Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 2930

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3104
The first sentence of the vision refers to meeting its development needs to make it a desirable and attractive place to live, work , learn and visit.  The provision of new homes is a key element of this development need and should by specifically referenced within the vision.  It should be added as an additional principle, as follows. ‘Providing new homes – ensuring the provision of sufficient homes, to make Cheshire West and Chester a good place to live'

Comment

Representation ID: 2932

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3106
Adapting to climate change Point 7 states that ‘areas at risk of flooding, both now and in the future, should be avoided’.  This wording should be amended to closer align with national planning policy and guidance.  Paragraph 170 of the NPPF states that: ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future)’ . The reference to inappropriate development allows flexibility for certain types of development to be located within areas of flood risk where this is appropriate. Additional environmental and social requirements Whilst we encourage the use and redevelopment of previously developed land, as set out in the second bullet, the Local Plan should not seek to minimise ‘the development of greenfield land as much as possible’. The housing requirement of 28,710 homes is far in excess of the identified capacity of available previously developed sites, which is estimated at approximately 5,000 homes.  The development of greenfield sites will therefore be inevitable in order for the housing need to be met. It should also be recognised that greenfield sites are often in sustainable locations, offering good opportunities for development, which both mitigates and is resilient to climate change.  The policy should seek to ensure the efficient use of land in accordance with Paragraph 129 of the NPPF, for both brownfield and greenfield land.  It should encourage development on sustainable greenfield sites with the least environmental or amenity value, as guided by Sections 11 and 15 of the NPPF.  We propose the following wording for the second bullet: ‘Encourage the use and redevelopment of previously developed land and buildings and the efficient use of greenfield land in sustainable locations.’

Comment

Representation ID: 2935

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3109
The Council should use the latest housing stock figures to calculate its minimum housing requirement.  The latest published figures indicate a housing need of 1,928dpa.  The Council is currently applying a 5% buffer to its housing requirement for the purposes of reporting its five-year housing land supply as delivery has fallen between 95-85% of requirement over three years (Housing Land Monitor Summary Report, 2024).  It also reports unaffordability of housing as a key issue at Section 5.3 of the Issue and Options Local Plan.  The Government has been clear within the NPPF that the supply of homes must be significantly boosted.  Council should therefore take an ambitious and proactive approach towards tackling housing need and affordability and plan to deliver in excess of its minimum housing requirement in order to meet the Vision of Cheshire West and Chester as a good place to live.

Comment

Representation ID: 2936

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3110
Given the level of housing need and the reported number of undeveloped sites with planning permission, the Council should be proactive and aim to tackle housing delivery from the outset of the plan period.  A stepped approach, with lower provision in the early plan years, would not be appropriate, unless the Council can provide robust and compelling justification for this approach. A stepped approach would potentially risk under delivery across the plan period as a whole, should longer-term sites not come forward as expected.  This would store up difficulties for mid to late plan stages, most likely increasing the risk of a presumption in favour being applied and speculative applications for new developments.

Comment

Representation ID: 2937

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3111
The proposed hierarchy is supported; however, the policy wording should be amended in line with  NPPF paragraph 72 to allow for viability ( ‘planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability’ ) as set out below: ‘The spatial strategy will follow the principle of directing new development and allocating land, towards viable previously developed sites within settlements…’ Given the anticipated housing requirement across the plan period and the likelihood that Green Belt release will be required, it is appropriate to include a reference to this within the principles.  The Council’s inclusion of a Green Belt Study as additional evidence required to inform the new plan at paragraph 1.19 of the Issues and Options document is welcomed.

Comment

Representation ID: 2939

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3113
The current Local Plan (Part One) is ten years old and has an evidence base which reflects the position over a decade ago.  The need for new homes and the affordability position has since intensified, alongside a change in the way that the housing requirement is calculated, which has resulted in more new homes needing to be delivered each year than in the previous version of the Local Plan.  Therefore, if the Council identifies a need to release land from the Green Belt in order to meet its housing need under the standard method, then it should do so. It is important that the Council also identifies where new homes are required and the types of housing in these different locations, rather than simply the overall number of homes required in the borough as a whole.  This will ensure that the right homes are delivered in the right places. Following the introduction of the concept of Grey Belt in the latest version of the NPPF, as part of its evidence base, the Council should identify land that meets the definition of Grey Belt and release it for development if it meets all of the necessary tests and the ‘Golden Rules’ are capable of being met.

Comment

Representation ID: 2940

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3114
Where constraints have been applied to limit the locations for potential new development, these should be specific to a particular type of development (e.g. housing), as different constraints will apply to different uses. Locally identified designations should form a second tier of constraint and not be included as showstoppers, as technically these can be amended as part of the Local Plan review.  This allows for the most sustainable development to be brought forward.

Comment

Representation ID: 2941

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3115
Countryside and Green Belt designations perform different functions and although it is recognised that land can be included in both, there should be separate policies for each. The previous approach of a single policy could potentially lead to confusion as to whether a site was in the Green Belt or not.

Comment

Representation ID: 2942

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3116
Any policy that prescribes a particular type and/or mix of housing should be evidence-based and location-specific.  It would not be appropriate to apply the same housing requirements across the entire borough as the needs will vary in different locations, for example in a Town Centre compared to an edge of settlement location.  The policy should also include suitable wording to allow for variation where it has been satisfactorily demonstrated that local circumstances support this. Viability will also be an important consideration and a suitable wording should be included in the policy to allow for a variation to the housing mix where it has been satisfactorily demonstrated that a policy-compliant mix would not be viable. Flexibility should also be included to avoid potential conflict with housing mix policies in an adopted Neighbourhood Plan, with clear guidance as to which of the policies would take precedent. The Council have included National Space Standards Evidence within its list of housing evidence to be prepared at paragraph 19.10 and Policy HO1 references that a new policy will be introduced requiring these standards, should this be justified by the evidence.  Nationally Described Space Standards should only be required where there is a clear need; however, site specific circumstances should always still be taken into consideration within the decision making process. 

Comment

Representation ID: 2943

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3117
In line with NPPF paragraphs 82 ad 83, the policy should emphasise the delivery of housing developments to meet identified local needs and therefore references to scale should be removed.  The wording ‘small in scale’ and modest should be deleted. The requirement for the Parish Council to prepare or commission a local needs assessment and to lead on detailed site assessment should be amended.  It is potentially onerous for the Parish Council and does not recognise that other organisations may be well placed to undertake or commission such studies.