Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 16349

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16930
The Commissioners recommends that a robust evidence base be prepared to support and inform the emerging Local Plan, with evidence provided to support strategic policies for housing, employment and low carbon energy provision specifically. The Consultation Document signposts to the evidence base documents prepared to date, to support the emerging Local Plan, include the Employment Areas Survey, Economic Needs Assessment, Playing Pitch Strategy, Peatlands of Cheshire West and Chester, Places Background Papers, Land Availability Assessment, Brownfield Land Register, Waste Needs Assessments and Local Aggregate Assessments. Additionally, it is noted that the following additional evidence is needed to support the new Local Plan: Retail and Town Centres Study (in preparation) Strategic Flood Risk Assessment (in preparation) Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) Housing Needs Assessment (to be prepared) Green Belt Study (to be prepared) Infrastructure Delivery Plan (to be prepared) Strategic Viability Assessment (to be prepared) Transport Assessment (to be prepared) Land Availability Assessment (in preparation). The Commissioners notes that the aforementioned list is not consistent with that referenced within Paragraph 3.1 of the Sustainability Appraisal, and therefore suggest that a comprehensive list encompassing all evidence base documents is provided across both the Sustainability Appraisal (2025) and draft Local Plan consistently, to ensure that this can be appropriately reviewed and considered. The Commissioners is particularly supportive of the preparation of a Green Belt Study, which should be utilised to inform whether “ exceptional circumstances exist [justifying to the removal of land from the Green Belt] and if so, which parts of the Green Belt need to be reviewed and amended ” as noted within the Sustainability Appraisal. Given the significant increase in the standard method figure of 1914 homes per annum which CWCC should be planning for through this Local Plan, the Green Belt Study is key in ensuring that the Local Plan can evidence and successfully deliver growth across the borough. It is important that these documents are completed to inform the next consultation stage of the Local Plan process, particularly in relation to the overall growth options and subsequent allocations that will underpin these within the Local Plan, and therefore it would be helpful if CWCC could provide a timeframe for when these will be provided.

Comment

Representation ID: 16350

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16931
The CWCC Local Development Scheme (2025) (‘LDS’) sets out the anticipated adoption of the new Local Plan in Summer/Autumn 2027. As noted within the LDS, “ further changes to the national planning system represent a high risk that could introduce some uncertainty and delay ”. Although the Commissioners is supportive of the general development of the new Local Plan, given national policy and legislative uncertainties, it is considered that a period of 15 years would not provide adequate flexibility if delays to adoption of the Local Plan were to happen. Additionally, the NPPF states in Paragraph 22 that “ strategic policies should look ahead over a minimum 15 year period from adoption ”, and where larger-scale development such as new settlements or significant extensions are proposed within the Local Plan “ policies should be set with a vision that looks further ahead (at least 30 years) to take into account the likely timescale for delivery ”. The Commissioners is supportive of the inclusion in principle of larger-scale developments, such as urban extensions, within the Local Plan particularly given the significantly increased standard method figure of 1914 homes per annum that CWCC should be planning for. However, the Commissioners considers that a period of 15 years does not adequately allow for policies to be positively prepared with consideration of the timescales for delivery of such developments. The Commissioners therefore suggests that the Plan period for the new Local Plan go above the “minimum” period as noted within the NPPF, and should reflect that of the currently adopted CWCC Local Plan, covering a period of 20 years.

Comment

Representation ID: 16351

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16932
The Commissioners is supportive of the approach towards the new Local Plan vision which aims to ensure that “ Cheshire West and Chester is to be a desirable and attractive place to live, work, learn and visit with vibrant towns and villages, by meeting our development needs in sustainable locations ”. The Commissioners particularly supports the need to meet development needs in sustainable locations from the outset, and suggests that the Vision go further, and contain clear aspirations to achieve ambitious levels of growth over the new Plan period. The Commissioners considers that the Local Plan Vision should be distinctive to Cheshire West and Chester in order to successfully provide the mechanisms and policies needed to ensure that all areas of the borough are able to “ grow and evolve ”, contributing positively to the ambitions of other CWCC documents such as the Plan for the Borough (2024-2028) and the Cheshire West and Chester Climate Emergency Response Plan (2020). The Commissioners recognises that responding successfully to the Climate Emergency is a priority for the Council, particularly noting the significant aspirations detailed within the Cheshire West and Chester Climate Emergency Response Plan (2020) and Local Action Plans (2022). These need to be progressed across this Local Plan period in order to achieve the Council’s ambition to become a carbon negative borough by 2045. The Commissioners therefore stresses the important role that the Local Plan can play in this, and considers that alignment to the climate change ambitions should be referenced within the Vision.

