Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15331

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15890
Peel does not support the approach to EN3. 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.

Comment

Representation ID: 15332

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15891
Peel supports this policy approach in principle, however it is important to ensure that flexibility is built into the policy to allow for technological advancements in this sector.

Comment

Representation ID: 15333

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15892
Peel does not support this policy approach. The approach is not flexible to a range of technologies (current and future) that will help the decarbonisation ambitions of the Council and future energy production. This policy should acknowledge that this an emerging sector and flexibility will be required to ensure a range of developments using different technologies is possible. This policy needs to acknowledge the importance of HyNet and the opportunities presented by this project as is explained in this representation at Sections 2 & 3 of this representation.

Comment

Representation ID: 15334

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15893
Peel is supportive of the flexibility of this policy recognising the sufficient capacity of waste management provision in the authority (as demonstrated in the WNA 2023).

Comment

Representation ID: 15335

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15894
Peel is supportive of the flexibility of this proposed policy and approach to waste management

Comment

Representation ID: 15336

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15895
Peel is supportive of the flexibility of this policy recognising the sufficient capacity of waste management provision in the authority (as demonstrated in the WNA 2023) and the wider uses at Protos. The developments supported at Protos should align with the comments provided to EP3 ORIGIN - Protos, which asks that the policy approach which proposes to safeguard the site for development in connection with resource recovery and waste, reducing carbon emissions and sustainable energy generation is also inclusive of developments in connection with sustainable energy use (alongside generation), energy intensive industries and advancements in environmental and innovative technologies.

Comment

Representation ID: 15351

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15910
This representation builds on the response to the informal consultations which have been previously undertaken, including the Local Plan Conversation (September 2021) and the Local Plan Evidence Base Consultation (March 2024). Turley, on behalf of Peel, submitted representations to both consultations to promote Peel’s land interests. In addition to the sites previously promoted, Peel has now acquired the former CF Fertilisers site which provides a unique opportunity to expand Protos onto brownfield land for the redevelopment / regeneration opportunity for sustainable energy generation/use, industrial decarbonisation, energy intensive industry, and resource recovery developments. Further details on this site can be found at Sections 5 - 12. The land at and surrounding Protos, including the former CF Fertilisers site, are of strategic importance to create a cluster / co-location of developments with large scale flexible development plots associated with clean growth including sustainable energy generation/use, industrial decarbonisation, energy intensive industry, resource recovery, and broader employment uses. These development opportunities will help Cheshire West and Chester Council (“CWACC”) to achieve their net zero carbon dioxide emission goals and meet employment needs in a sustainable way. To take advantage of this strategically important location to meet the needs of the borough, a flexible, supportive policy position is required through the allocation of land for development, including release of land from the Green Belt. 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: 15352

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15911
Section 2. Strategic Context Climate Change and Net Zero Climate change is unarguably one of the biggest challenges facing the UK, and indeed the world, right now. Urgent action is needed to reduce greenhouse gas emissions and create a more sustainable future. The UK is committed to reduce the UK’s greenhouse gas emissions to ‘net-zero’ by 20501. To achieve this, the UK Government has set out its national objectives within its Clean Growth Strategy2 to grow the country’s national income while cutting greenhouse gas emissions. The use of infrastructure is recognised as being ‘critical’ in achieving the UK’s set target of being net-zero by 20503. The investment into alternative renewable and low carbon energy sources will enable the UK’s power system to be virtually carbon free and meet additional demand for energy within the future, as well as creating an economic boost within the market. The use of the Ten Point Plan for a Green Industrial Revolution4 sets out how the UK achieve can net zero by 2050. Key to this is the production and use of hydrogen5, the investment in carbon capture, utilisation and storage (CCUS), which is seen as a necessity not an option6 , and the provision of and support for renewable energy schemes, including onshore wind and solar7.

