Local Plan Issues and Options (Regulation 18)

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Comment

Local Plan Issues and Options (Regulation 18)

Question HO 4

Representation ID: 16061

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

Representation Summary:

I&O_16642
Richborough supports the suggested Policy Approach towards delivering affordable housing, as set out in ‘HO 2’, which sets out the  requirement to provide affordable housing 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 Swanlow 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

Local Plan Issues and Options (Regulation 18)

Question OS 1

Representation ID: 16062

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

Representation Summary:

I&O_16643
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 viable and deliverable sites, such as at Swanlow Lane, is required to support the delivery of new open space and enhancements to biodiversity and green infrastructure that will be accessible for existing and future communities.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 11

Representation ID: 16063

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

Representation Summary:

I&O_16644
This section outlines that the above initial options for growth have been identified by CWaC. The site at Swanlow 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 attached] Overarching Comments Richborough consider that Policy Approach SS 5 should identify Swanlow Lane as a housing growth location in all three spatial strategy options. The site represents a logical and genuinely deliverable option for housing in Winsford, in a sustainable location to make use of existing access to public transport infrastructure and services. 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. [see attached] 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 building 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 Swanlow 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

Local Plan Issues and Options (Regulation 18)

Question SS 32

Representation ID: 16064

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

Representation Summary:

I&O_16645
For the reasons set out above and in the accompanying Vision Document, Richborough consider that land at Swanlow 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 will contribute to the identified housing needs of the Borough and supports a growth strategy that direct 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

Local Plan Issues and Options (Regulation 18)

Question IN 1

Representation ID: 16065

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

Representation Summary:

I&O_16646
Comments on the Emerging Local Plan Evidence Base Economic Development Needs Assessment (March 2025) The Economic Development Needs Assessment (“EDNA”) provided an overview of the strategic location of Winsford which benefits from being close to the countryside whilst also offering excellent transport links, with the M6 motorway and major A-roads linking the settlement with Merseyside, Chester and North Wales. The key strengths were identified as a growing  population, space to expand and the presence of a college (Warrington & Vale Royal College). The EDNA identified a demand for industrial space and an ambition to attract new businesses to locate in Winsford. However it was noted that many employees commute into work from outside of the town due to the weak town centre and residential offer.  Therefore, high quality new homes in Winsford will help to retain workers and underpin the towns employment base. The findings of the EDNA suggest that there is demand and ambition to expand Winsford’s employment offer, and that this would be supported by the delivery of a range of housing types and tenures. Employment Areas Survey (2024) The employment areas survey (2024) shows that the 3rd largest employment area in the borough is located in Winsford. This further reinforces the point that Winsford needs to be effectively planning to meet its housing needs to support its growing employment base.

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