Cheshire East Borough Council Local Plan Consultation
Pre-submission Core Strategy
Land at Centurion Way, Middlewich
December 2013
Cheshire East Local Plan: Consultation on Pre-submission Core Strategy
December 2013
Thank you for providing Persimmon Homes with the opportunity to inform the production of the Borough Council’s Local Plan. This representation forms the formal response from Persimmon Homes North West.
Persimmon Homes has traditionally been very active within Cheshire East, and is actively looking to pursue new development opportunities within the Borough. Persimmon has a keen interest in supporting and ensuring the delivery of plans that provide opportunities to sustainably meet the identified housing need of Cheshire East.
This representation pays particular concern to the Company’s land interest at Centurion Way, Middlewich, which we consider to be a sustainable location for housing development which could make a considerable contribution to the supply of housing in Cheshire East.
This representation follows previous representations submitted by the Company at earlier stages of the Local Plan process. Many of the comments made in those representations are salient to this Pre- submission version of the Core Strategy, and we would encourage the Council to consider those comments alongside this new representation .
Middlewich
Cheshire East’s Local Plan identifies Middlewich in the Settlement Hierarchy (Policy PG2) as a Key Service Centre along with Alsager, Congleton, Handforth, Knutsford, Nantwich, Poynton, Sandbach and Wilmslow.
The Local Plan recognises that Key Service Centres provide a range of services and opportunities for employment, retail and education, serving a wide catchment area and containing public transport links.
The Local Plan states that that development of a scale, location and nature that recognises and reinforces the distinctiveness of each individual town will be supported in Key Service Centres. Policy PG6 (Spatial Distribution of Development) states that Middlewich is expected to accommodate in the region of 80 hectares of employment land and 1,600 new homes.
Cheshire East, like many Boroughs in the North West has suffered from faltering housing delivery in recent years. Appendix E of the Core Strategy identifies that since the start of the Plan period in 2010/11, there has been an average of 551 net completions per annum, significantly lower than the annual housing target of 1,350 dwellings per annum.
Paragraph 47 of NPPF states that local authorities should look to significantly boost the supply of housing by using their evidence base to ensure that their local plan meets the full, objectively assessed needs for market and affordable housing.
The Cheshire East Local Plan states that the top priority for the Council is to increase the Borough’s economic prosperity and that the Core Strategy is vital in delivering the housing development to support this economic growth. The Core Strategy aims to deliver over 27,000 new homes in the plan period to 2030 (an average of 1,350 per annum). The Company would suggest that the proximity of Middlewich to the M6 Motorway and the presence of a large number of employers in the area make it a highly sustainable location for housing development, which can accommodate a higher quantum of development than that suggested in the Local Plan.
Land at Centurion Way, Middlewich
The Company’s current land interest is located north of Centurion Way and bisects the administrative boundaries of both Cheshire East and Cheshire West and Chester Council, although the site is predominantly within the boundary of Cheshire West and Chester. We would suggest that a sensitively masterplanned development scheme could create a solid and permanent boundary between the two Borough’s, whilst also making significant contributions to the Boroughs’ respective housing land supply’s, infrastructure and economy.
The site is currently predominantly greenfield and serves little agricultural purpose, other than for the grazing of horses.
The site is bound by development on two sides. The site is bordered to the south by an established residential area. Kinderton Hall is adjacent to the site to the west, with the B5309 highway and an established residential area beyond. The River Dane acts as a natural and permanent boundary to the open countryside to the north. The site is bound to the east by open countryside. Permitting a quantum of development on the site would provide the opportunity to create a permanent and solid boundary between the existing urban settlement and the open countryside, and prevent urban sprawl.
A planning application has recently been submitted to Cheshire West and Chester Council concerning land south east of the site at Holmes Chapel Road for a large mixed use rural enterprise scheme. This has been discussed in more detail below.
Cheshire East Strategic Housing Land Availability Assessment (February 2013)
Part of the site was assessed as part of the Cheshire East SHLAA (Site Ref: 2653) as being undevelopable. It is recognised that the site is currently designated open countryside.
The SHLAA recognises that the site has a potential capacity of 75 dwellings.
