Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13327

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13846
The length of the Local Plan period is critical. While the Council proposes a 15-year plan period, in accordance with paragraph 22 of the NPPF, this must be measured from the anticipated date of adoption, not from the plan’s base year. Given that adoption is unlikely before late 2027, or potentially early 2028, the plan period should extend to at least 2043 as a minimum. Furthermore, paragraph 22 of the NPPF states: “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), to take into account the likely timescale for delivery.” This is particularly applicable to the emerging CWaC Local Plan, which includes several significant strategic growth locations. For example: • CH02: Chester East- Piper’s Ash, with an estimated capacity of 4,316 dwellings, and • EP02: Ellesmere Port South, with an estimated capacity of 5,517 dwellings, and • WIN05: Winsford West- Hebden Green, with an estimated capacity of 6,376 dwellings. According to Lichfields’ Start to Finish (2024) report, large-scale sites of over 2,000 homes typically deliver an average of 150 dwellings per year. Even assuming two major housebuilders operate concurrently, potentially doubling delivery to 300 dwellings per year, the build-out period would still extend to over 20 years, particularly when accounting for a typical six-year lead-in time before the first completions, as also noted by Lichfields. This highlights the long-term nature of strategic site delivery and reinforces the need for a sufficiently long plan period. In summary, to ensure the Local Plan provides at least 15 years of housing supply from the point of adoption, the Council should, as a minimum, plan for an 18-year period between 2025 to 2043. However, given the likely inclusion of several strategic sites, many of which will continue delivering housing well beyond 20 years, a 30-year plan period (2025 to 2055) represents a more robust and appropriate approach. Extending the plan horizon allows for realistic, phased development of strategic sites, facilitates coordinated infrastructure planning, and helps maintain the relevance and deliverability of the Local Plan over the long term. This approach reduces the risk of policy gaps or early obsolescence.

Comment

Representation ID: 13328

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13847
We recognise that Neighbourhood Plans (NPs) can play a valuable role in delivering smaller-scale housing sites where there is strong local support. They provide a mechanism for communities to influence the form, location, and design of development in their area, ensuring that new homes reflect local character, infrastructure capacity, and community priorities. For sites of a smaller scale similar to the one promoted by Carden Group at Great Barrow, Neighbourhood Plans can be an effective vehicle for bringing forward housing, particularly where there is local engagement and support. Smaller allocations identified through NPs can complement the strategic framework of the Local Plan, contributing to housing delivery in a way that is sustainable, locally appropriate, and aligned with the Council’s overall growth strategy. In summary, Neighbourhood Plans should continue to have a role in supporting the delivery of locally led, smaller-scale housing sites, alongside influencing local design and policy. This approach allows communities to have a direct say in development, while ensuring that housing needs are met in a coordinated and sustainable manner.

Comment

Representation ID: 13329

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13848
We welcome the Council’s intention to set a positive, place-based vision for the future of Cheshire West and Chester, centred around sustainable growth, community wellbeing, and environmental protection. However, we believe the current vision omits a fundamental principle that is essential to the future prosperity and inclusivity of the borough: the need to plan positively for housing delivery in response to a national and local housing crisis. Nationally, the UK continues to face a systemic housing shortage. Successive governments have failed to meet the national target of 300,000 homes per year. The Centre for Cities recently concluded that Britain has built 4.3 million too few homes over the last seven decades. As a result, we request that the Council amend the vision to include a fifth principle, along the following lines: •  Meeting Housing Needs – meeting the full, objectively assessed housing needs of all parts of the borough, including affordable, market, and specialist housing.

Comment

Representation ID: 13330

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13849
We support Option A as the preferred framework for setting the strategic objectives of the new Local Plan. While Option B (Sustainability Appraisal objectives) plays an important role in testing the sustainability of policies, it is not suitable as the primary structure for the Local Plan’s strategic objectives.
Option A - take forward current Local Plan Objectives

Comment

Representation ID: 13331

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13850
Option A rightly places emphasis on key strategic priorities such as infrastructure provision (SO5), economic development (SO2), and transport (SO4), which are essential for attracting landowner and developer interest, enabling the planning and promotion of long-term strategic sites, and underpinning effective masterplanning and delivery. These objectives provide a robust framework to support the practical delivery of sustainable development.

Comment

Representation ID: 13332

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13851
SO10 should be amended to acknowledge that, in light of the significantly increased housing requirement and the limited brownfield land supply, the release of land from the North Cheshire Green Belt will be required.

