Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10156

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10653
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation document sets out the following list of additional evidence that is needed to support the new Plan: ▪ Retail and Town Centres Study (in preparation) ▪ Strategic Flood Risk Assessment (in preparation) ▪ Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) ▪ Housing Needs Assessment (to be prepared) ▪ Green Belt Study (to be prepared) ▪ Infrastructure Delivery Plan (to be prepared) ▪ Strategic Viability Assessment (to be prepared) ▪ Transport Assessment (to be prepared) ▪ Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the new Local Plan. Savills is supportive of the production of a Housing Needs Assessment, Land Availability Assessment and Green Belt Study which will inform the policies that relate to housing delivery in the new Local Plan. It is not considered that there is additional evidence that is required that is not already in preparation or due to be prepared that would be necessary to support the new Local Plan.

Comment

Representation ID: 10157

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10654
National policy requires that new Local Plans should set policies for 15 years following adoption, as a minimum. It is considered that the New Local Plan period for CW&C should cover a minimum of 20 years, due to the scale of strategic development that is required to meet the current and future needs of the borough and to reflect the ambitious housing delivery targets set by Government. A plan period of 20 years would ensure that the Local Plan is able to set the strategic policies to meet the current and future needs of the borough. As such it is proposed that the Local Plan period should be 2025 – 2045.

Comment

Representation ID: 10158

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10655
CW&C is a large and diverse borough with distinct towns and settlements that each have specific development needs. As such, the Council’s approach is supported which will establish concise visions for the key settlements, in addition to an overarching vision for the whole District. Local visions for each of the larger settlements (Chester, Ellesmere Port, Northwich, Winsford, Frodsham, Neston and Parkgate) will help to ensure that the specific development objectives of each settlement can be met through the Local Plan policies, which will in turn inform development proposals.

Comment

Representation ID: 10159

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10656
The Issues and Options draft sets out that the Council’s policy approach is to deliver a minimum of 1,914 new homes each year over the plan period, which would equate to 28,710 new homes. Savills notes that the most recent local housing need figure for CW&C is actually 1,928 dpa, which brings the overall 15 year total to 28,920 homes. While is owing to the incorporation of the latest affordability ratios. In response to question SS1, the new Local Plan should support the delivery of 1,928 homes per year as a minimum. The requirement for the new Local Plan to meet the standard method figure is clearly established in the NPPF and is the necessary approach that must be taken to ensure that the plan is consistent with national policy. Emphasis is placed on the fact that the national policy requirement is for Local Plans to adopt the standard method figure as a minimum. Savills recommends that the Council should take an ambitious approach and aim to exceed the minimum housing delivery indicated by the standard method, in order to support sustainable growth. National policy provides that in some cases, authorities will be able to justify a lower housing requirement than the standard method on the basis of local constraints on land and delivery (for example designations such as National Parks etc). Such circumstances do not exist in CW&C that would justify a reduced housing requirement. For example, there are no statutory National Parks in the borough.

Comment

Representation ID: 10160

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10657
The NPPF is clear that authorities are required to set strategic policies to meet their housing need in full across the plan period. To support the Government’s objective to significantly boost the supply of homes, it is important that ‘a sufficient amount and variety of land can come forward where it is needed’. Paragraph 70(b) of the NPPF states that to ensure land is allocated for housing in a way that boosts the supply of homes, plans should allocate ‘a range of sites by size, type and location to meet the housing requirements of different groups in the community’. A stepped housing requirement with reduced delivery in the early parts of the Plan period would, in effect, allow the Council to defer its full housing delivery to later phases of the Plan period. In areas where there are existing acute housing shortages, such as Neston, this would prolong existing issues surrounding affordability and access to housing. A stepped requirement would also ignore the opportunities for development sites that are immediately deliverable at the initial phases of the Plan period. Reduced targets in the early stages of the Plan period would risk slowing momentum, which conflicts with national housing objectives of boosting housing growth. As such, it is considered that the housing requirement should be clear and consistent throughout the Plan period, which would encourage market confidence and have a positive impact on overall housing delivery. Finally, the adoption of a stepped requirement would mean that the New Local Plan would have a more limited contribution to the Government’s stated aim of delivering 1.5 million homes during the current Parliament. For these reasons, the New Local Plan should not utilise a stepped requirement.

