Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9110

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9603
The revised Standard Method calculation, which resulted in the 1,914 dpa requirement, was designed to provide a minimum housing need figure in order to address the national shortfall in the supply of homes, and to support and enable growth in local areas. Whilst it is possible for this number to be reduced in constrained locations, where exceptional circumstances can be justified, we do not believe that such justification exists in Cheshire West and Chester. This is demonstrated within the Issues and Options consultation report, which has identified a number of different options for delivering the required minimum figure. Cheshire West and Chester’s Housing Strategy 2025-2035 states that there are 6,735 applicants registered on the housing waiting list. Furthermore, the Economic Needs Assessment shows a significant and steady growth in Employment within the assessment period (up to 2045). The evidence base clearly demonstrates that significant housing is needed, and as such the standard method should be the starting point for delivery. The shortfall in supply is chronic and needs to be addressed through emerging Local Plan. Furthermore, the PPG states how a range of circumstances may justify the determination of housing need which exceeds the standard method minimum, and that an assessment of need which establishes a figure which is higher than the standard method minimum will be considered sound if it “adequately reflects current and future demographic trends and market signals.” It is therefore important to consider whether any factors justify an increase in the Standard Method minimum when determining housing need but at the very least, there is no reason as to why the Council should drop below the identified dwellings per year as set out.

Comment

Representation ID: 9112

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9605
A stepped approach, as detailed within paragraph 12 of the Planning Practice Guidance (‘PPG’) for Housing Supply and Delivery, may be considered in relation to a significant change, or for strategic sites requiring a phased approach. The revised housing requirement represents an 800-dwelling increase, which may be seen as significant; however, CW&C reported in their latest Housing Monitoring Report (2024-2025) that in the last three years completions were as follows. (See attachment for full response). It is clear that as a Council, CW&C have been performing well against their previous requirement and delivering homes significantly higher year on year. As such, the revised target of 1,914 as set out in SS 1 should not be a significant jump in what the Council can provide. As set out through the following questions, whilst one spatial option is to deliver homes through larger strategic sites that could see slower or phased delivery whereby a stepped housing requirement could be suitable, we are of the view that this option should not be the preferred route. This would not allow for the for a distribution that suits identified needs throughout the borough. Whilst the Council has been performing well against previous targets, the Council can currently only demonstrate a 2.09 year supply of housing land, and the evidence base has demonstrated a clear shortfall in homes. There is a clear need for immediate delivery of new housing, and for the Council to identify suitable sites for immediate delivery to rebalance the revised housing need as well as sites to meet this position throughout the emerging Local Plan period. The PPG states that stepped housing requirements must be appropriately evidenced, and “not seek to unnecessarily delay meeting identified development needs”. We do not believe that such evidence exists, in that suitable sites for the supply of housing can be identified for delivery throughout the plan period, without the reliance on larger/strategic sites. As such, we do not believe it appropriate to consider a stepped housing requirement.

Comment

Representation ID: 9113

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9606
The spatial strategy principles set out to firstly direct new development and allocate land toward previously developed sites in settlements. Where this is not sufficient, to develop on the edge of existing settlements in locations with the best access to public transport and existing services and infrastructure. The principles also note that, depending on the settlement, this may require release of Green Belt land. We agree that previously developed land may be first allocated if the sites are demonstrated as deliverable; however, given the limited brownfield capacity in CW&C, it is clear that greenfield sites will need to be brought forward in and around settlements in order to meet the minimum housing requirement. Furthermore, previously developed land frequently comes with constraints such as existing buildings and contaminated land which can cause lengthy delays in the delivery of housing. In order to ensure a continuous supply of housing, it will be necessary to enable suitable greenfield sites to come forward alongside previously developed land. In order to facilitate this, we would agree with the release of suitable sites within the Green Belt. As such, SS3 should be amended to reflect the need for urban extensions in order to meet the housing requirement. This may be reworded to “where additional land is required to meet the housing requirement, the approach will be to develop on the edge…”.

Comment

Representation ID: 9116

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9609
We agree with the proposed settlement hierarchy. Chester is clearly the most sustainable location, and as such should accommodate the most growth in order to meet the needs of local residents. This is also reflective of the current and proposed ambitions for Chester as a Sub-Regional City. Furthermore, the Council has identified Chester as a key location for significant economic growth, both within the emerging Local Plan proposals, and within existing policy. The One City Plan for Chester, which was last updated by CW&C in 2024, sets out a key theme as ‘Business Friendly, Economy and Skills’. Within this, the Council has committed to attracting inward investment by focussing on growth opportunities, marketing the city as a place for business and to become a thriving city. In order to achieve the economic ambitions for Chester, significant additional housing will be required. The Local Plan must accommodate additional housing to Chester to account for the economic skew within the city.

