Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 12440

Received: 29/08/2025

Respondent: Carden Group

I&O_12957
The length of the Local Plan period is critical. While the Council proposes a 15-year plan period, in accordance with paragraph 22 of the NPPF, this must be measured from the anticipated date of adoption, not from the plan’s base year. Given that adoption is unlikely before late 2027, or potentially early 2028, the plan period should extend to at least 2043 as a minimum. Furthermore, paragraph 22 of the NPPF states: “ Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery .” This is particularly applicable to the emerging CWaC Local Plan, which includes several significant strategic growth locations. For example: • CH02: Chester East- Piper’s Ash, with an estimated capacity of 4,316 dwellings, and • EP02: Ellesmere Port South, with an estimated capacity of 5,517 dwellings, and • WIN05: Winsford West- Hebden Green, with an estimated capacity of 6,376 dwellings. According to Lichfields’ Start to Finish (2024) report, large-scale sites of over 2,000 homes typically deliver an average of 150 dwellings per year. Even assuming two major housebuilders operate concurrently, potentially doubling delivery to 300 dwellings per year, the build-out period would still extend to over 20 years, particularly when accounting for a typical six-year lead-in time before the first completions, as also noted by Lichfields. This highlights the long-term nature of strategic site delivery and reinforces the need for a sufficiently long plan period. In summary, to ensure the Local Plan provides at least 15 years of housing supply from the point of adoption, the Council should, as a minimum, plan for an 18-year period between 2025 to 2043. However, given the likely inclusion of several strategic sites, many of which will continue delivering housing well beyond 20 years, a 30-year plan period (2025 to 2055) represents a more robust and appropriate approach. Extending the plan horizon allows for realistic, phased development of strategic sites, facilitates coordinated infrastructure planning, and helps maintain the relevance and deliverability of the Local Plan over the long term. This approach reduces the risk of policy gaps or early obsolescence.

Comment

Representation ID: 12442

Received: 29/08/2025

Respondent: Carden Group

I&O_12959
We strongly believe that strategic site allocations for housing should be made through the Local Plan process, rather than being deferred to Neighbourhood Plans. While Neighbourhood Plans (NPs) have a valuable role in meeting ‘local’ housing needs, shaping local policy and design codes, relying on them to identify and allocate these types of housing sites is likely to delay delivery significantly. This is particularly important in the context of CWaC because the new Standard Method calculation increases the borough's housing need from 1,100 dwellings per annum (dpa), as set out in the adopted Local Plan, to 1,928 dpa – a 74% increase. Meeting this level of need will require an urgent and coordinated response, with larger allocations made in a timely, strategic, and deliverable manner. The Local Plan is the most effective and efficient mechanism to achieve this. In contrast, Neighbourhood Plans are often slow to prepare and update. National Open Data published by the Department for Levelling Up, Housing and Communities (DLUHC) (now known as the Ministry of Housing, Communities & Local Government) shows that the average time taken to bring forward a Neighbourhood Plan from designation to referendum is around five years. Many designated areas never complete the process at all. Even among those that do, few make site allocations, particularly for larger-scale developments. We recognise, however, that Neighbourhood Plans can still be a useful vehicle for delivering smaller-scale sites where communities wish to influence the form and location of local growth. This is consistent with the purpose of neighbourhood planning, which is to empower local people to shape development in their area. Smaller allocations can be identified in a way that reflects local character and infrastructure capacity. However, expecting Neighbourhood Plans to deliver larger, strategic sites would be unrealistic: such sites typically require cross-boundary coordination, significant infrastructure investment, and a timescale that far exceeds the capacity of most NP groups. The rapid nature of the Council’s plan-making timescales are such that there will be insufficient time for a NP body to prepare a plan, as many of the strategic decisions about site selection will be made this time next year with the publication of the Regulation 19 plan. Furthermore, relying on NPs to allocate housing introduces uncertainty for landowners, developers, and infrastructure providers. It creates inconsistency in strategic decision-making and increases the risk of delayed or insufficient housing supply. In summary, given the urgency of delivering higher housing numbers, the documented delays in Neighbourhood Plan preparation, and the need for a coordinated approach to infrastructure and growth, we strongly recommend that all strategic housing site allocations be made through the Local Plan. Neighbourhood Plans should complement this by supporting smaller, community-driven allocations where appropriate, as well as influencing design and local policy. This approach will provide clarity, accelerate delivery, and help meet the Council’s pressing housing needs in a plan-led, sustainable manner.

Comment

Representation ID: 12443

Received: 29/08/2025

Respondent: Carden Group

I&O_12960
We welcome the Council’s intention to set a positive, place-based vision for the future of Cheshire West and Chester, centred around sustainable growth, community wellbeing, and environmental protection. However, we believe the current vision omits a fundamental principle that is essential to the future prosperity and inclusivity of the borough: the need to plan positively for housing delivery in response to a national and local housing crisis. Nationally, the UK continues to face a systemic housing shortage. Successive governments have failed to meet the national target of 300,000 homes per year. The Centre for Cities recently concluded that Britain has built 4.3 million too few homes over the last seven decades. As a result, we request that the Council amend the vision to include a fifth principle, along the following lines: •  Meeting Housing Needs – meeting the full, objectively assessed housing needs of all parts of the borough, including affordable, market, and specialist housing.

