Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15477

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16036
Liberty Properties are supportive of the retention of objective SO1, which enables Key Service Centres to continue to develop, ancillary to the role of Chester as a sub-regional city and the Tier 2 settlement such as Northwich and Winsford and therefore, be suitable places for ongoing development. As part of a third tier, in terms of the spatial strategy to accommodate future development, Key Service Centres such as Cuddington & Sandiway provide a key focus across the Borough. It is the key service centres, such as Cuddington & Sandiway, that offer opportunity for expansion of an appropriate scale. Maintaining the character of the settlements whilst increasing population to support local schools and services. Such settlements are sustainably-located to benefit from the services and facilities of the wider Tier 2 settlements, such as Northwich itself, whilst being able to develop independently. Particular focus should be placed on those settlements with a train station, offering strong sustainability credentials, such as Cuddington & Sandiway Liberty Properties are supportive of the retention of objective SO9 which focuses development within and on the edge of main urban areas and key service centres. This is in accordance with all suggested spatial strategies which focus the largest areas of development on key service centres. Objective SO10 aims to protect the Green Belt. Whilst Liberty Properties are not necessarily against the suggested objective, there are two key points to consider: New national policy regarding Grey Belt opportunities for development within the Green Belt. Given this, and in consideration against the Council’s current housing position aligned with the new NPPF policy, it is submitted that the Council must support those sites that merit consideration as a Grey Belt opportunity, subject to infrastructure improvements in the locality, open space / recreation / BNG improvements, and affordable housing provision 15% above standard LPA policy (will be 45%). Liberty Properties’ land at Cuddington & Sandiway offers such an opportunity. Release of Green Belt to accommodate necessary allocation for development, e.g. housing, is not prohibited by national policy. Through reasoned strategic justification, boundaries can be amended through the Local Plan review process. If such an approach is pursued by the Council, Liberty’s land at Cuddington & Sandiway provides such an opportunity, without compromising the sustainability principles of the Plan.

Comment

Representation ID: 15522

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16081
The Sustainability appraisal objectives are less place specific. It is not clear the impact of these on policy as a whole. Applying the Local Plan objectives (Option A - take forward the current Local Plan objectives) provide a more specific direction for local planning policy. Notwithstanding the above, there are a number of principles in Option B that are fully supported and should be clearly included in the overall objectives of the Local Plan, most notably those supporting further development in settlements with a train station, such as Cuddington & Sandiway, e.g. : Make the best use of existing transport infrastructure and ensure everyone has access to high quality and affordable public transport, cycling and walking infrastructure

Comment

Representation ID: 15527

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16086
Liberty Properties do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand across the Borough, most notably for the key service centres, such as Cuddington & Sandiway. Liberty Properties do not believe the Council should consider a stepped housing requirement, planning for a lower level of delivery earlier in the plan period. Reference is made by the Council to a quantum of undeveloped planning permissions and undeveloped Local Plan allocations, the basis for which they would justify a stepped approach presumably. The counter argument is to ask why permissions haven’t been implemented and why allocations have not been progressed through Planning. Constraints are clearly precluding these development opportunities, the majority of which may be insurmountable and so the quantum may be deemed available but simply not deliverable.

Comment

Representation ID: 15532

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16091
Liberty Properties do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand across the Borough, most notably for the key service centres, such as Cuddington & Sandiway. Liberty Properties do not believe the Council should consider a stepped housing requirement, planning for a lower level of delivery earlier in the plan period. Reference is made by the Council to a quantum of undeveloped planning permissions and undeveloped Local Plan allocations, the basis for which they would justify a stepped approach presumably. The counter argument is to ask why permissions haven’t been implemented and why allocations have not been progressed through Planning. Constraints are clearly precluding these development opportunities, the majority of which may be insurmountable and so the quantum may be deemed available but simply not deliverable.

