Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15338

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15897
Richborough fully supports suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough as mandated by the Government’s Standard Method. In accordance with Government policy, Council’s must seek to, as a minimum, meet their local housing needs, informed using the Standard Method (including meeting the needs of neighbouring Authorities if appropriate); unless there are strong reasons why an Authority cannot do this. Paragraph 11 in the NPPF states that: “For plan-making, this means that: b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. Richborough does not consider that there is any strong reason for restricting development in CWaC, nor would doing so outweigh the benefits of meeting the Borough’s identified housing needs. As such, CWaC should plan for 1,914 new homes per annum, as an absolute minimum (and subject to considering neighbouring Authorities needs as part of its Duty to Co-operate).

Comment

Representation ID: 15339

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15898
Richborough objects to the Council’s consideration of a stepped housing requirement that plans for a lower level of housing delivery earlier in the Plan Period. CWaC Council will already be significantly underdelivering on the Standard Method housing requirement in the interim period before the Local Plan is adopted and therefore should be proactive early in the Plan Period to rectify this and ensure that homes are delivered within the Borough to address existing housing needs and meet mandatory targets. Moreover, a ‘backloading’ of housing delivery presents a serious risk of the Local Plan not delivering its housing requirement throughout the Plan Period, where significant pressure will be placed on the later years of the period with no guarantee of delivery. The Council should identify clearly deliverable sites that will support the required delivery of housing early in the Plan Period, ensuring that CWaC can meet its housing needs and does not fall behind in its delivery. CWaC should also consider the need to add a buffer to the overall housing requirement supported by allocations to allow for any sites whoseearly delivery slips; otherwise without this, any under-delivery in the early years of the Plan against the mandatory housing requirement could be exacerbated.

Comment

Representation ID: 15341

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15900
The suggested Policy Approach SS 3 outlines that the spatial strategy will follow the principle of directing new development towards previously developed sites within settlements first, as they are the most sustainable locations with the best access to services and facilities. SS 3 then promotes an approach that considers urban extensions on the edge of existing settlements, in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option. Richborough fully supports the suggested Policy Approach to SS 3 and in particular the sequential approach to considering deliverable and sustainable urban extensions once CWaC’s urban capacity has been exhausted. This policy approach should also give preference and priority to delivering a substantial level of the required growth in CWaC’s top tier settlements, including its Main Towns such as Winsford, which have the capacity, sites and existing infrastructure to deliver the level and type of sustainable growth required. Land at Darnhall School Lane would support this policy approach, located on the edge of the existing Main Town of Winsford, and offering the most deliverable and sustainable option for an urban extension to this settlement with existing access to services and facilities; providing the opportunity to deliver at scale with provision of community infrastructure and improved public transport solutions.

Comment

Representation ID: 15342

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15901
The Policy Approach to SS 4 ‘Settlement Hierarchy’ designates Winsford as a ‘Main Town’ (Tier 2) which is underneath only Chester as a ‘City’ in the hierarchy. PolicyApproach SS 4 outlines that an individual place-based policy for each settlement will set out the vision, core features, key issues and a clear strategy for what development will take place in each settlement. Richborough fully supports the designation of Winsford as a Main Town and the policy approach to having an individual policy for Winsford to enable a strategy for sustainable growth in the settlement to be considered. As a Main Town in the Borough, it is considered that Winsford should accommodate a level of development and growth that reflects is scale, location and sustainability, which should be reflected in the spatial strategy and land allocations in the emerging Local Plan (as set out below).

