Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10103

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10600
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation documents sets out the following list of additional evidence that is need to support the new 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). It is considered that the above list of additional evidence is sufficient to inform the policies of the New Local Plan. Savills is supportive of the production of a new Housing Needs Assessment, Land Availability assessment and Green Belt Study which will inform the policies that relate to housing delivery in the New Plan. It is considered that no further evidence documents are required beyond those already produced or currently being prepared to support the New Local Plan. 


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Comment

Representation ID: 10106

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10603
In response to question IN3, national policy requires that new Local Plans should set policies for 15 years following adoption, as a minimum. It is considered that the New Local Plan period for CW&C should cover a minimum of 20 years, due to the scale of strategic development that is required to meet the current and future needs of the borough and to reflect the ambitious housing delivery targets set by Government.  A plan period of 20 years would ensure that the Local Plan is able to set the strategic policies to meet the current and future needs of the borough.  As such it is proposed that the Local Plan period should be 2025 – 2045.


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Comment

Representation ID: 10107

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10604
CW&C is a large and diverse borough with distinct towns and settlements that each have specific development needs. As such, the Council’s approach is supported which will establish concise visions for the key settlements, in addition to an overarching vision for the whole District. Local visions for each of the larger settlements (Chester, Ellesmere Port, Northwich, Winsford, Frodsham, Neston and Parkgate) will help to ensure that the specific development objectives of each settlement can be met through the Local Plan policies, which will in turn inform development proposals.


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Comment

Representation ID: 10108

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10605
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, which would equate to 28,710 new homes in total.  Savills notes that the most recent local housing need figure for CW&C is actually 1,928 dpa, which brings the overall 15 year total to 28,920 homes. While this is owing to the incorporation of the latest affordability ratios. In response to question SS1, 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. National policy provides that in some cases, authorities will be able to justify a lower housing requirement than the standard method on the basis of local constraints on land and delivery (for example where statutory designations such as National Parks are present). Such circumstances do not exist in CW&C that would justify a reduced housing requirement. For example, there are no statutory National Parks in the borough.


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Comment

Representation ID: 10109

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10606
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 Winsford, 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. Finally, the adoption of a stepped requirement would mean that the New Local Plan would have a more limited contribution to the Government’s stated aim of delivering 1.5 million homes during the current Parliament. For these reasons, the New Local Plan should not utilise a stepped requirement. 


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Comment

Representation ID: 10116

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10613
The Issues and Options consultation document sets out that the spatial strategy will follow the principle of directing new development and allocating land towards previously developed (‘brownfield’) sites within settlements first. It is acknowledged that previously developed sites within settlements are often sustainable locations to support new development, therefore consideration should be given to the allocation of reasonable previously developed sites. However, it should be noted that not all brownfield land can be considered deliverable or reasonable alternatives to undeveloped sites. A detailed consideration of the deliverability and availability of each brownfield opportunity will be required to inform the urban capacity of the Distrct.  The spatial strategy principles state that where there are not enough opportunities for redevelopment within urban areas and towns, the approach will be to direct development to the edge of existing settlements in locations with the best access to public transport, services and infrastructure, as the next best sustainable option. The principles of the spatial strategy as set out in the consultation document are broadly supported. It is a fundamental purpose of the Local Plan to ensure that the development needs of the District are met and that development is directed to the most appropriate and sustainable locations. While a brownfield-first approach is supported and is consistent with national policy, the scale of development that is required in CW&C (i.e. at least 1,928 new homes per year), and the relative lack of appropriate previously developed sites, means it will be essential for development to be directed to other sites in sustainable locations on the edge of existing settlements. The land at Swanlow Lane, Winsford is a prime example of one such site.


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Comment

Representation ID: 10117

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10614
The Issues and Options document proposes that the New Local Plan will set out a settlement hierarchy based on the status and role of each settlement. The proposed settlement hierarchy is as follows: City – Chester Main Towns – Ellesmere Port, Northwich, Winsford Market Towns – Neston and Parkgate, Frodsham Other Settlements Savills agrees with the suggested settlement hierarchy as set out above. Chester is the only City within the borough and therefore performs a principle function and should be placed at the top of the settlement hierarchy. Winsford is included in the proposed settlement hierarchy as a Main Town, along with Northwich and Ellesmere Port. Its position on the second tier of the hierarchy reflects the opportunity in Winsford to deliver a higher proportion of housing than other settlements. The inclusion of Winsford as a main town is endorsed, since it is an established settlement in the borough with clear opportunities to deliver growth and housing development.


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Comment

Representation ID: 10119

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10616
The Site could come forward under any of Options A, B or C above. The Site is not located within the Green Belt and is in a sustainable location nearby to facilities in the existing settlement and local transport options. Notwithstanding that the Site could come forward under Option A, it is considered that the Council will still need to consider sites that are currently within the Green Belt in order to ensure sufficient land can come forward to meet the local housing requirement. Therefore, Options B and C are considered to be most appropriate to plan for a sustainable pattern of development in the District.


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Comment

Representation ID: 10120

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10617
The Issues and Options consultation document states under Option A that for housing development, Option A will include significant urban extensions to the south or Winsford of more than 11,000 homes. Option A could therefore deliver a significant proportion of homes that are much needed in CW&C. However, the Council is encouraged to be ambitious and plan to deliver a higher proportion of homes to boost growth. As such, sites that are currently in the Green Belt should also be taken into consideration when developing the new Local Plan under Options B and C.


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Comment

Representation ID: 10121

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

I&O_10618
Option B follows the existing Local Plan strategy and settlement hierarchy which is set out in Policy STRAT 2 of the Local Plan (Part One). That policy locates most new development in or on the edge of ‘main urban areas’ and an appropriate proportion of new development on smaller settlements which have adequate services, facilities and transport connections. The Issues and Options consultation document makes clear that a key difference between the adopted Local Plan (Part One) and the New Local Plan is that the current supply of previously developed land that can accommodate new development is much more limited, meaning larger areas of Green Belt and/or sites designated as Countryside are likely to be needed. The explanatory text on Option B explains that, while a proportion of development can be accommodated within existing settlements, ‘much of the new development under this option would need to be located within the Green Belt and/or Countryside’. The approach set out under Option B is an appropriate spatial strategy that is consistent with national policy and seeks to bring the adopted Local Plan policy up to date in respect of the spatial strategy. Option B would ensure that new development is directed to the most sustainable and logical locations in the District, which follows the established strategy in the adopted Local Plan (Part One).


Additional email 16/09/2025 confirming landownership details