Local Plan Issues and Options (Regulation 18)

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Local Plan Issues and Options (Regulation 18)

Question IN 1

Representation ID: 16445

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14513
The evidence base documents listed at paragraph 1.19 of the I&O, and within the evidence base section of the planning policy webpages, are considered to form a strong basis to inform and shape the new Local Plan. The Green Belt Study should be a Borough-wide assessment of the Green Belt, as opposed to simply focusing on an assessment of Green Belt land around Chester, as was the case in the preparation of the 2015 Part One Local Plan. This aligns with our comments later in this representation on Green Belt release across the Borough. Furthermore, the Green Belt assessment should include a specific assessment of those sites in the Green Belt that have been submitted to the Council as part of its Call for Sites, rather than those sites simply being assessed as part of a wider "parcel" of land. This will ensure that individual sites, in particular previously developed sites with clear development potential, are not identified as making a strong contribution to the Green Belt purposes as a consequence of the inclusion of additional land within a "parcel" that might not have been put forward for development and would not be suitable for development (for example, a brownfield parcel of land being assessed as part of a wider greenfield land parcel). It is considered that a Settlement Hierarchy assessment should be undertaken with clear criteria established to determine where settlements sit within the hierarchy, based on access to services, education and public transport amongst others. A Settlement Limits Review should also be undertaken, demonstrating how settlement boundaries within each of the settlements identified for growth within the new Local Plan (to be confirmed as part of the Local Plan process) will be adjusted to accommodate new housing and (where appropriate) economic growth. This includes any existing housing commitments which remain extant and where a lawful material start has been made, and any new housing commitments that may be granted during the Local Plan preparation process.

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Local Plan Issues and Options (Regulation 18)

Question IN 3

Representation ID: 16446

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14515
In accordance with paragraph 22 of the National Planning Policy Framework (NPPF) published in December
2024, the strategic policies of the new Local Plan should cover a minimum 15-year period from adoption. It
is not considered that the Council should consider new settlements as part of its development strategy such
that it would warrant an extended, 30-year Local Plan period.

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Local Plan Issues and Options (Regulation 18)

Question IN 6

Representation ID: 16447

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14516
There are a significant number of ‘made’ Neighbourhood Plans across the Cheshire West and Chester
Borough. Very few of these allocate any land for housing, and housing policies contained within largely
repeat the guidance contained within the Local Plan. To this end, their purpose in relation to the principle of
housing development is somewhat limited.

Given that it is a requirement for Neighbourhood Plan policies to conform with the strategic policies of the
Local Plan, it is not considered advisable that updated and new Neighbourhood Plans be progressed until
such time that the strategic policies of the new Local Plan have been tested and found sound. This would
ensure that Officer time and resource is not taken up assisting with the preparation of Neighbourhood Plans
that might be viewed as premature to the new Local Plan.
We would encourage Neighbourhood Plans to be streamlined, to avoid repeating existing Local Plan policies.

Instead, the policies contained within should instead focus on specific local needs, offering guidance on
potential house types and tenures that are required in a local area, any community needs and aspirations,
and any important design considerations (for example, where there is a Conservation Area).

Neighbourhood Plans should not include onerous policies aimed at restricting or frustrating development
that would otherwise accord with the Local Plan; instead, they should carefully facilitate development which
is in accordance with the justified policies contained within it and the Local Plan to ensure that the Council’s
development and spatial strategy can be met.

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Local Plan Issues and Options (Regulation 18)

Question SS 1

Representation ID: 16448

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14518
No. The Council’s new Local Plan should plan positively for growth consistent with paragraph 36(a) of the
NPPF. The latter is clear that Local Plans should provide a strategy which “as a minimum seeks to meet the
area’s objectively assessed needs.”

Based on the Local Housing Needs Figures published by the Government in December 2024, the Council
should plan for the Local Plan’s development and spatial strategy to deliver 1,914 dwellings per year across
at least a 15-year period, as a minimum (and any subsequent adjustments to the Local Housing Needs figure for the Borough). Given that the adopted Local Plan covers a period of 20 years, there is no reason why a
new 20-year Local Plan period could not be advanced, particularly given the considered need for strategic
Green Belt release across the Borough; this would allow for amended Green Belt boundaries to endure for
a longer period.

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Local Plan Issues and Options (Regulation 18)

Question SS 2

Representation ID: 16449

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14522

No. The Council’s development and spatial strategy should ensure that there is a sufficient supply of
deliverable housing land across the Borough to meet its minimum housing requirement from Year One of
the new Local Plan period. This can be achieved by ensuring that land is allocated for housing across the
Borough, in all of the Main Towns, larger villages and smaller villages as a minimum approach. There is no reason not to adopt this positive approach to housing delivery, particularly given that a large area of the
Borough is located outside of the Green Belt.

