Congleton Neighbourhood Plan Regulation 16 Consultation
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Congleton Neighbourhood Plan Regulation 16 Consultation
Submitted Plan
Representation ID: 73
Received: 14/11/2025
Respondent: Gladman Developments
Dear Cheshire East Neighbourhood Planning Team,
RE: Congleton Neighbourhood Plan – Regulation 16 Response
This letter provides Gladman Developments Ltd (Gladman) representations in response to the
submission version of the Congleton Neighbourhood Plan (CNP) under Regulation 16 of the
Neighbourhood Planning (General) Regulations 2012. This letter broadly supports the general
direction of the CNP whilst also suggesting some changes that may be beneficial to the wider
content of the plan.
Legal Requirements
Before a neighbourhood plan can proceed to referendum, it must be tested against a set of
basic conditions set out in paragraph 8(2) of Schedule 4b of the Town and Country Planning
Act 1990 (as amended). The basic conditions that the CNP must meet are as follows:
“(a) Having regard to national policies and advice contained in guidance issued by the
Secretary of State, it is appropriate to make the order.
(d) The making of the order contributes to the achievement of sustainable development.
(e) The making of the order is in general conformity with the strategic policies contained
in the development plan for the area of the authority (or any part of that area).
(f) The making of the order does not breach, and is otherwise compatible with, EU
obligations.
(g) Prescribed conditions are met in relation to the Order (or plan) and prescribed matters
have been complied with in connection with the proposal for the order (or
neighbourhood plan).”
National Planning Policy Framework
The National Planning Policy Framework (the Framework) sets out the Government’s planning policies for England and how these are expected to be applied. In doing so it sets out the requirements for the preparation of neighbourhood plans to be in conformity with the strategic priorities for the wider area and the role they play in delivering sustainable development to meet development needs.
Planning Practice Guidance (PPG) makes clear that neighbourhood plans should conform to national policy requirements and take account of the most up-to-date evidence. This is so that APC can assist Melton Borough Council (MBC) in delivering sustainable development and be in accordance with basic condition (d).
Congleton Neighbourhood Plan
Gladman support the community’s initiative to prepare a neighbourhood plan for Congleton and we welcome the opportunity to comment on the submission plan. The following section responds to the CNP submission document and its supporting evidence base. At this stage, we do not consider it necessary to comment on each policy contained within the CNP, rather we have sought to provide feedback with the aim to assist in creating robust policies. Our advice is intended to help the CNP in its examination in order to ensure that the CNP meets the basic conditions.
Relationship to Local Plans
To meet the requirements of the Framework and the Neighbourhood Plan Basic Conditions, neighbourhood plans should be prepared to conform to the strategic policy requirements set out in the adopted Development Plan. The adopted development plan relevant to the preparation of the CNP is the Cheshire East Local Plan Strategy (CELPS). The CELPS was adopted in July 2017 and sets out policies for the use and development of land across the whole of the borough. Within the CELPS, Congleton is identified as a Key Service Centre and was a key focus for growth, albeit much of the planned growth is adjacent to the Town Council administrative area, in neighbouring parishes.
Cheshire East Council have commenced work on preparing a new Local Plan which will be prepared under the ‘new style’ plan making framework. The introduction from central government of the revised standard method for calculating local housing need in England using the stock-based approach, has resulted in a significantly higher housing requirement for Cheshire East than the current adopted housing requirement, and will likely require all settlements to play their part in accommodating additional growth, especially the larger, more sustainable towns, such as Congleton.
Whilst it is expected that the CNP will be ‘made’ in advance of any firm progress on the Cheshire East Local Plan, it will nonetheless be crucial for Congleton Town Council to keep abreast of this process and any impacts that this could have on the Neighbourhood Plan. To this extent, Gladman welcome the acknowledgement set out in the ‘Monitoring and Review’ section of the CNP that there are a number of circumstances under which a partial review of the Neighbourhood Plan may be necessary, such as revisions to existing local plan documents. Whilst reference is made to changing local plan documents, the wording does not explicitly reference the emerging Cheshire East Local Plan, and we suggest that the draft Neighbourhood Plan could benefit from a commitment to undertake a review upon adoption of the Local Plan.
