Local plan scoping consultation

Comment

Representation ID: 2956

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

- Support the transition to net zero by 2050 and shape places in ways that are more resilient to the effects of climate change.
- Ensure there is a sufficient supply of minerals, essential to provide the infrastructure and goods the country needs.
- Support the sustainable reuse of cavities created through mineral extraction.
- Recognise that some energy infrastructure is location-specific, because its siting depends upon geology, existing infrastructure, network connections, pipeline corridors etc
- expressly acknowledge that such infrastructure may need to be located outside existing settlements and in the open countryside;

Comment

Representation ID: 2957

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

Since commencement of the current Cheshire East Scoping Consultation the Government has published their new National Planning Policy Framework (17 August 2026). In developing the new Plan, the Council should ensure that it reflects the key changes set out within the new NPPF:
- 30-Month Preparation Window: New-style local plans must be fully prepared and adopted within 30 months of publishing the Gateway 1 scoping assessment.
- 5-Year Update Cycle: Local authorities must begin preparing their next local plan no later than 5 years after adoption of the current plan.
- Commencement: Work on replacement plans must start sooner if recommended during an examination or there is a significant local change.
- Transition: The legacy plan-making system runs in parallel for a limited duration, with December 31, 2026, acting as the final submission date for older-style plans.
- Time Period – Local Plans should cover a minimum 10-year period.
- Site Identification – Local Plans should identify “appropriate sites” for development (change form “the most appropriate sites”).
If relevant to the development, adoption and implementation of the new Local Plan, then the Council should acknowledge the recent (Feb 2026) transfer of powers from Parliament to Cheshire and Warrington through the establishment of the Combined Authority, and election of a Mayor in 2027. The potential implications arising from these changes on the adoption programme should be made clear.

Comment

Representation ID: 2972

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

The scope provides an opportunity to establish a positive policy framework for energy infrastructure in locations that are necessarily rural / open countryside.
Priority matters for inclusion within the vision, aims and objectives should include:
- Support the transition to net zero by 2050 and shape places in ways that are more resilient to the effects of climate change. This is an objective of the new NPPF, and the Local Plan should incorporate policies that would support and deliver the necessary infrastructure.
- Identify opportunities for green infrastructure provision.
- In accordance with the new NPPF (Chapter 11) ensure there is a sufficient supply of minerals, essential to provide the infrastructure and goods the country needs. Since minerals are a finite natural resource, and can only be worked where they are found, best use needs to be made of them to secure their long-term conservation.
- Support the sustainable reuse of cavities created through mineral extraction.
- In relation to industrial minerals, use evidence of site capacities and demand to identify the level of provision needed to maintain a continuing level of supply for their use in industrial and manufacturing processes. Identify how these requirements can be met through the allocation of sites or identification of preferred areas, taking into account the distribution of industrial minerals.
The new Local Plan should:
- recognise energy infrastructure as a distinct land-use need, rather than treating it simply as another form of development competing with housing or employment land;
- recognise that some energy infrastructure is location-specific, because its siting depends upon geology, existing infrastructure, network connections, pipeline corridors, substations, gas networks, salt geology, operational requirements and other technical factors;
- expressly acknowledge that such infrastructure may need to be located outside existing settlements and in the open countryside;
- avoid applying settlement-focused sustainability criteria mechanically to infrastructure whose appropriate location is determined by technical/network considerations;
- provide a positive policy framework for energy storage, gas infrastructure, electricity infrastructure and emerging low-carbon energy technologies;
- distinguish between the different types of energy development, rather than adopting a blanket policy which effectively treats all gas-related infrastructure as equivalent to conventional fossil-fuel development;
- require the site-selection process to consider technical suitability and strategic energy-system benefits alongside landscape, ecology, heritage, flood risk and other environmental considerations;
- recognise opportunities for co-location and multi-functional energy sites, including storage, renewable generation, grid infrastructure and future low-carbon technologies;
- safeguard important energy infrastructure corridors and sites from incompatible development; and
- provide a clear route for development which is demonstrably appropriate in the countryside, subject to proportionate environmental assessment and mitigation.
The current Cheshire East policy, PG6, restricts open-countryside development to specified categories, including public infrastructure, essential works by public service authorities/statutory undertakers and other uses appropriate to a rural area. A new policy could make the treatment of energy infrastructure much more explicit and avoid arguments about whether a particular facility happens to fall within an existing exception.

Comment

Representation ID: 2973

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

We concur with the recognition that the local plan should make provision for mineral and associated infrastructure needed to support sustainable growth, through the identification of sufficient land to meet the identified need. This should also include associated development that may fall under separate use class (e.g. renewable and low carbon infrastructure that due to its nature and type may be most appropriately located within mineral or industrial sites).
The current national energy policy recognises the continuing importance of gas storage and gas infrastructure to energy security during the transition to net zero. The Government's EN-4 specifically addresses underground gas storage and explains that suitable storage locations are constrained by geology. The spatial strategy needs to recognise that certain energy infrastructure cannot be distributed according to conventional settlement hierarchy principles because its location is dictated by technical and physical characteristics. For underground gas storage in particular, the national policy explicitly identifies geology as a factor limiting where facilities can be located, including the availability and characteristics of suitable salt formations.