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Local Plan Issues and Options (Regulation 18)

Question SS 5

Representation ID: 16450

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14523
The identification of Chester as the City, plus the 5 no. Main Towns, is supported.

Clarification is required as to which settlements lie within the Northwich “Main Town” area. For example, Weaverham, Barnton, Lostock Gralam, Hartford, Davenham and Moulton are recognised as being villages
in their own right and are not viewed as being part of the town of Northwich “on the ground.” It is therefore
questionable whether these should instead be identified as a settlements in their own right, comparable to
the likes of Cuddington and Sandiway, Farndon, Helsby, Kelsall, Malpas, Tarporley, Tarvin and Tattenhall.

It is noted that reference is made to smaller settlements with a lower level of services and access to public
transport possibly being suitable for infill development and brownfield development. This approach is far too
restrictive. There are a number of smaller settlements which are capable of accommodating smaller, major
housing schemes (10-30 dwellings for example), rather than simply being restricted to infill or brownfield
development. There are some smaller settlements, some of which are identified as Local Service Centres
in the Part Two Local Plan, which can accommodate such growth and have access to public transport, primary school and other services; there is no need to restrict growth in these villages. This includes the likes of Burton, Duddon, Higher Wincham, Ashton Hayes, Waverton, Little Budworth and Kingsley.

Paragraph 83 of the NPPF is clear that housing should be located in rural areas where it will “enhance or
maintain the vitality of rural communities.” There are many rural communities across the Borough where
services have closed (i.e. shops, post offices), and public transport services have ceased (i.e. bus services)
owing to a lack of customers; these rural communities need more housing (including affordable housing)
and more people living within them to support and sustain them. The new Local Plan should ensure that this
is the case, rather than continuing to adopt the stance that they are only suitable for limited growth; that
very approach in the currently adopted Local Plan has contributed to some of the issues now facing the
smaller villages and communities across the Borough.

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Local Plan Issues and Options (Regulation 18)

Question SS 6

Representation ID: 16451

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14524
Yes. There is the need for a balanced distribution of housing across the Borough over the next Local Plan
period. Housing land should be allocated on deliverable and developable brownfield and greenfield land (Green Belt and Open Countryside) across the Borough in the Main Towns, larger villages, smaller villages, and on lawful previously developed sites in the Green Belt and open countryside which have a degree of locational sustainability that would make them suitable for a residential land-use (consistent with paragraph 148 of the NPPF). This approach will ensure that new housing is not just directed towards the Mains Towns and larger villages, adding pressure to existing infrastructure and services; it will also mean that smaller villages and rural areas/communities are much better supported than they have been since the current Part One Local Plan was adopted in 2015. This approach will also provide for the efficient use of brownfield land in the rural area outside of the Main Towns, larger villages and smaller villages which would otherwise likely remain vacant and derelict (and represent something of a missed opportunity).

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Local Plan Issues and Options (Regulation 18)

Question SS 8

Representation ID: 16452

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14527
As outlined above, it is considered that new housing over the duration of the new Local Plan period should firstly be directed towards the Main Town, larger village and smaller villages, with smaller levels of sustainable growth elsewhere within the Rural Area. The character of a smaller village requires no further protection than that in a larger village; ultimately, delivering new housing will inevitably have some degree of impact on the character of a settlement, regardless of its scale. The focus should instead be on ensuring that the new Local Plan provides for a balanced distribution of housing directed primarily towards the Main Towns, larger villages and smaller villages (but not excluding other parts of the Rural Area).

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Local Plan Issues and Options (Regulation 18)

Question SS 9

Representation ID: 16453

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14528
Yes. The annual housing requirement of the adopted Local Plan is set at 22,000 dwellings over 20 years, at a rate of 1,100 dwellings per annum.

The delivery of 1,914 dwellings per year over a 20-year period would equate to 38,280 new homes. This is a significant (74%) increase over the adopted Local Plan requirement. Even just a 15-year Local Plan period would require 28,170 new homes.

Given that a significant amount of previously developed land has been redeveloped for housing since 2010 as a result of developer-led proposals, there is now a reduction in the amount of available brownfield land to meet future needs (other than land for example identified for regeneration projects, and commercial/employment uses).

In line with paragraphs 145 to 147 of the NPPF, it is considered that exceptional circumstances exist to justify a change to the Green Belt boundaries across the Borough; this should not just be restricted to Chester and should involve a full and thorough assessment of the Borough’s Green Belt land to inform future land releases and boundary adjustments in its towns and villages. Priority should be given to the release of lawful previously developed land in the Green Belt, consistent with paragraph 148 of the NPPF.

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Local Plan Issues and Options (Regulation 18)

Question SS 11

Representation ID: 16454

Received: 29/08/2025

Respondent: Grimster Planning

Representation Summary:

I&O_14531
Please refer to comments in response to questions SS14, SS15 and SS17 below.

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