Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14972

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15531
The proposed plan period aligns with paragraph 22 of the NPPF, which states: Strategic policies should look ahead over a minimum 15 year period from adoption , to anticipate and respond to long-term 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” Whilst the Council’s ambition of a 15-year plan period aligns with the minimum period under national policy, Grosvenor considers that the Council should reasonably seek a plan period in excess of the minimum requirement of 15 years. The borough comprises a vast area with a significant range of different settlements, socio-economic conditions and development needs across the borough which require a strategic and long terms approach to planning for. By planning beyond the NPPF required minimum of 15 years (from adoption), the Council provides itself with the opportunity to identify and maintain an appropriate quantum and mix of sites (giving choice in terms of size and location) to provide a pipeline of sites capable of meeting a consistent trajectory in the short, medium and long term which is capable of meeting the increased housing requirement for Cheshire West and Chester under the Standard Method. Given the housing crisis which the Country currently faces, the need for a robust, deliverable supply of housing sites is, therefore, paramount.

Comment

Representation ID: 15014

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15573
Grosvenor is broadly supportive of the overall Vision set out under VI1 of the draft Plan. However, whilst the Vision identifies four overarching principles (tackling climate change, promoting wellbeing, providing infrastructure and protecting character) we consider it should also include an element in relation to meeting the future growth needs for the borough (both housing and employment). The Vision for the Plan should be aspirational in meeting the needs of the borough and the economic, social and environmental expectations of the Plan in meeting those needs. Fundamental to all of those aims will be meeting the Council’s requirements in terms of housing delivery in the face of a national housing crisis. As such, the Council should seek to ensure that the current and future housing needs of the borough are met - including the need for market and affordable, family homes, and homes for older people and for first-time buyers to align with the Government’s target to deliver 1.5 million new homes over the parliamentary period (and the significantly increased standard method housing need for Cheshire West and Chester published in December 2024). Notwithstanding this, the second part of VI1 (Vision – places) seeks to include individual Visions for larger settlements within the borough. This is welcomed and should align with the overarching principles set out above and with the spatial strategy, once selected.

Comment

Representation ID: 15015

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15574
We consider, it is more suitable to take inspiration from the objectives of the current Local Plan, whilst also using the Sustainability Appraisal, in order to set out up-to-date objectives specific to the new Local Plan and address current and future issues within the borough. The Vision for the borough must be set in meeting the development needs of the borough. Overall, the objectives based on the adopted Local Plan are still broadly relevant and we welcome the Council’s intention to alter S09 and S10 in relation to locating the majority of development within and on the edge of the main urban areas, such as Chester. However, as set out above, we consider that to provide for sustainable patterns of growth, the Local Plan must also seek to provide opportunities for growth in the lower order settlements to meet local needs. To achieve this, Grosvenor considers that the Local Plan must release sustainable sites from the Green Belt which will make an important contribution to meeting the Council’s housing requirement whilst supporting the role and function of the borough’s settlements, as we discuss further in these Representations.

Comment

Representation ID: 15016

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15575
Whilst the Council’s aspiration to mitigate the impacts of climate change and provide greater energy efficiency is admirable, and Grosvenor supports the move towards greater energy efficiency and carbon reduction via a nationally consistent set of standards and timetable, policies within the Local Plan should not set local energy efficiency standards for buildings that go beyond Building Regulations. As such, we suggest that Policy SD1 provides overarching ambitions to mitigate the impacts of climate change, but does not set specific requirements which are established in the latest Building Regulations and national policy. As such, we consider such matters are addressed at a national level to avoid different approaches and standards being used at the local level. The draft Plan makes reference to the ‘Planning – Local Energy Efficiency Standards Update’ Written Ministerial Statement (13 December 2023) which seeks to constrain local authorities in setting energy efficiency standards that go beyond current building regulations, and by directing local authorities, where they do set higher standards, to express these ‘as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).’ Notwithstanding the above, Section 4 of these Representations demonstrates that Grosvenor’s land interests are sustainable locations for residential development and are capable of helping the Council meet its future housing requirement and can deliver development in a manner which mitigates against the impacts of climate change. The purpose of these Representations is to assist the Council in delivering a sound Local Plan, which is robust in tackling the Climate Change Emergency through delivery of sustainable development at its Sites to meet the future needs of the borough. Indeed, as set out above, the principal aim of the estate is the long term stewardship of its land and the communities on it which will inevitably involve building sustainably for the future and tackling climate change. Regarding the third part of Policy SD1; ‘Additional environmental and social requirements’, Grosvenor raises concerns with the first bullet point, which seeks to encourage the use of previously developed land and minimise development on greenfield land. We do not consider the policy should ‘minimise’ development on greenfield land. As discussed later in this section of the Representations, development should be delivered in appropriate locations to meet the needs of residents, and development on previously developed land is subject to viability constraints and the challenges to meet housing needs, such as affordable housing. Therefore, whilst Grosvenor welcomes the aspiration to utilise previously developed land wherever possible, minimising greenfield development is at odds with the spatial strategy which we say will inevitably require Green Belt release and development on greenfield land to ensure housing needs can be met. Sustainable development should, instead, come forward in the right locations to support the future needs of the borough. Grosvenor is concerned that a reliance on previously developed land will be insufficient to meet the housing needs of the borough (particularly in relation to affordable housing) and a brownfield first approach should not act as a barrier to sustainable greenfield or Grey Belt development.

