Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 2658

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2811
The Council propose that the update to the Local Plan should plan for a period of 15 years. 3.4 Paragraph 22 of the National Planning Policy Framework (NPPF, 2024) states that ‘strategic policies should look ahead over a minimum 15 year period from adoption , to anticipate and respond to longterm requirements and opportunities such as those arising from major improvements in infrastructure. 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 echoed in PPG Paragraph: 064 Reference ID: 61-064-20190315. We consider that the Council will need to ensure that their plan covers an appropriate period of at least 15 years following adoption. The latest Local Development Scheme (LDS) (2025) suggests that the Local Plan will be adopted during 2027 at the earliest. This is ambitious. Given that the Local Plan adoption process can be prolonged, we suggest that the end date of the Plan should be kept under review to ensure that the Local Plan looks far enough into the future. Of course the evidence base documentation will need to reflect this.

Comment

Representation ID: 2659

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2812
The Issue and Options document states that due to changes in national planning policy the following objectives could be more difficult to deliver and therefore may need amending. Our response focuses on objective SO3, which relates to rural areas. Objective SO3 reads as follows “ SO3 In rural areas, support farming, agriculture and diversification  of the rural economy whilst ensuring development is of an appropriate scale and character ”. The NPPF is clear at paragraph 82 that planning policies in rural areas should be responsive to local circumstances and support housing developments that reflect local needs, including proposals for community-led development for housing. Furthermore the NPPF remains clear that in rural areas, housing should be located where it will enhance or maintain the vitality of rural areas. This is a key principle of the planning system as reflected in the Localism Act and the NPPF and one which should be referenced from the start. It is therefore imperative that the new Local Plan includes a specific objective relating to rural areas.  This objective should go beyond the current wording and also consider the development needs of  rural areas . The policy should be positively worded and clearly support appropriate local development where it will meet identified needs. We discuss this point in greater detail within our response to Question SS7 below. In practice, there is currently a disconnect between broad wording on growth for rural areas and the reality of achieving planning permission for modest rural developments. To achieve objectives for the rural areas this needs to change. This was evidence in 2014 by the Estate’s submitted planning application (Ref. No. 14/04463/OUT) for a modest model village in and around the village of Bickley with the objective of becoming recognised as an exemplar development. The proposals were prepared by the then Prince’s Foundation and carried support within the Council. However, in the end the conflict with growth distribution policies of the old Local Plan proved too difficult. This new Local Plan has the opportunity to rectify this sensitive planning balance and allow for modest levels of rural growth.

Comment

Representation ID: 2660

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2813
No. The Issues and Options draft sets out that the Council’s policy approach is to deliver a minimum of 1,914 new homes each year over the plan period. To ensure that the emerging local plan is consistent with national policy, the Council should use the Standard Method to calculate the local housing need (LHN) figure. The new method to calculate housing need uses housing stock as the starting point rather than population projection as it was felt that housing stock provides a better baseline because it “ provides a stable and predictable baseline  that ensures all areas, as a minimum, are contributing a share of the national total that is  proportionate to the size of their current housing market ”1. Savills notes that the most recent housing need figure for Cheshire West and Chester is actually 1,928 dpa as of May 2025 affordability ratios and not the figure of 1,914 dpa as referenced within the Issues and Options consultation material. In response to question SS1, it is strongly recommended that the new Local Plan should  support the delivery of 1,928 homes per year as a minimum . The requirement for the new Local Plan to meet the Standard Method figure is clearly established in the NPPF and is the necessary approach that must be taken to ensure that the plan is consistent with national policy. Emphasis is placed on the fact that the national policy requirement is for Local Plans to adopt the Standard Method figure as a minimum . Savills recommends that the Council should take an ambitious approach and aim to exceed the minimum housing delivery indicated by the Standard Method, in order to support sustainable growth. To tackle the national housing crisis, the Standard Method for calculating local housing need was reformed in December 2024 (in conjunction with an updated NPPF). The revised Standard Method was revised to reflect the Labour Government’s ambition to deliver 1.5 million homes in the next five years from 2024 to 2029 (or 300,000 dwellings per annum). The NPPF states that to determine the minimum number of homes needed, strategic policies should be informed by a local housing needs assessment, conducted using the Standard Method, as set out in the PPG. It should be noted that this housing need figure is a minimum – it is an unconstrainted ‘policy off’ assessment of the minimum number of homes needed in an area. Assessing housing need is the first step in deciding how many homes to plan for. However, it does not directly translate to the actual housing requirement. The housing requirement is a “policy on” figure. It considers local factors, policies, and constraints to determine whether the unconstrained housing need figure can be delivered in full. However, it is the Government’s clear intention that the identified housing need in an area should be met in full. The housing requirement can also exceed the minimum housing need figure to account for circumstances which include (but are not limited to) significant infrastructure or economic investment, large scale regeneration, or a new town development. The PPG2 clarifies this by stating that “ the standard method for calculating local housing need  provides a minimum number of homes to be planned for. Authorities should use the standard method  as the starting point when preparing the housing requirement in their plan ”. (Our emphasis). To ensure choice and competition in the market for land, and to also consider the chance that some allocations may not be deliverable, a buffer to the housing requirement should be applied to plan making to ensure sufficient dwellings are allocated to meet development needs. Therefore, to ensure the emerging local plan is consistent with national policy, the housing requirement should utilise the Standard Method, as set out in the Planning Practice Guidance (PPG) as the starting point3.   1 MHCLG, Guidance on housing and economic needs assessment (February 2025), paragraph 005 2 NPPG, 2024, Paragraph: 001 Reference ID: 68-001-20241212 3 National Planning Policy Framework, December 2025, Paragraph 62

