Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15007

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15566
Policy CH1 proposes to build on Chester’s cultural and heritage assets, leveraging its strengths as a compact, well-connected centre surrounded by accessible neighbourhoods. The strategy focuses on sustainable travel, placemaking, urban living, office space, and enhancing the vibrancy of the city centre. The proposed approach retains the content of existing policies STRAT 3 (Chester), CH1 (Chester settlement area), CH4 (University of Chester), CH5 (Chester conservation areas), and CH6 (Chester key views, landmarks, gateways, and historic skyline). However, policies relating to parking will be amended to encourage new residential and other uses within the city centre. Bloor supports the inclusion of a place-based policy for Chester, recognising its role as the primary settlement within the Borough. However, there is concern that the policy does not place sufficient emphasis on the role of residential development to meet the City’s needs. The policy should explicitly support the delivery of new homes in Chester, through a combination of urban infill and edge-of settlement suburban development. This is essential to maintaining Chester’s status as a key regional centre and ensuring its continued vitality and sustainability.

Comment

Representation ID: 15008

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15567
Policy TA1 sets out an overarching approach to minimise the need for travel by locating developmentwhere it is accessible to local services and facilities via a range of transport modes. This is guided by a vision-led strategy and a sustainable transport hierarchy. The policy specifies that new development should maximise opportunities for residents to meet their day-to-day needs within a reasonable walking distance (10 minutes or 800 metres) of their homes, while also enabling travel beyond their settlements through a variety of sustainable transport options. In relation to parking, TA1 proposes a flexible approach to parking standards that reflects the varying levels of non-car connectivity across the Borough and allows for future changes in connectivity.  Bloor supports the principles set out in TA1, particularly the emphasis on sustainably located development with access to services and multiple transport modes. In this regard, the site is located adjacent to the primary settlement of Chester, with a significant range of services and facilities with the city, and numerous transport options from the site. Regular bus services are available from Whitchurch Road and Boughton Heath Park and Ride, and the Shropshire Union Canal provides a direct pedestrian and cycle link separate from vehicles into Chester City Centre (National Cycle Network route 45), consistent with the principles of TA1. With regard to parking standards, Bloor supports the flexible approach outlined in TA1 and the consideration of future connectivity needs. However, Bloor requests that sufficient flexibility is maintained by avoiding the imposition of restrictive maximum parking standards across the Borough.

Comment

Representation ID: 15009

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15568
Policy HO1 outlines that the new approach to housing types and mix will be informed by a forthcoming Housing Needs Assessment [HNA]. This assessment will underpin specific policy requirements, including percentage splits for housing mix, provision of plots for self-build and custom homebuilding, and measures to meet the needs of an ageing population and residents with disabilities. Bloor supports the Council’s intention to deliver an appropriate mix of housing to meet the needs of the wider community. However, it is essential that this policy is applied with flexibility to ensure that individual sites can respond to market conditions. Certain locations may be better suited to a housing mix that differs from the recommendations of the HNA particularly in a location such as Chester where the majority of the units coming forward in the urban area are likely to be smaller apartment type developments. A rigid application of percentage-based requirements would not reflect the diverse local conditions across the Borough. Therefore, if specific percentage targets are pursued, Bloor recommends that these be expressed as ranges, with additional wording included to allow for flexible interpretation where justified. Furthermore, viability testing of the proposed housing mix policy will be necessary as part of the emerging Local Plan particularly given the high CIL charge in Cheshire West and Chester. This testing should be completed in advance of the Regulation 19 version of the Plan to ensure that the policy is deliverable and does not undermine the viability of development. Additionally, it is unclear whether Cheshire West and Chester will be undertaking a review of the adopted CIL Charging Schedule as part of this process, therefore Bloor would welcome clarity on this matter.

Comment

Representation ID: 15010

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15569
Policy HO2 proposes to set a percentage requirement for affordable housing across the Borough, with the potential for this to vary by sub-area. It is noted that a minimum of 50% affordable housing will be required on Green Belt sites, and that the policy will specify the types of affordable housing to be delivered. Additionally, Policy HO2 proposes that affordable housing will be required on all sites of 10 or more dwellings, with the threshold reduced to three or more dwellings in designated rural areas. Bloor supports the inclusion of affordable housing in new developments and agrees that a threshold of 10+ dwellings is appropriate for triggering this requirement. Bloor also supports the potential for subarea variation, ensuring that affordable housing provision reflects local market conditions and housing needs across the Borough. Viability testing of the proposed affordable housing requirements will be essential and must be undertaken as part of the emerging Local Plan, ahead of the publication of the Regulation 19 version.

Comment

Representation ID: 15011

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15570
HO 3 proposes to retain existing Policy DM 19 (Proposals for residential development), which provides the requirements for residential developments within identified settlements, the countryside, and the Green Belt. Bloor supports the proposed retention of Policy DM 19 on the basis that the flexibility that allows for development within the Green Belt to align with the provisions in the NPPF are retained, ensuring that local policy regarding development in the Green Belt does not become out of date or unreflective of national policy. Bloor does however request that specific references to the development of ‘grey belt’ land are made within the updated policy, ensuring that it is clear that development of such land is appropriate for residential development, subject to requirements of NPPF Paragraph 155 being applied.

Comment

Representation ID: 15012

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15571
GI 1 proposes to create a single policy relevant to green infrastructure, biodiversity and nature, with considerations on biodiversity net gain, tree replacement rates, and agricultural land. Bloor supports the streamlining of the numerous existing policies into one appropriate policy to cover this.  

Comment

Representation ID: 15013

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Emery Planning Partnership

I&O_15572
It is not considered appropriate for the Council to require a biodiversity net gain above the necessary 10% as set out under the Environment Act, however. The PPG noted that plan-makers 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 (Paragraph: 006 Reference ID: 74-006-20240214). To justify such policies, evidence will need to be provided as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development, which has not been considered at this time. Without sufficient justification, pursuing an increased requirement would not align with the appropriate guidance, and may render development across the Borough unviable, particularly in areas where the market is less strong.