Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14599

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15149
On the basis of the Council’s LDS, assuming adoption in Autumn 2027, the minimum plan period will be the 31st March 2043 so that there is a full 15-year period at adoption. However, this assumes that there are no delays between now and then, which in our view is unrealistic. It is also important to note that Local Plan examinations have historically taken multiple years. Specific examples include the Cheshire East Local Plan Strategy which took over 3 years and the Halton Delivery and Allocations Plan which took 2 years. More recently, Planning Inspectors have paused public hearings being held as part of the examination into the Charnwood Local Plan 2021-2037. This demonstrates the issues and delays can take place during the examination process. This issue has also been recently by the Inspectors for the Wiltshire Local Plan and in their letter dated 27th February 2025 state: “The revised spatial strategy topic paper (SD/16) shows the Plan period of 2020-2038 commencing in advance of the date of the most up-to-date calculation of Local Housing Need. In that regard, the plan period would look forward around 13 years from the current date which the Council seeks to justify as being 15 years from the date of the assessments of housing and employment needs. However, paragraph 22 of the Framework (September 2023) expects strategic policies to look ahead over a minimum of 15 years following adoption of the Plan. As a result, the submitted Plan would not appear to look sufficiently far ahead to anticipate and respond to long-term requirements and opportunities. We identify this matter to you at this early stage as it is clearly a matter of concern and one which will have implications for the rest of the examination, including our consideration of whether the Plan is positively prepared and consistent with national policy with respect to the overall amount of housing and employment land to be identified.” We consider that an element of flexibility is built in at the outset and the plan period should be to 2045.

Comment

Representation ID: 14600

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15150
We support the proposal for the larger settlements to have an individual vision. For Northwich, this vision should reflect the potential of the settlement to accommodate significant levels of growth to meet the development needs of the borough.

Comment

Representation ID: 14602

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15152
No. The publication of the revised Framework in December 2024 and the new Standard Method sets out a minimum need for 1,914 dwellings per annum. (See attachment - NPPF paragraph 62; Annex 2; PPG paragraph 003, 14) Paragraph 14 is not applicable in Cheshire West as the authority boundary aligns with the local plan boundary. Therefore, the standard method is mandatory in Cheshire West. As to whether the housing requirement can vary from the standard method, paragraph 040 (Reference ID: 2a-040-20241212) of the PPG states: “What is a housing requirement? The housing requirement is the minimum number of homes that a plan seeks to provide during the plan period. Once local housing need has been assessed, as set out in this guidance, authorities should then make an assessment of the amount of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters. The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The National Planning Policy Framework explains that the housing requirement may be higher than the identified housing need, and authorities should consider the merits of planning for higher growth if, for example, this would seek to reflect economic growth aspirations. Where authorities plan for higher growth this should not normally have to be thoroughly justified at examination.” Paragraph 40 states that authorities, once they have made an assessment of need, then need to consider land availability, constraints on development and any other relevant matters. The only meaningful policy restrain in Cheshire West has been Green Belt around Chester, but the Government is clear that “ authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan ”. That is an ongoing process as part of the evidence base but the Government is clear that a Green Belt review must be undertaken. With the potential exception of the Green Belt around Chester, we do not consider that there are any constraints that would result in a conclusion that the standard method cannot be met once the HELAA and Green Belt review has been undertaken given the availability of land around the settlements in the Borough. With the standard method as a minimum, the only other alternative in the PPG is a higher requirement which is expressly set out in paragraph 14 (Reference ID: 2a-014-20241212) of the PPG and paragraph 69 of the Framework which states: “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. As part of the local plan evidence base, a Housing and Economic Needs Assessment will be undertaken and that should form part of the Council’s consideration as to the final housing requirement and that should be the subject to consultation. Therefore, at this stage the housing requirement should be a minimum of 1,914 dwellings per annum with the potential for a higher requirement based on economic development or infrastructure investment.

