Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15321

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15880
Peel supports the flexibility of consented waste capacity within this policy; it is essential the policy does not limit the development of the site to waste management use (including the land already consented for such). Such an approach would also be contrary to evidence, which demonstrates an oversupply of provision. A detailed response to this policy question can be found at Section 5.

Comment

Representation ID: 15322

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15881
The new Local Plan must reflect the latest national policy context with respect to Green Belt, as set out in the revised NPPF (December 2024) and updated Green Belt PPG (February 2025). This includes the introduction of grey belt land and the role this has to play in delivering growth to meet the needs of the borough. The policy should also have due regard to the emerging Green Belt review evidence (once completed). The Council should consult on its proposed methodology and approach for the Green Belt Assessment as soon as possible and prior to the work being undertaken. The countryside boundaries will need to be amended to reflect the spatial strategy, revised settlement boundaries and site allocations to meet needs as identified in the emerging Local Plan.

Comment

Representation ID: 15323

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15882
Peel considers that there should be separate policies for Green Belt and countryside to reflect the different purposes of each. The relevant policies should be reflective of national policy.

Comment

Representation ID: 15324

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15883
Peel supports this approach in general. However, it is important to recognise that for some materials (such as waste) the transportation by non-road modes is a very complex matter based on market demand and costs. Whilst the use of non-road modes of transport can be explored, there should be no requirement or expectation in policy that such modes must be utilised – such demand should be market led (not policy led which could constrain development). To have any such restriction could limit and constrain developments being delivered, and thereby hinder economic growth / needs being met.

Comment

Representation ID: 15325

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15884
Peel would not support this approach for the reasons noted above

Comment

Representation ID: 15326

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15885
Peel supports the policy’s broad goals of promoting sustainable economic growth; however, we believe the Council should adopt a more ambitious stance towards employment development (as demonstrated in Section 4). To support long-term prosperity, we advocate for an expanded provision of employment land (general B-class uses), and to support the clean growth agenda we advocate for non-traditional and emerging sectors such as energy generation and industrial decarbonisation etc. The provision of land for non-traditional employment and 'special' industrial uses is not easily quantifiable, but there is clearly a demonstrated need for land for such developments which is additional to general-employment land (see Section 3). Further land will be required beyond that identified in the ENA to meet the needs of the borough to accommodate proposals associated with non-traditional employment and 'special' industrial uses – likely, but not necessarily outside general B classes. The Council is also encouraged to consider qualitative factors, so as to ensure that its proposed employment sites are of the requisite size and in suitable locations. This is highlighted in the ENA which acknowledges that around 45% of development land has been for large scale industrial and distribution sites. The policy should incorporate a flexible, diverse approach to land use, accommodating both large-scale industrial requirements and small-scale business hubs; along with land for non-traditional employment and ‘special’ industrial uses. The socio-economic benefits of proposals on land promoted by Protos is provided at Appendix 4. This demonstrates the economic growth potential of the area provided such developments are supported through the Local Plan.

Comment

Representation ID: 15327

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15886
The strategic locations identified (e.g., Chester Business Park, Gadbrook Business Park, and Cheshire Oaks Business Park) are well-established and critical for the area’s economic development. However, it would be beneficial to consider additional locations, particularly those on the periphery of key growth areas, where such areas meet a different economic need – including clean growth, as is presented throughout this representation. This includes the importance of Ellesmere Port for the achievement of economic growth and clean growth – as evidenced in CWACs ENA 2025, and as demonstrated in Sections 2, 3 and 4 of this representation.

Comment

Representation ID: 15328

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15887
Peel does not support this policy approach, specifically with regards to the approach towards peat, which is inconsistent with national policy, and is based on inaccurate evidence base. The suggested policy approach to peat specifies that peat should be protected from disturbance or loss from new development. This approach is inconsistent with national policy, which directs that development resulting in the loss or deterioration of irreplaceable habitats should be refused48. “Peat” is not an irreplaceable habitat – only blanket bog is – a specific type of peat. Additionally, the evidence base on which this is based – the Peatlands of Cheshire West and Chester Assessment by Cheshire Wildlife Trust is inaccurate – as is detailed further at Section 4. This policy should be updated to be reflective of national policy.

Comment

Representation ID: 15329

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15888
Peel does not support the suggested policy approach towards energy. The approach presented is inconsistent with national policy and does not provide a positive framework for related development proposals. As is explained throughout this representation, and as is demonstrated in the Council’s own evidence base, CWAC is uniquely positioned to be the lead authority / area in the net zero/decarbonisation agenda. It is one of only a handful of areas to be supported by the Government to create a Net Zero Cluster (see Section 2). The policy approach needs to recognise this opportunity and provide a supportive policy position for the delivery of energy-related developments consistent with national policy. National policy is clear that: To help increase the use and supply of renewable and low carbon energy and heat, plans should: a) provide a positive strategy for energy from these sources, that maximises the potential for suitable development, and their future re-powering and life extension, while ensuring that adverse impacts are addressed appropriately (including cumulative landscape and visual impacts); b) consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development; and c) identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems and for co-locating potential heat customers and suppliers.49 Noting the opportunities available, CWAC should recognise and allocate land suitable areas for renewable and low carbon energy production and sources, including land at Protos Phases 1, 2 & 3. Additionally, the land at and surrounding Frodsham Windfarm is suitable, available and deliverable for renewable energy developments. This land should be recognised within the Local Plan. This emerging policy should be flexible to emerging technologies which are likely to come forward over the plan period – the policies should not be so restrictive to take grasp of new opportunities.

Comment

Representation ID: 15330

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15889
Peel does not support the approach to EN2. This policy is not reflective of national policy as explained in response to EN1 and should be updated to reflect the positive policy basis for the support of such developments. Additionally, the evidence base (Landscape Sensitivity Study and Guidance on Wind and Solar Photovoltaic Developments (2016)) is now dated and should be updated to reflect the changes since this was undertaken almost 10 years ago.