Comment

Representation ID: 16352

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16933
The Commissioners is supportive of establishing a set of principles and priorities within the Local Plan Vision, and are supportive of the four current established principles as drafted. However, the Commissioners considers that the Vision principles should include a fifth statement, directly addressing the need to achieve ambitious levels of growth over the new Local Plan period in order to supports its housing and economic needs. Cheshire West and Chester has a significant housing need figure of 1,914 homes per annum demonstrated through the December 2024 standard method. CWCC note that a key issue for the borough will be “ meeting national policy obligations while maintaining the special character of Cheshire West and Chester ” in light of the level of housing development required by the government. Aspiring to these levels of growth will also attract increased inward investment, as well as satisfying the aims of the distribution of both housing and employment growth. In doing so, the Vision and Objectives will be “ prepared positively, in a way that is aspirational but deliverable ” in line with NPPF Paragraph 16b. Stating this from the outset will create a clear growth aspiration for the Local Plan, which will then subsequently be supported through strategic policies and allocations.

Comment

Representation ID: 16353

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16934
The Commissioners is supportive of the approach to establish concise visions for the key places identified in the new Local Plan, notably Ellesmere Port. Aligning with the Ellesmere Port Places Background Paper, the Commissioners considers that the vision should centre around capitalising on the settlement’s role as a “ major employment land resource for the borough” that has “become increasingly successful in attracting new employment opportunities ”, particularly in relation to providing new co-located housing, employment and low carbon energy development. The Commissioners stresses the importance of considering housing and economic development aspirations and strategy for growth holistically, in order to deliver sustainable development and communities across the borough. This is a consideration that should be referenced within the vision for Ellesmere Port, cognisant of its current unique makeup as a town in proximity to significant employment provision and emerging opportunities. The Commissioners considers that these visions should ensure alignment with the overarching vision of the Local Plan, to avoid diluting the aspirations of the Local Plan and ensure the successful delivery of much needed sustainable growth across the borough.

Comment

Representation ID: 16354

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16935
The Commissioners considers that Option C is most appropriate. Paragraph 3.1 and 3.2 of the Consultation Document note the key issues impacting the drafting of the Local Plan objectives, “ changes to national planning policy, including the weakening of Green Belt protection; introduction of grey belt; and a significant increase in the local housing need ” as reasons for some objectives being more difficult to deliver . Cognisant of the above, the Commissioners considers that the current Local Plan objectives, although a good starting point, will need to be updated to reflect the current and emerging national policy context.

Comment

Representation ID: 16355

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16936
Generally, the Commissioners considers that the current Local Plan objectives provide a stronger baseline for updating the Sustainability Appraisal objectives insofar as they provide overarching strategic goals, formatted in the context of the principles of sustainable development. However, as mentioned within the response to question OB 1, the Commissioners considers that updates should be made, not only to objectives SO1, SO3, SO9, SO10, but to all objectives, to ensure that these reflect the new Local Plan vision for the borough. The Local Plan objectives should focus on delivery in order to achieve the growth aspirations of the borough, whilst also including reference to the Climate Emergency and achieving the overarching aims of the Plan for the Borough (2024-2028) and the Cheshire West and Chester Climate Emergency Response Plan (2020). The Commissioners considers that, although all current Local Plan objectives should be updated to reflect the new emerging opportunities and challenges facing the borough, objectives SO4, SO5 and SO6 represent those which are key to ensuring the delivery of necessary growth across Cheshire West and Chester. Cognisant of this, the Commissioners suggests that the following updates to these objectives are made: Current Local Plan Objectives – SO4 and SO5 The Commissioners is supportive of objectives SO4 and SO5 insofar as they highlight the importance of placing the provision of infrastructure, facilities and amenities at the forefront of the emerging Local Plan, both through, and in support of, the delivery of new development. Furthermore, the Commissioners supports the general aim of these objectives, as they will enable sustainable growth to be bolstered across Cheshire West and Chester, in alignment with paragraphs 20(b) and 22 of the NPPF. In order to strengthen the effectiveness of these objectives, the Commissioners considers that direct reference should be made to the role of large-scale development sites located on the edge of key settlements, in achieving improved infrastructure and reliable transport networks. The Commissioners notes that such reference would align with the objective SO9, as well as the Commissioners’ preferred spatial strategy for the Local Plan, which is centred around focussing development in proximity to strategic transport corridors. The Commissioners considers that new development, particularly development in proximity to existing strategic transport corridors and key settlements, will act as a catalyst for future infrastructure investment in the borough, in turn bolstering the sustainability and growth aspirations of the emerging Local Plan and ensuring that Cheshire West and Chester becomes increasingly inclusive and accessible. Current Local Plan Objective – SO6 The Commissioners supports objective SO6, and notes that in order to ensure this objective is met, a range of viable and readily deliverable sites should be allocated within the emerging Local Plan, which should ensure all differing market requirements and housing needs are identified and responded to positively across the borough. Such allocations should be distributed in line with identified need in order to provide choice in housing type and location across all areas of the borough, regardless of size. However, a preference should be given to sites that benefit from proximity to the existing city of Chester and the main towns, in order to ensure the delivery of sustainable communities across the borough and more generally, to assist in meeting the wider ambitions of the emerging Local Plan.