Comment

Representation ID: 15017

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15576
Grosvenor welcomes the recognition at paragraph 5.2 of the draft Local Plan that strategic policies should be informed by local housing need conducted using the standard method in national planning practice guidance (NPPF, paragraph 64). The figure for Cheshire West and Chester is a minimum of 1,914 new homes each year, equating to 28,710 new homes over a 15-year plan period. The Council’s emerging Local Plan will, therefore, be required to plan for housing using the new Standard Method which represents a significant step-up from the adopted housing requirement of 1,100 units per annum set out in STRAT2 of the Local Plan Part One. The increased housing requirement within the new Standard Method means that exceptional circumstances will, therefore, exist to justify altering Green Belt boundaries as part of the Local Plan preparation. We consider it will be inevitable that the Council will need to allocate Green Belt sites to meet its new housing requirement which is circa 75% increase from the previous Local Plan requirement upon which previous Green Belt Boundaries were established. The Council suggests that the latest housing land monitoring data identifies undeveloped planning permissions for almost 6,000 homes, and the Land Availability Assessment (Stage One) evidence base document indicates that there is a supply of circa. 5,000 homes for sites on previously developed land, including undeveloped Local Plan allocations, within the main urban areas and Key Service Centres (KSC). However, the draft Local Plan acknowledges that this figure is likely to reduce once a detailed assessment of the constraints of these sites is carried out in Stage Two. Whilst Grosvenor reserves further comments until the Stage Two Land Availability Assessment is undertaken, the Council will clearly need to identify additional sites to address its’ housing supply shortfall so that it can meet its increased housing targets. Those sites should be located in the most suitable locations and be directed to support the sustainable growth of the borough’s settlements. As such, the Local Plan spatial strategy (discussed further below) must consider an appropriate balance of development to ensure that housing needs are met and delivered in the right locations. Furthermore, we consider that the Council will need to undertake a Grey Belt Assessment across the borough to identify the supply of potential Grey Belt Sites available to meet housing and employment needs. The Council will also need to undertake a housing needs assessment to further understand what homes are needed in the borough, and a viability assessment to determine if the Council’s housing land supply is capable of addressing those needs (for example, delivery of affordable homes on previously developed land). On the face of it, Grosvenor does not object to the housing requirement of 1,914 set out in SS1. However, we note that the Council must ensure that the latest standard method figure is used as a minimum and the Council should ensure that it has identified sufficient sites to accommodate residential development and support the vitality and viability of all of its settlements, LSC. We consider that growth should be disaggregated across the settlement hierarchy to ensure that LSC (including those within the Green Belt) are provided with the level of growth they need to maintain their role and function in that hierarchy.

Comment

Representation ID: 15018

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15577
As discussed above, Grosvenor is supportive of the re-use of previously developed land, however we highlight that sustainable development should come forward where it is needed and capable of addressing housing needs to support the future needs of the borough as a whole. Grosvenor is concerned that an over reliance on brownfield land will be insufficient to meet the housing needs of the borough and should not act as a barrier to sustainable greenfield or Grey Belt development, which can also be located in sustainable locations with good access to services and facilities. To address the increased housing requirement, it is highly likely that Green Belt release will be required to meet the borough’s identified housing needs over the next plan period. This is considered an exceptional circumstance to Green Belt release as stipulated at paragraph 146 of the NPPF. SS3 goes on to say that where there are not enough planning permissions and opportunities for redevelopment within urban areas and towns, the approach will be to develop on the edge of existing settlements in locations with the best access to public transport, existing services and infrastructure. The Council also suggest that this may require the release of Green Belt land which we are supportive of. However, it is worth noting that the degree of accessibility to public transport will vary across the borough and across the settlement hierarchy proportionate to the size and function of those settlements; we consider that development should be directed to settlements which perform best in relative to that function. Set within this context, the Council will need to undertake a Green Belt Review to assess which sites may be appropriate for release to meet identified need for homes. This will need to be considered alongside the spatial strategy. As we come onto later in these Representations, Grosvenor seeks to promote a strong candidate for Green Belt release to the East of Wrexham Road on the edge of the settlement of Chester.

