Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15281

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15840
These representations promote Peel’s land interests as follows: Protos – comprising the consented Protos Phase 1 and 2 sites to establish a more flexible policy position than currently to respond to the up-to-date strategic context and the economic / clean growth opportunities. Protos Phase 3 – comprising land directly east of Protos – this land is promoted as an extension to Protos Phases 1 & 2 with a similar policy position to create a clean growth cluster / co-location of developments with large scale flexible development plots associated with energy generation, industrial decarbonisation, energy intensive industry, and resource recovery. The former CF Fertilisers site – this site represents a unique brownfield redevelopment / regeneration opportunity and in synergy with Protos is promoted for large scale flexible development associated with energy generation, industrial decarbonisation, energy intensive industry, resource recovery, and special employment uses. Land south of the former CF Fertilisers site – this land is promoted for release from the Green Belt for general employment use to help meet the need for employment land across the borough within the Plan period. Land west of Protos – this land should be removed from the Green Belt, as it serves no Green Belt purpose. Land comprising Frodsham Wind Farm – this land is promoted as a renewable energy zone. Land at Station Road - This land is promoted for the allocation of: Commercial, Business and Service uses (Use Class E), General Industry (Use Class B2) and/or Storage & Distribution (Use Class B8) uses. Land at North Road - This is promoted for the allocation of: Energy/Electricity Production & Generation (Use Class Sui Generis), Waste Treatment (Use Class Sui Generis), General Industrial (Use Class B2 / E(g)) and/or Storage & Distribution (Use Class B8) uses. Peel is a committed delivery partner in CWACC. It is successfully delivering Protos including the delivery of key energy generation and resource recovery facilities across land within Phase 1, the delivery of ecological management areas, and the delivery of essential infrastructure comprising electricity upgrades, highway improvements and improvements to the canal berth along the Manchester Ship Canal. Peel remains committed to bringing the land at and surrounding Protos forward for delivery to achieve shared objectives with the Council and create significant benefits for the borough (and wider sub-region). However, this can only be achieved through flexible and positive Local Plan policies and the allocation of land for development

Comment

Representation ID: 15282

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15841
The R18 LP confirms that CWAC Council 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. Peel looks forward to being given the opportunity to review and comment on these critical evidential documents. It is essential that the evidence base that informs the emerging Local Plan reflects the latest national policy as set out in the NPPF and Planning Practice Guidance (“PPG”). In particular this includes ensuring that the proposed Green Belt Study aligns with the updated Green Belt PPG published in February 20259, including consideration of grey belt opportunities. Further comments on the specific evidence base relevant to Peel’s land interests are provided in more detail at Chapter 4. This includes the Peatlands of Cheshire West and Chester, the Waste Needs Assessment, and the Cheshire West and Chester Economic Needs Assessment 2025.

Comment

Representation ID: 15283

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15842
The emerging Local Plan should have a clearly defined monitoring framework, which establishes key monitoring indicators for each relevant policy and defines how the objectives / targets established in the Local Plan are being met and, if not, why and what actions will be taken and when to address any issues. It should also confirm the associated data sources and means of reporting. It is important that employment delivery is effectively monitored so that if annual monitoring shows delays, action is taken to address this as soon as possible.

Comment

Representation ID: 15284

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15843
The I&Os Document confirms that CWAC Council intends to plan for a period of 15 years. Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. In order to ensure a robust approach to the emerging Local Plan, reflecting the likely timescales for preparation and accounting for a 15-year plan period post-adoption in line with the NPPF (paragraph 22), Peel considers that the Council should, as a minimum, be looking to prepare a new Local Plan that will look forward to at least 2045 to enable a 15-year plan period post-adoption. It is important to note in this regard that the adopted Local Plan applied a 20-year plan period. It may also be necessary for the Council to consider whether the scale of employment need, and the strategic sites identified to meet this need, require the emerging Local Plan to extend over a longer period.

