Weston and Crewe Green Neighbourhood Plan Regulation 16 Consultation

We have been instructed to submit comments in response to the Regulation 16 Consultation on the Weston and Crewe Green Neighbourhood Plan on behalf of the Duchy of Lancaster.

We understand the current consultation version of the Neighbourhood Plan follows the adoption of two previous versions that include the original Weston and Basford Neighbourhood Plan (made on 18 December 2017) and a modified version that was made on 20 February 2024. As such, the latest version that is currently being consulted on, is intended to address alterations to the Parish Council administrative boundary following an extension of the boundary to include the Parish of Crewe Green and the removal of the area of Chorlton Parish. It is therefore understood that the thrust of most of the policies remain largely the same, but have been updated to address the implications of extending the designated area, as determined by the Neighbourhood Area Decision Notice dated 8 March 2024.

Neighbourhood Plans have an important role in shaping development on a local level and so the Weston and Crewe Green Neighbourhood Plan is welcomed, especially as it includes a detailed understanding of the elements and features that define the character of the neighbourhood plan area. The policies in the neighbourhood plan subsequently provide a clear steer in relation to the appearance and character of development to be supported based on a detailed analysis and appreciation as to the means for conserving and enhancing the character of the neighbourhood area going forward.

Policy E1
We understand that a number of additional viewpoints have been identified on the “Location map of local views and vistas” included on page 17 due to assessment of the extent of the enlarged designated area. The additional views are 9, 10, 11, 12, 13.

In respect of view 9 on page 62, it appears the photograph has been taken some distance along a private track off Barthomley Road rather from Barthomley Road itself, as is hopefully illustrated by the screenshot from Google Maps under Figure 1 (please refer to emailed version of the same comments). Given that a hedge runs along Barthomley Road and views are only fleetingly offered by gaps serving access points or undulations in the topography over the tops of hedges then we question whether the view point is of public interest, especially as the photograph has been taken from private land. We would therefore ask for the inclusion of view point 9 to be considered for deletion or else amended so the photograph is taken from Barthomley Road itself and offers a clear vista. If no clear vista can be achieved without obstruction from hedges or as views are only of short distances due to the undulating topography then we would suggest that the view point should be deleted on the basis that the open rural setting is not readily visible.

With regard to view 11 on page 63, the photograph is a close-up of a view above an established roadside hedge where the image focuses on a relatively short distance view created by the undulating topography. As such, the photograph does not offer a long distance view of the Green Belt beyond as there is no true depth to the photograph.

Additionally, the photograph and the arrow shown on the map on page 17 are at an angle that suggest looking across Old Park Road from one side to the other. There are no stopping places or properties from which the view point might be appreciated as Old Park Road is one of the main roads serving the wider area and is subject to the national speed limit. As such, drivers should be focused Old Park Road rather than the view from the side window, especially given the speed of the road.

Furthermore, the intention of the photograph and arrow are explained to be with a view to protecting views from the proposed South Cheshire Growth Village across to the east, but the photograph is taken from a position where there is a tree belt directly behind the photographer and development is to be delivered in the vista of the photograph. This is on the basis that development is proposed on land between the south side of Old Park Road and the railway line.

As such, views from Old Park Road or the South Cheshire Growth Hub are unlikely to be gained from the position or angle shown by the arrow and it is questionable as to whether the photograph represents the view that the policy seeks to protect. Given that paragraph 13 of the National Planning Policy Framework sets out that neighbourhood plans should support the delivery of strategic policies and paragraph 30 refers to how neighbourhood plans should not undermine strategic policies then it appears the viewpoint runs contrary to the allocation of the South Cheshire Growth Hub because of the intention for development to be delivered within the vista identified by the arrow and photograph. We would therefore like to suggest that view 11 is deleted, especially as there do not appear to be any public vantage points within the extent of land that is allocated that might offer views eastwards.

With reference to view 12, the arrow suggests the photograph has been taken from Weston Road when it has, in fact, been taken from the private driveway that serves Crewe Hall Hotel. As the view is from a private driveway that serves only a hotel then it is questionable whether the viewpoint is in the public interest, as it is not widely available to the general public. Furthermore, the view is of a Registered Park and Garden, and therefore subject to national planning policy and legislation concerning heritage assets. Consequently, it should not be necessary for the Neighbourhood Plan to include policies concerning a designation that is already dealt with at a more strategic level. We would therefore like to suggest that view 12 is deleted due to the duplication with the heritage designation.

Policy E2
We appreciate the latest version of the Neighbourhood Plan is simply intended to respond to administrative changes to the parish boundary and that the policy and supporting plans are being carried across from previous made versions, but we would like to comment on Plan 3 and Plan 4 within the Neighbourhood Plan and policy E2.

Having reviewed the Natural Environment Report, it appears that the wildlife corridors illustrated on Map 10 (which is also Plan 3 within the Neighbourhood Plan) and the medium distinctives habitats on Map 9 (Plan 4 within the Neighbourhood Plan) have been defined largely on the basis of merging the extent of the deciduous woodland from Map 3 and broadleaf woodland from Map 4. The high habitat distinctiveness areas shown on Map 9 (Plan 4 within the Neighbourhood Plan) then reflect the Local Wildlife Sites and Potential Local Wildlife Sites shown on Map 6 within the Natural Environment Report.

Whilst the means of identifying the wildlife corridors and distinctive habitats appear to be a reasonable starting position, we are concerned that it is rather rudimentary given the lack of site survey and fails to consider overlapping statutory designations. As such, policy E2 simply aims to protect existing wildlife corridors and distinctive habitats without due regard to the condition of the woodlands or other planning matters, including heritage. The root of this comment is because the area of woodland that dissects the Registered Park and Garden on the north side of Crewe Hall is identified as a medium distinctiveness habitat and part of the defined wildlife corridor. However, the woodland consists of the original landscape scheme attributed to William Andrews Nesfield and then an area of poplars that were planted after 1941 following the draining of the lake which had formed part of the original landscape design. The “Bryant's Map of Cheshire 1831" on page 70 of the Neighbourhood Plan illustrates the extent of the original lakes. As such, there is a potential conflict in so far as if a scheme were to be brought forward for the restoration of the Registered Park and Garden then it would be contrary to policy E2. We would therefore be grateful if amendments could be considered to criteria a and c of policy E2 so as to avoid unnecessary conflicts between planning policies and designations.

In respect of criterion a, we would like to suggest the policy clause is amended to read (please refer to emailed version of our comments for underlining of new words) “Planning applications will only be supported if they demonstrate that they will not adversely affect designated wildlife habitats in the plan area, unless the benefits would outweigh the potential for harm (See note 1).”

With regard to criterion c, we would like to suggest the wording is amended to read “Development proposals which create barriers to the movement of wildlife along wildlife corridors within the plan area will be resisted (See note 3). Development proposals should enhance and / or preserve the connection between corridors and wildlife sites.”

The suggested changes are subtle but will ensure the criteria are consistent with other planning policies and the way in which planning applications are expected to be determined with reference to Section 38(6) of the Planning and Compulsory Purchase Act 2004; section 70(2) of the Town and Country Planning Act 1990; and paragraph 11 and Sections 15 and 16 of the National Planning Policy Framework.

Next Steps
Neighbourhood plans are an important element of the planning system and offer a truly local opportunity to shape development, especially with a view to protecting and enhancing the natural and built environment. We therefore welcome the efforts of the Parish Council in drafting the Weston and Crewe Green Neighbourhood Plan and the opportunity to have had chance to comment on the draft document.

We trust our comments will assist in ensuring the neighbourhood plan is robust and effective in its application.