Policy 15 – Congleton’s Landscape Character
Gladman agrees any new development should enhance the local landscape character, however, believe that the policy wording should provide greater flexibility. The policy identifies six locally important landscape areas on Map 7 and seeks to restrict any new built form within these landscape areas to small scale. Gladman consider that this approach would limit the growth of Congleton and acts as a barrier to development. Four of the six landscape areas directly adjoin the settlement edge and limiting growth in these areas to only small scale could limit future sustainable opportunities, this is especially pertinent in the context of the increase in local housing need for Cheshire East and the important role which Congleton is likely to play in ensuring that the authority’s housing needs are met in full.
Gladman believes that with sensitive design, development can minimise any impact on the designated areas and be able to provide features to enhance the designated landscape areas.
Policy 18 – Views, Vistas and Gateways
Policy 18 of the CNP requires development to protect or enhance key views, vistas and landmarks where relevant. Map 8 shows the key views and vistas within and from Congleton, taken from the Congleton Landscape Character Assessment. The assessment was published in 2020, prior to the completion of the Congleton bypass. The bypass covers areas north and west of the settlement and therefore may affect some of the identified views within these areas. Gladman would recommend that to be for the evidence to be a sound base from which to base this policy on, the Landscape Character Assessment should be updated given the new context.
Conclusion
Gladman are broadly supportive of the proposed policies of the CNP and its content and we commend the Neighbourhood Plan Development Working Group in the work to date. Through our consultation response, Gladman has sought to clarify the relationship of the draft CNP as currently proposed with the requirements of national planning policy and the strategic policies for the wider area. Gladman would like to highlight that the above consultation response is not a criticism of the work put into the draft CNP so far.
Should further clarification be needed on points raised above, the Working Group are welcome to contact Richard Naylor at r.naylor@gladman.co.uk.
Yours sincerely
Richard Naylor
Dear Cheshire East Neighbourhood Planning Team,
RE: Congleton Neighbourhood Plan – Regulation 16 Response
This letter provides Gladman Developments Ltd (Gladman) representations in response to the
submission version of the Congleton Neighbourhood Plan (CNP) under Regulation 16 of the
Neighbourhood Planning (General) Regulations 2012. This letter broadly supports the general
direction of the CNP whilst also suggesting some changes that may be beneficial to the wider
content of the plan.
Legal Requirements
Before a neighbourhood plan can proceed to referendum, it must be tested against a set of
basic conditions set out in paragraph 8(2) of Schedule 4b of the Town and Country Planning
Act 1990 (as amended). The basic conditions that the CNP must meet are as follows:
“(a) Having regard to national policies and advice contained in guidance issued by the
Secretary of State, it is appropriate to make the order.
(d) The making of the order contributes to the achievement of sustainable development.
(e) The making of the order is in general conformity with the strategic policies contained
in the development plan for the area of the authority (or any part of that area).
(f) The making of the order does not breach, and is otherwise compatible with, EU
obligations.
(g) Prescribed conditions are met in relation to the Order (or plan) and prescribed matters
have been complied with in connection with the proposal for the order (or
neighbourhood plan).”
National Planning Policy Framework
The National Planning Policy Framework (the Framework) sets out the Government’s planning policies for England and how these are expected to be applied. In doing so it sets out the requirements for the preparation of neighbourhood plans to be in conformity with the strategic priorities for the wider area and the role they play in delivering sustainable development to meet development needs.
Planning Practice Guidance (PPG) makes clear that neighbourhood plans should conform to national policy requirements and take account of the most up-to-date evidence. This is so that APC can assist Melton Borough Council (MBC) in delivering sustainable development and be in accordance with basic condition (d).
