their own specific hinterland.