Comment

Representation ID: 15353

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15912
Section 2. Strategic Context Industrial Decarbonisation and ORIGIN The North West of England produces approximately thirty-eight mega-tonnes of carbon dioxide per annum. CWAC is currently one of the highest emitting boroughs of greenhouse gases in the UK. Carbon Dioxide per capita estimates for 2022 within the scope of influence of Local Authorities (including commercial, domestic, industry, transport and public sectors) were 7.3kt per capita in CWAC, compared to 4.3kt per capita for England, which is mostly from industry, buildings and road transport. The Ellesmere Port complex alone consumes c. 5% of the UK’s energy. In short CWAC has more to do, and more opportunity to make a difference, than most places across the country – the planning process has a key part to play in achieving this. CWAC has set an ambitious target to reach ‘net zero’ by 2045 or earlier. The Council aims to work with central Government and stakeholders to further economic progression through development of infrastructure which will provide environmental advantages as well as the provision of jobs and inward investment (“clean growth”). The Net Zero North West (NZNW) Cluster has been established to bring together industries, businesses and communities from across the North West to collectively drive down CO2 emissions and achieve net zero as a region by 2040. Additionally, to help achieve their own net zero emission targets by 2045, CWAC aims to establish the UK’s first low carbon industrial hub, which involves the creation of a clean growth industrial cluster around Ellesmere Port, known as “ORIGIN”. Protos (Phases 1 & 2) is a key project within the ORIGIN area - identified by CWAC amongst the major investments in the cluster. Both NZNW and ORIGIN are becoming more established, and their importance continues to grow. ORIGIN has the scale and capacity to become a global leader in energy technology, leading the UK in industrial decarbonisation, supporting the Green Industrial Revolution and delivering one of the world’s first Net Zero Carbon Industrial clusters. The Ellesmere Port Investment Prospectus8 sets the ambition for ORIGIN to be the place where solutions to climate change become reality. ORIGIN is a fundamental part of the growth of not only CWAC, but also the North West and the UK as a whole. ORIGIN is becoming known for the progress it is making in creating a decarbonised industrial cluster with security in clean energy and hydrogen to build sustainable income streams and create jobs. Key stakeholders in the area from both the private and public sector have set out a clear vision and realistic action plan to deliver the interventions needed to help unlock major private sector investment opportunities and these are outlined in a Development and Infrastructure Framework (DIIF) for the area. Invest Net Zero Cheshire, a partnership between the Cheshire and Warrington Local Enterprise Partnership (further information below) and the Cheshire Energy Hub has produced a portfolio of £1bn of viable projects that meet the aim of net zero carbon emissions, whilst satisfying the energy demands of the area. This blueprint offers long term, sustainable investment opportunities in net zero and clean growth9. The most significant project in the area is the HyNet Cluster (“HyNet”), an industry-led initiative to develop world leading Carbon Capture Usage and Storage (CCUS) and Hydrogen Power10. The HyNet development represents nationally critical infrastructure to achieve net zero. It is a low cost, highly deliverable, world-leading low carbon energy cluster aimed at removing carbon from all industrial emitters across the region. It will provide the blueprint for UK’s broader strategy to achieve net zero emissions while supporting economic growth and energy security. Vertex Hydrogen, a key part of Essar Energy Transition (EET) is planning investment of nearly £500 million building a new production plant in Ellesmere Port. This is likely to stimulate significant further growth locally, with opportunities for other businesses to locate in close proximity to the hydrogen plant to decarbonise their operations. This will be most important for heavy industry/waste management who create significant carbon emissions. Additionally, and very recently (5th August 2025), the Government announced additional projects associated with the HyNet Cluster which will support a total of 2,800 direct skilled jobs across Cheshire (and also Flintshire)11. This includes the Connah’s Quay Low Carbon project in North Wales, and the Ince Bioenergy with Carbon Capture and Storage at Protos. These projects are added to the existing projects identified for priority negotiations, including: Protos Energy Recovery Facility, Encyclis, Protos, Ellesmere Port (Cheshire); Hanson Padeswood Cement Works Carbon Capture Project, Heidelberg Materials, Padeswood (North Wales); and Hydrogen Production Plant 1 (HPP1), EET Hydrogen, Stanlow (Cheshire). There are also an additional five “standby” projects to provide contingency, including: Silver Birch, Climeworks UK Ltd , Stanlow (Cheshire); Essar Energy Transition Industrial Carbon Capture (EET ICC), EET Fuels, Stanlow (Cheshire); Hydrogen Production Plant 2 (HPP2), EET Hydrogen / Progressive Energy, Stanlow (Cheshire); Parc Adfer Energy from Waste Industrial Carbon Capture Project, Enfinium Group Ltd, Deeside (North Wales); and Runcorn Carbon Capture Project, Viridor, Runcorn (Cheshire). These projects are focussed within CWAC and (largely) in and around the Ellsemere Port and ORIGIN area, demonstrating the strategic importance and the focal point of this area to support clean growth and the movement towards net zero. As demonstrated with the projects above, Protos is already acting as a catalyst for industrial decarbonisation. Protos is placed within ORIGIN (known as the “Eastern Growth District”), recognising its importance in enabling HyNet and serving industrial users. Protos is uniquely positioned to HyNet, with the main infrastructure pipelines and other above ground components being located approximately 1km south of Protos and therefore provides the opportunity to be able to host projects which are able to utilise the HyNet infrastructure (subject to securing planning permission). The land surrounding Protos, which is promoted through these representations, also benefits from the same adjacency. This land sits to the east and south of ORIGIN’s Eastern Growth District. As is detailed further at Sections 5 - 12, this land has unique characteristics being large-scale, flat, and in close proximity to established and planned essential infrastructure (HyNet, gas and electricity connections, canal and rail, strategic highway) – as well as proximity to the existing Protos development and other significant industrial and employment uses in the area. This provides an opportunity to create synergies and utilise infrastructure provision to cluster developments associated with decarbonisation and clean growth.