The assessment recognises that the site is sustainably located, in close proximity to existing employment and residential uses, and is accessible by public transport. It is however noted that the site is located some distance away from Middlewich town centre (approximately 1.2km). It is also stated that the site is located within flood zone 1 and represents little or no risk and its topography is relatively flat.
The assessment also identifies several constraints to housing development on the site, including potential access and contamination issues.
The Company agrees with the assertion that the site is located within a sustainable location, in close proximity to existing residential and employment areas. We would suggest however that the access of the site is not necessarily a physical constraint as it holds a significant main road frontage in close proximity to a key junction. Byley runs through the site and provides an existing access point, subject to further modelling works. We would however disagree with the site being located some distance from Middlewich town centre. The site is located approximately 1.2km from Middlewich town centre, and is currently served by a number of public transport services, as well as being located on a key transport route through the settlement. We would contend that the site is located is a significantly more sustainable location than sites H1 and H2 of the Middlewich Town Strategy (plan below), of which H1 is allocated as a housing site in the emerging Local Plan.
Middlewich Town Strategy
The site has also been identified within the Middlewich Town Strategy (July 2012) as a potential site for future residential development that could deliver around 200 dwelling (Ref H3).
Through a consultation exercise, a Stakeholder Panel placed the identified sites in order, based on their perceived suitability for development.
The site at Centurion Way was placed at number 4, behind H6, H7 and H8, although it is worth noting that it was given the highest priority in terms of suitability of all greenfield sites considered.
Paragraph 6.6 of the Middlewich Town Strategy states that the initial preference for housing development is the use of vacant buildings and brownfield sites. It does however state at paragraph 6.7 that one or more of the greenfield sites within Diagram 1 may be required to contribute to housing need. We would suggest that it stands to reason, taking account to the conclusions of the Middlewich Town Strategy and the stakeholder panel, that the site at Centurion Way is the most suitable greenfield site for residential development and permitting development on the site would make a significant contribution to the Borough’s housing land supply.
Ensuring deliverability – development on brownfield sites The Council has recently published an assessment of additional brownfield land for housing development (November 2013) to establish what contribution brownfield land is envisaged to play in the provision of new housing and to establish whether any additional quantum of development could come forward on previously developed land in the Plan period, excluding those sites already identified in the Core Strategy as strategic locations, existing allocations, those under construction or those identified as deliverable or developable sites in the 2012 SHLAA.
It is identified at paragraph 4.2 that pre-NPPF policy approaches restricting greenfield development has resulted in high levels of land reuse over the last decade or so and therefore much of the previously developed land within Borough has already been redeveloped for new residential or employment purposes. It is recognised in table 2 that in Middlewich, during the period 2003-2013, there were 296 net completions on brownfield land, with 154 on greenfield sites.
The assessment findings highlight that there is a limited amount of additional brownfield land within the Borough with the potential for housing development, amounting to a theoretical total of 349 homes, of which 56 are located within Middlewich. Paragraph 9.2 recognises that the findings of the assessment support the case that there is a need to change Green Belt boundaries to accommodate housing development.
The Company supports the findings of the Study, and the need to change Green Belt boundaries to accommodate housing development, particularly to the north of the Borough. We would also encourage the Council however, to identify other suitable greenfield sites that could potentially accommodate housing development. We would also encourage the Council to consider distributing a larger portion of its housing growth to those settlements that could accommodate additional growth, such as Middlewich.
Current Planning Policy
The site is currently designated within the Local Plan as Open Countryside (Policy PG5). The Local Plan states that development in the open countryside will normally be unacceptable unless it can be shown to be essential to local needs, and seeks to restrict development on such land, save for development that is essential for the purposes of agriculture, forestry, outdoor recreation, essential works or other uses appropriate to a rural area.
The Company would suggest that the site at Centurion Way represents a suitable site to accommodate housing development to meet local needs, owing to the sites location close to existing residential and employment areas.
Recent Appeals
There have been several recent appeal decisions in Cheshire East, which support the development of land in Open Countryside.
Loachbrook Farm, Sandbach Road, Congleton, Cheshire, CW12 4TE
An appeal decision concerning a 200 dwelling scheme on Open Countryside at Loachbrook Farm, Congleton (Appeal Ref: APP/R0660/A/11/2158727) was allowed. The Inspector acknowledged the site’s location within the open countryside and its development would locally harm the character and appearance of the area and would be contrary to the saved policies of the Congleton Borough Local Plan, consistent with NPPF and therefore carry significant weight.
