Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14660

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15210
Miller Homes agree that the listed evidence base is appropriate. However, it is will be prepare and publish these documents (particularly the Housing Need Assessment and Strategic Viability Assessment) as early as possible in the process so they can review the conclusions and understand what baring these have on wider policies.

Comment

Representation ID: 14662

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15212
The Council should be planning for at least the 1,914 dpa as required under the Standard Method figures published in 2024. Any figure above this base level will ensure the LPA can address the shortfall in affordable housing provision and the need to sustain future economic growth in the borough. Contextually, under the previous NPPF method, the annual housing target for Cheshire West and Chester was 532 dwellings. Under the standard method established within the latest NPPF and the updated figures published March 2024/2025 in line with affordability ratios, the annual housing target for the Council is 1,912 dwellings per year. 3.4 As the Council’s strategic policies are more than five years old, paragraph 78 is also highly relevant. The Council needs to demonstrate a five-year supply against the standard method (taken from Planning Practice Guidance). Using the Council’s latest land supply figure and published affordability, the 5-year calculation is as follows: •Annual Requirement = 1,912 • 5-year Requirement = 9,560 • Plus 5% buffer = 10,038 • Deliverable Supply = 4,209 • Years Supply = 2.09 years The shortfall in supply is chronic and needs to be addressed through emerging Local Plan. In terms of the housing figure proposed in the policy, it is important to highlight that ‘exceptional circumstances’ must be demonstrated to justify any deviation from the standard method. As clarified in the PPG, this requirement applies specifically to proposals for a lower housing need figure than that generated by the standard method. A higher figure is not as rigorously tested. Our emphasis is based on the statement written in the PPG: “The standard method uses a formula to identify the minimum number of homes expected to be planned for. The standard method…identifies a minimum annual housing need figure. It does not produce a housing requirement figure.” In contrast 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 deliver below the identified dwellings per year as set out.

Comment

Representation ID: 14663

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15213
The PPG states: “A stepped housing requirement may be appropriate where there is to be a significant change in the level of housing requirement between previous policies and / or where strategic sites will have a phased delivery or are likely to be delivered later in the plan period. Strategic policy-makers will need to identify the stepped requirement in strategic housing policy, and to set out evidence to support this approach, and not to unnecessarily delay meeting identified development needs. Stepped requirements will need to ensure that planning housing requirements are met fully within the plan period. In reviewing and revising policies, strategic policy-makers should ensure there is not continued delay in meeting identified development needs.” CWAC reported in their latest Housing Monitoring Report (2024-2025) that in the last three years completions were as follows:(see Table in attachment - paragraph 3.11) It is clear that CWAC 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 out-of-line for the council to achieve. As explored in the following questions, one spatial option involves delivering homes via. larger strategic sites, but this may result in slower or phased delivery and could justify a stepped housing requirement. Therefore, we consider this approach unsuitable as a preferred option, as it would not support a distribution pattern that effectively meets identified needs across the borough. As such, we would not suggest that the Council consider a stepped housing requirement and that it should be aspirational in its approach to setting their housing requirement at the identified level of 1,914 or higher to ensure and support early delivery of housing over the plan period.

Comment

Representation ID: 14664

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15214
Given the limited availability of brownfield land, the targeted release of sites around sustainable settlements such as Kingsley is essential to meeting housing needs. Prioritising previously developed land aligns with the principles of sustainable development, as does promoting a well-distributed pattern of growth that meets needs across Cheshire West. Both elements of the proposed approach, focusing on brownfield sites and, where necessary, expanding at the edge of existing settlements, should be pursued together to ensure a comprehensive and balanced spatial strategy.

