Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15958

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16539
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, the Local Plan period should be 2025 – 2045.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15959

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16540
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. For the purposes of the New Local Plan, Northwich should continue to include satellite settlements such as Davenham.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15960

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16541
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. It is noted 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 this 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.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15961

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16542
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 Northwich, this would prolong existing issues surrounding 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.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15962

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16543
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 reasonable previously developed sites within settlements can be sustainable locations to support new development, therefore development should be directed to these locations in the first instance. 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.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15963

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16544
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 principal function and should be placed at the top of the settlement hierarchy. The second tier of the proposed settlement hierarchy includes Ellesmere Port, Northwich and Winsford as ‘Main Towns’. The inclusion of Northwich specifically as a main town is endorsed, since it is an established settlement in the borough with clear opportunities to deliver growth and housing development. Northwich should continue to include satellite settlements, such as Davenham, for the purpose of planning policy. Northwich is a desirable location for development and is able to accommodate further growth through the New Local Plan. This should be reflected in its status in the settlement hierarchy. 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 settlement area.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15964

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16545
Land at London Road, Davenham could come forward under Options A, B or C, since it is not located in the Green Belt and is located in a sustainable location nearby to public transport options and the existing settlement of Davenham. Notwithstanding that the Site can be delivered under Option A, the most appropriate spatial strategy for the District is considered to be a combination of Options B and C. Option A alone as a spatial strategy could risk discounting sustainable sites that are within the Green Belt from contributing to housing delivery which could in turn lead to a shortfall of overall housing being delivered across the District. In order to ensure the Local Plan is ambitious and plans to deliver sufficient housing (i.e. a minimum of 1,982 homes per year), the Council will need to review Sites that are both within and outside of the Green Belt, which are in sustainable locations. 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.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15965

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16546
As mentioned above, while the Site could come forward under Option A, this is not in itself considered to be an appropriate spatial strategy for the New Local Plan. The reason being is that the Council is required to meet is local housing requirement in full (being 1,928 homes per annum) as a minimum and in order to fulfil its role in setting strategic policies to meet this requirement, the New Local Plan will be required to allocate sufficient land for housing development. Option A could restrict opportunities for sustainable residential development on the edge of existing settlements that are currently within the Green Belt. It is problematic as it would serve to restrict the growth of some of the most sustainable settlements and result in a pattern of development that is less sustainable. There is not a sufficient supply of reasonable previously developed land that is suitable and available for housing in CW&C and as such, Green Belt sites must be assessed for their contribution to housing delivery, in accordance with the NPPF.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15966

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16547
Option B follows the existing Local Plan strategy and settlement hierarchy which is set out in Policy STRAT 2 of the Local Plan (Part One). That policy locates most new development in or on the edge of ‘main urban areas’ and an appropriate proportion of new development on smaller settlements which have adequate services, facilities and transport connections. The Issues and Options consultation document makes clear that a key difference between the adopted Local Plan (Part One) and the New Local Plan is that the current supply of previously developed land that can accommodate new development is much more limited, meaning larger areas of Green Belt and/or sites designated as Countryside are likely to be needed. The explanatory text on Option B explains that, while a proportion of development can be accommodated within existing settlements, ‘much of the new development under this option would need to be located within the Green Belt and/or Countryside’. The approach set out under Option B is an appropriate spatial strategy that is entirely consistent with national policy and seeks to bring the adopted Local Plan policy up to date in respect of the spatial strategy. Option B would ensure that new development is directed to the most sustainable and logical locations in the District, which follows the established strategy in the adopted Local Plan (Part One).


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.

Comment

Representation ID: 15967

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16548
Option C seeks to direct residential development to settlements that are served by the rail network and main bus route corridors. This strategy maximises opportunities for sustainable travel choices and could support further improvements to existing public transport services through development. This Option would require land to be released from the Green Belt in locations that are well connected by existing transport corridors. Option C is a logical approach to the spatial strategy that aims to take advantage of existing settlements that are on the railway network or bus routes, as such the Option is considered to be appropriate for the New Local Plan. However, the extent of development should still be guided by the level of day-to-day services that are available in the settlements. As such a blending of Options B and C would seem like a logical approach, with the potential of settlements assessed individually when allocating development.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.