Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15349

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15908
This section outlines that the above initial options for growth have been identified by CWaC. The site at Darnhall School Lane is identified as part of a wider potential growth option, as reference ‘WIN05’, in Options A and C, as illustrated in Figure 2: See attachment. Richborough consider that Policy Approach SS 5 should identify Darnhall School Lane as a housing growth location in all three spatial strategy options. The site represents the most sustainable and genuinely deliverable option for housing in Winsford, of a scale that is capable of providing a range of benefits to Winsford and the wider borough. The Vision Document at Appendix 2 demonstrates the reasons why the site is deliverable and why it would represent a sensitive and logical extension to the southern edge of Winsford in spatial, physical and visual terms. It is also without major constraints when considering the major physical and policy constraints on Winsford’s settlement edge, particularly when compared to other identified potential growth locations. Figure 3 identifies the growth locations in the context of the Winsford Constraints Map at Figure 9.3 (Page 112) of the Issues and Options Consultation. Based on the above, Richborough consider that WIN05 represents the most appropriate and least constrained option, when considered in the context of alternative growth locations, including: • WIN04 – this location includes a conservation area and a number of listed buildings adjacent to the settlement boundary. Any development in this location would have a significant impact on statutory heritage assets. • WIN07 – this location is a less logical option to expand Winsford, encroaching into the open countryside to the north, and located further from key services and facilities in the town. Richborough consider that to meet the levels of growth proposed in Winsford (which for the lowest growth options in 3,000-5,000 homes), WIN05 should be identified as a key strategic site, which is the most logical and appropriate location to amend the settlement boundary, in any growth scenario that is pursued. Richborough’s comments on each current growth option is provided below. Option A  Richborough would support Option A which identifies significant urban extensions to the south west of Winsford, and a level of growth for Winsford that would deliver around 11,000 homes. However, Option A does need to recognise that there needs to be some Green Belt release, especially around Chester as the top tier settlement. This option seeks to retain the Green Belt, by focussing development on settlements without Green Belt constraints, such as Winsford. The site is identified as a potential location for housing growth within this option under ‘WIN05’. Winsford is a Main Town in the Borough and therefore it appropriate to direct a significant level of growth to the settlement, commensurate with its capacity for growth and non-Green Belt location. Option B Option B seeks to follow the Local Plan level and distribution of development with reference to the settlement hierarchy, by locating most new development on the edge of main urban areas or around smaller settlements which have adequate services, facilities and access to public transport. Option B recognises that “a key difference between the Local Plan (Part One) and the new Local Plan is that there is a much more limited supply of previously developed land to accommodate new development, and unlike the last plan, larger areas of Green Belt and/or countryside are likely to be needed”. Richborough welcomes this recognition and considers that any growth strategy that follows Option B should reflect this situation and attribute a level of growth to Winsford that reflects its status as a Main Town and a key focus for growth in the adopted Local Plan. To follow the level and distribution of development within the adopted Local Plan, Winsford should accommodate a higher level of growth than is attributed within proposed Option B. Within the adopted Local Plan, Winsford had a requirement of 3,500 homes out of the total Borough requirement of 22,000 which equates to 16%. Within Option B, only 3,000 – 5,000 homes are proposed for Winsford out of a total requirement of 28,170 homes which equates to a range of 11-18%. This is likely to result in a lower proportion of growth within Winsford, which is not in line with the distribution of development as per the adopted plan and in line with the settlement hierarchy. Furthermore, Winsford has a history of underdelivering on its housing requirements due to a lack of deliverable sites. Out of the 3,500 housing requirement, only 2,513 homes were completed in the period of 2010-2024 which is a shortfall of 987 homes or 28% (reported in the CWaC Annual Monitoring Report, 2024). This is a significant shortfall which is not attributable to market conditions, but the selection of sites with poor deliverability. As discussed earlier, the Station Quarter Allocation (in the Local Plan Part One and the Winsford Neighbourhood Plan), has known deliverability constraints and has failed to deliver homes, and therefore there are concerns over relying on this allocation to provide for the settlement’s housing needs in the next Plan Period. Notwithstanding this and in the context of comments in relation to the suitability of proposed residential growth locations, Richborough strongly considers that the site at Darnhall School Lane should be identified for housing growth within Option B, as a deliverable and sustainable option for housing growth in Winsford to meet the local housing needs. The site is wholly deliverable and sequentially preferable to other options, and should be fully considered as a sustainable urban extension if Option B is taken forward. Option C Option C seeks to focus development around settlements on the railway network or main bus route corridors. This identifies housing growth in Winsford for around 3,000 – 5,000 homes. The site is identified as a potential location for housing growth within this option under ‘WIN05’. Richborough supports Option C and considers that Winsford is a highly sustainable settlement to accommodate growth due to having a train station with regular services to major employment centres Liverpool Lime Street and Birmingham New Street.

Comment

Representation ID: 15350

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15909
For the reasons set out above and in the accompanying Vision Document, Richborough consider that land at Darnhall School Lane as part of growth location WIN05 represents the most suitable and deliverable location for growth in Winsford, when considered in the context of all other growth options. The site forms a logical and sustainable extension to the settlement of Winsford, is within single ownership, and has no constraints that would prevent it delivering homes early in the Plan Period. As demonstrated in Appendix 2, it has the potential to accommodate a sensitive landscape led development that meets the identified housing and community infrastructure needs of the Borough and supports a growth strategy that directs the level of growth to Winsford that will support its future vitality. Richborough consider that the site should be considered as a crucial element of the emerging Local Plan’s deliverable supply under any growth option that is pursued.

Comment

Representation ID: 16049

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16630
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: 16050

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16631
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 whose early 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: 16051

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16632
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 Swanlow Lane would support this policy approach, located on the edge of the existing Main Town of Winsford, and offering a sustainable and deliverable option for an urban extension to this settlement to make use of existing access to services and facilities.

Comment

Representation ID: 16053

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16634
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. Policy Approach 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: 16054

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16635
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 Swanlow 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. 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: 16058

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16639
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 Swanlow 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. 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: 16059

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16640
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 highlights the 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 Swanlow 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 180 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.

Comment

Representation ID: 16060

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16641
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.