Comment

Representation ID: 12444

Received: 29/08/2025

Respondent: Carden Group

I&O_12961
We support Option A as the preferred framework for setting the strategic objectives of the new Local Plan. While Option B (Sustainability Appraisal objectives) plays an important role in testing the sustainability of policies, it is not suitable as the primary structure for the Local Plan’s strategic objectives.
Option A - take forward current Local Plan Objectives

Comment

Representation ID: 12445

Received: 29/08/2025

Respondent: Carden Group

I&O_12962
Option A rightly places emphasis on key strategic priorities such as infrastructure provision (SO5), economic development (SO2), and transport (SO4), which are essential for attracting landowner and developer interest, enabling the planning and promotion of long-term strategic sites, and underpinning effective masterplanning and delivery. These objectives provide a robust framework to support the practical delivery of sustainable development.

Comment

Representation ID: 12447

Received: 29/08/2025

Respondent: Carden Group

I&O_12964
SO10 should be amended to acknowledge that, in light of the significantly increased housing requirement, the limited brownfield land supply, and the necessity of directing development to the most sustainable locations, the release of land from the North Cheshire Green Belt will be required.

Comment

Representation ID: 12448

Received: 29/08/2025

Respondent: Carden Group

I&O_12965
Option B, while important for environmental protection and broader sustainability goals, does not place sufficient emphasis on housing delivery. This approach risks sidelining the urgent need to address the local housing crisis, especially given the significant increase in housing requirements for Cheshire West and Chester. Without a clear focus on facilitating the timely allocation and development of housing sites, Option Bs objectives may hinder effective planning and slow the delivery of much-needed homes, undermining the Local Plan’s ability to meet pressing community and market demands.

Comment

Representation ID: 12449

Received: 29/08/2025

Respondent: Carden Group

I&O_12966
We welcome the Council’s acknowledgment of the need to meet the housing requirement identified by the Government’s standard method. However, we strongly urge the Council to plan for a housing requirement above the 1,928 dwellings per annum (dpa) baseline figure (based on the latest May 2025 affordability ratios). This position is entirely consistent with the NPPF which makes clear at paragraph 11(b) that the standard method provides only a minimum starting point for assessing housing need. Planning for a higher figure is not only justified by national policy but essential to delivering a robust Local Plan. In the case of Cheshire West and Chester, there is clear and compelling evidence that a higher figure can be delivered sustainably. For example, according to the Council’s latest 2025 Housing Land Monitor report, between 2014/15 and 2024/25, annual completions have consistently exceeded the 1,100 dpa housing target, peaking at 2,542 dwellings in 2017/18. Over this 11-year period, the Council has over-delivered by more than 9,000 dwellings against the adopted Local Plan target, evidencing both market appetite and delivery capability. In light of the evidence, we recommend that the Local Plan sets a housing requirement of at least 2,200 dwellings per annum. This represents a modest uplift of around 15% above the standard method figure, which is substantially lower than the average over-delivery of 54% the borough has achieved since 2014. This proposed figure is both realistic and deliverable, based on the area's consistent track record of strong housing delivery. Setting a higher requirement not only reflects market capacity but ensures the Local Plan remains robust, responsive to change, and capable of supporting long-term economic growth and housing affordability.

Comment

Representation ID: 12450

Received: 29/08/2025

Respondent: Carden Group

I&O_12967
The Council should not adopt a stepped housing requirement in the new Local Plan. Delaying delivery in the early year’s risks failing to address urgent housing needs and affordability challenges. The NPPF makes clear that the standard method figure is a minimum starting point and that local plans should aim to meet housing needs as soon as possible. In Cheshire West and Chester, there is no justification for a stepped approach, as the borough has a strong track record of delivery, frequently exceeding the current adopted LP target. A stepped trajectory would unnecessarily delay much- needed homes, complicate delivery, and reduce certainty. Instead, the Council should maintain a consistent annual requirement from the outset to reflect market capacity, ensure timely delivery, and support the objectives of the NPPF. There is no justification for a stepped housing delivery as the Council has consistently delivered about the local plan housing requirements, and a level in excess of the proposed housing requirement.

Comment

Representation ID: 12451

Received: 29/08/2025

Respondent: Carden Group

I&O_12968
We broadly support the principle of prioritising previously developed (brownfield) land within existing settlements. However, we must stress that the scale of available brownfield land is wholly insufficient to meet the district’s housing needs over the plan period. According to the most recent Brownfield Land Register (2021), only 96 hectares of brownfield land across the borough remain without planning permission. Based on typical brownfield densities in the UK, estimated by the CPRE State of Brownfield 2022 report at approximately 70 dwellings per hectare, this equates to a theoretical capacity for around 6,720 dwellings. However, this figure should be treated with caution. The Brownfield Land Register does not account for a range of site-specific constraints that frequently affect deliverability. These include flood risk, contamination, heritage restrictions, ecological value, and site access issues. In addition, many brownfield plots are in fragmented ownership or face significant viability challenges due to abnormal development costs. As such, the actual number of dwellings that can be delivered from these sites is likely to be substantially lower. A realistic assumption must apply a discount to reflect these limitations, reducing the notional 6,720 dwelling figure to a far more modest and deliverable total. Moreover, the most recent 2025 Housing Land Monitor Summary Report identifies a supply of 6,407 dwellings when assessed against the housing requirement. Given this context, and the need to deliver a minimum of 34,000 homes (1,914 dpa over an 18-year plan period) we urge a more balanced and realistic policy approach that acknowledges the essential role of greenfield, and specifically Green Belt, sites in delivering sustainable housing growth that helps maintain village vitality. We therefore recommend that Policy SS3 be amended to include the following: • A clear recognition that, while brownfield sites are to be prioritised, their capacity is inherently limited and are insufficient to meet the Council’s full housing needs. • An explicit commitment to the release of greenfield sites, including within the Green Belt. Overall, a sound spatial strategy must be evidence-led, and the current housing land supply and brownfield positions clearly demonstrate the need to release greenfield and Green Belt land.