Comment

Representation ID: 9118

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9611
The NPPF outlines the process for review under paragraph 145, noting that the boundaries should only be altered where “exceptional circumstances are fully evidenced and justified through the preparation or updating of plans”. The NPPF goes on to note that exceptional circumstances include where LPA’s cannot meet its identified need for homes, commercial or other development through other means. Whilst the Council has previously been able to meet its housing need, the identified requirement of 1,914dpa represents an exceptional circumstance; particularly in light of the Council being currently only able to demonstrate a 2.09 Year Housing Land Supply, well below the 5-year supply required by national policy. As such, circumstances have changed to justify Green Belt release. We believe that, subject to a formal Green Belt Review, a number of sites can be identified that are suitable for release around Chester in order to meet the identified housing requirement. In particular, the Miller Developments site at Mannings Lane is suitable due to the clear and defensible boundary formed by the A55 North Wales Expressway to the east, connections to Hoole and opportunities for sustainable travel.

Comment

Representation ID: 9121

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9614
Whilst it is expected that, through a review of the Green Belt and limited release, appropriate land can be identified within the emerging Local Plan to meet the revised housing requirement, it is expected that additional sites will be required as some identified sites may not come forward in the plan period. A site’s location within the Green Belt should not preclude development, in particular where sites meet Grey Belt definitions and or can demonstrate connections to sustainable travel. Within the Chester context, the Chester Millenium Greenway is a key sustainable transport corridor that should be considered. As such, we would expect policy DM19 to be retained within the emerging Local Plan, with specific reference to Grey Belt added, in accordance with the revised NPPF.

Comment

Representation ID: 9123

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9616
The detail of each option is discussed in more detail below, under option specific questions, however at present, we support none of the presented options in their current form. (See attachment for all responses) Miller Developments believe that subject to the detailed amends, Option B is the best option, however, the sustainable principle of option C is supported and would be the next preferred option.

Comment

Representation ID: 9125

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9618
The spatial strategy must accommodate the minimum housing requirement as established by the standard method and enable immediate growth to address the shortfall in homes within the council area. In accordance with the Spatial Strategy Principles, the strategy should direct development to the most sustainable areas, both within and on the edge of settlements. From a review of all options, an adaptation of Options B & C, with a greater focus on overall sustainability to include the presence/provision of local services and through matching housing growth with economic growth would be the most appropriate approach. By doing so, this alternative approach would: • Prioritise brownfield and urban regeneration sites where available. • Direct growth to main settlements (Chester, Ellesmere Port, Northwich, Winsford) but avoid an over reliance on a few very large urban extensions. Chester should be considered for a greater amount to align with economic ambitions. • Allow smaller, proportionate growth in Local Service Centres and rural settlements to sustain schools, shops, and services. The benefits of an alternative proposition would be as follows: • Deliverable: it would avoid an over-reliance on a few large, infrastructure-heavy urban extensions that could delay. • Sustainable: it would support travel by train and bus, reduces car dependency, and strengthen smaller communities whereby development supports improved infrastructure. • Balanced: by doing so it would allow growth to be distributed fairly across the key places, towns, villages, and the rural area. • Defensible: it still allows for targeted Green Belt release where contributions to the Green Belt purposes to not strongly contribute. Overall, the key to this approach would be to spread growth across multiple settlements which reduces risk and ensures flexibility if some sites don’t come forward as planned. This approach would enable settlements targeted for greater economic growth to sustainably meet increased housing requirements.

Comment

Representation ID: 9128

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9621
Option A is unsuitable for a number of reasons. Firstly, the option is reliant on Major Urban Extensions for over 55% of its housing requirement. Major Urban Extensions require considerable infrastructure and typically take upwards of 15 years to deliver. The delivery of homes would therefore likely not occur, at least entirely, within the plan period. This would put the Council at risk of a significant shortfall of delivery. This is particularly relevant to the proposed 11,000+ homes to the south/west of Winsford. The existing Local Plan, alongside the Winsford Neighbourhood Plan, allocated land to the south/east of Winsford for 1,000 new dwellings, to be known as the Station Quarter. Of this allocation, just 215 homes have been approved, with the final homes still to be complete. As such, it is unlikely that Winsford would deliver the proposed additional MUE, as it is significantly behind in the delivery of Station Quarter. Furthermore, Major Urban Extensions within Northwich and Winsford would not appropriately address the housing need for Chester, nor does it support Chester as a sub-regional city. Option A allocates just 1,500-3,000 dwellings to Chester, despite naming Chester as a focus for office development and areas for development within existing employment areas and identifying Chester at the top of the Settlement Hierarchy. The underdevelopment of housing within Chester would undermine the economic growth ambitions and could also encourage unsustainable patterns of travel. Significant housing development should be directed to Chester to support the economic profile of the city. Option A is therefore inappropriate due to the poor distribution across the district and the over reliance on long-term strategic extensions.

Comment

Representation ID: 9129

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9622
Option A should be discarded as an option for the Local Plan. The MUE could be safeguarded for the next plan period, or allocated in addition to the housing figures required.