Local Plan Issues and Options (Regulation 18)
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Local Plan Issues and Options (Regulation 18)
Question IN 2
Representation ID: 16437
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15472
Whilst we expect the safeguarded land for HS2 to be lifted, if it remains in place as the Local Plan progresses, the monitoring framework will need to take account of the prospect of this being lifted once the Local Plan is adopted. Triggers for an immediate Local Plan review should be put in place to address the prospect of the safeguarding being lifted during the plan period (if not lifted prior to adoption).
To ensure the employment land needs are met, the monitoring framework should also include employment land completions split by type and use class, size of sites, floorspace etc. Triggers for a Local Plan review should also be put in place to address the prospect of employment land needs not being met on a rolling basis throughout the plan period.
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Local Plan Issues and Options (Regulation 18)
Question SS 3
Representation ID: 16438
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15473
The Council should be positively planning to deliver a minimum of 9.9ha of employment land each year, which is endorsed in the Economic Development Needs Assessment 2025.
The 9.9ha figure is based on past completions since 2011. However, completions in 2023 and 2024 have been much higher than the average since 2011. As such, there is justification for a higher employment land requirement based on recent completions, which should be considered as a reasonable alternative in the Sustainability Appraisal.
As also noted in the Economic Development Needs Assessment 2025, to deliver the requirement, there may be a need to switch from previously developed land to greater levels of greenfield provision.
The Stage One Land Availability Assessment 2025 identifies a significant amount of land with employment potential which is adjacent to the urban area and outside of Green Belt, including this site at Northwich (Table 4.1). There is no reason the minimum employment land requirements should not be met through an appropriate spatial strategy and employment allocations, and as mentioned a higher employment land requirement would be justified based on recent completions and is achievable.
[See table 4.1 representation]
The Economic Development Needs Assessment 2025 notes that Ellesmere Port will continue to see most of the future demand, followed by Northwich, and these should be the priority areas for provision. However, whilst the largest demand may be at Ellesmere Port there is also clear market demand for large unconstrained sites, of which there is only 6.17ha identified at Ellesmere Port.
After Ellesmere Port, Northwich has delivered the largest amount of employment floorspace in Cheshire West. As demonstrated in the market evidence section of the Vision Document for the site (Appendix 2 - Vision Document), there is clear market demand given the proximity of the site to the strategic road network and also a skilled employment base.
As such, priority should be given to directing significant amounts of employment floorspace towards Northwich, of which there are nine sites identified in the Stage One Land Availability Assessment 2025 which are outside the Green Belt, including this site.
Not all these sites may ultimately be found to be suitable following the second stage of the Land Availability Assessment but what is clear is no better performing site than the King Street site identified in the current evidence base.
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Local Plan Issues and Options (Regulation 18)
Question SS 4
Representation ID: 16439
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15474
The spatial strategy seeks to direct new development and allocate land towards previously developed sites within settlements first. It goes on to note that where there are not enough planning permissions and opportunities for redevelopment within urban areas and towns, the approach will be to develop on the edge of existing settlements in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option.
To deliver the employment requirement there may be a need to switch from previously developed land to greater levels of greenfield provision on non-Green Belt sites first. To be clear, Green Belt sites should not be given priority over non-Green Belt sites for employment development, such as this site. The Council's proposed spatial strategy allows for this occurrence and on this basis, we can support the spatial strategy.
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Local Plan Issues and Options (Regulation 18)
Question SS 5
Representation ID: 16440
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15475
Northwich is identified as a main town and is second on the settlement hierarchy after Chester, and we support its position within the settlement hierarchy.
Given Northwich's strategic location, market demand, proximity to the strategic road network and also a skilled employment base, it should be directed significant amounts of employment development as and when decisions are made on the distribution of development.
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Local Plan Issues and Options (Regulation 18)
Question SS 30
Representation ID: 16441
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15476
Map 5.6 in the Issues and Options Regulation 18 Consultation report shows the potential growth areas at Northwich, including three potential greenfield employment sites including:
- NOR03 Wincham East - 6ha;
- NOR04 Gadbrook South - 15ha; and,
- NOR05 Southwest Gadbrook Park - 32ha.
