Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 8414

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

I&O_8905
Wain Estates strongly support the general location of the proposed growth options around Northwich, in particular, the land referenced ‘NOR08’ which identifies Wain Estates’ land interest at Model Farm, Hartford for housing. The land at Peckmill Farm, Davenham is currently excluded as an identified growth option and Wain Estates request the Council reviews this position to extend ‘NOR06’ south on the basis that land to the south of the A556 should be viewed  favourably by CWaC given its location outside of the Green Belt and given that the land at Peckmill Farm is demonstrated to be available, achievable and a suitable location for development. NOR06 also currently consists of Davenham Conservation Area, which includes several listed buildings such as Davenham Hall, a Grade II* listed building, a Local Green Space designation in the ‘made’ Davenham and Whatcroft Neighbourhood Plan. The land at Peckmill Farm, to the south of NOR06, does not include any national or local designations.

Comment

Representation ID: 8415

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

SS1
I&O_8906
Paragraph 5.2 of the Issues and Options document states that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method to establish a housing requirement figure for the whole area, which shows the extent to which the identified housing need can be met over the plan period [NPPF para. 69].  The local housing need figure for CWaC, calculated using SM3, is 1,928. This is a significant 262% increase from the previous standard methodology figure for CWaC of 532. It also represents a 75% increase from the current Local Plan housing requirement of 1,100. As it stands, the Issues and Options document indicates that the plan will cover a 15-year period which equates to a total figure of 28,710 new homes. NPPF para. 22 states that “strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities”. [Emphasis in bold] Given the significant increase in CWaC’s housing need figure a substantial amount of developable land is going to be required to fulfil the identified need target over the Plan period, from a range of different sites across the administrative area. To meet the identified need of 28,710 new homes, CWaC’s Land Availability Assessment (Stage One) [LAA] report suggests that the assessment has identified a total of 502 potential sites that could deliver in the region of 29,500 units based on an initial assessment against key designations, including ‘Open Countryside’ and ‘Green Belt’ sites, and constraints and applying general, non-site-specific density assumptions to estimate capacity. However, this figure is likely to significantly reduce once a detailed assessment of the constraints, development potential, availability and achievability is carried out in stage two of the process. A shortfall of housing land supply is, therefore, likely to be identified which emphasises the need to allocate deliverable sites including the land at Model Farm, Hartford and Peckmill Farm, Davenham, both of which are included as part of the LAA. Both of Wain Estate’s land interests should be favoured against Green Belt sites considered in the LAA. Wain Estates does not support the concept of a stepped housing requirement that plans for a lower level of housing delivery earlier in the plan period. The Issues and Options document presents no evidence to justify a stepped approach, and Cheshire West has been delivering very high numbers of homes over the past decade in line with the new standard method requirement and a stepped housing requirement would be counterintuitive. The Housing Delivery Test (December 2023) [HDT] identified that CWaC scored 249% which means CWaC exceeded its housing delivery target by 149% over the previous three years which demonstrates a strong record of delivering new homes. Whilst this most recent HDT figure was calculated based on SM3, it demonstrates that positively planning for housing growth through strategic policies can ensure that future housing delivery target are achieved. Sites, including Wain Estates’ land interests, are deliverable within the early years of the Plan period and would make a valuable contribution towards meeting CWaC’s identified need in the short term. Implementing a stepped approach through policy would hinder the delivery of homes and, in the context of the quantum of deliverable sites across the borough, lead to an unjustified shortfall of housing against the SM3 target, especially in context of the Council’s current five year housing land supply position. In addition, a stepped approach could not accord with the national policy to boost the delivery of homes and would impact the delivery and availability of affordable housing, introduce uncertainty for developers, and potentially result in a delay in meeting CWaC’s identified development needs.

Comment

Representation ID: 8416

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

SS3
I&O_8907
Paragraph 5.6 and draft policy SS3 indicates that the spatial strategy will follow the principle of directing new development and allocating land towards previously developed sites within settlements first, as they are most sustainable locations with best access to services and facilities. SS3 goes on to state that where there are not enough planning permissions and opportunities for redevelopment within urban areas and towns, the approach will be to develop 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. Depending on the settlement this may require the release of Green Belt land. Whilst Wain Estates generally supports this principle, it is highly unlikely that this approach will facilitate the delivery of sufficient homes to meet CWaC’s identified needs alone. This principle should facilitate the development of land that can be made sustainable through improvements to surrounding infrastructure and facilities on both Green Belt and non-Green Belt land. Wain Estates notes that several growth areas identified under spatial growth ‘Option C – Sustainable Transport Corridors’ appear to have been selected primarily due to their proximity to railway stations— even in cases where service levels are limited to just one train per day in each direction. In contrast, Wain Estates’ sites in Hartford and Davenham offer a genuinely sustainable choice of transport modes. Both locations are also well positioned to access a broad range of facilities and services available in Hartford, Davenham, and the wider Northwich settlement area