Comment

Representation ID: 15354

Received: 29/08/2025

Respondent: Peel NRE Limited

Agent: Turley

I&O_15913
Section 2. Strategic Context Infrastructure, Economic Growth and Job Creation National The Government recently published the ‘UK’s Modern Industrial Strategy’12. This sets out a ten-year plan to deliver long term sustainable growth and investment in high growth sectors. The strategy focuses on tackling barriers to growth in the highest potential growth-driving “frontier” sectors and firms, creating the right conditions for increased investment, high-quality jobs and ensuring tangible impact in communities across the UK. Spatially, the strategy focusses on promoting city regions outside of London and the South-East, where economic performance has historically been focused. Tackling this comparative underperformance is identified as being key to economic growth and reducing inequality across the regions. The revised National Planning Policy Framework (NPPF) published in December 2024 establishes the Governments vision for sustained economic growth. Since its election in July 2024, the Government has been clear in its view that “sustained economic growth is the only route to improving the prosperity of our country and the living standards of working people”13. It has stated that its “central mission” is to “restore economic growth” and it also aims to deliver the infrastructure that the country needs14. The updated NPPF (December 2024) provides a policy framework to facilitate the Government’s commitment to aim for the highest sustained growth in the G7, with more people in good jobs, higher living standards and productivity growth across the country. It recognises that growth can only be achieved in partnership with businesses. It establishes the intention for the planning system to “help create the conditions in which businesses can invest, expand and adapt”. In this context it confirms that: “Significant weight should be placed on the need to support economic growth and productivity.”15 In order that sustainable development is pursued in a positive way, the NPPF retains the “presumption in favour of sustainable development”16, which requires local authorities – in the development of their Local Plans – to “meet the development needs of their area”17. NPPF requires planning policies to “set out a clear economic vision that positively and proactively encourages sustainable economic growth having regard to the national industrial strategy” (paragraph 86a) and “pay particular regard to facilitating development to meet the needs of a modern economy” (paragraph 86c). It notes that “the UK’s Modern Industrial Strategy identifies priority sectors for growth and support as: advanced manufacturing; clean energy industries [emphasis added]; creative industries; defence industries; digital and technology businesses; financial services; life sciences; and professional and business services” (Footnote 43). In this context it also requires planning policies to “be flexible enough accommodate needs not anticipated in the plan” (paragraph 86e). The updated NPPF expects the planning system to recognise and address the specific locational requirements of different sectors. It specifically identifies that this should include making provision for: a) clusters or networks of knowledge and data-driven, creative or high technology industries; and for new, expanded or upgraded facilities and infrastructure that are needed to support the growth of these industries (including data centres and grid connections); b) storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially where this is needed to support the supply chain, transport innovation and decarbonisation [emphasis added]; and c) the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience18. The Clean Energy Industries Sector Plan (updated on 5th August 2025)19 sets the ambition to make the UK a global leader in the clean energy industry by 2035, doubling investment levels across in the industries to over £30 billion per year and creating jobs across the country. This Plan builds on the UK’s Modern Industrial Strategy. This vision