Comment

Representation ID: 14610

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15160
No. With the substantial shortfall in housing supply at present there will be an uplift in housing delivery as the local plan progresses so that the full annual requirement can be met in the early years with larger strategic sites that are to be allocated increasing supply throughout the plan period. In the period after the adoption of the local plan in 2015, annual completions were: • 2015-2016 – 1,769 dwellings; • 2016-2017 – 2,017 dwellings; • 2017-2018 - 2,542 dwellings; • 2018-2019 – 1,849 dwellings • 2019-2020 – 1,849 dwellings. That level of housing completions was against a requirement of 1,100 dwellings. Therefore, as the new local plan will allocate land for a higher number, we see no reason based on previous delivery that there should be a stepped requirement. Flexibility/Buffer We consider that there should be a buffer of at least 10% which is based on the Local Plans Expert Group report to the Communities Secretary and to the Minister of Housing and Planning where a 20% buffer was recommended. The report recommends at paragraph 11.4 that the Framework should make clear that local plans should be required to demonstrate a five year land supply but also focus on ensuring a more effective supply of developable land for the medium to long term, plus make provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework. The Guildford Local Plan 2019 is relevant to the issue of releasing Green Belt to provide flexibility in the housing land supply. A supply of 14,602 dwellings was provided against a housing requirement of 10,678 dwellings, equating to a flexibility allowance of 37%. Of supply, some 6,742 dwellings were to be provided on sites to be released from the Green Belt. The plan was subject to an unsuccessful Challenge (Compton PC vs Guildford BC [2019] EWHC 3242 (Admin)) which specifically addressed this point. The Judgment draws the following conclusions under Issue 2: Was the conclusion that there were exceptional circumstances justifying the allocations of housing land, released from the Green Belt, to provide headroom of over 4,000 dwellings above the 10,678 OAN lawful, and adequately reasoned? • Once meeting the OAN is accepted as a strategic level factor contributing to “exceptional circumstances”, it follows that the provision of headroom against slippage and for flexibility to meet changes, “future-proofing” the plan, as the Inspector put it, would also contribute to such circumstances (paragraph 91). • The headroom figure was a judgement based on the sites which were available to meet a requirement figure somewhat over 10,678, and to do so in such a way that, over the initial and subsequent years of the plan, the rolling five year housing supply, with a 20% buffer for some years, would be maintained (paragraph 96). • As part of the total supply, the Inspector was entitled to conclude that the plan should allocate additional sites, that may be sequentially less preferable than other sites, because they were necessary allocations in order to provide the initial five year housing land supply (paragraph 101). We consider that the above key points are broadly applicable to Cheshire West and the Plan must provide sufficient flexibility and there is a need to release additional deliverable sites to provide a five-year housing land supply and ensuring the requirement is met in the plan period. Even if there were to be a degree of over-provision, there would be wider benefits of providing a level of housing in excess of the minimum requirement, namely improving affordability and meeting affordable housing needs. Conclusion Option B under SS5 states that “the government’s new housing target of 28,170 homes” which is the 1,914 dwellings multiplied by 15 years. However, based on the above, the plan period should be longer as the start date for a plan (which should be 2025) is not the adoption date and with the need for a plan period to 2045 in our view, the housing requirement that this Plan should be meeting is for a 20 year period and should be 38,280 dwellings. With an added buffer of at least 10%, then the Plan should be meeting at least 42,000 dwellings.

