Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11786

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12284
MSCC is generally supportive of CWaCC’s existing development plan and acknowledges the work that has gone into producing the latest documents for consultation. MSCC provided separate comments relating to the evidence base in March 2024, including the Employment Land Survey, Places Background Paper, and Land Availability Assessment and Call for Site. This consultation response builds upon previous comments and therefore should be read alongside the previously submitted representations. The previous consultation response was generally supportive and sought to ensure the strategic economic importance for MSCCs assets was recognised within the new Local Plan. In summary, previous comments suggested that for the Local Plan to align with national policy requirements, it should: • Safeguard existing and potential wharves and canal-side land for freight and port-related activity. • Resist proposals for non-port-related or incompatible development which could prejudice current or future operational capacity of the Canal, being mindful of the agents of change principle. • Support investment in canal-related infrastructure to enable greater use of waterborne freight and enhance multi-modal connectivity. • Promote modal shift and decarbonisation by recognising the Canal’s role in reducing HGV movements and cutting carbon emissions. • Embed the Canal within strategic growth and employment policies, ensuring its contribution to the borough’s economy and inward investment offer is fully recognised. • Work proactively with the Manchester Ship Canal Company and wider stakeholders to maximise the economic, environmental and sustainability benefits of the Canal. The purpose of these representations is to ensure the ongoing operational activities and future ambitions of MSCC’s interests are safeguarded as part of any future development plan preparation. On this basis, and due to the significant port interests within the Borough, it was also recommended that CWaCC should include reference to the National Policy Statement for Ports (2012) as a material consideration when undertaking the Local Plan review, in addition to the government guidance already referenced in the consultation documents. Neither the Local Plan Issues and Options (Regulation 18) document nor the Sustainability Appraisal reference the National Policy Statement for Ports.

Comment

Representation ID: 11787

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12285
While the SA includes broad sustainability themes such as infrastructure and economic growth, there is currently no clear reference to the Manchester Ship Canal as a strategic freight corridor within the appraisal criteria. It is therefore recommended that the document includes a specific SA sub-objective such as: “Support for safeguarding and enhancing strategic freight water corridors (specifically the Manchester Ship Canal) to provide a resilient, low-carbon freight network and economic infrastructure.” This addition would ensure the Canal’s multifunctional value is systematically assessed across all options and policies. In the appraisal of Spatial Strategy Options A–C, it is suggested that the Council explicitly evaluates how each spatial approach supports the Canal’s modal shift potential and contributes to sustainable freight movement. Option C (focused on sustainable transport corridors) should be appraised positively in this regard. It is also suggested that policy approaches—particularly those related to transport, employment allocations, and canal-side development—be appraised for their alignment with safeguarding canal operations and promoting waterborne freight. This would reinforce the strategic status of the Manchester Ship Canal across multiple Local Plan themes.

Comment

Representation ID: 11788

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12286
National Policy Statement for Ports (January 2012) In March 2023, the government announced a review of the National Policy Statement for Ports under the provisions of the Planning Act 2008. This review will include a thorough examination of the modelling and forecasts that support the statement of need for development, and the environmental, safety, resilience, and local community considerations that planning decisions must take into account. Consultations took place in June and July 2025, but the review has yet to conclude and therefore the National Policy Statement for Ports (DfT 2012) (NPS) remains in place and carries full weight. It is part of the planning system established under the 2008 Act to deal with nationally significant infrastructure proposals. It provides the framework for decisions on proposals for new port development. It emphasises the essential role of ports in the UK economy. It notes that for an island economy, there are limited alternatives available to the use of sea transport for the movement of freight and bulk commodities and that shipping will continue to provide the only effective way to move the vast majority of freight in and out of the UK, and the provision of sufficient seaport capacity will remain an essential element in ensuring sustainable growth in the UK economy. The strategic importance of port facilities, such as the Manchester Ship Canal, is recognised at a national and regional level. This strategic importance must also be recognised at a local level through the development plan. Accordingly, MSCC wish to emphasise and repeat the request for reference to be made to the NPS as the new Local Plan progresses.

Comment

Representation ID: 11789

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12287
It is noted that all options are capable of accommodating at least 29,000 new homes and 149 hectares of employment land. Option C, which focuses on sustainable transport corridors, aligns most closely with the Manchester Ship Canal’s role as a low-carbon, resilient freight route. However, the draft consultation does not explicitly reference the Canal within these options. This represents a missed opportunity to recognise and embed its role in delivering sustainable growth. Accordingly, it is suggested that in the description of Option C (and subsequent preferred strategy), CWaCC should include the following text: “The Manchester Ship Canal will be recognised and promoted as a strategic sustainable transport corridor. Its wharves and associated infrastructure will be safeguarded to support modal shift, reduce carbon emissions from freight, and underpin the borough’s industrial and employment base.”  

