Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11216

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11714
The R18 LP confirms that CWAC intend to prepare additional evidence to support the emerging Local Plan, including a Housing Needs Assessment, Green Belt Study, Infrastructure Delivery Plan, Strategic Viability Assessment and Land Availability Assessment. Paragraph 32 of the NPPF requires that the preparation of all policies should be underpinned by relevant and up-to-date evidence which is adequate and proportionate to justifying policies. To this extent and, principally with regard to the proposed allocation of Chester Business Quarter, it is considered imperative that the Council produces the evidence it has outlined as soon as possible to inform its new Local Plan. This must include an up-to-date Housing Needs Assessment which includes a detailed consideration of the need for different tenures of affordable housing and recognises the different local housing markets in operation across the authority and the needs of different segments of the housing market. Similarly, whilst an Economic Development Needs Assessment (EDNA) has been recently published as we refer in subsequent questions several deficiencies of this study have been identified, and it should be updated accordingly to support the next draft of the Local Plan. Furthermore, the Council will need to complement these assessments with up-to-date evidence of the availability of housing and employment land to ensure that calculated needs can be  accommodated through appropriate land allocations and policies.

Comment

Representation ID: 11223

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11721
The emerging Local Plan should contain a clearly defined monitoring framework, which establishes key monitoring indicators for each relevant policy and defines how the objectives / targets established in the Local Plan are being met and, if not, why and what actions will be taken and when to address any issues. It should also confirm the associated data sources and means of reporting. Following on from this it is essential that housing delivery is actively monitored in order to understand the Borough’s delivery rate against the identified housing requirements. This should be done at least annually in accordance with Paragraph 78 of the NPPF in order for both CWACC to take any necessary action and to allow developers to accurately apply the strategic policies of the Local Plan.

Comment

Representation ID: 11227

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11725
The R18 LP confirms that CWACC intends to plan for a period of 15 years. Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments 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. In order to ensure a robust approach to the emerging Local Plan, reflecting the likely timescales for preparation and accounting for a 15-year plan period post-adoption in line with the NPPF (paragraph 22), Habiko considers that CWACC should, as a minimum, be looking to prepare a new Local Plan that will look forward to at least 2045 to enable a 15-year plan period post-adoption. It is important to note in this regard that the adopted Local Plan applied a 20-year plan period.

Comment

Representation ID: 11230

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11728
In accordance with paragraph 15 of the NPPF, Local Plans should provide a positive vision for the future of CWAC. The current vision, whilst positive and well meaning, is not deemed to be particularly ambitious with regard to the Government’s growth ambitions. Habiko believe that the vision ought to make clear reference to addressing the housing crisis through planning proactively and sustainably for a substantial quantum of new housing to meet the Borough’s diverse needs and to provide much needed affordable housing for a range of demographics. The vision should aim to sustain the vitality and viability of Chester city centre and other town centres by increasing the level of residential accommodation within designated centres thus increased footfall. Similarly, the vision should reflect the need to contribute towards economic growth through the allocation of employment sites in suitable locations where they respond to a clear requirement and for all intents and purposes are deliverable.

Comment

Representation ID: 11233

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11731
Again, whilst Habiko understand the R18 LP’s focus on addressing the climate emergency and bridging the inequality gap and delivering prosperity for all, these objectives are only achievable through harnessing the benefits of sustainable economic growth therefore it is important that the emerging Local Plan recognises that ambitious growth targets are required through the allocation of sufficient land for housing and employment needs in the right locations.

Comment

Representation ID: 11234

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11732
Yes, Habiko supports the proposed approach to establishing specific visions for key places within the Borough, provided that these visions align with the overall Spatial Strategy and Settlement Hierarchy. The focus on Chester in particular as the Borough’s largest settlement is supported.

Comment

Representation ID: 11235

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11733
It is considered that the emerging Local Plan objectives ought to reflect the specific requirements of CWAC based on a complete up-to-date evidence base. This may not well be possible at regulation 18 stage, however basing objectives on the current development plan and/ or Sustainability Appraisal are unlikely to be fit for purpose given the current Government’s clear direction to see a return to economic growth and substantial uplift in housing delivery.

Comment

Representation ID: 11237

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11735
It is considered that the emerging Local Plan objectives ought to reflect the specific requirements of CWAC based on a complete up-to-date evidence base. This may not well be possible at regulation 18 stage, however basing objectives on the current development plan and/ or Sustainability Appraisal are unlikely to be fit for purpose given the current Government’s clear direction to see a return to economic growth and substantial uplift in housing delivery. As above, an approach consistent with identified needs following all necessary evidence being collated.

Comment

Representation ID: 11238

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11736
The Government published updated dwelling stock figures in May 2025 which means that CWAC’s local housing need (‘LHN’) figure has further increased to 1,914 dwellings per annum (‘dpa’); an increase of 14 dpa, which equates to a total of 28,920 dwellings over a 15-year plan period and 38,560 dwellings over a 20-year plan period. The Council is advised to keep the precise figure under review, as further affordability and housing stock data will become available before the Regulation 19 consultation scheduled for autumn 2026.In accordance with the NPPF, the standard  methodology for assessing local housing need in England and the July 2024 Written Ministerial Statement – “Building the Homes we need” – this is the minimum housing need figure that should be considered in preparing the emerging Local Plan. Furthermore, in line with paragraph 69 of the NPPF, the Council may also need to consider if it is appropriate to plan for a higher housing need figure than the standard method indicates to reflect growth ambitions linked to economic development or infrastructure investment. In summary, Habiko does not consider there to be any justification in planning for a lesser number of units than the LHN requirement. 

Comment

Representation ID: 11239

Received: 28/08/2025

Respondent: Habiko LLP (c/o Muse)

I&O_11737
Whilst the full evidence base in order to support such an approach is not yet available, Habiko considers that CWACC ought to plan for meeting, as a minimum, its annual LHN requirement of 1,914 dwellings per annum, in order to avoid risking sustained under delivery, support economic growth and to respond to the evidence of existing and immediate needs for affordable housing outlined in Section 4 of these representations.