Comment

Representation ID: 16356

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16937
As noted in response to questions OB 1 and OB 3, the Commissioners considers that updates be made to all objectives, inclusive of objectives SO1, SO3, SO9, SO10, to ensure that these reflect the new Local Plan vision for the borough. Current Local Plan Objective – SO1 The Commissioners supports objective SO1 and considers that it remains largely reflective of the preferred settlement hierarchy within the emerging Local Plan. The Commissioners particularly supports reference to the main town of Ellesmere Port, and considers that allocations within this settlement should underpin this objective in order to bolster sustainable growth within the borough. Current Local Plan Objective – SO9 Whilst the Commissioners notes the important role previously developed land can play in delivering sustainable development, as is noted within Paragraph 125 of the NPPF, large-scale greenfield opportunities will be fundamental in not only meeting the housing needs of the borough, but also ensuring the growth and vitality of all areas in Cheshire West and Chester through the delivery of infrastructure, community facilities, and open space. Cognisant of this, the Commissioners supports objective SO9 however suggests that, in the context of “ the majority of development within and on the edge of the main urban areas and key service centres ”, reference to the role of large-scale development sites in these areas should be noted. The Commissioners concurs that growth should be prioritised in established settlements that benefit from a range of supporting services and facilities but notes that the emerging Local Plan should look to allocate sites that would be best equipped to benefit from existing infrastructure, whilst also providing new infrastructure and services to the borough. The Commissioners notes that their Site would be able to provide and/or connect into new infrastructure and services to support and expand upon the existing sustainable communities. The Site would also provide the opportunity for the creation of high-quality sustainable travel modes i.e., walking routes, cycle routes, and bus services as well as the possibility for mobility hubs which benefit not only the new community, but also existing residents within Ellesmere Port and the wider locality. Finally, the Commissioners notes that the language used within objective SO9 should be updated to reflect the settlement hierarchy as referenced within SS 4 – notably this refers to Chester as the “ city ”, and the settlements of Ellesmere Port, Northwich and Winsford as “ main towns ”. Current Local Plan Objective – SO10 The Commissioners generally supports objective SO10 insofar as it aims to support the environmental quality and character of the borough. However, the Commissioners considers that the objective should retain the intention to protect the character of the North Cheshire Green Belt, but to also reflect the removal of Green Belt land, if, following robust evidence, such a removal is to be undertaken to bolster growth within the borough.

Comment

Representation ID: 16357

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16938
The Commissioners is largely supportive of the suggested policy approach towards sustainable development which sets out enhanced requirements for new developments in the context of ensuring that climate change mitigation and adaption is prioritised in light of Cheshire West and Chester’s declared Climate Emergency. The Commissioners is supportive of the use of the caveat “ where relevant ” within the policy approach, and suggests that, when considering these sustainable development requirements in conjunction with the need to deliver much needed housing across the borough, such requirements should be considered on a case by case basis. It is considered that new development will act as a catalyst to future infrastructure investment in the district, which will bolster the sustainability and growth aspirations of the emerging Local Plan and ensure that Cheshire West and Chester becomes increasingly inclusive and accessible, satisfying many of the requirements of policy approach SD 1. Cognisant of this, and with awareness of the need for CWCC to deliver 1,914 homes per annum as a minimum under the new standard method, the Commissioners stresses the importance of ensuring that these requirements do not result in much needed development becoming unviable or undeliverable. Each development should endeavour, where possible, to deliver these climate mitigation and adaption requirements, however this should not come at a detriment to timely delivery. The Commissioners understands the importance of delivering these climate mitigation and adaption requirements in order to futureproof the borough in reaction to the declared Climate Emergency. Therefore, the Commissioners suggests that the Local Plan seek to prioritise the allocation of large-scale development sites which are more easily able to incorporate requirements such as “ high quality, interconnected and multifunctional green and blue infrastructure”, “water efficiency, water recycling and rainwater harvesting measures ” and “ sustainable transport choices to create healthy and inclusive communities “, through holistic masterplanning.