It was also suggested by the Council that with a 5% buffer, there is a housing land supply which equates to a 3.75 year supply. It was considered by the appellant that a 20% buffer was required, as a result of persistent under-delivery, which would produce a housing land supply of 3.28 years. It was recognised by the Inspector that whichever size of the buffer used, it is clear that a five year deliverable supply of housing cannot be demonstrated, and represents a substantial shortfall. This also carries significant weight.
The Inspector acknowledged in allowing appeal that whilst there would be impacts on the open countryside and harm to character and appearance, these are outweighed by the need of the Council to secure a five year housing land supply.
The appeal at Loachbrook Farm represents an example of where the contribution that development on designated open countryside can make to a Council’s housing land supply far outweighs the harm it will have on its character and appearance.
We would highlight that since the above appeal was allowed (16 August 2012), the housing land supply situation in Cheshire East has remained below that requirements of the NPPF, with the Inspector at the recent appeal for Land north of Congleton Road, Sandbach (APP/R0660/A/13/2189733) accepting a demonstrable housing land supply in the region of 3.9 to 4.1 years.
We would wish to reinforce the beliefs of the Inspectors, who state that significantly more weight should be placed on the contribution to housing requirements when considering planning applications for residential development in open countryside.
Landscape Appraisal
Cheshire Landscape Character Assessment
The Cheshire Landscape Character Assessment (LCA) identifies that the site falls within Landscape Character type 7: East Lowlands Plain. The LCA states that the area is characterised by:-
• Flat and almost flat topography
• Small to medium sized fields (up to 8ha), used mainly for pasture and arable farming
• Mainly hawthorn hedgerows and hedgerow trees
The LCA comments that the area is dominated by the large urban centres of Northwich, Middlewich, Sandbach and Winsford.
The landscape is a predominantly flat, large scale landscape with relatively few hedgerow trees or dominant hedgerows. This combined with the low woodland cover, creates an open landscape with long views in all directions to a distant skyline.
It is recognised that there is a great difference in the perceived tranquillity of the more remote rural areas, with scattered and dispersed settlement linked by narrow country lanes, and those areas influenced by large scale industrial sites such as Winsford and Middlewich. With the latter, the absence of high vegetation and the open nature of the surrounding landscape allow the large structures to intrude over a very extensive area. The area is traversed by two very dominant overhead power lines, one along a north-south axis, the other along the area’s western flank, and these further diminish the area’s rural character.
The M6 crosses through character area, and two arterial routes from Crewe (A533 and A5022) run north. There are two railway lines that link Elworth to Holmes Chapel and Middlewich, and the Trent and Mersey Canal passes through the area. Both the motorway and railways are visually intrusive when they cross the level plain on raised embankment.
The Company agrees with this assessment of the landscape area, and would also wish to highlight the key issues identified as affecting the landscape character of the area. These includes changes in farming and the pressure to diversify and changing patterns of land ownership with the purchase of agricultural holdings by non-farmers becoming a significant force for change. It is also considered that the upgrading of lanes and minor roads has led to an increasingly suburban character of the countryside. This is certainly the case for this particular stretch of the highway, with the site being located at a key junction between Holmes Chapel Road and Centurion Way, a key route to the M6 from Middlewich.
We would contend that the relatively flat topography identified in the LCA makes the site suitable for housing development, and we would encourage the Council to allocate it for housing development in the emerging Local Plan. As noted later in the report, the topography to the north west of the Borough is particularly problematic. The Middlewich Town Strategy identifies two sites for housing development, H4 and H5, which are located in areas with topographical issues, where development is likely to be constrained. We would encourage the Council to identify sites in locations where there are limited physical constraints, and where housing development is deliverable.
Site Specific Landscape Features
The site is predominantly open countryside in use for horse pasture. There are no buildings or structures on site. There are several buildings on the western boundary of the site. These include Kinderton Hall.
View from south west of site towards Kinderton Hall Typical existing site hedgerow boundary
The surrounding built form lies predominantly to the west and south west of the site. It is characterised by medium density detached and semi-detached residential housing to the south west and employment uses to the south. The north and east of the site is predominantly open countryside.