Comment

Representation ID: 8417

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

SS4
I&O_8908
The settlement hierarchy proposed within draft policy SS4 is welcomed by Wain Estates, specifically in support of Northwich. Wain Estates request that the policy confirms that Northwich is defined as the town of Northwich, and adjacent settlements including Davenham and Hartford for clarity. An individual place-based policy for each settlement is welcomed, however the wording of such policies should be flexible and not overly prescriptive to allow flexibility to deliver homes and meet CWaC’s identified housing need in and around key settlements.

Comment

Representation ID: 8418

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

Map 5.6
I&O_8909
A high-level review of the Northwich growth options identified on Map 5.6 has been carried out the provide a comparison between them and Wain Estates’ land interests. NOR01  This parcel is located within the Green Belt and is located adjacent to the settlement boundary of Northwich. This parcel was included within CWaC’s Land Availability Assessment site ref. 2177 however given its Green Belt location, the parcel is not considered to be ‘suitable’. This parcel has a Grade 2 Agricultural Land Classification [ALC] and comprises land that is subject to pockets of surface water.  The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, because they are not designated as Green Belt, and do not comprise any Grade 2 ALC NOR02 This parcel is located within the Green Belt and is adjacent to the settlement boundary of Northwich. This parcel does not appear to have been included within CWaC’s Land Availability Assessment. This parcel has Grade 2 and 3 ALC, is subject to surface water across the entirety of the parcel and falls within a minerals supply and safeguarding area for salt. The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, because they are not designated as Green Belt NOR06 This parcel is located within the Countryside and is adjacent to the settlement boundary of Northwich. This parcel has been considered ‘suitable’ for residential development within CWaC’s Land Availability Assessment site refs. 1839, 1940, 1653 and 0887. This parcel has a Grade 3 ALC classification, comprises limited pockets of land subject to surface water flood risk and falls within a mineral supply and safeguarding area for salt. Wain Estates consider this parcel to be a preferred growth location given that it does not hold a Green Belt designation and has more limited constraints. However, this parcel should be extended further south to include the Land at Peckmill Farm given this land parcel is not constrained, forms a natural extension to the existing settlement boundary, does not fall within the Green Belt and is deliverable. NOR06 also currently consists of Davenham Conservation Area, which includes several listed buildings such as Davenham Hall, a Grade II* listed building, a Local Green Space designation in the ‘made’ Davenham and Whatcroft Neighbourhood Plan. The land at Peckmill Farm, to the south of NOR06, does not include any national or local designations and is less constrained.  NOR07  This parcel is located within the Countryside and is adjacent to the settlement boundary of Northwich. This parcel comprises an area of ancient woodland which would be retained as part of future development proposals. This parcel comprises predominantly Grade 3 ALC, with a small area of Grade 2, comprises limited pockets of land subject to surface water flood risk and falls within a minerals supply and safeguarding area for sand and gravel. Wain Estates consider this parcel to be a preferred growth location given that it does not hold a Green Belt designation. The constraints identified are not considered to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that this site is not sequentially preferable to NOR08 and Wain’s site at Peckmill Farm, Davenham because it contains an area of land covered by dense trees which could limit the sites developable area and contains a number of titles which could potentially restrict developability due to ownership constraints. NOR08  This parcel is located within the Countryside and is adjacent to the settlement boundary of Northwich. This parcel comprises Grade 3 ALC, limited pockets of land subject to surface water flood risk and falls within a minerals supply and safeguarding area for sand and gravel. Wain Estates consider this parcel to be a preferred growth location given that it does not hold a Green Belt designation and has limited constraints and is considered to be suitable to accommodate growth NOR09 This parcel is located within the Green Belt and is adjacent to the settlement boundary of Northwich. This parcel is considered as within CWaC’s Land Availability Assessment site refs. 0660 and 1836, albeit given its Green Belt location, is not identified as ‘suitable’ for development. This parcel comprises Grade 3 ALC and comprises significant pockets of land subject to surface water flood risk. The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, Pg 8/12 34129411v1 because they are not designated as Green Belt.   NOR10 This parcel is located within the Green Belt and is adjacent to the settlement boundary of Northwich. This parcel comprises predominantly Grade 3 ALC, with a small area of Grade 2. This parcel comprises limited pockets of land subject to surface water flood risk and falls within a minerals supply and safeguarding area for sand and gravel. The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, because they are not designated as Green Belt. NOR11  This parcel is located within the Green Belt and is adjacent to the settlement boundary of Northwich. This parcel was included within CWaC’s Land Availability Assessment albeit given its Green Belt location, is not identified as ‘suitable’. This parcel comprises Grade 3 ALC and comprises limited pockets of land subject to surface water flood risk, falls within a minerals supply and safeguarding area for sand and gravel and comprises a small area of land falls within Flood Zone 2 and 3. The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, because they are not designated as Green Belt NOR12 This parcel is located within the Green Belt and is adjacent to the settlement boundary of Northwich. A small area of the eastern part of this parcel was included within CWaC’s Land Availability Assessment site ref. 1691 albeit given its Green Belt location, it is not identified as ‘suitable’. This parcel comprises Grade 2 and 3 Agricultural Land and comprises pockets of land subject to surface water flooding albeit these are not substantial. The constraints identified are not considered significant to restrict development and this parcel could be suitable to accommodate growth. However, Wain Estates consider that its sites are sequentially preferable, because they are not designated as Green Belt. The table above illustrates that Wain Estates’ land interests are situated in the most favourable growth locations within the wider Northwich settlement area. Importantly, neither site lies within the Green Belt nor is subject to greater constraints than other areas identified for growth around Northwich. Coupled with that, the sites will have imminent applications and as such, if approved, could deliver homes in the first 5 years.