Comment

Representation ID: 11790

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12288
The key policies relevant to MSCC’s interests are Policy DM 38 – Waterways and Mooring Facilities (from the adopted Part Two Plan, carried forward into the Issues & Options), and Policy EP 2.C – Former Booston Oil Depot Allocation Policy DM 38 supports development adjacent to waterways where it contributes to regeneration, respects local character, and safeguards structural and operational integrity of the waterway. Importantly, it explicitly acknowledges the Manchester Ship Canal as an important commercial waterway and a Statutory Harbour Authority, noting that public access is restricted The policy provides a foundation to argue that canal-side development must not undermine canal operations. However, the policy is framed largely around environmental, recreational, and regeneration benefits. It should be strengthened to safeguard the Canal’s operational capacity as a freight corridor and prevent incompatible development that could prejudice its long-term role. Accordingly, it is suggested that the wording amendment is made to the wording of Policy DM 38 by adding the following clause: “Development proposals adjacent to, or affecting, the Manchester Ship Canal must safeguard its role as a strategic freight corridor and Statutory Harbour Authority. Proposals should not prejudice existing or potential wharf operations and should demonstrate how opportunities for waterborne freight transport have been considered and, where feasible, secured.”

Comment

Representation ID: 11791

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12289
The Former Booston Oil Depot Allocation (Policy EP 2.C) is adjacent to the Manchester Ship Canal. It is allocated for employment uses (B1, B2, B8 – noting the policy was adopted prior to the changes to the Use Class Order and introduction of Class E). The policy requires proposals to be accompanied by a transport assessment and to maximise non-road modes of transport The explanation accompanying the policy highlights the site’s multimodal potential—including reinstating a rail freight link and canal access—as part of the Port Wirral area in the draft Mersey Ports Masterplan. This illustrates the recognition of canal-linked freight infrastructure as part of strategic employment growth. The recognition of the site’s multimodal potential, including canal access, is welcomed. This should be made explicit as a requirement, not just an option, to align with national policy on safeguarding wharves and promoting modal shift (NPPF paragraphs 105–106). Accordingly, any update or replacement of Policy EP 2.C should include the following supporting text: “Proposals should be designed to maximise the potential for multimodal freight transport. Given its location adjacent to the Manchester Ship Canal, applicants will be expected to demonstrate how waterborne freight movements have been integrated into development proposals, unless it can be robustly demonstrated that this is not viable.” Alongside the above-mentioned amendments to specific policies, in order to ensure the Canal’s role is woven throughout the Local Plan, references should be added under: • Economy & Employment policies (recognising the Canal as critical infrastructure supporting investment and job creation). • Transport & Infrastructure policies (positioning the Canal as part of the sustainable transport hierarchy). • Climate Change policies (highlighting modal shift from road to waterborne freight as a key decarbonisation measure). Suggested general wording that could be used within the vision and/or objectives section of these policy areas within the emerging Local Plan could be as follows: “The Local Plan recognises the Manchester Ship Canal as a nationally significant piece of infrastructure and a strategic economic asset for Cheshire West and Chester. The Canal will be safeguarded and enhanced to ensure its continued role in supporting the local economy, delivering sustainable freight transport, and contributing to carbon reduction and supply chain resilience.”

Comment

Representation ID: 11793

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12291
Alongside amendments to specific policies, in order to ensure the Canal’s role is woven throughout the Local Plan, references should be added under: • Economy & Employment policies (recognising the Canal as critical infrastructure supporting investment and job creation). • Transport & Infrastructure policies (positioning the Canal as part of the sustainable transport hierarchy). • Climate Change policies (highlighting modal shift from road to waterborne freight as a key decarbonisation measure). 3.24. Suggested general wording that could be used within the vision and/or objectives section of these policy areas within the emerging Local Plan could be as follows: “The Local Plan recognises the Manchester Ship Canal as a nationally significant piece of infrastructure and a strategic economic asset for Cheshire West and Chester. The Canal will be safeguarded and enhanced to ensure its continued role in supporting the local economy, delivering sustainable freight transport, and contributing to carbon reduction and supply chain resilience.”

Comment

Representation ID: 11861

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12360
Alongside amendments to specific policies, in order to ensure the Canal’s role is woven throughout the Local Plan, references should be added under: • Economy & Employment policies (recognising the Canal as critical infrastructure supporting investment and job creation). • Transport & Infrastructure policies (positioning the Canal as part of the sustainable transport hierarchy). • Climate Change policies (highlighting modal shift from road to waterborne freight as a key decarbonisation measure). 3.24. Suggested general wording that could be used within the vision and/or objectives section of these policy areas within the emerging Local Plan could be as follows: “The Local Plan recognises the Manchester Ship Canal as a nationally significant piece of infrastructure and a strategic economic asset for Cheshire West and Chester. The Canal will be safeguarded and enhanced to ensure its continued role in supporting the local economy, delivering sustainable freight transport, and contributing to carbon reduction and supply chain resilience.”

Comment

Representation ID: 11862

Received: 28/08/2025

Respondent: Peel Ports Group Limited

Agent: Pegasus Planning Group Ltd

I&O_12361
Alongside amendments to specific policies, in order to ensure the Canal’s role is woven throughout the Local Plan, references should be added under: • Economy & Employment policies (recognising the Canal as critical infrastructure supporting investment and job creation). • Transport & Infrastructure policies (positioning the Canal as part of the sustainable transport hierarchy). • Climate Change policies (highlighting modal shift from road to waterborne freight as a key decarbonisation measure). 3.24. Suggested general wording that could be used within the vision and/or objectives section of these policy areas within the emerging Local Plan could be as follows: “The Local Plan recognises the Manchester Ship Canal as a nationally significant piece of infrastructure and a strategic economic asset for Cheshire West and Chester. The Canal will be safeguarded and enhanced to ensure its continued role in supporting the local economy, delivering sustainable freight transport, and contributing to carbon reduction and supply chain resilience.”