The A54 runs along the southern boundary of the site and leads to the M6 Motorway.
The site boundary is predominantly sporadic and sparse low level hedgerows, with different types of wooden and wire fencing. Many of the hedges are broken with only a few creating a dense boundary.
Local Topography
The site is divided into a number of fields with a gentle undulating topography, separated by Byley Lane. The site is generally flat.
Vegetation and Trees
There are a number of native trees and hedgerows on the site boundaries which demarcate the original field pattern. The condition of the vegetation is generally in good condition. The hedges create a dense boundary between fields.
Views to and from the site
The immediate views of the site from Centurion Way and Holmes Chapel Road provide views of open countryside, although these are partially screened by hedgerows and wooden fencing.
Views from Byley Lane, which traverses the site, are screened by dense and mature hedgerows.
Views from the site present a distinctly urban feel. The immediate views of the site to Holmes Chapel Road are a mix of urban and rural perspectives. There are views onto open countryside, however this is mixed with views of a busy highway junction (Centurion Way) and a largely built up area of mixed uses, including a public house, hotel and employment premises.
Views from the site looking south west are of established residential areas, adding to the urban feel of the southern edge of the site.
View from site to Centurion Way View from Centurion Roundabout (Site on right)
Physical Opportunities and Constraints
The Company contends that the site north of Centurion Way can be developed into a highly sustainable development in the north of Middlewich, creating a key gateway to the Borough from the M6 Motorway.
The Plan below illustrates how the key overall opportunities and constraints can be developed into a highly sustainable development.
There are few physical constraints save for the overhead power lines which run along the eastern part of the site. These power lines provide little by the way of constraints to development as they can be incorporated into a scheme through effective masterplanning, or can be re-aligned or relocated underground as required by future development demands.
The hedgerow pattern along the boundary of the site remains an element within the landscape, which any future development of the site has the opportunity to respond to.
The site benefits from being located at a key junction in Middlewich (Centurion Way Roundabout), with a significant frontage onto the highway at both Centurion Way (B5309) and Holmes Chapel Road (A54), and benefits from being well connected to a range of transport networks, including private vehicular trips and public transport, with bus stops at the Centurion Way roundabout and further along Centurion Way to the west of the site boundary.
There are also opportunities to create access to the site from Byley Lane. The development of the site presents opportunities to improve the area’s existing highways/infrastructure, including works to the Middlewich Bypass. The sites location on the north eastern boundary of Middlewich provides an opportunity to improve the boundary between the urban and rural fringe. The development of the site along with the proposed Cheshire Fresh scheme south of Holmes Chapel Road provides an opportunity to create an attractive gateway to the town.
View towards Centurion Roundabout from Holmes View east on Holmes Chapel Road Chapel Road (Site on right)
Visual Assessment
As noted earlier in this representation, the site north of Centurion Way is designated Open Countryside within the current Local Plan. Recent appeal decisions have permitted development on such sites, owing to Inspector’s placing significantly more weight on faltering housing delivery in the Borough and a presumption in favour of sustainable development than the loss of Open Countryside. The Company has undertaken a visual assessment of the site to highlight its suitability for future housing development, without compromising the visual amenity and attractiveness of the open countryside in Middlewich.
Does the site provide views of open countryside close to where people live?
Yes, the site offers views of open countryside to adjacent residential and employment properties. We would however suggest that its location at a key junction in the town, on the edge of the urban settlement represents a natural development opportunity.
The area is fairly suburban in feel, owing to development on three sides, which will be further exacerbated by the Cheshire Fresh scheme south of Holmes Chapel Road.
Established employment area, Pochin Way Through a considered masterplanning exercise, the Company would seek to retain key countryside elements and key views into the countryside. We would suggest that the site is the best site in the north of the town to meet housing need and the retention to retain open countryside should be balanced by the realisation of acute housing shortage in the Borough.
Is there a perception that the settlement is at risk of merging/coalescence of adjacent settlements?
No. The site is located on the north eastern boundary of Middlewich, and there is a significant buffer between the edge of Middlewich and Holmes Chapel, with the M6 Motorway providing an additional boundary of permanence. We would suggest the site represents a logical site for future housing development. A quantum of development on the site north of Centurion Way, along with the proposed Cheshire Fresh scheme south of Holmes Chapel Road, presents an opportunity to create a distinct and solid gateway to Middlewich from Holmes Chapel Road.
