Thank you to all residents (members and non-members) that filled our community centre hall on 29th October, just a few days before the CWaC Local Plan deadline for representations. Fifty-one representations were hand delivered to CWaC the following day, and we know many more of you submitted via post directly or used email. At a last count on the CWaC portal, over 500 representations had been received, and based on some name checking I don’t think this is all of them yet…

Keep in touch,

Mark Sams

Westminster Park’s local wildlife includes Great Crested Newts have been seen in both Winkwell Field and the marl pits in the Greenbelt land that the Council wish to handover to developers.

Great Crested Newts are internationally important species of conservation concern as described on this Cheshire Biodiversity web site – http://www.cheshire-biodiversity.org.uk/action-plans/listing.php?id=34

Specific actions plans for Great Crested Newt conservation are documented at http://ukbars.defra.gov.uk/archive/plans/lbap_complete_plan.asp?X={5C19A854-E33D-459E-98A2-DD28A91EE8BB}&LBAP={2CF2A1EE-9AE6-4436-ABA7-21E8B659574D}&CO=

There is no evidence in the Local Plan for conservation or an impact assessment for bio-diversity when re-designating this Greenbelt land, i.e. a Habitats Regulations Assessment (HRA) in accordance with the Conservation of Habitats and Species Regulations 2010.

NOTE: There is a ‘Habitats Regulations Assessment Screening Report – June 2013.pdf” as a part of the plan, but it does NOT cover the Greenbelt land next to Wrexham Road and the importance of the marl pits to our Great Crested Newts.

You have until 5pm tomorrow to save our Great Crested Newts – Please send this additional information (below) to spatialplanning@cheshirewestandchester.gov.uk

Dear Spatial Planning Team,

The local plan is NOT LEGALLY COMPLIANT because there is no evidence in the Local Plan that a Habitats Regulations Assessment has been carried out in accordance with the Conservation of Habitats and Species Regulations 2010 given that Great Crested Newts are known by residents to be living in the marl pits on this Greenbelt land.

Kind Regards,

<Full name>

<Full Address>

<Post Code>

Following our Local Plan meeting tonight at the Community Centre, please find below an updated letter with reasons why the Local Plan is not legally compliant:

Download (DOC, 33KB)

Evidence that the housing requirement in the local plan has been inflated in the last stages of preparation…

This is the latest (2013) draft plan for Dee Valley water plans for water supply requirements for the local plan period.

The link for appendix E is via their web site:

http://www.deevalleywater.co.uk/article.php?id=129

Check out their population estimations and point 2.4 the required need for Chester from the chief planner.  Interestingly it also includes information for Flintshire, Denbighshire and Wrexham.

Download (PDF, 491KB)

Click here to submit a response

You will see this screen:

Click Login/Register, then register using the button marked ‘register’.

Choose Register as Consultee…

Fill in and complete registration –

write down password if needed and press OK…

Confirm your email address, and then proceed to update your contact details and submit comments…

You can respond now via email to spatialplanning@cheshirewestandchester.gov.uk

<Write your Name and address incl. postcode>

Dear Mr. Owens,

I object to the re-designation of any Green Belt land as part of the CWaC local plan.

“The draft local development plan is unsound because:”

1)            There is no justification for re-designating Green Belt land for housing. The assessment of the number of new homes required is deeply flawed and is ‘dwelling-led’ rather than based on evidenced needs. The result is a housing target of more than twice that determined by the Dept of Communities and Local Government‘s projected increase in households..  It is not based on ‘proportionate’ evidence.

2)            There is no justification for the “ambitious”  growth targets which do not enjoy public support. The results of what little consultation there has been with the public have been ignored. They are well above any historical or natural levels and are not deliverable.

3)            There is no justification because the plans are disproportionate to the need.  The Strategic Land Availability Assessment (SHLAA) shows that there is no shortage of land availability over the 20 year period. The Green Belt should not be dismembered for a ‘perceived’ shortage over the very short term.

4)            It is not positively prepared as there is no evidence of co-operation (as required in the planning guidance) with neighbouring authorities.

5)            It is not effective as there is no evidence of joint working on cross boundary strategic priorities.

6)            It is not consistent with the NPPF and national planning guidelines in its lack of use of secondary nationally produced data.

7)            It is not positively prepared in that it fails to address the issues of waste treatment capacity, traffic congestion, water supply etc with neighbouring authorities.

