Local Plan Issues and Options (Regulation 18)

Support

Representation ID: 16468

Received: 08/12/2025

Respondent: Gladman Developments Ltd

The Council proposes that the new Local Plan covers a period of 15 years. Paragraph 22 of the NPPF sets out that strategic policies should look ahead over a minimum 15-year period from adoption and 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). Gladman recommends that the new Local Plan covers the period up to 2045 at least to ensure it meets the minimum 15-year period from adoption taking into account potential plan-making delays. The Council will need to consider whether any proposed site allocations require the new Local Plan to cover a minimum 30-year period in line with national policy.

Support

Representation ID: 16469

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16513
Gladman considers that the allocation of sites to meet housing needs over the plan period should not be deferred to neighbourhood plans. Instead, to ensure sites come forward quickly and the Council is able to maintain a robust housing land supply, the Local Plan should allocate sufficient land across the borough to deliver the minimum housing required to meet its needs in full.

Object

Representation ID: 16470

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16514
The delivery of new housing to meet the needs of all residents across the borough is a critical issues that must be addressed through the emerging Local Plan. The NPPF is clear that the standard method should be used as the starting point in establishing the housing requirement for an area. Gladman notes that the most up-to-date local housing need figure for the authority, defined using the standard method, is 1,928 dwellings per annum, which equates to 28,920 dwellings over a 15-year plan period. The PPG sets out that there are some specific circumstances in which an alternative approach to the standard method could be justified(1). Gladman submits that in this case, an alternative approach to the standard method is not justified. As such, there is no reason for the Council not to plan for its housing need defined by the standard method.

Gladman wishes to remind the Council that the NPPF sets out that a local planning authority can choose to set a housing requirement higher than its identified housing need. For example, this can be to include provision for neighbouring areas or reflect growth ambitions linked to economic development or infrastructure investment. The Council should consider the merits of planning for higher growth.

The PPG sets out that an increase in the total housing figures included in a plan may need to be considered where it could help deliver the required number of affordable homes(2). Therefore, the Council could choose to plan for a higher number than its local housing need figure to support the delivery of affordable housing.

Gladman stresses that the standard method should only be considered the starting point for calculating the new Local Plan’s housing requirement.

Gladman submits that the new Local Plan should make provision for more dwellings than the minimum housing requirement for the plan period. It is essential that flexibility is built into the emerging Local Plan to ensure the Council is able to respond positively to changes in circumstances over the plan period. A housing land supply buffer of 10-20% is generally considered suitable to mitigate against delays in delivery as a result of changes in the planning and/or economic context. The housing land supply buffer should be flexible with a diverse range of components to positively respond to delayed delivery and changes in the planning and/or economic context. Furthermore, Gladman recommends the application of a non-implementation rate to ensure the overall provision figure is robust and the minimum housing requirement for the plan period is met in full.

The purpose of the emerging Local Plan is to identify sufficient sites to meet the housing requirement in full. Therefore, Gladman recommends allocating additional medium- and large-scale sites instead of relying on windfalls to provide greater certainty in meeting its minimum overall housing requirement over the plan period. The additional sites would ensure the continued vitality and viability of settlements and identified housing needs are met in full. Critically, the deliverability of the allocations would be tested by an inspector at examination to ensure they are deliverable over the plan period.

1 PPG Reference ID: 2a-003-20241212
2 PPG Reference ID: 2a-024-20190220

Object

Representation ID: 16471

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16515
A stepped housing requirement would act to artificially supress the delivery of housing in the early years of the Local Plan to allow time for strategic allocations to come forward for development. The Government is seeking to deliver 300,000 homes per year between 2024 and 2029, equating to 1.5 million homes over the course of the parliament. If this target is to be achieved, every local planning authority in the country needs to play its part. A lower level of housing delivery in the early plan period would make it more difficult to achieve and result in local housing needs not being met in full in the short to medium term. The Government’s ambition to significantly boost the supply of homes is reflected in the NPPF. Gladman submits that a stepped housing requirement would be in conflict with national policy unless there was robust evidence to demonstrate that the housing requirement will be met in full over the plan period.

Gladman considers that the backloading of housing land supply could threaten the deliverability of the Local Plan. If the Council fails to achieve higher delivery rates at the end of the plan period, there will be limited scope to ensure that the housing requirement can be met in full. As such, Gladman recommends that the Council does not pursue a stepped housing requirement.

Support

Representation ID: 16472

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16516
Gladman agrees with the Council’s sequential approach to allocating sites for residential development. However, Gladman submits that there should not be an overreliance on brownfield development and that the capacity of brownfield sites should not be overestimated.

