Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 1976

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2092
The Council propose that the update to the Local Plan should plan for a period of 15 years. The NPPF [1] states 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. The HBF considers that the Council may want to be looking to prepare a new Local Plan that will look forward to at least 2045 to ensure that it covers the 15-year period, they may also want to consider whether any strategic sites require the Council to plan over a longer period for these areas. [1] NPPF December 2023 Paragraph 22 / NPPF 2024 Paragraph 22

Comment

Representation ID: 1977

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2093
The HBF considers that the Local Plan should include a vision, and it should ensure that meeting the current and future housing needs is a key part of the vision and objectives for the Plan, this includes the housing needs for market housing, family homes, homes for older people and homes for first-time buyers. The HBF considers that whilst the Council may take inspiration from the objectives of the current Local Plan and the Sustainability Appraisal, that it should prepare objectives specific to this Plan that address the issues and challenges that are current in Cheshire West.

Comment

Representation ID: 1978

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2094
The HBF continues to recognise the need to move towards greater energy efficiency and carbon reduction via a nationally consistent set of standards and timetable, which is universally understood and technically implementable. This is in line with the Written Ministerial Statement of December 2023 (WMS) [1] , which states that the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned building regulations. The WMS clearly states that any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures: that development remains viable, and the impact on housing supply and affordability is considered in accordance with the NPPF; and the additional requirement is expressed as a percentage uplift of a dwellings Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). National planning policy is silent on the issue of embodied carbon standards as are building regulations. The HBF would therefore question why the Council consider that this policy is necessary. The HBF considers it is best that such matters are addressed at a national level to avoid different approaches and standards being set in different areas. The housebuilding industry is working with the Future Homes Hub to develop a roadmap to reducing embodied carbon and whilst Councils may want to go further and faster the HBF have concerns that this will impact on the deliverability of development with a disproportionate impact on SME developers. Given that the Government has been clear that it does not want to see a proliferation of different standards across the country, the HBF would suggest that the approach being taken by the Council in setting such a standard is not consistent with the approach advocated in the WMS [2] . The HBF is also concerned that planning may be too early in the building process to fully assess the carbon impact of a design. It may be that further decisions are made post planning, which do not require further consent which would impact on the carbon emissions. The HBF considers that if the Council is to introduce a policy in relation to embodied carbon it will have to closely consider how it will be monitored and what the implications are for the preparation of any assessment, particularly in relation to how easily accessible any data is. The Council will also have to consider how the policy will interact with other policies, for example, in relation to design, energy efficiency or resilience to heat, as well as the viability and delivery of development. AECOM, on behalf of MHCLG, has completed a research report on the practical, technical and economic impacts of measuring and reducing embodied carbon in new buildings [3] . This report highlights issues with the lack consistency in reporting on carbon assessment outputs, the quality of carbon assessments, large gaps in the availability of both product specific EPDs and generic data, the variation in product carbon results for similar building products, and lack of consistency across carbon tools. The report also highlights issues with the uptake of lower embodied carbon materials and products due to costs, risks and insurance, the need to upskill the industry and access to carbon tools. Whilst this report makes recommendations as to how all of the challenges they identify can be addressed, they have not been addressed yet and are not likely to be ad-dressed in the short term. The HBF is concerned that as such, there are significant challenges with introducing a policy in relation to embodied carbon, for many of the reasons identified in this research. Without consistent data and information, it will be almost impossible for applicants to provide decision makers with reliable information on which to base a decision. The HBF does not consider that it is a reasonable requirement for development to maximise opportunities to generate energy from renewable sources. The HBF recognises that there may be potential for energy to come from renewables, however, it may not always be the most sustainable, efficient or effective approach. [1] WMS December 2023 https://questions-statements.parliament.uk/written-statements/detail/2023-12-13/hcws123 [2] https://questions-statements.parliament.uk/written-statements/detail/2023-12-13/hcws123 [3] https://assets.publishing.service.gov.uk/media/6823078e53add7d476d8194c/The_Practical__Technical_and_Economic_Impacts_of_Measuring_and_Reducing_Embodied_Carbon_in_New_Buildings.pdf

Comment

Representation ID: 1979

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2095
Heat networks are one aspect of the path towards decarbonising heat, however currently the predominant technology for district-sized communal heating networks is gas combined heat and power (CHP) plants. Over 90% of district networks are gas fired. As 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. The Council should be aware that for the foreseeable future it will remain uneconomic for most heat networks to install low-carbon technologies. Furthermore, some heat network consumers do not have comparable levels of satisfaction as consumers on gas and electricity networks, and they pay a higher price. For example, a consumer living in a building serviced by a heat network does not have the same opportunities to switch supplier as they would for most gas and electricity supplies.

Comment

Representation ID: 1980

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2096
The HBF notes that due to the housing stock figures being updated in May, the housing need figure has actually increased to 1,928 dwellings per annum and brings the overall total over 15 years to 28,920. The HBF considers that this housing figure will need to be considered to reflect the latest government guidance in relation to the Written Ministerial Statement [1] , the standard methodology and 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 as set out in the NPPF [2] . The HBF considers that the Council will need to consider an appropriate balance of development, to ensure that all of their housing needs are met in terms of types and tenures; locations and markets, and to ensure that the Plan can deliver against its housing requirements. The HBF considers that it will be necessary to gather appropriate evidence including a housing needs assessment and a Viability Assessment to determine what types of homes may be needed and can be delivered in Cheshire West and Chester. The HBF considers this is likely to include a wide range and variety of homes, from homes for first-time buyers, to family homes, to homes to suit the older population. The HBF would encourage the Council to work with the home building industry working in the area to determine the types of homes that are currently being delivered, and where there is demand from home purchasers. The HBF considers that it is appropriate for the Council to plan for the affordable needs of its community, and to ensure that it does this in line with the requirements in the NPPF [1] . This should ensure that any affordable housing requirements are clearly set out, and are evidenced as viable through an assessment, and that flexibility is provided within the policy where viability may be an issue. [1] NPPF December 2024 paragraphs 35, 64-66 [ 1] Building the Homes we need – Written Ministerial Statement 30th July 2024 [2] NPPF December 2024 paragraph 69