Comment

Representation ID: 15535

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16094
Liberty Properties support these spatial strategy principles. This ensures that future residential development still follows the hierarchical position as per the adopted Local Plan, with strategic support for key service centres, e.g. Cuddington & Sandiway. Grey Belt opportunities can be accommodated, together with small scale urban extensions on open countryside or Green Belt release, with appropriate levels in the key service centres, e.g. Cuddington & Sandiway.

Comment

Representation ID: 15536

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16095
Liberty Properties express support for the settlement hierarchy, as per the existing Local Plan. Whilst, suggested Policy SS 4 includes reference to the key service centres, as listed in the adopted Local Plan (Part One), it is not specific in its support for future development levels in them. As per the suggestion for a individual place-based policy for each of the top tier settlements, the same should apply to the key service centres, setting a clear strategy for what development will take place in each settlement. As an example, Cuddington & Sandiway in particular offers good opportunity for a place-based policy, with particular focus on those that offer sustainability infrastructure such as a train station. Promoting growth in the ‘supplementary’ settlements (key service centres), ensures the ‘core’ settlement does not lose their identity through too large a quantum of growth. Increasing population to support local schools and services and maintaining the character of the wider settlements, that are sustainably-located, but able to develop independently, should be supported.

Comment

Representation ID: 15538

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16097
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably the first and second tiers of the settlement hierarchy, so including Northwich, but also the key service centres well related to and benefitting from shared service and facilities to such areas, e.g. Cuddington & Sandiway. Therefore, Liberty Properties are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Liberty Properties would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. However, unlike the previous Study, which only assessed Green Belt around the settlement boundary of Chester, any new Study is now required to include assessment of Green Belt around all Tier 1 & Tier 2 settlements and the key service centres (where Green Belt id applicable) – Cuddington & Sandiway specifically included. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt. Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Liberty Properties would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. This can include Chester to a certain degree, but priority should be given to the second tier settlements and the key service centres where Green Belt is applicable, such as Cuddington & Sandiway.

Comment

Representation ID: 15551

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16110
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably the first and second tiers of the settlement hierarchy, so including Northwich, but also the key service centres well related to and benefitting from shared service and facilities to such areas, e.g. Cuddington & Sandiway. Therefore, Liberty Properties are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Liberty Properties would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. However, unlike the previous Study, which only assessed Green Belt around the settlement boundary of Chester, any new Study is now required to include assessment of Green Belt around all Tier 1 & Tier 2 settlements and the key service centres (where Green Belt id applicable) – Cuddington & Sandiway specifically included. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt. Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Liberty Properties would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. This can include Chester to a certain degree, but priority should be given to the second tier settlements and the key service centres where Green Belt is applicable, such as Cuddington & Sandiway.

Comment

Representation ID: 15552

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16111
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably the first and second tiers of the settlement hierarchy, so including Northwich, but also the key service centres well related to and benefitting from shared service and facilities to such areas, e.g. Cuddington & Sandiway. Therefore, Liberty Properties are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Liberty Properties would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. However, unlike the previous Study, which only assessed Green Belt around the settlement boundary of Chester, any new Study is now required to include assessment of Green Belt around all Tier 1 & Tier 2 settlements and the key service centres (where Green Belt id applicable) – Cuddington & Sandiway specifically included. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt. Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Liberty Properties would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. This can include Chester to a certain degree, but priority should be given to the second tier settlements and the key service centres where Green Belt is applicable, such as Cuddington & Sandiway.

Comment

Representation ID: 15553

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16112
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably the first and second tiers of the settlement hierarchy, so including Northwich, but also the key service centres well related to and benefitting from shared service and facilities to such areas, e.g. Cuddington & Sandiway. Therefore, Liberty Properties are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Liberty Properties would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. However, unlike the previous Study, which only assessed Green Belt around the settlement boundary of Chester, any new Study is now required to include assessment of Green Belt around all Tier 1 & Tier 2 settlements and the key service centres (where Green Belt id applicable) – Cuddington & Sandiway specifically included. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt. Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Liberty Properties would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. This can include Chester to a certain degree, but priority should be given to the second tier settlements and the key service centres where Green Belt is applicable, such as Cuddington & Sandiway.