NOR03 encapsulates 1495 Wincham Estate (B), as identified in the Stage One Land Availability Assessment 2025. This is a relatively small site and is unlikely to be suitable for strategic industrial development. Moreover, the site is within the Green Belt and has not been identified as having employment potential in the Council's assessment.
NOR04 and NOR05 encapsulates 1402 Land at Gadbrook Park and 0878 Land south of A556, Rudheath as identified in the Stage One Land Availability Assessment 2025. These sites are identified in the current Local Plan for employment development. They have been allocated for four years and, as yet, planning applications have not come forward, although we are aware that applications may be pursued in the not-too-distant future, which we intend to monitor closely.
It is noted in the Issues and Options Regulation 18 Consultation report that the potential sites identified in the document does not indicate that the Council supports their development, and that additional technical work will be needed.
It will be necessary to undertake this additional work diligently and consider in detail all sites that have been identified as suitable for employment development in the Stage One Land Availability Assessment 2025, including this site, and not just those identified within the potential growth options.
Missing from the evidence base is a transparent methodology explaining why these three sites are identified in the Options Regulation 18 Consultation report. Moving forward we fully expect to see a clear site selection methodology that considers all sites, which will be scrutinised as part of future representations.
Indeed, there are other sites which have been identified within the Council's evidence base as having employment potential like the King Street site, which is outside of the Green Belt, and would comply with the approach within the NPPF and align with any of the spatial strategy options taken forward.
There is simply no rationale that we can find as to why Green Belt site NOR03, along with NOR04 and NOR05, are identified as potential sites on Map 5.6 and other sites have been omitted, including this site.
To reiterate, this site is considered in the Stage One Land Availability Assessment 2025, and it is identified as being potentially suitable for mixed employment development (B2, B8, Eg).
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Local Plan Issues and Options (Regulation 18)
Question EG 1
Representation ID: 16442
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15477
We support the suggestions that to meet future employment land a flexible supply of employment land allocations will need to be identified to cater for a range of types and size of business. These will cover use class B including B2 (General Industrial), B8 (storage or distribution) and Class E (Commercial Business and Service), primarily E(g) (Offices, Research and Development and industrial processes).
We note that the supply will be met through commitments, vacant/previously developed land in established employment areas, expansion land for specific employers or new allocations identified to meet strategic development needs.
The Economic Development Needs Assessment 2025 notes that large scale sites should make up a minimum of 40% of the future total (80ha) but that this could rise to 65% or more (125ha) reflecting trends towards large units for both inward investment and strategic distribution.
Allocating larger scale sites will provide the flexibility the plan needs, as these sites could potentially be delivered for smaller scale employment needs, if demand changes throughout the plan period. Allocating smaller sites simply cannot provide flexibility to deliver larger footplate schemes.
We therefore consider that the employment land provision established in the plan strategy should be closer to the 65% advocated in the Council's evidence for large scale industrial, warehousing or distribution use to reflect current market trends.
Additional locations for economic use may be identified on the edge of settlements, dependent on the chosen plan strategy which is supported. At Northwich, several sites are identified in the Stage One Land Availability Assessment 2025 which are on the edge of the settlement and not within the Green Belt, including this site. Indeed, not all these sites may ultimately be found to be suitable following the second stage of the Land Availability Assessment, but what is clear is that there is no better performing sites with employment potential that this site which are completely unfettered by Green Belt, Flood Zone 3 and local greenspace designations.
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Local Plan Issues and Options (Regulation 18)
Question NO 2
Representation ID: 16443
Received: 29/08/2025
Respondent: NPL Group (UK) Ltd
Agent: Pegasus Planning Group Ltd
I&O_15478
These representations are made in the context of NPL Group's land at King Street, Rudheath, Northwich. The Council's own evidence base identifies the land as suitable as available for employment development, with the most recent evidence reaffirming its employment potential.
Moving forward, the Council should identify the land at King Street as an employment allocation which can deliver 76.9ha of employment land. If the Council are not minded to allocate the entirety of the land then they should allocate the land that is completely unfettered by HS2 safeguarding which can deliver 38.6ha of employment land and acknowledge the remainder of the land as employment expansion.
Even with the delivery of HS2, the land at King Street is capable of being delivered and out performs potential employment sites identified in the Issues and Options Consultation report in terms of sustainability, market and long-term economic contribution.