Comment

Representation ID: 14611

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15161
The top tier of the settlement hierarchy is broadly similar to the settlement hierarchy in the current Local Plan Part 1. Paragraph 55 of the Local Plan Part 1 Inspector’s report (December 2014) stated: “The Plan seeks to locate the majority of new development at Chester, Ellesmere Port, Northwich and Winsford. Approximately 80% of new housing in the Borough is intended to be developed in these main urban areas. They are the largest settlements in the Borough by some way, provide the main opportunities for employment, retailing and social and community facilities and act as focal points for public transport. They possess the greatest capacity to accommodate new development. ” (our emphasis) Whilst there is a need to provide housing in the rural areas to ensure that villages can grow and thrive, the Inspector’s conclusions on Chester, Ellesmere Port, Northwich and Winsford are still applicable now in that they are the largest settlements and possess the greatest capacity to accommodate new development. Turning to Northwich, Section 5 of the Places Background Paper – Introduction identifies that: • Northwich accommodates 204 retail units – second only behind Chester in the borough. • As of 2021 there were 27,010 jobs provided in Nortwhich - second only behind Chester in the borough. • The economically active population in Northwich is 31,050 – third highest in the borough behind Chester and just behind Ellesmere Port (32,233). Northwich is also highly sustainable in terms of sustainable transport options, with frequent bus and rail services available to Chester, Manchester, Crewe, Frodsham, Knutsford and Winsford. It is therefore entirely appropriate that Northwich is identified within the top tier of the settlement hierarchy, and that it accommodates a very significant level of development as part of meeting the overall development needs of the borough.

Comment

Representation ID: 14612

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15162
Yes. There are exceptional circumstances for the release of the site from the Green Belt. At the strategic level, there is a significant need for new housing across Cheshire West and Chester. Under the Government’s standard method, the local housing need in the borough is 1,928 dwellings per annum. The Issues and Options consultation sets out three options for growth, and under Options B & C - the only options which comply with the requirement in national planning policy to meet local housing need in full – the Council’s stated position is that between 11,000 and 12,000 need to be delivered on sites which are currently in the Green Belt. In terms of Northwich, the Issues and Options document identifies that there is a need to accommodate at least 5,000 dwellings in Northwich under any of the three options consulted upon. Whilst there are some non-Green Belt options around Northwich, the Council needs to consider holistically how it can meet development needs in the most sustainable way, having regard to paragraph 148 of the Framework and the need to promote sustainable patterns of development. We set out the site-specific exceptional circumstances applicable to Weaverham South (growth option: NOR10) in our representations on the site at Section 6 of this statement.(see attachment)

Comment

Representation ID: 14613

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

I&O_15163
Under all three options, Northwich is proposed to accommodate at least 5,000 dwellings. This is logical because Northwich is a key settlement in the borough and under any scenario it should be a significant focus for development.

Comment

Representation ID: 14614

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

NOR10
I&O_15164
Bloor Homes is promoting Weaverham South, which is identified within the consultation as growth option NOR10. Details of the site and the proposed allocation are provided in Section 6 of these representations.(see attachment)

Comment

Representation ID: 14615

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

NOR10
I&O_15165
We generally support the proposed policy approach. However, we do not consider that it is justified to retain policies from the current Part 2 Local Plan when there have been material changes in circumstances, both in relation to the policy context and development needs for the new Local Plan, and also in relation to the latest position on the sites referenced in those policies. For example, we understand that the proposals for Wincham Urban Village have altered considerably since the site was allocated in the Part 1 Local Plan. This should be reflected in an up-to-date suite of policies, which also considers the deliverability of those sites over the plan period. We note that the draft policy is still being developed in relation to key allocations and related infrastructure. Our client proposes Weaverham South (Growth option: NOR10) as an allocation for residential development in section 6 of these representations. The site is capable of making a significant contribution towards meeting the housing requirements of Northwich and the wider borough, and we consider that its allocation should form a key part of the strategy for Northwich.

Comment

Representation ID: 14616

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

NOR10
I&O_15166
The sites identified as key allocations already benefit from policy support in the current development plan. However, the Council should not pre-judge the allocation of these sites, and they should be subject to the same site selection and sustainability assessment process as other prospective allocations. The should also carefully consider the latest position in relation to the deliverability of those sites. As set out above, we propose Weaverham South (Growth option: NOR10) as a key allocation / site in Section 6 of these representations.(see attachment)