Comment

Representation ID: 13333

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13852
Option B, while important for environmental protection and broader sustainability goals, does not place sufficient emphasis on housing delivery. This approach risks sidelining the urgent need to address the local housing crisis, especially given the significant increase in housing requirements for Cheshire West and Chester. Without a clear focus on facilitating the timely allocation and development of housing sites, Option Bs objectives may hinder effective planning and slow the delivery of much-needed homes, undermining the Local Plan’s ability to meet pressing community and market demands.

Comment

Representation ID: 13335

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13854
We welcome the Council’s acknowledgment of the need to meet the housing requirement identified by the Government’s standard method. However, we strongly urge the Council to plan for a housing requirement above the 1,928 dwellings per annum (dpa) baseline figure (based on the latest May 2025 affordability ratios). This position is entirely consistent with the NPPF which makes clear at paragraph 11(b) that the standard method provides only a minimum starting point for assessing housing need. Planning for a higher figure is not only justified by national policy but essential to delivering a robust Local Plan. In the case of Cheshire West and Chester, there is clear and compelling evidence that a higher figure can be delivered sustainably. For example, according to the Council’s latest 2025 Housing Land Monitor report, between 2014/15 and 2024/25, annual completions have consistently exceeded the 1,100 dpa housing target, peaking at 2,542 dwellings in 2017/18. Over this 11-year period, the Council has over-delivered by more than 9,000 dwellings against the adopted Local Plan target, evidencing both market appetite and delivery capability. In light of the evidence, we recommend that the Local Plan sets a housing requirement of at least 2,200 dwellings per annum. This represents a modest uplift of around 15% above the standard method figure, which is substantially lower than the average over-delivery of 54% the borough has achieved since 2014. This proposed figure is both realistic and deliverable, based on the area's consistent track record of strong housing delivery. Setting a higher requirement not only reflects market capacity but ensures the Local Plan remains robust, responsive to change, and capable of supporting long-term economic growth and housing affordability.

Comment

Representation ID: 13336

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13855
The Council should not adopt a stepped housing requirement in the new Local Plan. Delaying delivery in the early year’s risks failing to address urgent housing needs and affordability challenges. The NPPF makes clear that the standard method figure is a minimum starting point and that local plans should aim to meet housing needs as soon as possible. In Cheshire West and Chester, there is no justification for a stepped approach, as the borough has a strong track record of delivery, frequently exceeding the current adopted LP target. A stepped trajectory would unnecessarily delay much- needed homes, complicate delivery, and reduce certainty. Instead, the Council should maintain a consistent annual requirement from the outset to reflect market capacity, ensure timely delivery, and support the objectives of the NPPF. There is no justification for a stepped housing delivery as the Council has consistently delivered about the local plan housing requirements, and a level in excess of the proposed housing requirement.

Comment

Representation ID: 13337

Received: 29/08/2025

Respondent: Landowner (Manor Park)

I&O_13856
We broadly support the principle of prioritising previously developed (brownfield) land within existing settlements. However, we must stress that the scale of available brownfield land is wholly insufficient to meet the district’s housing needs over the plan period. According to the most recent Brownfield Land Register (2021), only 96 hectares of brownfield land across the borough remain without planning permission. Based on typical brownfield densities in the UK, estimated by the CPRE State of Brownfield 2022 report at approximately 70 dwellings per hectare, this equates to a theoretical capacity for around 6,720 dwellings. However, this figure should be treated with caution. The Brownfield Land Register does not account for a range of site-specific constraints that frequently affect deliverability. These include flood risk, contamination, heritage restrictions, ecological value, and site access issues. In addition, many brownfield plots are in fragmented ownership or face significant viability challenges due to abnormal development costs. As such, the actual number of dwellings that can be delivered from these sites is likely to be substantially lower. A realistic assumption must apply a discount to reflect these limitations, reducing the notional 6,720 dwelling figure to a far more modest and deliverable total. Moreover, the most recent 2025 Housing Land Monitor Summary Report identifies a supply of 6,407 dwellings when assessed against the housing requirement. Given this context, and the need to deliver a minimum of 34,000 homes (1,914 dpa over an 18-year plan period) we urge a more balanced and realistic policy approach that acknowledges the essential role of greenfield, and specifically Green Belt, sites in delivering sustainable housing growth that helps maintain village vitality. We therefore recommend that Policy SS3 be amended to include the following: • A clear recognition that, while brownfield sites are to be prioritised, their capacity is inherently limited and are insufficient to meet the Council’s full housing needs. • An explicit commitment to the release of greenfield sites, including within the Green Belt. Overall, a sound spatial strategy must be evidence-led, and the current housing land supply and brownfield positions clearly demonstrate the need to release greenfield and Green Belt land.