8)            The plan is not effective as it has not been demonstrated that the plan can be delivered.  It is simply not a credible plan given recorded past delivery levels and the latest demographic changes recorded by the ONS indicate.

The case for re-designating any Green-Belt has not been made.  We cannot understand why this Authority is encouraging the development of Green-Belt land and countryside, against the wishes of the community rather than primarily utilising all available Brownfield land as demanded by the National Planning Framework      …who are they representing ? 

Sign & Date

email :

spatialplanning@cheshirewestandchester.gov.uk

… or send to:

Spatial Planning, The Forum Offices, Chester CH12HS

Updated 28/10/2013 – Whichever form your representation takes, you must link all your points to the below questions of legal compliance and soundness.

Legal Compliance

For the Local Plan to be considered legally compliant, the following needs to be determined:

• Whether the Local Plan is detailed in the current Local Development Scheme (LDS) and that the key stages have been followed.
• That community involvement has been carried out in accordance with the current Statement of Community Involvement (SCI).
• Whether the Local Plan makes satisfactory regard to the Sustainable Community Strategy (SCS).
• That the Local Plan complies with the Planning and Compulsory Purchase Act 2004 (as amended).
• That the Local Plan complies with the Town and Country Planning (Local Planning) (England) Regulations 2012.
• That a Sustainability Appraisal Report (SA) is published to accompany the Local Plan and is adequate.
• That the Habitats Regulations Assessment (HRA) is carried out in accordance with the Conservation of Habitats and Species Regulations (The Habitats Regulations) 2010.
• That the Local Plan has regard to national planning policy.
• That Section 110 of the Localism Act 2011 (Duty to Co-operate) has been complied with.

Do yo consider the Local Plan to be legally compliant?

1. Yes
2. No

Soundness

Paragraph 182 of the National Planning Policy Framework sets out the considerations in relation to a plan being considered ‘sound’.

• Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
• Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
• Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities;
• Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the NPPF.

Do you consider the Local Plan is ‘unsound’ because it is not:

1. Positively prepared
2. Justified
3. Effective
4. Consistent with national planning policy

Download (PDF, 250KB)

Green Belt Information Loop ……….. protecting Cheshire’s rural heritage and charm

Local Plan

Local planning authorities must prepare a local plan which sets planning policies in a local authority area, this includes setting house building targets.  This is the plan which will inform all future planning applications over the next few years – it is important therefore that it is as accurate as possible.  The present position is that the Plan is in ‘draft form’ and is out for public consultation.

Including the supporting reports, the Plan is over 1000 pages , took 4 years to prepare, cost hundred of thousands   and unfortunately is presented in such a way that the average person will find it difficult to understand.

To summarise though,    CWaCC are proposing to build 22,000 houses across Cheshire West over the next 20 years (5,500 of these in Chester).  However … population projections from the Government (DCLG) indicate this figure across the Borough should be only  10,000 .  The Council, in proposing to set these much higher than needed housing targets, are suggesting we are going to have a great flurry of growth and the generation of 14,000 new jobs over and above finding work for the current 22,000 currently unemployed in the Borough.  Dreams of a megalomaniac – wonder who that might be?  Incidentally, the  plan   fails  to take into account all the empty homes and the sites where there is already planning permission but the houses have not been built yet  . over 6,000 (this incidentally is because nobody can afford to buy them!)

As I think everybody must know by now … the impact of setting housing targets above practical achievable levels will encourage the release of  more and more countryside ,   unnecessarily for development – the developers will go for this type of land first because it is cheap to buy (although a lot of Chester’s Green Belt  already has options already on it from the big builders) and it yields the biggest profits.  Land like this should ONLY go as an absolute last resort when everything else has been used up.

It is vital that as many people as possible get involved with it – and there is a page of the Council’s website where you can have your say! [LOCAL PLAN REPRESENTATION]

THERE IS A DEADLINE to get in your representations – this is the 1st November.   Unlike some Council surveys however, where people wonder whether their views are ever read, all representation received for this will have to be personally presented to the Government’s Planning Inspector who will look at it.