is supported by the following aspirations: • Be the most attractive place in Europe to invest in Clean Energy Industries. • Have grown exports in all frontier Clean Energy Industries. • Have created hundreds of thousands of good quality jobs across the country. • Have driven higher domestic commercialisation of evolving clean energy technologies. • Have secured more resilient and robust supply chains. This Plan confirms that across the UK in 2022 there were already approximately 450,000 jobs in low carbon and renewable energy jobs or in the wider supply chains, and suggests hundreds of thousands of jobs could be supported by 2030. Carbon capture will help to decarbonise heavy industry as the country accelerates to net zero, whilst protecting skilled, manufacturing jobs and creating new export opportunities for British business in new technologies. Carbon capture alone is expected to add around £5 billion per year to the UK economy by 2050. Regional Cheshire and Warrington are home to a strong, educated, and entrepreneurial labour market. The Cheshire and Warrington LEP covers Cheshire West, Cheshire East and Warrington (now known as Enterprise Cheshire and Warrington). The LEP’s ambition is to be the healthiest, most sustainable, inclusive, and fastest-growing place in the UK by 2045, set out in their Sustainable and Inclusive Economic Strategy21. This Strategy recognises the areas considerable sector strengths to unlock growth from decarbonisation and the transition to clean energy. This also means supporting other significant sectors, including manufacturing; business and finance; and logistics and distribution. The LEP’s Local Industrial Strategy (2019)22 identifies the Stanlow refinery in Ellesmere Port which has historically been at the heart of the traditional carbon economy, but also highlights the emerging strengths in hydrogen production and storage and nuclear engineering. The Cheshire and Warrington Sustainable and Inclusive Growth Commission was set up by the Subregional Leaders’ Board in November 2020, with the aim of building on progress to date to help realise Cheshire and Warrington’s ambition of becoming the most sustainable and inclusive subregion in the UK. One of their recommendations is to build the UK’s First Net Zero industrial cluster around the area’s large hydrogen and net zero projects – i.e. the HyNet Cluster. The current number employed in the ‘Low Carbon and Renewable Energy Economy’ (LCREE) in Cheshire and Warrington is estimated to be about 4,000. These numbers are set to grow. Ecuity has forecast a fourfold growth to 15,000 employed in the LCREE in Cheshire and Warrington by 203023. However, this growth could be more significant if the project portfolio developed by Net Zero North West is delivered (as described above). In July 2021, NZNW published an Economic Investment Prospectus designed to stimulate over £200 billion of investment in the region in eighteen key projects. The prospectus proposes to deliver a 38.5 MtCO₂ emissions reduction to meet the North West’s decarbonisation net zero goal by 2040 through £206.9 billion of investment, which, it says, will help support 660,000 jobs to be secured or created and grow the economy by £285 billion GVA. The growth of the Low Carbon and Renewable Energy Economy will be driven, in the first instance, by the reskilling of the existing workforce. For example, car manufacturers will transition from the assembly of cars with internal combustion engines to the assembly of cars with batteries. Industries will need to reshape how they operate to reduce carbon emissions and help the area to become net zero including what they produce, how they consume energy, and how they mitigate emissions. This shift will lead to changes to the nature of work in these industries. This will need new skills, and for the existing workforce to reskill. The decarbonisation industry will not only help the UK meet the zero carbon goals, but it will also help to protect and grow the high value local manufacturing jobs. High-value jobs within low carbon sectors directly aligns with the UK’s Industrial and Clean Growth Strategies.