Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15301

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15860
Peel considers the most appropriate spatial strategy for CWAC will be a combination of all options, recognising that Green Belt release will very likely be required to meet the development needs of the borough and for development to be in the right locations to take advantage of existing and planned infrastructure, and be capable of accommodating development needs in a sustainable manner. All of the options represent very strict choices, which do not reflect a considered approach to plan-making. Option A does not recognise the evolved needs (and altered supply) or the wider policy context; as noted, we consider it very likely that Green Belt will need to be released in order to meet the needs of the borough in a sustainable manner. This will represent exceptional circumstances (as noted in response to question SS 9); Green Belt should not be regarded as an overriding constraint justifying unmet needs or unsustainable patterns of development. Option B warrants detailed consideration, as it was clearly justified in the preparation of the adopted Plan, but this needs to be appraised and developed in the context of evolved circumstances (needs, supply, policy drivers etc., for the respective uses the Plan needs to cater for). Option C has some merit in its focus on sustainable transport but it is a crude option on its own – this consideration of sustainability should be balanced against all others. A tailored strategy should be developed, based on a comprehensive evidence base. In respect of employment needs Peel considers this should comprise the following considerations: The availability of land (within the Plan period) within and surrounding key employment areas, which is (in priority order): ‒ Realistically deliverable (i.e. viable) brownfield / PDL land. ‒ non-Green Belt greenfield land. ‒ grey belt land. ‒ Other land within the Green Belt. The suitability of land to cater for a range of employment needs (traditional and non-traditional) needs. The proximity to existing and planned infrastructure for sustainable and clustering development opportunities.

Comment

Representation ID: 15302

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15861
No

Comment

Representation ID: 15303

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15862
See response to question SS 12.

Comment

Representation ID: 15304

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15863
No

Comment

Representation ID: 15305

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15864
See response to question SS 12.

Comment

Representation ID: 15306

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15865
No

Comment

Representation ID: 15307

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15866
See response to question SS 12.

Comment

Representation ID: 15308

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15867
Peel does not support excluding areas that are subject to constraints that would act as potential ‘showstoppers’ to restrict future development46. This approach is not consistent with national planning policy which directs that for plan-making47 strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses unless such matters provide a strong reason for restricting overall scale, type and distribution of developments. These constraints need to be considered in the round, against wider considerations such as needs and sustainable patterns of development, and whether potential impacts could be minimised and mitigated (such that a strong reason does not arise). The list provided also goes beyond that directed by footnote 7 of NPPF para 11 and is therefore inconsistent. 46 including: Local Green Spaces; designated habitats sites; Sites of Special Scientific Interest; irreplaceable habitats; designated heritage assets; key settlement gaps; Areas of Special County Value; strategic open space; areas of flood risk; and significant hazard zones. 47 NPPF para 11

Comment

Representation ID: 15309

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15868
Peel’s view is that it is crucial that the Council ensures that the preparation of the emerging Local Plan, and associated planning policies and allocations are justified through robust up-to-date evidence. The Council’s Climate Change Emergency Plan should be reviewed to ensure it is representative of the updated context and advancements CWAC has made, and continues to make, in their efforts towards industrial decarbonisation. It is important the spatial strategy is informed by key infrastructure provision to meet CWACs needs and ambitions – particularly regarding addressing climate change.

Comment

Representation ID: 15310

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15869
As identified above, Peel is of the view that in establishing a spatial strategy for the emerging Local Plan that CWAC should adopt an approach that focuses employment development around established locations, proven to be in demand, and established and emerging infrastructure. The spatial strategy needs to be reflective of the Council’s evidence base – for meeting employment needs this needs to be based on the ENA 2025 (but noting Peel’s stated concerns around the quantum of land being proposed as a requirement), and also on wider objectives such as addressing climate change, and driving economic clean growth for the borough. As demonstrated at Sections 2, 3 & 4 of this representation, there is an urgent and imperative need to decarbonise traditional heavy industries , to support economic growth, and sustain and grow employment opportunities for the borough. Some of these opportunities and needs are not necessarily quantifiable in the same way as traditional employment and housing needs are, but the needs and opportunities are clear none the less – in economic terms, climate change terms, and for sustainable growth and development (as demonstrated at Section 2). This is an opportunity to be grasped by CWAC, from which an enormity of benefits would arise. There is obvious opportunity to create synergy between traditional employment uses and non-traditional more specialist uses and there are evident benefits to be gained from clustering such developments together, focused around existing and planned industries and infrastructure. For reasons evidenced in this representation, and recognised in the Council’s own evidence base (ENA 2025), Ellesmere Port represents the industrial and decarbonisation heartland of the borough, as well as being one of the main settlements and centres of population (and hence labour), and hence is the location – clustered around ORIGIN and Protos – that is best placed to grasp these synergistic opportunities and together to accommodate both traditional and non-traditional employment needs.