Comment

Representation ID: 2974

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

We agree that to meet objectively assessed needs, it is important to identify a range of sites to give greater choice. Minerals can only be worked where they are found, and consequently the approach to site identification needs to reflect this unique status. Mineral sites were submitted through previous call for sites (2017 onwards). We understand that these are being reviewed and will be updated with promoters before assessment. This should include those representations made previously by Kistos Energy Gas Storage Limited and EDF (Hole Gouse Gas Storage) Limited. It is recognised that an initial site assessment and allocation options will be published at a later stage of the plan making process, and we would welcome engagement as that process develops. It is important that any site assessment recognises that energy sites cannot simply be assessed using the same locational criteria as housing and employment sites. For example, a conventional housing site might score positively because it is close to a settlement, shops, schools and public transport. For an underground gas storage facility, those characteristics may be almost irrelevant. What matters instead include:
- geological suitability;
- proximity to the gas transmission/distribution network;
- pipeline connection;
- pressure and capacity;
- electricity connection;
- access for construction and maintenance;
- separation from sensitive receptors;
- operational safety requirements;
- land availability;
- environmental constraints;
- potential for expansion;
- ability to integrate with other energy infrastructure; and
- strategic contribution to energy security and system flexibility.
Future site assessment methodology should contain a dedicated methodology for energy infrastructure, or at least technology-specific criteria.
5.20 Settlement Hierarchy
The approach to Settlement Hierarchy should follow that within the newly published NPPF, with recognition to the new Chapter 4 on achieving sustainable development and the presumption in favour of it.

Comment

Representation ID: 2975

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

In seeking to enable businesses to invest, expand and adapt, Chapter 7 of the new NPPF requires Local Plans to allocate sites to implement the economic vision and strategy over the plan period. This removes previous criteria-based policy reliance, replacing it with certainty afforded by allocations. The proposed scope follows this approach and we support it. In addition to new sites, it should recognise the need of existing industrial and commercial employers to expand and develop, and policies of the Local Plan should help to facilitate that expansion. It should also recognise that industrial development may be required to diversify in order maintain growth. Policies should not unreasonably restrict opportunities for sustainable growth.

Comment

Representation ID: 2976

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

We agree that the Local Plan should establish a minerals strategy based on an understanding of the Borough’s mineral resource, future demand and environmental and community constraints. It recognises that plans need to maintain a sufficient supply of minerals and national and local importance, including salt (brine). The document acknowledges that salt is one of the borough’s most important mineral resources (accounting for around 85% of the UK salt production). It is a critical mineral essential to chemicals, pharmaceuticals and food production. The Plan therefore needs to ensure sufficient long-term supply. This approach is broadly supported.
The Plan also recognises that former salt caverns provide naturally important gas storage facilities, and may have future potential for other uses (hydrogen, carbon storage, compressed air etc). The relevant policies of the plan should seek to support the flexible options that may come forward during the plan period, that can help deliver economic growth, ensure self-sufficiency, drive towards net zero, and safeguard against dependence on less dispatchable options.
We support the identification of Mineral Safeguarding Areas, and we support the ongoing identification and allocation of sites for future development. Kistos Gas Storage Limited would support working collaboratively with the Council in the development of their Local Plan to ensure that these opportunities can be delivered in a timely manner.

Comment

Representation ID: 2977

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

Policy should establish that development in the countryside can be appropriate where:
- the development is required to meet an identified energy, infrastructure or decarbonisation need;
- its location is justified by technical, operational, geological or network considerations;
- there is no reasonably practicable alternative location which would deliver the same strategic function with materially less environmental harm; and
- appropriate mitigation, landscape treatment, restoration and biodiversity measures are secured.
The Council's emerging approach places considerable emphasis on landscape, ecology, agricultural land, Green Belt, heritage and flood risk when distributing development. This is an acceptable approach; however, proportionality and technology-specific assessment should be recognised. Energy infrastructure which is necessarily located in the countryside should not be regarded as inherently inappropriate merely because it is outside a settlement boundary. Its acceptability should depend upon the characteristics and strategic function of the infrastructure, the sensitivity of the receiving environment, the availability of alternatives and the effectiveness of mitigation.

Comment

Representation ID: 2978

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

The Plan recognises the need for sustainable climate change adaptation. Meeting the challenge of climate change now has its own chapter within the new NPPF, in recognition of the fact that the Government sees this as a pillar of future planning need. The Brinefield at Warmingham provides a unique opportunity to deliver strategic scale solutions (large scale long-term energy storage and low carbon alternatives) that could prove critical in the UK meeting their legal obligations. The Local Plan should recognise this opportunity, and ensure that the policies of it do all possible to help deliver the development needed. This should sit central to the Local Plan aims and objectives.
The Council proposals a specific section on Renewable and Low Carbon Energy, stating that the Plan should support renewable and low-carbon generation, larger renewable schemes and flexible energy systems.

Comment

Representation ID: 2979

Received: 28/08/2026

Respondent: Kistos Energy Storage Limited

Agent: Axis

We support the move to ensuring good design, and for plan-making the shift in the NPPF towards greater reliance on national guidance, with local plans focussing on locally specific design matters rather than duplicating national policy.