Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15998

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16579
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. 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.


Email from Jonathan Ainley

Comment

Representation ID: 15999

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16580
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’. 3.18 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 Chester, 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.


Email from Jonathan Ainley

Comment

Representation ID: 16000

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16581
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 the most 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 District. 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.


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Comment

Representation ID: 16001

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16582
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 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. Chester was allocated the largest amount of housing in the current Local Plan. It therefore follows that it will see a greater proportion of housing attributed to it in the New Local Plan. To sustain Chester’s status as a principle City in the District, it should be attributed the highest proportion of housing of any settlement in the Borough which will contribute to continued sustainable growth. Notwithstanding its position at the top of the proposed settlement hierarchy, Chester is arguably the most constrained of the settlements on the hierarchy, partly owing to the surrounding Green Belt as well as the Welsh border to the west and area of flood risk to the north. Accordingly, any settlement extensions, will likely need to be directed to the south, south east and south west of Chester. This includes the Site, which would make a significant contribution to the housing requirement in Chester in a logical location 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.


Email from Jonathan Ainley

Comment

Representation ID: 16002

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16583
The most appropriate spatial strategies for CW&C are Options B and C above. To ensure the Local Plan is ambitious and plans to deliver sufficient housing, in accordance with national policy, Option A should be discounted, as retaining the current Green Belt 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 the prioritisation of previously developed land for housing development is acknowledged, the Council cannot identify a sufficient supply of available and suitable previously developed land in urban areas that is capable of accommodating the housing requirement. As such, land in the Green Belt must be considered in order to ensure CW&C addresses its local housing need within the Plan period.


Email from Jonathan Ainley

Comment

Representation ID: 16003

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16584
Option A is not 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. It is considered that Option A would 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.


Email from Jonathan Ainley

Comment

Representation ID: 16004

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16585
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).


Email from Jonathan Ainley

Comment

Representation ID: 16005

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16586
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 wellconnected 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. Strategic-scale Green Belt release around Chester should be considered under this Option. However, the extent of development should still be guided by the level of day to day services that are available in the settlements.


Email from Jonathan Ainley

Comment

Representation ID: 16006

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16587
At Paragraph 72, the NPPF makes clear that planning policies should identify ‘a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability’. To ensure the New Local Plan is consistent with the NPPF, it is critical that the Council takes into consideration the availability, suitability and economic viability of proposed housing allocation sites. In terms of availability, the Council should consider the ownership of proposed sites and whether sites can feasibly come forward within the Plan period. In the case of the Site at Manor Farm, Christleton, the land is clearly available, since it is under the control of Northern Trust. As such, there are no land assembly or ownership constraints that could pose a delay to development of the land. It is in Northern Trust’s interest to secure planning permission and implement the development as soon as possible, should the Site benefit from a residential allocation in the New Local Plan. In terms of suitability, it is important for the Council to consider the sustainability of proposed allocation sites, in accordance with its policy approach at Policy TA 1. This includes assessing existing provision of public transport services and proximity to settlements and local centres.  Locations that are detached from existing settlements or poorly connected to public transport are not sustainable, and therefore are unlikely to be suitable for residential development within the new Plan period. The Site at Manor Farm, Christleton is in a sustainable location in close proximity to Chester and the desirable village of Christleton. The Site is a sustainable location that is suitable for residential development and would make a significant contribution to meeting the identified need for a variety of housing in CW&C. When assessing sites for potential allocations, it will be important for the Council to ensure that allocated sites can realistically be delivered within the Plan period. As such, factors affecting deliverability of potential housing sites will be a key consideration, so technical constraints, such as ecology, flood risk and topography should all be taken into account when the Council assesses sites for potential allocations.


Email from Jonathan Ainley

Comment

Representation ID: 16007

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16588
Map 5.4 of the Issues and Options document identified four potential growth areas around Chester. All four of the growth areas are within the current Green Belt. CH01 is beyond the north of Chester and is identified as an opportunity for mixed use development. CH02 is a strip of land along the eastern side of Chester’s settlement boundary and is identified for housing development. CH03 and CH04 are located beyond the south east and north east of the settlement boundary respectively and are both identified for housing growth.


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