Congleton Neighbourhood Plan
Gladman support the community’s initiative to prepare a neighbourhood plan for Congleton and we welcome the opportunity to comment on the submission plan. The following section responds to the CNP submission document and its supporting evidence base. At this stage, we do not consider it necessary to comment on each policy contained within the CNP, rather we have sought to provide feedback with the aim to assist in creating robust policies. Our advice is intended to help the CNP in its examination in order to ensure that the CNP meets the basic conditions.
Relationship to Local Plans
To meet the requirements of the Framework and the Neighbourhood Plan Basic Conditions, neighbourhood plans should be prepared to conform to the strategic policy requirements set out in the adopted Development Plan. The adopted development plan relevant to the preparation of the CNP is the Cheshire East Local Plan Strategy (CELPS). The CELPS was adopted in July 2017 and sets out policies for the use and development of land across the whole of the borough. Within the CELPS, Congleton is identified as a Key Service Centre and was a key focus for growth, albeit much of the planned growth is adjacent to the Town Council administrative area, in neighbouring parishes.
Cheshire East Council have commenced work on preparing a new Local Plan which will be prepared under the ‘new style’ plan making framework. The introduction from central government of the revised standard method for calculating local housing need in England using the stock-based approach, has resulted in a significantly higher housing requirement for Cheshire East than the current adopted housing requirement, and will likely require all settlements to play their part in accommodating additional growth, especially the larger, more sustainable towns, such as Congleton.
Whilst it is expected that the CNP will be ‘made’ in advance of any firm progress on the Cheshire East Local Plan, it will nonetheless be crucial for Congleton Town Council to keep abreast of this process and any impacts that this could have on the Neighbourhood Plan. To this extent, Gladman welcome the acknowledgement set out in the ‘Monitoring and Review’ section of the CNP that there are a number of circumstances under which a partial review of the Neighbourhood Plan may be necessary, such as revisions to existing local plan documents. Whilst reference is made to changing local plan documents, the wording does not explicitly reference the emerging Cheshire East Local Plan, and we suggest that the draft Neighbourhood Plan could benefit from a commitment to undertake a review upon adoption of the Local Plan.
Policy 15 – Congleton’s Landscape Character
Gladman agrees any new development should enhance the local landscape character, however, believe that the policy wording should provide greater flexibility. The policy identifies six locally important landscape areas on Map 7 and seeks to restrict any new built form within these landscape areas to small scale. Gladman consider that this approach would limit the growth of Congleton and acts as a barrier to development. Four of the six landscape areas directly adjoin the settlement edge and limiting growth in these areas to only small scale could limit future sustainable opportunities, this is especially pertinent in the context of the increase in local housing need for Cheshire East and the important role which Congleton is likely to play in ensuring that the authority’s housing needs are met in full.
Gladman believes that with sensitive design, development can minimise any impact on the designated areas and be able to provide features to enhance the designated landscape areas.
Policy 18 – Views, Vistas and Gateways
Policy 18 of the CNP requires development to protect or enhance key views, vistas and landmarks where relevant. Map 8 shows the key views and vistas within and from Congleton, taken from the Congleton Landscape Character Assessment. The assessment was published in 2020, prior to the completion of the Congleton bypass. The bypass covers areas north and west of the settlement and therefore may affect some of the identified views within these areas. Gladman would recommend that to be for the evidence to be a sound base from which to base this policy on, the Landscape Character Assessment should be updated given the new context.
Conclusion
Gladman are broadly supportive of the proposed policies of the CNP and its content and we commend the Neighbourhood Plan Development Working Group in the work to date. Through our consultation response, Gladman has sought to clarify the relationship of the draft CNP as currently proposed with the requirements of national planning policy and the strategic policies for the wider area. Gladman would like to highlight that the above consultation response is not a criticism of the work put into the draft CNP so far.
Should further clarification be needed on points raised above, the Working Group are welcome to contact Richard Naylor at r.naylor@gladman.co.uk.
Yours sincerely
Richard Naylor
