Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14935

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15494
Policy HO 3 (Proposals for Residential Development) states that Local Plan (Part Two) Policy DM 19 will either be retained as a separate policy or the general principles will be incorporated into other policies in the new Local Plan. With regard to residential development on land designated within the Countryside, Bloor consider that the wording of Local Plan (Part Two) Policy DM 19 should be amended to facilitate development in sustainable locations that would otherwise be wholly acceptable. In the context of current under delivery in Cheshire West and Chester, and a national housing crisis, the proposed policy should be less restrictive to enable development on Countryside land to come forward where the Council is currently unable to meet its housing need. This will ensure that there is sufficient choice and supply of land for new homes and be critical for the Council to meet its housing requirement.

Comment

Representation ID: 14936

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15495
The LPIO’s suggested approach is to combine Local Plan (Part One) Policies ENV 3 and ENV4, with elements of Local Plan (Part Two) Policies DM 44 and DM 45, to create a single new green infrastructure, biodiversity and nature policy. Bloor welcomes the streamlining of numerous existing policies into one policy. LPIO Question GI3 asks whether the new Local Plan policy should go above the statutory 10% biodiversity net gain requirement. The National Planning Practice Guidance [PPG] states that “Planmakers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” 1 In the absence of any such evidence, the proposal for Local Plan policy to be above the statutory 10% biodiversity net gain requirement would be contrary to the PPG. The implementation of such a policy without due consideration to viability, could have significant implications on development in the borough. The proposals have the potential to create a barrier to housing delivery and reduce the ability of developers to provide other contributions which may be required to make development acceptable. Furthermore, the requirement to deliver more onsite BNG has a significant effect on the ability to redevelop brownfield sites particularly where there is the presence of habitats such as Open Mosaic Habitat. Coupled with that, the delivery of onsite BNG can affect the net developable area of a site therefore requiring more land to deliver the development requirements of the plan.

Comment

Representation ID: 14937

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15496
LPIO Question QI2 asks whether the new Local Plan policy should impose a 2:1 ratio for a tree replacement policy. The Council should fully consider the impact of the proposed policy on the viability of schemes, to ensure that any future requirements do not prevent the delivery of homes. The policy should also be worded with sufficient flexibility to allow for proposals to reflect local characteristics and the efficient use of land. It would be more effective to base the replacement of trees around the value of trees lost and enable reduced provision where it can be justified through appropriate evidence. 

Comment

Representation ID: 15000

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15559
The introductory section to the LPIO consultation document provides detail on the background to the consultation, the scope of the emerging Local Plan, the evidence base, the plan period, and next steps. In particular, it is noted in this section that the Council consider the appropriate plan period to be 15 years. National planning policy specifies that strategic policies should look ahead over a minimum 15 year period from adoption to anticipate and respond to long-term requirements and opportunities. The adopted Local Development Scheme (May 2025) notes that adoption is expected in summer/autumn 2027, with a fifteen year period taking the Local Plan to 2042, Bloor considers that it would be appropriate for the Council to plan for a slightly longer period to 2045, allowing greater flexibility for any delays that are encountered during the plan making process and ensuring that the emerging Local Plan genuinely does anticipate and respond to long-term development needs.

Comment

Representation ID: 15001

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15560
VI 1 sets out the proposed vision for Cheshire West and Chester, aspiring to be a desirable and attractive place to live, work, learn and visit. VI 1 also provides four overarching principles, namely tackling climate change, promoting wellbeing, providing infrastructure and protecting character.  Bloor supports the Council’s overarching vision and the four principles by which this will be achieved. However, there is a lack of focus on new homes within this Plan. Given that the Council is seeking to establish the Borough as an attractive place to live, the delivery of new homes is fundamental to ensuring that housing provision is not only planned but also realised. As such, Bloor suggests that the overarching principles be amended to provide a more explicit focus on new homes in the Borough.

