Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15356

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15915
Blueoak Estates supports suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough using the Government’s Standard Method. In accordance with Government policy, Council’s must seek to, as a minimum, meet their local housing needs, informed using the Standard Method (including meeting the needs of neighbouring Authorities if appropriate); unless there are strong reasons why an Authority cannot do this. Paragraph 11 in the NPPF states that: “For plan-making, this means that: b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. Blueoak Estates agrees with the Council’s view and considers that there is no reason for restricting development in CWaC, nor would doing so outweigh the benefits of meeting the Borough’s identified housing needs. As such, CWaC should plan for 1,914 new homes per annum, as an absolute minimum (and subject to considering neighbouring Authorities needs as part of its Duty to Co-operate).

Comment

Representation ID: 15357

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15916
No. A fundamental principle of the NPPF is that strategic policies should meet the full objectively assessed housing need over the entirety of the plan period. Blueoak considers that introducing a stepped housing requirement, where a lower housing target is set for early years of the plan, would be contrary to this principle and risks undermining housing delivery and consolidating issues associated with previous and ongoing under-delivery. A stepped trajectory would frontload housing undersupply into the first part of the plan period, creating a significant risk that the authority will fail to meet its Standard Method housing requirement during this time. This approach would not only delay the provision of much-needed housing but could also lead to worsening affordability issues, hinder economic growth, and constrain the local housing market at a time when demand is already acute. For these reasons, Blueoak would strongly object to the use of a stepped housing requirement and recommends that CWaC adopt a housing trajectory that seeks to deliver the full annualised housing need from the start of the plan period, thereby ensuring a sustainable supply of housing and support for the delivery of strategic objectives throughout the borough.

Comment

Representation ID: 15358

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15917
The suggested Policy Approach SS 3 outlines that the spatial strategy will follow the principle of directing new development towards previously developed sites within settlements first, as they are the most sustainable locations with the best access to services and facilities. Following this, the sequentially preferable location promoted is an approach that considers development on the edge of existing settlements, in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option. Blueoak’s site at Land to the West of Cheshire Cat aligns with the proposed Policy Approach, being situated on the edge of the Christleton Local Service Centre and within the designated Green Belt, which washes over the entire settlement. The site benefits from proximity to existing amenities and sustainable transport options, making it a logical and well-connected location for future development that supports the Council’s spatial strategy. Blueoak therefore supports the Council’s proposed policy approach to spatial strategy principles so long as they maintain the principle that edge of settlement development is sustainable and necessary, particularly where a settlement is washed over by the Green Belt. Such an approach also accords with the national policy approach to Grey Belt.

Comment

Representation ID: 15359

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15918
The Policy Approach to SS4 ‘Settlement hierarchy’ sets out the settlement hierarchy, and outlines that an individual place-based policy for each settlement will set out the vision, core features, key issues and a clear strategy for what development will take place in each settlement. Additionally, it recognises that smaller settlements which have a lower level of services and access to public transport could acceptably accommodate infill development and small previously developed sites to meet local needs. Blueoak supports the settlement hierarchy in general and wishes to emphasise that Chester, at the top of the hierarchy, should accommodate a substantial share of new development and as much as possible in the form of redevelopment of previously developed sites, including via appropriate change of use to residential, and associated supplementary development. However, developments in smaller settlements, that are appropriate in scale and design to conserve the settlements’ character and setting, are also absolutely necessary to deliver the overall housing required, both borough-wide and in relation to the smaller settlements themselves. The Policy Approach further states that “development… should not exceed the capacity of existing services and infrastructure unless the required improvements can be made.” To ensure that high-quality developments are not unfairly disadvantaged, particularly in smaller settlements where viability can be more sensitive, Blueoak recommends that the Local Plan includes clear wording: requiring that any planning contributions sought (e.g. by Statutory Consultees) are underpinned by robust, transparent evidence and methodology; and, setting out that such obligations must comply with the legal tests set out in Regulation 122 of the Community Infrastructure Levy (CIL) Regulations 2010 to ensure that contributions sought are necessary, directly related to the development and fairly and reasonably related in scale and kind to the development. Additionally, the recognition of the opportunity for smaller settlements to acceptably accommodate infill development is strongly supported.