Comment

Representation ID: 2662

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2815
The NPPF is clear that authorities are required to set strategic policies to meet their housing need in full across the Plan period. To support the Government’s objective to significantly boost the supply of homes, it is important that ‘ a sufficient amount and variety of land can come forward where it is  needed ’. Paragraph 70(b) of the NPPF states that to ensure land is allocated for housing in a way that boosts the supply of homes, plans should allocate ‘ a range of sites by size, type and location to meet the  housing requirements of different groups in the community ’. A stepped housing requirement with reduced delivery in the early parts of the Plan period would, in effect, allow the Council to defer its full housing delivery to later phases of the Plan period. In areas where there are existing acute housing shortages, such as Northwich, this would prolong existing issues surrounding affordability and access to housing. A stepped requirement would also ignore the opportunities for development sites that are immediately deliverable at the initial phases of the Plan period. Reduced targets in the early stages of the Plan period would risk slowing momentum, which conflicts with national housing objectives of boosting housing growth. As such, it is considered that the housing requirement should be clear and consistent throughout the Plan period, which would encourage market confidence and have a positive impact on overall housing delivery.

Comment

Representation ID: 2663

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2816
Yes. Whilst it is inevitable that the focus of a spatial strategy will be the main urban areas, it is important that the rural areas including within he spatial strategy in their own right and as they too play a key role in the delivery of housing. Rural areas have populations and businesses. Rural areas have development needs. Such areas also have their own issues which are often not recognised or addressed in Local Plan hierarchies or spatial approaches as they are often considered to be minor and inconsequential in the overall development plan context. Please see our further comments and examples of other Council policies under SS7 below.

Comment

Representation ID: 2664

Received: 15/08/2025

Respondent: Cholmondeley Estate

FRO01, HEL01
I&O_2817
The Local Plan should include place-based policies for smaller settlements, such as Helsby. These settlements contain a range of services and facilities and are appropriate locations for growth. These could be delivered by way of site specific allocations and also more general policies relating to the settlements in terms of sites within the settlement boundary and sites which are outside, but immediately adjacent to, the settlement boundary. In this regard we support the initial proposals under FRO01 and HEL01 in Options B and C. In addition, there are significant parts of the District which are considered to be ‘rural’. Increasingly the population of such rural areas is declining, in part due to limited housing growth. As such, it is becoming increasingly difficult to support services in rural areas due to the limited demand. New housing growth could support this. The NPPF is clear at paragraph 82 that planning policies in rural areas should be responsive to local circumstances and support housing developments that reflect local needs, including proposals for community-led development for housing. As set out in Paragraph 83 of the NPPF, planning policies should promote sustainable development in rural areas, and housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby. As an example, such a planning policy could follow Policy HG5 of the Hambleton Local Plan whereby windfall non-allocated residential development in smaller settlements supported and decided on a case by case basis with consideration to the existing built form, current size of the settlement and the character of the settlement. Extract of adopted policy HG5 below. [see attached] The above policy provides flexibility for small sites in rural settlements to come forward where there is a local need. Furthermore, the former Ryedale District (now part of North Yorkshire Unitary Council), within the adopted Ryedale Core Strategy 2013 supported the rural housing needs of the communities. The Ryedale Local Plan Review – Key Decisions Consultation February 2023 proposed an  amendment to SP2 which would allow for small scale development (up to 5 units) on sites  outside of, but immediately adjacent to, all settlements, including small villages . Similarly to Hambleton, Ryedale recognised the necessity to support the rural housing needs of the communities, which is supported through Paragraphs 82 and 83 of the NPPF. In addition, this approach also supports the NPPF’s requirement to support small sites coming forward and the benefits that can have for small housebuilders and providing competition in the housing market. The new Local Plan should include a policy which supports small sites within rural areas, as it will help provide a range of choice, meeting local needs, such as for downsizing and smaller more affordable properties, as well as providing opportunities for self and custom build homes. In rural areas this type of development can help support local services and facilities and the sustainability of these settlements. Small villages within CW&C are rural in nature, often centred around a church or green space. Others may be more linear in nature, but all have a historic core around which development has gradually grown to form the villages we see today, as is the case with Helsby. This cumulative increase generally results in the creation of a particular character and a sense of place. This is how housing growth in villages is envisaged, as gradual, reflecting that special character of the rural villages and so should be supported as part of any new CW&C Local Plan.