Although Gladman recognises the important role brownfield development plays in delivering much-needed housing, it must be noted that the viability of brownfield sites is more challenging, due to issues such as remediation costs, and can result in less affordable housing provision. Furthermore, brownfield sites are often more suited to being developed into high-density flatted development with typically one or two bedrooms per apartment. Therefore, Gladman stresses that an appropriate balance should be struck between brownfield and greenfield development so that the varied housing needs in the borough can be met in full.

In line with the sequential approach to allocating sites for residential development, Gladman submits that the Council should prioritise the allocation of sustainable greenfield sites.

Support

Representation ID: 16473

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16517
Gladman broadly supports the Council’s approach to the emerging settlement hierarchy but notes that depending on the spatial strategy option selected for the new Local Plan, the hierarchy may be amended. As a result, Gladman reserves the right to comment further on this matter as the emerging Local Plan progresses.

Support

Representation ID: 16474

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16518
Gladman submits that housing growth should be distributed according to the settlement hierarchy with the most sustainable settlements in the borough being directed the highest levels of housing growth. The level of housing growth allocated to a settlement should be proportionate to its size and sustainability. As such, Gladman considers that there should be limited levels of housing growth allocated to settlements in the tiers below those that have a level of facilities and services that mean they can meet day-to-day needs of their residents and those living in surrounding areas, such as Cuddington and Sandiway, Tattenhall and Tarvin.

Support

Representation ID: 16475

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16519
Gladman submits that the new Local Plan should contain place-based policies for all of the settlements identified in the settlement hierarchy including the ‘smaller settlements’ of Cuddington and Sandiway, Farndon, Helsby, Kelsall, Malpas, Tarporley, Tattenhall and Tarvin. Gladman submits that each place-based policy should set out the number of dwellings allocated to the settlement. In order to meet housing needs in full, housing growth should be directed to the settlement level rather than broadly to a settlement tier, as this can lead to higher levels of growth to some settlements and lower levels to others.

Support

Representation ID: 16476

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16520
Gladman considers that the level of housing growth allocated to a settlement should be proportionate to its size and the level of facilities and services available. Gladman notes, however, that new residential developments can help to reinforce existing facilities and services through additional provision. This needs to be considered by the Council.

Support

Representation ID: 16477

Received: 08/12/2025

Respondent: Gladman Developments Ltd

I&O_16521
Gladman would support a spatial strategy comprising of Green Belt release around Chester and the retention of the Green Belt elsewhere in the borough as being the most appropriate spatial strategy for Cheshire West and Chester to pursue through the new Cheshire West and Chester Local Plan. Gladman notes that 58% of the borough is not designated as Green Belt meaning that there is sufficient land available outside of this designation that can come forward for residential development over the emerging local plan period to meet a significant amount of its overall housing requirement. Due to the annualised housing requirement of 1,928 dwellings per annum for the borough as its minimum starting point, it is inevitable that there will have to be some further Green Belt release around Chester to accommodate the borough’s overall housing needs.

There are a number of sustainable settlements that lie outside of the Green Belt or are only partially constrained by the designation that are capable of accommodating further housing growth over the emerging plan period such as Cuddington and Sandiway, Middlewich, Tattenhall, Tarvin and Winsford.

Gladman supports the release of Green Belt around Chester due to it being the most sustainable location in the authority area (Tier 1 settlement). Chester is an important sub-regional centre, and the Council rightly recognises it as a key economic driver. This was the strategy that the Council undertook as part of the Cheshire West and Chester Local Plan (Part One) by only opting to release land from the Green Belt on the edge of Chester due to the sub-regional role of the city, high levels of in-commuting, affordable housing need and delivering a mix of housing.

Gladman is promoting Land off Hare Lane and Belle Vue Lane, Chester that has been identified by the Council as part of a larger swathe of land located to the east of Chester for housing development as shown on Map 5.4 ‘Chester Growth Options’ (ref: CH02) within the Issues and Options (Regulation 18) consultation document. Gladman submits that the site is suitable, available and deliverable as summarised in the site submission at Section 5 of this document.

[map included in attachment]

Furthermore, Gladman supports the recent statement made by Baroness Taylor of Stevenage in her formal response to Cotswold District Council on 26th August 2025 (3). In her reply, Baroness Taylor acknowledged the district’s constraints but emphasised ‘that all areas must “play their part” in meeting national housing needs’. She pointed to the revised methodology’s affordability focus and strategic planning goals. The same approach has to be taken by all local planning authorities across the country in order to deliver the 300,000 new homes per year (1.5 million homes over the Parliamentary term) target set by Government as part of its manifesto.

Once the Council decides on the strategy it wants to progress with through the new Cheshire West and Chester Local Plan, Gladman reserves the right to comment further.

3 Baroness Taylor of Stevenage response to the Leader of Cotswold District Council (26th August 2025) - https://news.cotswold.gov.uk/news/leader-of-cotswold-district-council-responds-to-governments-letter-stating-housing-targets-remain