Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 2049

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2169
The Council should ensure that all of their policy requirements are fully justified and evidenced. MCI broadly agree that the evidence base documents produced so far (listed on the website) and those that are to be prepared forms the right evidence to inform the new local Plan. In addition to the documents prepared to date and those which are still to be produced MCI urge the Council to undertake a comprehensive review of settlements as the Places Background Paper focus on Urban Areas and Key Service Centres only to the detriment of Rural Settlements. Rural settlements such as Moulton form an important part of the settlement hierarchy. The Issues and Options background data highlights that there are many settlements which are of a similar size to the Key Service Centres which are being overlooked due to limited services. These settlements would benefit from growth to support existing and encourage further services, may are located within close proximity to larger Urban Areas and through enhanced transport links sustainability could be enhanced. A comprehensive Settlement review would enable potential opportunities to be identified.

Comment

Representation ID: 2050

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2170
In accordance with paragraph 22 of the NPPF (2024) the Council should look at setting strategic policies for at least a 15-year period from adoption of the Local Plan and respond to long term requirements and opportunities.  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).

Comment

Representation ID: 2051

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2171
The new Local Plan should have a Vision to ensure that it is meeting the current and future needs in relation to housing. In MCI’s opinion, the Vision should contain (more appropriately) reference to how the Borough will grow over the new Plan period, taking into account existing directions of growth and responding to objectively assessed and identified needs.   Any evidence prepared to support the vision such as a settlement hierarchy should be robust, up to date and objective. It should go beyond a simple spreadsheet of data in relation to services and instead assess the functional role of those services—distinguishing between those that serve local needs and those that act as service hubs for wider communities.   A comprehensive assessment should also evaluate the economic, social, and spatial roles of settlements. This includes their contribution to the local and regional economy, their connectivity to other settlements, and their role in providing employment, education, healthcare, and other key services.   A meaningful settlement hierarchy should be informed by a multi-dimensional evidence base that reflects both quantitative data (e.g. population size, service provision, transport links) and qualitative insights (e.g. functional relationships, economic roles, strategic importance). This approach ensures that planning decisions are transparent, defensible, and aligned with sustainable development principles.   The Local Plan should provide a balanced spatial strategy, ensure that while recognising planning designations and constraints in plan area. The Local Plan should seek to meet the areas ‘objectively assessed needs’ as set out within paragraphs 11, 23 36 and 124 of the National Planning Policy Framework (NPPF, 2024) correctly to deliver a sustainable future for the area and ensure sufficient allocations are made for housing, employment, infrastructure related development. The Vision should be clearly articulated and the relationship between the Vision and the Objectives set out further within the document. To provide certainty to communities, the Plan should outline how development will be phased and how supporting infrastructure will be delivered.   It is also important that the Vision acknowledges the interrelationship of settlements with neighbouring towns and cities, to reflect real-world patterns of movement, employment, and service use.   The Local Plan Vision involves looking ahead to what Cheshire West and Chester will look like in circa 20 years’ time so it should reflect the Plan period, and what the Council wants to achieve and thinking about different ways of approaching it.   The Vision should be based on a sound understanding of the form and function of the Plan area, and can draw upon various sources including past Plans, sustainability work being undertaken alongside the Plan and stakeholder involvement, The Vision should be aspirational but realistic, locally distinctive, and spatial in planning terms. In addition, the NPPF (2024) requires (paragraphs 24-27) that local planning authorities are under the duty to cooperate with each other, and with other prescribed bodies, on strategic matters that cross administrative boundaries.

Comment

Representation ID: 2052

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2172
Whilst the Council may wish to look at the objectives of the current Local Plan and the Sustainability Appraisal, any objectives prepared should be specific this Plan and address the issues and challenges that are current in Cheshire West. Taking forward the current Local Plan objectives may result in a plan which is outdated and not relevant to the current and future needs of Cheshire West and Chester.

Comment

Representation ID: 2053

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2173
MCI do not consider that taking forward the current Local Plan objectives is an appropriate approach. The objectives should flow from the Local Plan vision, establishing the way in which the plan area will deal with the identified critical issues. The objectives should be clear, realistic, locally distinctive and spatial in planning terms. Taking forward the current Local Plan objectives may result in a plan which is outdated and not relevant to the current and future needs of Cheshire West and Chester.

Comment

Representation ID: 2054

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2174
MCI do not consider that taking forward the Sustainability Appraisal objectives is an appropriate approach. As highlighted the objectives should flow from the Local Plan vision, establishing the way in which the plan area will deal with the identified critical issues. The objectives should be clear, realistic, locally distinctive and spatial in planning terms.

Comment

Representation ID: 2055

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2175
Whilst MCI absolutely agrees that there is a need to tackle climate change and action should be taken locally by the Council, their view is that this action should be restricted to issues associated with the location of development, ensuring that growth is located close to services and facilities or where there are high levels of access to public transport and active travel options which allow residents to pursue a lower carbon lifestyle. They also agree that other measures to address climate change such as the inclusion of SuDS, tree planting and appropriate public open space and habitat creation should be planned for. Whilst MCI recognises the urgency to move at pace to address climate change this needs to be led centrally and rolled out nationally. The Council should seek to ensure that they produce a sustainable Plan which supports a balance of homes and employment and is in line with the guidance provided by the NPPF (2024) and the PPG. The Council should ensure that any climate change policy is only implemented in line with the December 2023 Written Ministerial Statement which states that “a further change to energy efficiency building regulations is planned for 2025 meaning that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes” . It goes on to state that “ the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current, or planned building regulations, should be rejected”. National planning policy is silent on the issue of embodied carbon standards as are building regulations. MCI therefore question why the Council consider that this policy is necessary. MCI considers it is best that such matters are addressed at a national level to avoid different approaches and standards being set in different areas.

Comment

Representation ID: 2056

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2176
See response to Question SD1.

Comment

Representation ID: 2057

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2177
We consider that the starting point for considering the amount of new housing that should be planned for must be grounded in the most up-to-date government guidance. This includes the Written Ministerial Statement (30 th July 2024), the standard method for calculating local housing need, and the National Planning Policy Framework (NPPF, 2024). In particular Paragraph 69 of the NPPF (2024) which states “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period.” We consider it important that the Council should consider adopting a housing requirement that exceeds the figure derived from the standard method, in order to support strategic objectives related to economic growth or infrastructure investment, as envisaged in the NPPF (2024). Reference (and not duplication) should be made to inform the reader and the community that paragraph 36  of the NPPF (2024) has been taken into consideration in particular parts a) and d) which requires that Local plans are: “a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development” and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.” The Council should clearly articulate how it intends to bridge the gap between past delivery and future need, particularly in light of the government’s continued emphasis on housing delivery performance through the Housing Delivery Test. Appropriate evidence should be gathered to determine what types of homes may be needed and can be delivered in Cheshire West and Chester. This should include planning for affordable housing needs in line with the requirements of paragraphs 35, 64-66 of the NPPF 2024. Any affordable housing requirements should be clearly set out, there should be a viability assessment to support them and there should be flexibility within the policy where viability may be an issue.

Comment

Representation ID: 2058

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2178
The Council may consider a stepped housing requirement that plans for a lower level of delivery earlier in the plan period. This approach would need to be fully justified and there would need to be a clear strategy to ramp up delivery later in the plan period.