Comment

Representation ID: 1981

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2097
The HBF considers that it is important that the spatial strategy allows for the delivery of sufficient homes to meet the local housing needs, across the range of housing needs in a variety of locations. The HBF agrees that this is likely to require more than just homes on previously developed land within the existing settlements, and that it is likely to see a level of Green Belt release. The Council will need to ensure that they are able to fully evidence the exceptional circumstances for Green Belt release, the NPPF states that these can include but are not limited to where an authority cannot meet its identified need for homes through other means. The HBF also considers that the Council will need to undertake a Green Belt Review to assess which sites may be appropriate for release. This will need to be considered alongside the spatial strategy. The Council may also want to ensure that they consider sites that could be made sustainable or \may contribute to improving the sustainability of an existing settlement, as well as sites that are currently considered sustainable as part of their assessment.

Comment

Representation ID: 1982

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2098
The HBF would wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation.

Comment

Representation ID: 1983

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2099
The HBF does not consider that it is in a position to comment on which of these growth options is likely to be appropriate without full consideration of the land availability and suitability in each of these approaches. It may be that elements of each approach should be taken forward to garner as many of the positives from each approach, for example supporting the vitality of smaller settlements, but also supporting the development of land within or adjacent to the larger settlements where developments are likely to be sustainable. The HBF considers that an approach which does not include a level of Green Belt release is unlikely to be appropriate, this would be unlikely to meet the local housing needs across the Borough, and could lead to an unsustainable spatial strategy. The HBF considers that the Council should ensure that whichever spatial strategy option is chosen, it should ensure that an appropriate level of housing can be delivered and that it can meet the needs of all aspects of the housing market.

Comment

Representation ID: 1984

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2100
The HBF notes that the Council have excluded areas of land that would act as potential ‘showstoppers’ to restrict future development it suggests that these include Local Green Spaces, designated habitats sites, Sites of Special Scientific Interest, irreplaceable habitats, designated heritage assets, key settlement gaps, Areas of Special County Value, strategic open space, areas of flood risk and significant hazard zones. The HBF considers that some of this list are not showstoppers to development, and they should not all be classified in the same way, some of these are national designations, some of them will mean no development will be appropriate, some will be local designations and could be reconsidered, and some would not necessarily stop development, they may just be an additional consideration to be taken into account as development is planned for. For example, key settlement gaps, are only a local designation protected by a policy in the Local Plan, the HBF recommends that the Council keeps these areas under review as it considers its housing need and the sustainability of locations suitable for development. It may be that the provision of good quality sustainably located housing is most appropriate in these locations. The HBF does not consider that the separation of these settlements should necessarily override the provision of housing where it is needed and where it can be sustainably located.

Comment

Representation ID: 1985

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2101
The HBF is keen that the Council produces a plan which can deliver against its housing requirement. To do this it is important that a strategy is put in place which provides a sufficient range of sites to provide enough sales outlets to enable delivery to be maintained at the required levels throughout the Plan period. The HBF and our members can provide valuable advice on issues of housing delivery and would be keen to work proactively with the Council on this issue. It is important that housing delivery is effectively monitored so that if housing monitoring shows delays to housing delivery across Cheshire West and Chester action is taken to address this as soon as possible. The Council will need to monitor the delivery of housing and publish progress against a published Housing Trajectory, and Housing monitoring should be undertaken on a site-by-site basis. The HBF also notes that the NPPF [1] requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong reasons why this cannot be achieved. The HBF has undertaken extensive consultation with its small developer members. One of the chief obstacles for small developers is that funding is extremely difficult to secure without a full, detailed, and implementable planning permission. Securing an implementable planning permission is extremely difficult if small sites are not allocated. Without implementable consents lenders are uneasy about making finance available or the repayment fees and interest rates they set will be very high. Small developers, consequently, need to invest a lot of money and time up-front in the risky business of trying to secure an allocation and a planning permission, and this is money that many small developers do not have. The HBF would therefore wish to see the 10% small sites allowance delivered through allocations (and not windfall). Such sites are important for encouraging the growth in SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the 1980s, small developers accounted for the construction of half of all homes built in this country resulting in greater variety of product, more competition, and faster build-out rates. Since then, the number of small companies has fallen by 80%. The HBF also notes that support for small and medium builders need not be limited to only small sites of less than 1Ha. SMEs also deliver on other types of non-strategic sites (for example up to 100 units).  The inclusion of additional non-strategic allocations would expand the range of choice in the market, and (possibly most importantly), be of a scale that can come forward and make a contribution to housing numbers earlier in the plan period. The Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver Cheshire West and Chester’s housing requirement. This sufficiency of housing land supply should ensure that the Council can meet the housing requirement, ensure the maintenance of a 5-year housing land supply and achieve the Housing Delivery Test. The HBF also strongly recommends that the plan allocates more sites than required to meet the housing requirement as a buffer. This buffer should be sufficient to deal with any under-delivery which is likely to occur from some sites and to provide flexibility and choice within the market. Such an approach would be consistent with the NPPF requirements for the plan to be positively prepared. The HBF believes that the Plan should provide for a wide range of deliverable and developable sites, including a buffer and small site allocations in Cheshire West and Chester in order to provide competition and choice to ensure that housing needs are met in full. [1] NPPF 2024 Paragraph 73