Comment

Representation ID: 16358

Received: 29/08/2025

Respondent: Church Commissioners for England

Agent: Deloitte LLP

I&O_16939
To ensure that the emerging Cheshire West and Chester Local Plan is positively prepared, the Commissioners considers that the Council should set a housing requirement of at least 1,914 homes per annum, in line with national policy. The Planning Policy Guidance (PPG) states that the standard method figure identified under the recently published NPPF and adjusted following guidance of affordability ratios, is “ a minimum annual housing need figure ”. The new Standard Method figure was introduced under the backdrop of the Government’s strong ambitions to deliver 1.5 million homes over the next five years. As such, Cheshire West and Chester’s housing requirement should be no less than 1,914 homes per annum, which equates to approximately 28,710 homes over the proposed 15 year plan period. However, as the Commissioners has already noted, the emerging Local Plan period should be aligned to that of the current CWCC Local Plan, covering 20 years – which would result in approximately 38,280 homes across the plan period. The Commissioners considers that, at a minimum, the standard method figure should be planned to ensure alignment with Paragraphs 15 and 16 of the NPPF, which states that plans should “ provide a positive vision for the future ” and be “ prepared positively in a way that’s aspirational and deliverable ”. The Consultation Document acknowledges that “ authorities would be able to justify a lower housing requirement than the figure the method sets on the basis of local constraints on land and delivery ”. The Commissioners notes that any reduction on the housing requirement of 1,914 homes per annum, as set out through the standard method, would have to be clearly justified through robust evidence, and all opportunities for meeting this need should be fully explored. At present, the Commissioners does not consider that there is any evidence which would justify a lower housing requirement, and stresses the importance of the preparation of a Housing Needs Assessment to establish the housing requirement figure for the borough. Housing Land Monitor Summary Report (2025) The Housing Land Monitor Summary Report 2025 notes that there has been an annual surplus in the delivery of homes since 2014 compared with the adopted Local Plan target of 22,000 homes (1,100 per annum). With the report detailing that year’s 2016/17, 2017/18 and 2018/19 delivered annual net completions in excess of even the new proposed standard method figure of 1,914 homes per annum. The net total of homes anticipated to be delivered from 2017-2025 as summarised within the Housing Land Monitor Summary Report 2025 totalled 8,800, however 15,335 were delivered. This significant surplus of delivery suggests that the adopted Local Plan is not aspirational enough, with the housing target falling short of the actual delivery potential of the borough. Cognisant of the above, the Commissioners considers it essential to ensure the housing target within the emerging Local Plan is at least the proposed standard method figure of 1,914 homes per annum, in order to not only sufficiently meet demand, but to also support the growth aspirations of the borough. As the net completions across 2016/17, 2017/18 and 2018/19 has demonstrated, housing has historically been delivered in excess of this standard method figure and therefore the Commissioners considers that the Local Plan should be able to facilitate the level of growth detailed through the proposed standard method figure, as a minimum . The Commissioners stresses the importance of ensuring that the Local is “ prepared positively, in a way that is aspirational but deliverable ” as required by paragraph 16 of the NPPF, which should be reflected within the housing delivery target for the borough. The Commissioners recommends that CWCC seek to commission an updated Housing Needs Assessment to inform the preparation of the emerging Local Plan. The Commissioners emphasises the importance of this document and in turn the methodology utilised within it when identifying the needs and requirements of different parts of the borough and to reach an appropriate and aspirational minimum homes per annum figure for the emerging Local Plan. This will ensure that the Local Plan remains in line with paragraph 16 of the NPPF. Undeveloped Planning Permissions and Local Plan Allocations The Land Availability Assessment (Stage One) (2025) report suggests that there are sites on previously developed land without planning permission, including undeveloped Local Plan allocations, within the main urban areas and Key Service Centres, with a potential capacity of just over 5,000 homes. Additionally, the latest housing land monitoring data indicates that the borough currently has undeveloped planning permissions for almost 6,000 homes. The Commissioners notes that the continued inclusion of such allocations and planning permissions within the Local Plan would result in uncertainty in the deliverability of the overall housing needs across the borough. The Commissioners considers that a Local Plan that does not provide allocated sites that are confidently deliverable over the plan period nor an appropriate strategy for the delivery of the housing requirement would ultimately result in an unsound Local Plan. Therefore, the Commissioners considers that CWCC should undertake further research on the undeveloped and unimplemented sites in order to appropriately justify the retention of any allocations which have not been brought forward through the current Local Plan. It is stressed that, in order for the plan to be sound, sites should be evidenced to be deliverable and achievable within the Plan period. Oly then should they be allocated and subsequently considered as contributors to meeting the housing need of the borough. The Commissioners considers that alternative sites that provide deliverable and achievable sustainable development, such as the Commissioners’ landholdings ‘Land South of Ellesmere Port’, should be prioritised for allocations over those which have remained unimplemented.