The topography of the site is fairly flat, and therefore there is a significant actual and perceived gap between the two settlements.
Would future development on the edge of the urban area significantly reduce visual separation between settlements?
No. As stated above the topography of the area is such that the perceived and actual visual separation of the two settlements of Middlewich and Holmes Chapel would not be reduced. There are no views of Holmes Chapel from the periphery of Middlewich, nor are there views of Middlewich from Holmes Chapel.
View from Middlewich towards Holmes Chapel
Sustainability Appraisal
As previously stated in this representation, the site is in a highly sustainable location, in close to proximity to the shops, schools and other services and amenities in Middlewich. The sustainable nature of the site has been confirmed in the SHLAA, which recognises the sites location to existing residential and employment areas as well as its accessibility to a range of public transport services. The Company has undertaken a sustainability appraisal of the site at Centurion Way using table 9.1 of the Local Plan, which advises on the desired distances to local amenities which developments should aspire to achieve.
The results of an accessibility assessment are set out below:-
Rating Description
Meets minimum standard
Fails to meet minimum standard (Less than 60% failure for amenities with a specified maximum distance of 300m, 400m or 500m and 50% failure for amenities with a maximum distance of 1km or 2km.)
Significant failure to meet minimum standard (Greater than 60% failure for amenities with a specified maximum distance of 300,400 or 500m and 50% failure for amenities with a maximum distance of 1km or 2km.
The site scores fails against 8 criteria of the sustainability checklist set in table 9.1 of the emerging Local Plan, 4 of which are significant failures.
The committee report for planning application 13/2069N (since withdrawn from committee) submitted by Taylor Wimpey for up to 275 dwellings east of Crewe Road, Shavington failed against 12 criteria in the sustainability checklist. It was considered by the Council in the committee report for the application (6 th November 2013) that the site was accessible to non car modes and is located within reach of local facilities, and as such does not raise any sustainability concerns, and therefore it was not considered that a refusal on locational sustainability could be sustained in this case.
It was suggested by the Council’s Highways Officer that the sustainability of the site is considered to be good, and is within walking distance of the local primary school, with shops, leisure and medical centres’ within reasonable walking distance. It was suggested by the Council that these facilities can be found in the town, and that with Crewe being the Borough’s principle town, development is to be expected on the periphery of the settlement.
We would suggest that the site at Centurion Way, comparable to the site east of Crewe Road, represents an extremely sustainable location for residential development. The site is located in close proximity to local shops, schools and leisure and medical facilities on foot, as well as excellent public transport links, which were recognises by the Council in its assessment in the 2012 SHLAA.
We would also wish to highlight, as emphasised by the Council in its committee report for the above application, that previous Inspectors have deemed accessibility to be but one element of sustainable development and it is not synonymous with it. There are many other components of sustainability, other than accessibility, including meeting general and affordable housing needs and assisting economic growth and development.
Other sites in Middlewich
The Local Plan identifies two strategic housing sites within Middlewich, which are expected to contribute a combined 850 residential dwellings during the Plan period; a significant proportion of Middlewich’s housing requirements.
Glebe Farm, Middlewich (Site CS 20)
Glebe Farm is a large greenfield site to the south of Middlewich, which is expected to deliver 450 homes. The Local Plan states that these are expected to be delivered towards the middle/latter stages of the Plan period, with 262 homes expected during the early part of the plan period (2015- 2020) and 188 homes expected in 2020-2025.
The site is located on the edge of the existing urban area and is adjacent to existing residential areas, employment and open countryside.
Brooks Lane, Middlewich (Strategic Location SL9)
Brooks Lane is a large brownfield site approximately 0.5km south of Middlewich town centre. The site is currently occupied by employment premises. The site is expected to deliver a mix of uses as well as 400 homes, including leisure and community facilities and a local centre with up to 300 sqm of retail, with delivery expected towards the middle/latter years of the Plan period, with 150 homes expected in the years 2020-2025 and 250 homes expected in the years 2025-2030.