Comment

Representation ID: 10163

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10660
The Issues and Options consultation document sets out that the spatial strategy will follow the principle of directing new development and allocating land towards previously developed (‘brownfield’) sites within settlements first. It is acknowledged that previously developed sites within settlements are often sustainable locations to support new development, therefore consideration should be given to the allocation of reasonable previously developed sites. However, it should be noted that not all brownfield land can be considered deliverable or reasonable alternatives to undeveloped sites. A detailed consideration of the deliverability and availability of each brownfield opportunity will be required to inform the urban capacity of the Distrct. The spatial strategy principles state that where there are not enough opportunities for redevelopment within urban areas and towns, the approach will be to direct development to the edge of existing settlements in locations with the best access to public transport, services and infrastructure, as the next best sustainable option. The document also states that depending on the settlement, this may require the release of land that is currently designated as Green Belt. The principles of the spatial strategy as set out in the consultation document are broadly supported. It is a fundamental purpose of the Local Plan to ensure that the development needs of the District are met and that development is directed to the most appropriate and sustainable locations. While a brownfield-first approach is supported and is consistent with national policy, the scale of development that is required in CW&C (i.e. at least 1,928 new homes per year), and the relative lack of appropriate previously developed sites, means it will be essential for development to be directed to other sites in sustainable locations on the edge of existing settlements. This will necessitate the release of land from the Green Belt. It follows that the Council will need to provide evidence to demonstrate that exceptional circumstances exist to amend Green Belt boundaries. The NPPF states that such exceptional circumstances can include where an authority cannot meet its identified need for homes through reasonable non-Green Belt alternatives.

Comment

Representation ID: 10166

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10663
The Issues and Options document proposes that the New Local Plan will set out a settlement hierarchy based on the status and role of each settlement. The proposed settlement hierarchy is as follows: ▪ City – Chester ▪ Main Towns – Ellesmere Port, Northwich, Winsford ▪ Market Towns – Neston and Parkgate, Frodsham ▪ Other Settlements Savills agrees with the suggested settlement hierarchy as set out above. Chester is the only City within the borough and therefore performs a principle function and should be placed at the top of the settlement hierarchy. Neston and Parkgate is included in the third tier of the proposed settlement hierarchy, categorised as a ‘market town’ along with Frodsham. This categorisation demonstrates the realistic opportunity for Neston to make a significant contribution to overall housing delivery in CW&C. Neston’s inclusion in the settlement hierarchy above other smaller settlements highlights that it is a sustainable settlement that can accommodate proportional housing growth. As such, its inclusion as a market town in the settlement hierarchy is supported. The consultation document sets out that the New Local Plan will include individual place-based policies for each settlement which will set out the vision, core features, key issues and clear strategy for what development will take place in each settlement. The placed-based policy is supported in principle as this will add clarity in terms of the expectations of the Council for each of the larger settlement areas.

Comment

Representation ID: 10167

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10664
The Local Plan (Part One) was adopted in January 2015, which is more than 10 years ago. Since that time, national policy in relation to Green Belt has changed  substantially. The most recent version of the NPPF requires local authorities to make plans to meet their local housing need (standard method figure) in full. This requirement stems from the Government’s commitment to significantly bolster the delivery of homes and speed up planning in order to deliver 1.5 million new homes over the next Parliament. In order to deliver sufficient homes in CW&C to meet its housing requirement and ensure a sustainable pattern of development, some parts of the Green Belt will need to be released for development. This is because the Council will not be able to deliver its housing requirement solely on previously developed sites or other sustainable sites that are available and deliverable, without releasing some Green Belt sites to alleviate the acute need for housing. Particularly if it is focussing on the most sustainable settlements towards the top of the settlement hierarchy. Currently, approximately 42% of the borough is designated as Green Belt, which is substantially higher than the national average of 12.6%. This also tends to be focussed around the most sustainable settlements such as Chester, Ellesmere Port, and Northwich. While, in accordance with the proposed spatial strategy principles, development should firstly be directed to previously developed land and existing settlements, the release of Green Belt land will be necessary to accommodate sufficient growth in the District whilst ensuring a sustainable pattern of development.

Comment

Representation ID: 10168

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10665
The New Local Plan should adopt a flexible approach that is consistent with national policy where it relates to Green Belt. The Council is required by the NPPF to review its Green Belt boundaries where it is unable to meet its local housing need in full using other appropriate sites. As such, the New Local Plan should incorporate sustainable development opportunities to deliver homes in sustainable locations that are within the Green Belt. The Site at Liverpool Road, Neston should be allocated for housing since it is in a sustainable location and can deliver homes in the early stages of the New Plan period.

Comment

Representation ID: 10169

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10666
The most appropriate spatial strategies for CW&C are Options B and C above. For the reasons outlined above, namely to ensure the Local Plan is ambitious and plans to deliver sufficient housing, Option A should be discounted, as retaining the current Green Belt extent would restrict realistic opportunities to deliver sustainable development in appropriate locations in the borough. In order to deliver at least 1,928 new homes per year, the Council will need to assess land that is currently within the Green Belt for its potential to deliver sustainable residential development.  While Savills recognises the prioritisation of previously developed land for housing development, there is not a sufficient supply of available previously developed land in urban areas that is capable of accommodating the housing requirement.

None of these