Comment

Representation ID: 15343

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15902
The suggested Policy Approach to WI 1 is to update and combine the existing Local Plan Part 1 STRAT 6 Policy with Part 2 Policies W 1 and W 2, as the overarching and locally distinct policy for Winsford. This will update the allocations, including any that have been competed or require a new approach, and any new locations for housing and employment development in Winsford. The Station Quarter allocation is proposed to be retained. The explanatory text identifies Winsford as one of the Borough’s four Main Towns and highlights key priorities as being regeneration to the town centre and improvements to open space. Richborough supports the suggested Policy Approach WI 1 in having an overarching and locally distinct policy which sets out the allocations within the settlement. This will enable more strategic growth to be identified that can meet housing and employment needs within the settlement. However, it is important that the chosen allocations are genuinely deliverable and able to promote opportunities for improvements to open space, services and facilities and public transport. For example, the Station Quarter Urban Extension allocation, which is carried forward from the Local Plan Part 1 (adopted 2016) and the Winsford Neighbourhood Plan (made 2014) is proposed to be retained, despite its significant lack of delivery since the allocation. At present, only two of the five proposed development parcels have been built out and the 2024 Monitoring Forecast suggests that progress on the remaining development parcels has stalled. It is important to take a realistic approach to delivery throughout the Plan Period, and to ensure that demonstrably deliverable sites are identified in Winsford that can deliver development in the early part of the Plan Period.  Richborough consider that there is a clear need to review the settlement boundary in Winsford (under any Growth Option), and that deliverable urban extensions to the town are required to ensure that deliverable sites are identified to support the significant growth needs of Winsford, and to ensure that any under-delivery of the town’s regeneration sites (as has been evident at the Station Quarter) can be countered by sites that can support delivery early in the Plan Period. Land at Darnhall School Lane should be identified as a residential growth location within the Policy WI 1 ‘Winsford’, being a sustainable urban extension to meet the housing needs of the borough in the early part of the Plan Period, whilst providing a range of other benefits which align with the proposed policy approach, including improvements to open space and community infrastructure. The deliverability of the site is set out in Section 3 and the accompanying Vision Document at Appendix 2 – and Richborough strongly consider that the site should be considered as a suitable and deliverable site allocation for Growth Scenarios A, B and C, providing an opportunity to support a urban extension in single ownership that can deliver housing early in the Plan Period.

Comment

Representation ID: 15344

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15903
The Winsford Development Framework (March 2016) is focussed around the enhancement and regeneration of the town centre for both visitors and residents, with key priorities including redeveloping the retail core, improving the connectivity of the town centre and providing new facilities to encourage people to spend time in the centre of Winsford and the High Street. The Development Framework recognises that Winsford is suffering from a general lack of interest from developers and end users and highlightsthe importance of attracting new investment and occupiers to create the step change that is needed to deliver on the vision. Richborough is supportive of any proposals to carry through the aspirations of the Winsford Development Framework in the new Local Plan and considers that the development of the site at Darnhall School Lane would support in the delivery of these aspirations, by providing a significant boost to Winsford’s supply of high-quality market and affordable homes on the immediate edge of the settlement. The delivery of approximately 1,100 new homes will boost the viability, vitality and vibrancy of local services and facilities by increasing the local population density and demand, which will directly support the regeneration aspirations for Winsford. The quantum of development the site can accommodate will result in a mix of households of differing age groups meaning a full spectrum of services and facilities would be supported.

Comment

Representation ID: 15345

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15904
The suggested Policy Approach to Green Belt and the countryside identifies the potential to add in other uses appropriate to the countryside. The explanatory text also identifies that there is an option to split the policy into separate policies regarding the countryside and Green Belt. Richborough is supportive of the approach to Green Belt and Countryside, or a separation of the policy, if it provides clarity on the policy differences between Green Belt and open countryside policy.

Comment

Representation ID: 15346

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15905
Richborough supports the suggested Policy Approach towards delivering affordable housing, as set out in ‘HO 2’, which sets out the requirement to provide affordablehousing on all new developments that include the provision of new homes, unless there are exceptional circumstances. The delivery of available and achievable housing developments, such as at Darnhall School Lane, provide the most effective way to deliver affordable housing along with the delivery of a mix of housing types to meet local needs. The provision of greater quantities of market housing will also help to alleviate the constraints on supply, and in turn help to reduce the upward pressure on house prices.

Comment

Representation ID: 15347

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15906
Richborough is supportive of the suggested Policy Approach towards open space, sport and recreation, that seeks to “support proposals that improve the quality and quantity of accessible open space, sport and recreation. This should include the improvement of the network of existing open spaces and improving accessibility to green corridors, and enhancing biodiversity in line with the suggested policy approach in GI 1 ‘Green infrastructure, biodiversity and geodiversity’. However it is emphasised that the need to allocate large-scale, viable and deliverable sites, such as at Darnhall School Lane, is required to support the delivery of new open space, sports facilities and green infrastructure that will be accessible for existing and future communities.

Comment

Representation ID: 15348

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15907
Richborough supports the suggested Policy Approach OS 2 ‘Community Facilities’, which seeks to “support proposals for new or improved community facilities and cultural or local services that serve the local community”. It is reiterated here that the allocation of large-scale, viable and deliverable sites, such as Darnhall School Lane, is crucial to support the delivery of new community facilities. For example, the illustrative masterplan for the site (included within the Vision Document at Appendix 2) demonstrates the potential for the site to include a two form entry primary school (or enable the expansion of the existing Hebden Green Community School), along with a new local centre which could include a range of community services, sports pitches, and play facilities to cater to various age groups. This is a significant opportunity to deliver new community infrastructure for both existing and future residents, that foster a sense of place and create new communities.