Comment

Representation ID: 14665

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15215
The proposed settlement hierarchy sets out the key settlements as Chester (City), Ellesmere Port (Main Town), Northwich (Main Town), Winsford (Main Town), Neston and Parkgate (Market Town) and Frodsham (Market Town). Each of these settlements will have individual place-based policies within the emerging Local Plan. Additional settlements are also identified as able to meet the day-to-day needs of residents and those in surrounding areas. Beyond this, the hierarchy accepts that smaller settlements (e.g., Davenham) could accommodate infill development and small previously developed sites. We agree with the proposed settlement hierarchy however, in principle, no settlement should be excluded from development, provided that their character is protected by high-quality planning and design (see Q SS 8), they are situated on routes that facilitate sustainable travel modes e.g., public transport, and local facilities can be provided. Such development could actually benefit the sustainability of some settlements and bring forward additional services and facilities depending on what is required from additional housing or economic development. As such, we agree that it is necessary for smaller settlements to also accommodate some growth.

Comment

Representation ID: 14666

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15216
The population growth of CWAC cannot solely be addressed by larger settlements, as smaller settlements have their own demographic needs based on individual housing sub-markets and historic housing delivery. As highlighted before, we recommend the emerging Local Plan aims for more than the minimum housing-need figure by using it as a starting point. This can help to ensure that the housing needs in each area are not only met but are also exceeded. Therefore, in terms of distribution, we recommend housing is distributed in a manner which ensures the minimum housing need specific to each sub area of the borough and evenly distributed.

Comment

Representation ID: 14667

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15217
Green Belt release is critical in CWAC to provide the level of housing that has been identified as a minimum through the Standard Method calculation and allow for housing to be distributed effectively throughout the borough and not simply towards larger settlements that are not located within the Green Belt. The NPPF sets out that in exceptional circumstance, such as in instances where an authority cannot meet its identified need for homes, commercial or other development through other means, they can review their Green Belt boundaries (in accordance with the policies in this Framework) and propose alterations to meet those needs in full. Given the scale of housing uplift and the large swathe of the borough currently located within the Green Belt, CWAC will likely need to identify additional land by undertaking a full green belt review and additional housing needs evidence to support this. Whilst the site promoted through these representations is not located within the Green Belt and Miller believe that this their site should be a priority location due to its non-Green Belt status, Miller still support the release of Green Belt Land as it will be required to ensure a well distributed housing delivery.

Comment

Representation ID: 14668

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15218
As set out in the following response, we believe an alternative spatial option should be explored.(see question SS 12 and attachment)

None of these

Comment

Representation ID: 14669

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15219
We do not consider that any single option, as presented in the document, as the most appropriate spatial option and an alternative spatial option is detailed below. From a review of all options, an alternative strategy could combine the strengths of Option B (distribution development by settlement hierarchy) and Option C (focussing development at sustainable transport corridors), while avoiding too much of a focus on a large urban extension only approach. By doing so, an alternative approach would: o Prioritise brownfield and urban regeneration sites where available. o Direct growth to main towns (Chester, Ellesmere Port, Northwich, Winsford) but avoid addressing needs through a few very large urban extensions. o Support medium-scale growth at rail-served villages and key service centres (e.g. Lostock Gralam, Cuddington & Sandiway, Helsby, Frodsham, Tarporley) through targeted Green Belt releases. o Allow smaller, proportionate growth in Local Service Centres and more rural settlements (e.g. Davenham) 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 result in a delay of supply. • Sustainable: it would support travel by train and bus, reducing car dependency, and strengthen smaller communities, as development would result in a subsequent improvement to infrastructure. • Balanced: it would allow growth to be distributed fairly across towns, villages, and the rural area. • Defensible: it would still allow for targeted Green Belt release particularly where a strong contribution to Green Belt purposes is not identified. Overall, the key to this approach would be to spread growth across multiple settlements to reduce risk and ensure flexibility if some sites don’t come forward as planned.

Comment

Representation ID: 14671

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

I&O_15221
New housing or employment development should be allowed in other settlements, for example, smaller settlements are appropriate locations for limited infill or extension developments for housing and in some circumstances for commercial development. This is particularly the case in rural areas, as it would support the rural economy and small-scale businesses. This will contribute to meeting the overall housing needs of the plan period and help to support the vitality of rural towns and villages.