Comment

Representation ID: 15019

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15578
We welcome the retention of a settlement hierarchy and a place-based approach for each settlement. However, this must be evidenced by a thorough review of the needs of each settlement and the ability of each settlement to deliver sustainable and proportionate development over the next plan period. Grosvenor is broadly supportive of the main thrust of Policy SS4 of the draft Plan which proposes that the new Plan will set out a settlement hierarchy based on the status and role in providing local infrastructure and services for Chester, Ellesmere Port, Northwich, Winsford, Neston and Parkgate, and Frodsham. Policy SS4 also highlights further settlements that have a level of facilities and services to meet the needs of residents and surrounding areas which include Cuddington and Sandiway, Farndon, Helsby, Kelsall, Malpas, Tarporley, Tarvin and Tattenhall. Chester should remain at the top of the settlement hierarchy. However, we consider that Waverton (currently identified as a LSC) should also be considered in the settlements listed above in Policy SS4, as it is an important and sustainable location to accommodate new development and benefits from its proximity to local facilities, transport connections and employment opportunities. Grosvenor, therefore, seeks the settlement boundary of Waverton (an LSC) to be expanded to include the original settlement to the south, taking into account the functional and social links between the older parts of Waverton and the area now included within the settlement boundary to the north. Waverton should be allocated sufficient land to allow the organic growth of the village. Grosvenor has land interests in Waverton, described further in Section 4, which form logical infill and edge of settlement opportunity sites capable of providing sustainable development to meet the future needs of the village. By directing a sustainable level of growth toward Waverton the Council will support this area as a strong and vibrant community, where young people want to live and work, and that they will have a strong economic role. As set out above, Waverton is washed over by the Green Belt and therefore it will be necessary for the Council to allocate development at Waverton to facilitate that growth. Overall, the strategic approach set out within the Part One Local Plan is supported in terms of its hierarchical approach to the distribution of development towards the largest and most sustainable settlements; with lower order settlements providing growth that is consistent with the role and function of those settlements. Accordingly, Grosvenor would support the review of the Local Plan taking a similar approach to the setting out of strategic policies, subject to regard being had to the uplift to the Council’s housing requirement and the latest aspirations and needs of each settlement.

Comment

Representation ID: 15020

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15579
Grosvenor does not consider that Option A is a suitable spatial strategy that can ensure the increased housing requirement for Cheshire West and Chester can be achieved, or that new development will be distributed in a sustainable manner to support the role and function of each settlement. Option A seeks to retain the existing Green Belt and there does not appear to be any sufficient upto-date evidence to confirm that the Council has enough deliverable land to achieve its housing requirements in the context of the mandatory housing targets which have been re-introduced based on the Standard Method Calculation. Map 5.1 of the draft Local Plan shows the extent of the Green Belt which would be retained under Option A. This covers 42% of the borough and surrounds the northern settlements of Chester, Ellesmere Port, Northwich, Neston and Parkgate and Frodsham – 5 of the 6 largest settlements as identified in Policy SS4. As such, these important settlements are clearly constrained by the Green Belt and we question whether Option A is a realistic approach to ensure a proportionate level of development over the next plan period to support the growth needs of these settlements. 2.49 Option A suggests that housing development will primarily be located to the south of Northwich (c. 5,000 homes), south/west of Winsford (11,000 homes) and growth around other places not in the Green Belt. Firstly, as mentioned above, there is insufficient evidence to demonstrate that these sites can accommodate the Council’s housing requirement. Notwithstanding this, the approach of Option A will not deliver a proportionate level of growth as the strategy is not based on where development is needed and only directs new housing towards sites located outside of the Green Belt. For these reasons, it is considered that a blended approach between Options B and C should be progressed by the Council, as both of these options will consider the release of Green Belt in the most sustainable locations.

Comment

Representation ID: 15021

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15580
It is welcomed by Grosvenor that Option B would focus housing development around Chester, Ellesmere Port, Northwich and Winsford which are the largest settlements and will need sufficient new development over the next plan period to support growth. We also welcome that 2,500 homes across rural areas, including Green Belt land will be expected to accommodate new development However, the Council should carefully review its settlement hierarchy to ensure it plans for proportionate growth for each of its settlements, including Waverton which is identified as a LCS in the adopted Local Plan.

Comment

Representation ID: 15022

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15581
Option C seeks to see new homes focused in and around settlements on the railway network and on main bus route corridors. Whilst we do not object to a blended approach to the spatial strategy using Option C to focus development in sustainable locations, this should not preclude development from coming forward in smaller settlements, which do not benefit from a train station. New development in some rural locations and smaller settlements is considered appropriate to help support the needs of its residents. Option C also does not take into consideration the improvements to local facilities and transport infrastructure, which can be delivered by future development, either on-site or via financial contributions which can enhance the sustainability and the role and function of smaller settlements.