Our  conclusion is that this plan   is  a confidence trick  to release certain parcels of land across the Borough   The way the plan is constructed serves to confuse and there is no trail on how these figures have been arrived at. Interestingly the ruling group have pushed this not fit for purpose draft forward

Somewhere in  our  Authority there seems an obsession with promoting the interests of developers rather than a balanced approach to include the views of the community for a reasonable number of new dwellings  to be developed,  based upon actual need.   Through a trick of presentation of the figures  they have  attempted  to  say  that there is a shortage of  building land in Chester thus requiring the  release  of  a tranche of  valuable GREEN BELT to the south of the city by Wrexham Road. This is  a nonsense.   T he council have identified over 42,000 (units) without  fully  counting windfalls  which on average account for a further 300 dwelling pa

In addition to the Wrexham Road Green Belt, another tactic to grab more Green Belt land is the inclusion of a 5th park and ride scheme at Mannings lane  in the Transport Strategy .This is land in-between the Zoo  P &R and Sainsbury’s P& R. The case for this has not been proved. We ask the question why would someone in the Authority be so keen as to want this Green Belt land releasing

Ask your self the questions:

Who has an interest in this Mannings Lane land ?… It is owned by Mannings Lane Development. I understand the Bells have a 12.5% holding each in this company

Likewise ask yourselves about the ownership of the Wrexham Rd Green Belt site ? Who owns the land ? Have the boundaries and one or two fields added or changed recently? Are there any options out on part of this land?

CWaC consultation on the plan has been inadequate, if not illusionary.  We cannot see where any of the  views previously expressed  by the community have fully materialised in the plan.

Under Localism, the Plan should embody the wishes of the community People have expressed views for low development, the retention of the  Green Belt and the countryside and to optimise developments on City and Town regeneration on brown field sites

ALL of this has been pushed aside with the figures skewed so that it appears we have to build  an unsustainable number of houses on the Green Belt and countryside

This plan does not follow the Governments planning guidance procedure, it is subjective and has no objective basis for recommending building 22,000 houses in the Borough

Our guess is that very few of those consulted, if anybody, specifically understands the detailed workings of how they came up with their figures.  The trail is difficult to follow,  it is as if  it has been constructed to deceive – in fact I challenge any councillor who voted for this to explain how the figures in the local plan have been constructed – I bet they can’t!

Increasingly it is becoming obvious to many that the whole ‘emerging’ plan has been written  with a slant for property speculation,  ignoring the views of the  local community 

If you want a say on the local plan what you need to do is is  complete a representation form

Representation Form  details found at …..

One of our residents has provided these annotated maps which show quite clearly the lack of roads in the west/south of Chester and why there will be traffic problems with the CWaC local plan.

NOTE: We have heard various things about a future Western Relief Road, none of which indicate it is viable during the lifetime of the plan.

Download (PDF, 1.23MB)

Also, here is traffic data for local reference:

http://www.uktrafficdata.info/cp/west-cheshire-a483-handbridge-park-7202

The site allows various points to be selected.  Unfortunately it only shows averages not peaks.

It does show that average traffic peaked in 2007 (when economic activity in Chester peaked) and has gone down since then.

Please let us know if you find this traffic data useful for local plan responses – we suggest any comments should be at the strategic level.

1) Write an email, e.g.

Dear Jeremy Owens,

I object to the re-designation of Green belt land by Wrexham Road as part of the CWaC local plan.

The local plan is unsound because;

1)      There is no justification for using Greenbelt land as the assumptions made by the council for the number of new homes required includes too much contingency; therefore any subsequent assumption that Greenbelt land is required is invalidated.

2)      There is no justification for setting an ambitious target for household growth, a target which does not enjoy public support, that is well above natural levels and then making optimistic assumptions for future growth do not in themselves constitute the ‘very special circumstances’ required for Greenbelt release.

3)      The is no justification for using Greenbelt land as the Strategic Housing Land Availability Assessment (SHLAA) shows there is no shortage of land availability over the full 20 year period of the plan.

4)      It is not positively prepared as there is no evidence you have co-operated with neighbouring authorities to meet housing demand in Wales or have a plan to deal with drainage issues via Balderton Brook should this plan go ahead. There is a high risk drainage may not be possible or affordable by the developers in this area.

Kind Regards,

<Insert name and FULL address inc. post code>

2) Send a letter

You can use content from our WRPA representation, customise our template letter or create your own. You must answer at least one of the questions in part B of the ‘draft local plan representation form‘ and include your name and full address including post code.