Comment

Representation ID: 8424

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

NO1
I&O_8915
Wain Estates welcome the notion of the new Local Plan setting out the level and location of new development within Northwich and the surrounding settlements which make up the Northwich urban area. For clarity, Wain Estates requests that these settlements are listed within the policy wording and include Davenham, Moulton and Hartford. Wain Estates also request that the specified level of new development within Northwich and the surrounding settlements should be set as a minimum amount to create a positive policy framework to facilitate growth in line with CWaC’s identified housing need. Any infrastructure requirements needed to support the levels of growth identified for Northwich and the surrounding urban area should be clearly identified and evidenced within the policy wording so that developers are aware of the associated contributions required, and associated triggers, to facilitate development.

Comment

Representation ID: 8427

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

ID1
I&O_8918
Wain Estates notes that planning obligations may be necessary to ensure the impacts of development are mitigated and wishes to reiterate that the policy should state that obligations will only be sought where they are necessary, directly related to the development, and are fairly and reasonable related in scale and kind. The policy should make allowances for viability to be considered in the negotiation of planning obligations and should ensure that provisions are in place for contributions to be proportionately requested from new developments to meet future demand. The necessary infrastructure requirements should be outlined in an Infrastructure Delivery Plan which should detail anticipated requirements in the context of the identified growth areas and associated scale of development necessary to meet CWaC’s identified need.

Comment

Representation ID: 8428

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

HO1
I&O_8919
Wain Estates is generally supportive of a policy to provide direction to developers on the required mix of housetypes, sizes and tenures required to meet the identified needs of the local area. It is important that the policy is justified to reflect the evidence of the Housing Needs Assessment but also provides flexibility within the suggested mix, potentially through a percentage scale. Wain Estates request that the policy wording includes flexibility to propose alternative tenure splits where it can be justified by local needs, so that site specific factors can be considered.

Comment

Representation ID: 8429

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

HO2
I&O_8920
Wain Estates understands the need for CWaC to plan for the affordable housing needs of the borough and are supportive of the inclusion of affordable housing in new developments. A breakdown of the affordable tenure split should be included within the policy, however this should reflect the latest evidence within the Housing Needs Assessment and integrate flexibility for developers to propose alternative tenure splits where justified. Wain Estates welcome the inclusion of the policy allowing for off-site contributions where it is justified with a viability assessment.

Comment

Representation ID: 8430

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

DS1
I&O_8921
Wain Estates is generally supportive of the need to include a policy to encourage high quality design. The content of the proposed policy approach should not be overly prescriptive and place any unnecessary design requirements on developments which could impact viability