We would contend that the Council’s suggestion that such a large proportion of Middlewich’s housing requirements is expected to be delivered through these two sites is a risky and overly optimistic proposition. The Planning Inspector has previously touched on this issue (Appeal Ref: APP/R0660/A/13/2189733), raising concerns that the Council is being over-optimistic in its assessments for some draft strategic sites. The Inspector concludes that the Council’s assessment of likely delivery of strategic sites is too great, and it should not be forgotten that if sites are excluded from calculations now, but come forward anyway, the delivery of a greater level of housing is not in itself problematic, as there are no caps on numbers.
The Company believe this is certainly the case with regards to Brooks Lane, which is currently in active employment use. We would encourage the Council to identify sites, in additional to those strategic sites identified in the Local Plan, for housing development that can contribute to the housing land supply, which will ease the reliance on the strategic sites to come forward to meet the Borough’s housing targets.
We would also suggest that focusing residential development to the north of Middlewich to greenfield sites such as the land at Centurion Way, where deliverability of housing development provides comes with greater certainties than a heavy reliance on the development of strategic sites in viable employment use. This would enable the retention of viable employment sites such as land at Brooks Lane.
Cheshire Fresh
As noted earlier in this representation, a hybrid planning application (Application Reference: 13/03828/FUL) has recently been submitted to Cheshire West and Chester Council for a mixed use rural enterprise scheme, incorporating an auction house with associated livestock accommodation building, barn and pump house, enterprise centre and related business and offices, light industrial and manufacturing and distribution areas, machinery dealerships, hotel and leisure facilities, retail and a food court, with associated car parking and vehicular access from the A54 and Pochin Way. Documents submitted as part of the application suggest that it will create 766 jobs over a 5/6 year period.
Like the Company’s land interest at Centurion Way, the application site bisects the administrative boundaries of both Cheshire East and Cheshire West and Chester, and like the site north of Centurion Way, is predominantly within the boundary of Cheshire West and Chester. The Cheshire East Strategic Planning Board determined on 17 th July 2013 that the application would be determined by Cheshire West and Chester. A part of the site is currently designated for employment development, although a large part of the site also designated Open Countryside.
Cheshire East Council, have submitted comments during consultation, recognising the scheme as a ‘unique concept’, noting that the development of the site will assist in the retention of two established employers in the area.
The site is located on the eastern edge of Middlewich, and is bordered to the north by Holmes Chapel Road, the main road linking Middlewich with the M6 Motorway. The site is bound to the west by Pochin Way and a public house, an office development and a hotel. Beyond Pochin Way is a large employment park, which currently employs approximately 2,000 people.
The Cheshire East committee report recognised the site as being located in an accessible location close to Middlewich town centre, accessible by walking, cycling and public transport.
Prospective Housing Site
It was recognised that the negative impacts of the scheme fall mainly on the loss of open countryside, and that a scheme of such large scale would normally not be accepted. It is however highlighted that NPPF provides significant support for sustainable economic growth, and this loss is demonstrably outweighed by the economic and associated benefits and that the presumption in favour of sustainable development is applied.
We would contend that allowing development at Centurion Way represents sustainable development in line with NPPF, and the significant benefits in delivering a quantum of residential development on the site will demonstrably outweigh the loss of open countryside.
Development north of Centurion Way coupled with the development of the Cheshire Fresh scheme at Holmes Chapel Road presents an opportunity to create a key gateway into Middlewich from M6 Motorway.
Midpoint 18, Middlewich (Strategic Location 10
Midpoint 18 Business Park is located south of the site at Centurion Road and provides over 128,000 sqm of mixed employment uses for a number of major companies including Tesco, Wincanton and Kuehne + Nagel.
The site is identified within the Local Plan for extension during the Plan period, delivering up to 70 hectares of additional employment land, also making significant contributions to the proposed Middlewich Bypass.
The Local Plan recognises at paragraph 15.284 that the site delivers a significant contribution to the Core Strategy Objectives and Vision by promoting economic prosperity, recognising that the future prosperity of Middlewich will rely in large part on its proximity to the M6 corridor and its ability to maximise opportunities presented by this to provide new and more skilled jobs.
The Company agree with the importance of delivering employment development in Middlewich to achieve the Council’s economic growth aspirations. We would suggest that a key part of delivering stated economic growth aspirations is to deliver the required housing in such growth areas. We would suggest that the site at Centurion Way presents such a site, and could deliver much needed housing to support future economic growth aspirations.