Comment

Representation ID: 2665

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2818
The principle of protecting the prevailing character of smaller settlements through the new Local Plan is supported. However, the new Local Plan should take into account opportunities for development in and around smaller settlements that can enhance and expand the existing provision of services and infrastructure, such as education and healthcare facilities. Cumulatively, growth around small settlements can make a significant contribution to overall delivery. In some settlements in CW&C, existing services and infrastructure are already constrained. As such, the new Local Plan should recognise opportunities for development to facilitate the delivery of additional capacity in terms of services and infrastructure. Residential development has demonstrable benefits for economic growth and can facilitate the delivery of community and other services. Therefore, the Local Plan should not restrict development in smaller settlements to the capacity of existing services and infrastructure.

Comment

Representation ID: 2666

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2819
The Local Plan (Part One) was adopted in January 2015, which is more than 10 years ago. Since that time, the national policy framework in relation to Green Belt has changed substantially. The introduction of the new Standard Method has increased the housing requirement significantly. The most recent version of the NPPF requires Local Authorities to make plans to meet their local housing need (standard method figure) in full. This requirement stems from the Government’s commitment to significantly bolster the delivery of homes and speed up planning in order to deliver 1.5 million new homes over the next parliament. Currently, approximately 42% of the borough is designated as Green Belt, which is substantially higher than the national average of 12.6%. In order to deliver sufficient homes in CW&C to meet its housing requirement, some parts of the Green Belt will need to be released for development. This is because the Council will not be able to deliver its housing requirement solely on previously developed sites or other sustainable sites that are available and deliverable, without releasing some Green Belt sites to alleviate the acute need for housing.

Comment

Representation ID: 2667

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2820
Yes – New Settlement. The Estate’s land ownership comprises 7,500 acres of predominantly agricultural land roughly between Whitchurch and Nantwich. It is one of the largest areas of land owned and managed by a single entity within the combined Cheshire Districts. Given the extent of the Estate’s ownership we wanted to make clear our commitment to working with the Council to explore the long term proposition of delivering a new settlement on the Estate’s land. New settlements offer the ability to manage growth and development by creating new, self-contained communities, rather than simply expanding existing ones. Albeit are usually developed over a longer time period due to the associated lead-in times. We recognise that this spatial strategy option is not required as part of the new Local Plan, but instead highlight that a new settlement should be explored in the future beyond this Plan period . Initial discussions on a possible new settlement have taken place and we would therefore welcome further discussions with the Council moving forward. Whilst not necessarily relevant for this Local Plan period, it maybe helpful to make reference to the potential for a new settlement in the future to make sure stakeholders are informed of potential longer term strategies for the region.

Comment

Representation ID: 2668

Received: 15/08/2025

Respondent: Cholmondeley Estate

I&O_2821
The Issues and Options document sets out that the current Local Plan policies in relation to the mix and type of new housing will be substantially amended to reflect the emerging Housing Needs Assessment. The new policy approach will provide detailed requirements for sizes, types and tenures of housing, which will be based on the Needs Assessment. Savills is generally supportive of the need to provide a range and choice of homes to meet the needs of local areas. However, it is also important that any policy ensures that housing delivery will not be compromised or stalled due to overly prescriptive requirements. The policy approach to housing mix should consider the scale and viability of sites. The housing mix policy should also be applied flexibly and should make allowance for homes to be provided as required by the market. The Estate commissioned Cheshire Community Action to undertake an assessment of Housing and Economic Needs, dated December 2022. The Report assessed the key factors affecting the communities and businesses that reside within and surrounding the Cholmondeley Estate; with a focus on housing and the local economy in the context of rural areas. It summarises that most housing tenures are unaffordable across the area, particularly for those who are employed by local businesses. Building energy efficient housing is highlighted as key to affordability. The majority of local employees are commuting considerable distances and a lack of affordable accommodation in the area is linked to recruitment difficulties. The report concluded that there were in December 2022 nearly 200 households in need of housing within and surrounding the Cholmondeley Estate. Hence, the need to ensure that any new housing policies consider the needs of people living within rural areas in terms of size and types of tenures.