Comment

Representation ID: 15360

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15919
Following the revisions to the Framework, there have been substantial changes to national planning policy that justify a review of Green Belt boundaries. Most notably, the revised NPPF introduces the concept of the Grey Belt, defined as land within the Green Belt that is either previously developed or does not strongly contribute to key Green Belt purposes (specifically purposes (a), (b), or (d) as set out in paragraph 143 of the NPPF). This new classification provides a more nuanced approach to assessing Green Belt land and enables local authorities to identify parcels that may be suitable for development without undermining the overall integrity of the Green Belt. The NPPF now explicitly states that exceptional circumstances for Green Belt release include situations where an authority cannot meet its identified housing or development needs through other means. Given the significant uplift in CWaC’s housing requirement under the new Standard Method, and the Council’s own acknowledgment of this in the Issues and Options consultation, such circumstances now exist. In this context, Blueoak considers that emerging Local Plan requires updating to reflect the current national policy landscape. The introduction of Grey Belt policy, combined with the pressing need to meet increased housing targets, provides a robust justification for reviewing Green Belt boundaries and identifying sustainable, well-located sites for release. In the context of Christleton, which is currently washed over entirely by the Green Belt designation. It is important to also identify appropriate and sustainable Grey Belt sites, such as this one that can make a valuable contribution to Christleton’s and CWaC’s housing needs.

Comment

Representation ID: 15361

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15920
The new standard method has led to a significant rise in CWaC’s LHN figure, increasing from 532 dpa to 1,914 dpa, equivalent to a 259.77% uplift. This represents a substantial increase compared with the current Local Plan requirement of 1,100 dpa. To ensure that the new Local Plan is robust, it is essential that CWaC’s future housing needs are based on the new Standard Method. Consequently, the Local Plan will need to allocate land beyond existing settlement boundaries to accommodate this increased level of housing demand. The site is on the edge of Christleton, comprises Grey Belt land, and has previously secured planning permission for residential development, which remains extant. Accordingly, while Option A seeks to retain the Green Belt, it remains important to recognise that certain sites, such as the subject land at Christleton, represent appropriate and sustainable opportunities to meet the borough’s significantly increased housing needs, in a way that fully accords with the national policy approach to Grey Belt.

Comment

Representation ID: 15362

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15921
Option B seeks to follow the Local Plan level and distribution of development with reference to the settlement hierarchy, by locating most new development on the edge of main urban areas or around smaller settlements which have adequate services, facilities and access to public transport. Option B recognises that “a key difference between the Local Plan (Part One) and the new Local Plan is that there is a much more limited supply of previously developed land to accommodate new development, and unlike the last plan, larger areas of Green Belt and/or countryside are likely to be needed”. Additionally, Option B sets out that 2,500 homes are expected to be delivered across the rest of the rural area, both within Green Belt and non-Green Belt land. Blueoak welcomes this recognition and considers that any growth strategy that follows Option B should reflect this situation and attribute a level of growth to edge of existing settlements for growth in the adopted Local Plan, including Grey Belt sites on the edges of settlements such as Christleton, even where no Green Belt release takes place.

Comment

Representation ID: 15363

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15922
Option C seeks to focus development around settlements on the railway network or main bus route corridors. This involves the release of Green Belt sites to deliver more than 12,000 homes. Blueoak supports Option C as set out in the Issues and Options consultation, which promotes a more flexible and responsive spatial strategy. This approach recognises the potential of sustainably located settlements and edge-of-settlement sites to contribute meaningfully to housing delivery over the Local Plan period. Edge-of-settlement locations, particularly those adjacent to Local Service Centres such as Christleton, benefit from existing infrastructure, access to public transport, and proximity to amenities. These characteristics make them well-suited to accommodate growth in a way that supports sustainable development principles, while also helping to meet the increased housing need identified under the revised NPPF.

Comment

Representation ID: 15364

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15923
While the overarching aim of retaining the Green Belt and protecting the countryside is supported in principle, it is important that the policy allows for a degree of flexibility to ensure that the borough’s substantial increased housing needs can be met. The new Standard Method has resulted in a significant rise in CWaC’s housing requirement, which cannot realistically be accommodated without considering the release and/or development of Green Belt sites. In particular, sites that fall within the Grey Belt, are located on the edge of sustainable settlements, and which have previously secured planning permission for residential development should be treated as appropriate candidates for development. The Christleton site represents a clear example of such land. Its location, characteristics, and planning history make it a sustainable and deliverable option for meeting part of the increased housing requirement. Accordingly, the policy approach in GB1 should be amended to recognise that, while the Green Belt may need to be retained should be retained wherever possible, there are exceptional and justified circumstances where the release of suitable sites can and should be supported. Green Belt policy in the Local Plan should align fully with national policy as set out in the NPPF, ensuring consistency in approach and clarity in its application. This includes identifying appropriate and sustainable Grey Belt sites such as this one in settlements such as Christleton.

Comment

Representation ID: 15365

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15924
Blueoak is supportive of an approach to separate Green Belt and Countryside policy definitions.