Comment

Representation ID: 15002

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15561
Policy SS1 states that the Council plans to deliver a minimum of 1,914 new homes per year over the plan period. For a 15-year plan, this equates to a total of 28,710 new homes assuming a 2025 start date. This minimum figure is based on the Council’s Local Housing Need [LHN] as of December 2024, calculated using the revised stock-based methodology introduced alongside the December 2024 iteration of NPPF. Bloor supports the Council’s use of its LHN figure in the emerging Local Plan, as it enables proactive planning to meet housing needs. However, the 1,914-dwelling requirement is no longer reflective of the current LHN. Following the release of updated housing stock data and March 2025 affordability ratios, the Council’s LHN now stands at 1,928 dwellings per year. Accordingly, the policy should reflect the most up-to-date LHN when the draft Local Plan is published as a minimum. Additional flexibility should be built into this figure to reflect the adoption date of the plan, whilst also accommodating any delays that may arise during the plan-making process. Pursuing a 20 year plan period to 2045 would increase the requirement for new homes to over 38,000 dwellings, a more appropriate figure to ensure that needs are met. Additionally, Bloor considers that a 10% buffer should be included to this figure, as recommended by the Local Plan Expert Group, to ensure sufficient flexibility, choice and competition in the market for land, which would require c. 42,000 dwellings be delivered over the 20 year period.  To accommodate this level of development, Chester should be seen as an ideal location for the development of a significant portion of the Borough’s new housing, having been identified to accommodate almost a quarter of the Borough’s residential development in the current plan period. Bloor considers that Chester, being the Borough’s largest settlement with a range of facilities and services and strong transport connectivity, should as a minimum accommodate a similar proportion of residential development as in the adopted Local Plan. Bloor does not support the use of a stepped housing requirement, as efforts should be made to meet the full annual need from the outset of the plan period. A stepped requirement in Cheshire West would be counterintuitive particularly given the immediate need for market and affordable homes in the authority coupled with the high annual delivery, which broadly aligns with the standard method requirement, over the past decade. In light of the national housing shortage, an issue affecting both the Borough and the wider North West too, it would be inappropriate for the Council to delay immediate action by backloading the requirement. This is especially the case as there are numerous deliverable sites, such as Whitchurch Road, being promoted for development which can meet needs in the early years of the plan period. Therefore, Bloor recommends that a fixed annual requirement be adopted to ensure timely delivery of the necessary number of homes.

Comment

Representation ID: 15003

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15562
Policy SS3 states that the spatial strategy will prioritise directing new development and land allocations towards previously developed sites within settlements. Where necessary, development will then be directed to the edges of existing settlements, particularly in locations with good access to public transport, services, and infrastructure, which may require the release of Green Belt land. Bloor supports this approach, recognising the importance of bringing underutilised urban sites back into active use, while also acknowledging the need for greenfield development on the edge of settlements. However, Bloor is keen to ensure that the strategy does not result in an over-reliance on urban and brownfield sites, given the potential viability challenges and the limited range of development types that such sites can accommodate. In particular, it should be noted that the Council’s own Land Availability Assessment (Stage One) report suggests that there is only capacity for c. 5,000 dwellings on previously developed land without planning permission, including undeveloped Local Plan allocations, within the main urban areas and Key Service Centres, well below the minimum number of dwellings required in the plan period and only enough to accommodate c. 2.5 years of new homes based on the Council’s LHN. It is also important to note that some settlements within the Borough, such as Chester, have a constrained supply of urban and brownfield land. Therefore, the spatial strategy should reflect the varied characteristics of the Borough and incorporate sufficient flexibility to respond to local circumstances.

Comment

Representation ID: 15004

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15563
Policy SS4 outlines that the new Local Plan will establish a settlement hierarchy based on each settlement’s role in providing infrastructure and services to its population and surrounding hinterland. The proposed hierarchy includes the following: 1 Chester (city) 2 Ellesmere Port (main town) 3 Northwich (main town) 4 Winsford (main town) 5 Neston and Parkgate (market town) 6 Frodsham (market town) Bloor supports Chester’s position at the top of the hierarchy, reflecting its large population and the breadth of services and facilities it offers. Chester presents a clear opportunity to accommodate a proportionate level of development and is the logical choice for the top-tier settlement. Ellesmere Port, Northwich, and Winsford each play an important role within the Borough and support Chester in its role as the largest settlement.