Comment

Representation ID: 15285

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15844
In accordance with paragraph 13 of the NPPF, “neighbourhood plans should support the delivery of strategic policies contained in local plans or spatial development strategies; and should shape and direct development that is outside of these strategic policies”. Footnote 17 of the NPPF confirms that “neighbourhood plans must be in general conformity with the strategic policies contained in any development plan that covers their area”. Similarly, as set out at paragraph 30 of the NPPF “neighbourhood plans should not promote less development than set out in the strategic policies for the area, or undermine those strategic policies”. Furthermore, they must meet the ‘basic conditions’ set out in paragraph 8 of Schedule 4B to the Town and Country Planning Act 1990 (as amended) (as per paragraph 38 of the NPPF). Peel recognises the value of neighbourhood planning in providing communities with an opportunity to shape a vision for their area. However, it is essential that the emerging Local Plan seeks to meet all needs in CWAC by allocating sufficient land to accommodate these needs, and does not rely on any shortfall to be delivered by neighbourhood plans. Peel disagrees with the Council’s assertion at paragraph 1.27 of the R18 LP that much of the content of the existing neighbourhood plans across CWAC won’t be affected by the emerging Local Plan. Many of these neighbourhood plans make direct cross references to the policies of the adopted Local Plan (and previous iterations of the NPPF and PPG), which are, or will become, out-of-date. Therefore, Peel considers that once the emerging Local Plan has been adopted, it will be necessary for the respective neighbourhood forums to review and update their neighbourhood plans to ensure continued consistency with the strategic policies of the Local Plan. These neighbourhood plans should not attempt to overtly restrict development where it is needed to meet local needs and should be informed by an evidence base to support all proposed policies.

Comment

Representation ID: 15286

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15845
In accordance with paragraph 15 of the NPPF, Local Plans should provide a positive vision for the future of each area. Peel considers that the emerging Local Plan should establish an ambitious yet realistic vision for the future of CWAC, explaining how the Council wishes to see the area grow and evolve up to the end of the Plan period. 13.14 Central to the vision must be a commitment to meeting the current and future needs of the Borough, including meeting employment needs for traditional and non-traditional employment uses. The vision should reflect a strong commitment to fostering economic growth throughout CWAC. Paragraph 81 of the NPPF stresses the importance of supporting sustainable economic growth, which is essential for building a competitive and resilient local economy. The vision should clearly outline how the Local Plan will contribute to strengthening the local economy, creating employment opportunities, supporting local businesses, and attracting investment whilst also supporting clean growth having regard to the national industrial strategy (NPPF Paragraph 86a)

Comment

Representation ID: 15287

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15846
Peel agrees that the key principles included in the proposed vision (i.e. tackling climate change, promoting wellbeing, providing infrastructure and protecting character) are necessary and show commitment to addressing key challenges facing CWAC. Meeting the employment (and housing) needs of the borough should also be included as a principle/priority.

Comment

Representation ID: 15288

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15847
Peel supports the proposed approach to establishing specific visions for key places within the Borough, subject to this aligning with the defined Spatial Strategy and Settlement Hierarchy, and being informed by the evidence base. Whilst no definitive vision is proposed for Ellesmere Port yet, the emerging Local Plan should ensure the vision for Ellesmere Port captures the role of its surroundings (see ORIGIN), and the land hereby promoted, should be focussed on supporting and clustering developments that enable the achievement of meeting the borough’s clean growth agenda through the provision of low carbon energy generation and industrial decarbonisation infrastructure, and also support jobs within manufacturing and the Low Carbon and Renewable Energy Economy.

Comment

Representation ID: 15289

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15848
C. Neither of these.
Neither of these

Comment

Representation ID: 15290

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15849
Peel considers the objectives from Options A & B should be combined to ensure the objectives from the existing Local Plan (Option A) are representative of the progressed needs of the borough identified in Option B. See response to Question OB 6 for further information.