Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 12044

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12558
The evidence base documents listed at paragraph 1.19 of the I&O, and within the evidence base section of the planning policy webpages, are considered to form a strong basis to inform and shape the new Local Plan. The Green Belt Study should be a Borough-wide assessment of the Green Belt, as opposed to simply focusing on an assessment of Green Belt land around Chester, as was the case in the preparation of the 2015 Part One Local Plan. This aligns with our comments later in this representation on Green Belt release across the Borough. Furthermore, the Green Belt assessment should include a specific assessment of those sites in the Green Belt that have been submitted to the Council as part of its Call for Sites, rather than those sites simply being assessed as part of a wider “parcel’ of land. This will ensure that individual sites are not identified as making a strong contribution to the Green Belt purposes as a consequence of the inclusion of additional land within a “parcel” that might not have been put forward for development and would not be suitable for development (for example, a brownfield parcel of land being assessed as part of a wider greenfield land parcel). It is considered that a Settlement Hierarchy assessment should be undertaken with clear criteria established to determine where settlements sit within the hierarchy, based on access to services, education and public transport amongst others.  A Settlement Limits Review should also be undertaken, demonstrating how settlement boundaries within each of the settlements identified for growth within the new Local Plan (to be confirmed as part of the Local Plan process) will be adjusted to accommodate new housing and (where appropriate) economic growth. This includes any existing housing commitments which remain extant and where a lawful material start has been made, and any new housing commitments that may be granted during the Local Plan preparation process. 

Comment

Representation ID: 12050

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12564
In accordance with paragraph 22 of the National Planning Policy Framework (NPPF) published in December 2024, the strategic policies of the new Local Plan should cover a minimum 15-year period from adoption. It is not considered that the Council should consider new settlements as part of its development strategy such that it would warrant an extended, 30-year Local Plan period.

Comment

Representation ID: 12051

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12565
There are a significant number of ‘made’ Neighbourhood Plans across the Cheshire West and Chester Borough. Very few of these allocate any land for housing, and housing policies contained within largely repeat the guidance contained within the Local Plan. To this end, their purpose in relation to the principle of housing development is somewhat limited. Given that it is a requirement for Neighbourhood Plan policies to conform with the strategic policies of the Local Plan, it is not considered advisable that updated and new Neighbourhood Plans be progressed until such time that the strategic policies of the new Local Plan have been tested and found sound. This would ensure that Officer time and resource is not taken up assisting with the preparation of Neighbourhood Plans that might be viewed as premature to the new Local Plan. We would encourage Neighbourhood Plans to be streamlined, to avoid repeating existing Local Plan policies. Instead, the policies contained within should instead focus on specific local needs, offering guidance on potential house types and tenures that are required in a local area, any community needs and aspirations, and any important design considerations (for example, where there is a Conservation Area). Neighbourhood Plans should not include onerous policies aimed at restricting or frustrating development that would otherwise accord with the Local Plan; instead, they should carefully facilitate development which is in accordance with the justified policies contained within it and the Local Plan to ensure that the Council’s development and spatial strategy can be met.

Comment

Representation ID: 12053

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12567
No. The Council’s new Local Plan should plan positively for growth consistent with paragraph 36(a) of the NPPF. The latter is clear that Local Plans should provide a strategy which “ as a minimum seeks to meet the  area’s objectively assessed needs.” Based on the Local Housing Needs Figures published by the Government in December 2024, the Council should therefore plan for the Local Plan’s development and spatial strategy to deliver 1,914 dwellings per year across at least a 15-year period, as a minimum (and any subsequent adjustments to this figure). Given that the adopted Local Plan covers a period of 20 years, there is no reason why a new 20-year Local Plan period could not be advanced, particularly given the considered need for strategic Green Belt release across the Borough; this would allow for amended Green Belt boundaries to endure for a longer period.

Comment

Representation ID: 12054

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12568
No. The Council’s development and spatial strategy should ensure that there is a sufficient supply of deliverable housing land across the Borough to meet its minimum housing requirement from Year One of the new Local Plan period. This can be achieved by ensuring that land is allocated for housing across the Borough, in all of the Main Towns, larger villages and smaller villages as a minimum approach. There is no reason not to adopt this positive approach to housing delivery, particularly given that a large area of the Borough is located outside of the Green Belt.

Comment

Representation ID: 12055

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12569
The identification of Chester as the City, plus the 5 no. Main Towns, is supported.

Comment

Representation ID: 12056

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12570
Yes. There is the need for a balanced distribution of housing across the Borough over the next Local Plan period. Housing land should be allocated on deliverable and developable brownfield and greenfield land (Green Belt and Open Countryside) across the Borough in the Main Towns, larger villages, smaller villages, and on lawful previously developed sites in the Green Belt and open countryside which have a degree of locational sustainability that would make them suitable for a residential land-use (consistent with paragraph 148 of the NPPF). This approach will ensure that new housing is not just directed towards the Mains Towns and larger villages, adding pressure to existing infrastructure and services; it will also mean that smaller villages and rural areas/communities are much better supported than they have been since the current Part One Local Plan was adopted in 2015.

Comment

Representation ID: 12058

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12572
Yes. The annual housing requirement of the adopted Local Plan is set at 22,000 dwellings over 20 years, at a rate of 1,100 dwellings per annum. The delivery of 1,914 dwellings per year over a 20-year period would equate to 38,280 new homes. This is a significant (74%) increase over the adopted Local Plan requirement. Even just a 15-year Local Plan period would require 28,170 new homes. Given that a significant amount of previously developed land has been redeveloped for housing since 2010 as a result of developer-led proposals, there is now a reduction in the amount of available brownfield land to meet future needs (other than land for example identified for regeneration projects, and commercial/employment uses). In line with paragraphs 145 to 147 of the NPPF, it is considered that exceptional circumstances exist to justify a change to the Green Belt boundaries across the Borough. 

Comment

Representation ID: 12060

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12574
For the reasons outlined in response to earlier questions, Option A is not considered to be an appropriate strategy to meet the Borough’s housing and economic requirements over a 15-20 year Local Plan period.

Comment

Representation ID: 12063

Received: 29/08/2025

Respondent: Beneficiaries of E C Francis

I&O_12577
Option B would underplay the role of the larger and smaller villages, with the suggestion that they would cumulatively deliver 5,500 new homes. If the requirement over a 20-year Local Plan period is 38,280 new homes, this equates to just 14% of the overall housing growth in the most sustainable settlements of the Borough (and 19.15% over a 15-year Local Plan period). This is not considered to be representative of a sustainable spatial strategy.