Development south of Middlewich
In analysing the current supply of deliverable housing opportunities in Middlewich, the Company would suggest that the majority of sites identified for future housing development are located to the south of Middlewich, and there are very few realistic housing opportunities in the north of the settlement, perhaps owing to the undulating topography to the north west, and to restrictions placed on development due to the administrative boundaries of both Cheshire East and Cheshire West Council’s being drawn tightly around the north of the settlement. It is also evident that a number of the sites to the south of the Borough, including the strategic site at Brooks Lane are in active use for other purposes, including employment, and therefore cannot be relied on to deliver housing in the short to medium term.
The findings of the SHLAA suggest that there are very few developable sites in the north of the Borough that can accommodate a significant quantum of development. Focusing housing development predominantly to the south of the Borough could saturate the housing market in the area and have detrimental impacts on the future delivery of housing.
We would encourage the Council to identify sufficient sites in the north of the Borough to deliver housing development, such as the land at Centurion Way, where there are few current development sites and demand remains high. We would encourage the Council to identify sites that are not currently in use for employment, such as Brooks Lane, that can deliver housing in the short term.
Duty to co-operate
It is stated at Paragraph 178 of NPPF that public bodies have a duty to cooperate on planning issues that cross administrative boundaries, particularly those which relate to strategic priorities such as meeting overall housing requirements. Paragraph 159 also notes that local planning authorities need to assess their full housing needs, working with neighbouring authorities where housing market areas cross boundaries. Housing is therefore, a key consideration which must be addressed through the duty to cooperate.
This guidance has been echoed by the Inspector of several plans including Coventry and Kirklees, where it was noted that compliance with paragraph 178 needs to go beyond consulting with neighbouring authorities but should make agreements to tackle such strategic issues.
The Council’s Draft Duty to Cooperate Statement of Compliance states that where locally arising needs cannot be met in the plan area without breaching physical, environmental or existing policy restrictions, then the option of neighbouring areas contributing to the plan making authority’s development should be explored.
The Council notes at paragraph 1.10 that in the preparation of the Local Plan, the Council has carried out extensive dialogue and engagement from with neighbouring authorities. It is stated however within the Council’s Draft Duty to Cooperate Statement of Compliance that the development proposed in the Core Strategy at Middlewich is to meet Cheshire East’s requirements and is not required to meet Cheshire West and Chester’s requirements. We would suggest that such a stance does not demonstrate a duty to co-operate in action, and is therefore in conflict with the objectives of NPPF and recent Inspector’s comments.
It is also highlighted at Chapter 9 of the Duty to Cooperate Statement of Compliance that the Council has ‘approached all neighbouring authorities’ to ascertain whether any of these councils are capable of accommodating any of Cheshire East’s housing requirements. Whilst the responses of Manchester, Trafford, Newcastle-under-Lyme, Stockport’s and Stoke-on-Trent’s response is provided, we are perturbed that no apparent response/reasoning has been given to Cheshire West and Chester.
There is also little expansion on how Cheshire East expects to deal with both its own housing supply shortfall and also the shortfall experienced in other neighbouring Borough’s
The Company consider that the land at Centurion Way, Middlewich provides significant scope for substantial co-operation between Cheshire East and Cheshire West and Chester and can deliver housing delivery that contributes to the delivery of new homes in both Boroughs’.
Concluding Comments
Overall, we would like to raise the following point with regards to the Council’s Pre-submission Core Strategy:-
• The Company would encourage the Council to demonstrate substantial cooperation with Cheshire West and Chester Council - as part of its duty-to-cooperate - to deliver on key strategic issues in Middlewich, including the delivery of housing development, in accordance with NPPF.
• We would encourage the Council to identify additional deliverable development opportunities in Middlewich to achieve housing targets, without placing heavy reliance on the strategic sites coming forward in this Plan period, particularly in the north of the settlement.
• We would suggest the site at Centurion Way presents a sustainable location for housing development, and presents an opportunity to provide much needed housing in the north of Middlewich, and enhance the existing gateway to the town from the M6.
I trust this makes the Company’s position clear. If you wish to discuss any aspect of this representation further, please do not hesitate to contact Persimmon Homes North West. Furthermore, the Company look forward to continue participating as part of the Council’s Housing Market Partnership.