Comment

Representation ID: 15005

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15564
Policy SS5 outlines three growth options for the distribution of development across the Borough: a Option A – Retain the Green Belt b Option B – Follow current Local Plan level and distribution of development c Option C – Sustainable transport corridors Option A focuses housing development in areas outside the Green Belt, such as south of Northwich, southwest of Winsford, and around settlements like Tarporley, Tattenhall, Malpas, and Farndon. This option would retain the Green Belt and would not result in any release through the new Local Plan.  Option B proposes continuing the approach set out in the existing Local Plan, with large urban extensions around Chester, Ellesmere Port, Northwich, and Winsford, and limited development in smaller settlements. This option includes the release of Green Belt land to accommodate approximately 11,000 dwellings. Option C also involves Green Belt release, but with a more balanced distribution, with modest development around major settlements and increased development in smaller settlements with rail stations or along bus corridors. Green Belt release in this instance would accommodate in excess of 12,000 dwellings. Bloor is broadly supportive of both Option B and Option C, as they allow development to be directed to the most sustainable locations within the borough. It would be illogical to avoid such locations solely to protect the Green Belt, particularly when national policy provides a clear framework for its release.  Additionally, much of the northern part of the Borough is constrained by Green Belt. This includes the land around Chester. Allowing Green Belt release in these sustainable locations ensures that new homes are positioned close to essential services and amenities. Avoiding Green Belt release would lead to an over-reliance on smaller settlements in the south of the Borough, which often lack the same level of infrastructure and sustainability credentials. While these settlements should accommodate a proportionate level of growth, directing the majority of development to them would not represent a sustainable spatial strategy. Bloor would additionally like to highlight the latter paragraphs of SS 5, noting the findings of the Inspector’s report on the examination of the adopted Local Plan (Part One) which concluded that additional release of Green Belt land around Chester would have a significant adverse effect on thepurposes of including land within the Green Belt including to the historic setting, and that the amended Green Belt boundary proposed was capable of enduring and would not need to be altered at the end of the plan period (2030). To this regard, the Inspector’s report was published in 2014 and considered the adopted Local Plan in a vastly different policy context, and against an objectively assessed need for housing well below the current LHN. It would be inappropriate to draw out the conclusions from this report and apply this to the emerging Local Plan given the currently incomparable context. Looking to the site itself, the Cheshire West and Chester Stage One Green Belt Study, prepared in 2013 as part of the evidence base for adopted Local Plan (Part One), noted that in regard to wider 25ha study area four (Land South of Whitchurch Road), the triangular land parcel in which the site sits, there were no views in to or out of the city due to the land’s topography, and that the landscape and setting is fragmented within the parcel in relation to this Green Belt purpose (d). The Cheshire West and Chester Stage Two Green Belt Study (2013) similarly noted that whilst the removal of this parcel would impact on the area’s ability to maintain the remaining gap between Chester and Christleton and affect its role in helping to define the setting and special character of the historic city, current land use patterns have already compromised the gap between the city and the village to some degree and the new boundary following removal from the Green Belt would not reduce the distance between the city and Christleton. The argument that the release of this area in particular from the Green Belt would significantly impact the historic setting of Chester therefore does not appear to be substantiated, especially given the additional guidance on assessing the contribution land makes to the Green Belt purposes provided in the PPG (Paragraph: 005 Reference ID: 64-005-20250225). Of particular note, since the preparation of the Stage One and Two Green Belt Study, a retirement village has come forward in the northwest of the parcel on the site of the former Beechmoor Garden Centre, allowed at appeal in 2019 (ref. APP/A0665/W/18/3203413), further urbanising the wider parcel. Bloor therefore considers that it is inappropriate for the Council to rely on the conclusions of the Inspector’s report here, which are not entirely reflective of the area specific assessments undertaken to inform the adopted Local Plan. Avoiding the release of Green Belt sites in Chester on the findings of an Inspector’s report published almost 11 years prior to this consultation would be entirely illogical, particularly given efforts to direct development to the most sustainable locations. Looking to the final paragraph of SS 5, which recognises that there may be other approaches that could be taken outside of the three suggested options, Bloor would like to reiterate the importance of locating development in the most sustainable locations, regardless of Green Belt designation particularly given the existence of national policy mechanisms that allow for appropriate Green Belt release. Pursuing an option that avoids such release should not be considered appropriate given the nature of the Borough’s existing patterns of development. Bloor therefore recommends that the Council proceed with either Option B or Option C as the preferred spatial strategy for the new Local Plan.

Comment

Representation ID: 15006

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15565
The LPIO identifies four potential growth options for Chester, three of which are for housing and one for mixed use: 1 ‘CH01’: Chester North – Upton Triangle: Mixed Use, 2,359 dwellings; 2 ‘CH02’: Chester East – Piper’s Ash: Housing, 4,316 dwellings; 3 ‘CH03’: Chester South – Wrexham Road: Housing, 2,164 dwellings; and, 4 ‘CH04’: Chester North – North of Blacon: Housing, 3,141 dwellings. All four options are identified in growth Options B and C. No growth options identified for Chester correlate with spatial strategy Option A, noting the Green Belt designation of land around Chester. Bloor considers that the broad location ‘CH02’ represents the most suitable potential growth area for Chester, owing to its strong relationship with the existing settlement. The wider parcel benefits from strategic road connections public transport link into to Chester City Centre and its extensive range of facilities. The scale and location of this option offer the opportunity to accommodate a significant proportion of Chester’s growth without resulting in excessive urban sprawl. While the other identified growth options may present opportunities for expansion, Bloor considers that these would result in a more noticeable change to the settlement boundary and patterns of development that are less well integrated with the existing urban form compared to ‘CH02’. Bloor therefore recommends that the Council proceed with ‘CH02’ as the preferred growth option for Chester, ensuring the delivery of the new homes the city needs in a sustainable and well-connected location.