Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9067

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9560
Northstone agree that the listed evidence base is appropriate, however the Green Belt Study should include a detailed parcel-by-parcel assessment of land around Lostock Gralam, explicitly considering: • The relative contribution of each parcel to Green Belt purposes (as set out in NPPF para 143). • Accessibility to sustainable transport, particularly rail. • Capacity to deliver housing without causing coalescence of settlements. • Additional infrastructure capacity assessments should examine scope for targeted investment in road, rail, and utilities at Lostock Gralam to support higher growth levels.

Comment

Representation ID: 9078

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9571
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 CWAC 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 annually. Under the standard method established within the new NPPF and updated figures published in March in line with affordability ratios, the annual housing target for the Council is 1,912 dwellings per year. 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 therefore chronic and needs to be addressed through emerging Local Plan. In terms of the figure suggested through the policy, it is important to note how ‘exceptional circumstances’ need to be shown to justify an alternative approach to the standard method. Crucially as the PPG states (summarised below), it is only for a housing need figure which is lower than standard method for which ‘exceptional’ justification needs to be shown. A higher figure is not as rigorously tested. The PPG states “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.” (NJL emphasis). The PPG emphasises how the assessment of need must be carried out separately and prior to the determination of a housing requirement. Furthermore, the PPG refers to exceptional circumstances being required to justify housing need which is below the Standard Method minimum. 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 drop below the identified dwellings per year as set out.

Comment

Representation ID: 9079

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9572
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 paragraph 3.12 of attached rep for table of completions an requirement) It is clear that, as a Council, they 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 if suitable sites are proposed through the emerging Local Plan. 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 a distribution that suits identified needs throughout 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: 9081

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9574
Direct new development and allocating land toward previously developed sites in settlements first. Where not sufficient, develop on the edge of existing settlements in locations with the best access to public transport and existing services and infrastructure. This may require release of Green Belt land. Given limited brownfield capacity, targeted Green Belt release around sustainable transport hubs such as Lostock Gralam is essential to meeting this target. Whilst reviewing previously developed land first aligns with the principle of sustainable development as does promoting development that is well distributed and ensures needs around Cheshire West are fully met. A such, both aims as above should be developed side by side to ensure a comprehensive approach to the Local Plan spatial strategy.

Comment

Representation ID: 9082

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9575
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, they are situated on routes on which public transport can be made sustainable, 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 accommodate some growth

Comment

Representation ID: 9083

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9576
The population growth of CWAC cannot be addressed by larger settlements only with smaller settlements having their own demographic needs based on their specific housing market sub-area and past housing delivery. As highlighted before, we recommend the emerging Local Plan aims for more than the minimum housing need figure but should use this as the starting point with the minimum need in each area must be met and 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 smaller settlements with sustainable offer should be identified. It is notable that some settlements may have transport benefits, but not services (e.g. Acton Bridge and Hooton), so are less logical to look at them for more housing. Whilst other settlements (e.g. Lostock Gralam) do have more services and employment opportunities should be considered positively for more housing.

Comment

Representation ID: 9084

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9577
Green Belt release is critical in CWAC to provide the level of housing that has been identified at 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, authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full. Given the scale of housing uplift and the large swathe of the borough currently located within the Green Belt, it is likely that additional land will be sought and CWAC will need to undertake their Green Belt review and additional housing needs evidence to support this. In the context of Exceptional Circumstances, we consider the land north of Manchester Road, Lostock Gralam should be a priority location for growth as identified through the mapped options. As detailed through our response to SS 6, smaller settlements which have appropriate transport connections and services should be able to accommodate the delivery of homes.

Comment

Representation ID: 9085

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9578
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 Options B (distribution across the settlement hierarchy) and Option C (focus on sustainable transport corridors), while avoiding too much of a focus on a large urban extension only approach. By doing so it an alternative approach would: • Prioritise brownfield and urban regeneration sites where available. • Direct growth to main towns (Chester, Ellesmere Port, Northwich, Winsford) but avoid an over reliance on a few very large urban extensions. • 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. • 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 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.

Comment

Representation ID: 9086

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9579
Yes, there will be a need to allow for new housing and employment land in other settlements. Smaller settlements are appropriate locations for limited infill or extension developments for housing and in some circumstances for commercial development; particularly in rural areas where this would support rural and small-scale businesses. This will contribute to meeting the overall housing needs of the plan period, as well as support the vitality of rural villages and towns.

Comment

Representation ID: 9087

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9580
Northstone do not agree with this option, as it whilst this in theory could meet the longer-term housing needs providing it is viable, it does not address short term acute housing needs in the borough. The fundamental aim of the NPPF requires sustainable development which in turn requires sustainable patterns of development that link to jobs and economic growth around peoples needs. Constraining release to only near the key centres (Chester and Northwich) is not feasible. This option heavy relies on Large urban extensions as part of its strategy for over 55% of its housing requirement. These often require substantial upfront infrastructure investment (e.g. new highways, schools, GP capacity, utilities). The consultation document acknowledges significant pressures on transport networks, school places, and healthcare across the borough. These costs can: • Delay delivery of housing, undermining the Council’s five-year supply. • Reduce viability for affordable housing and community facilities. • Concentrate pressure on single locations rather than distributing growth sustainably. 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 completed. As such, it is unlikely that Winsford would deliver the proposed additional large urban extension, as it is significantly behind in the delivery of Station Quarter and is unlikely to create a meaningful impact on housing numbers earlier in the plan period. Focusing growth on a small number of large extensions risks creating an imbalanced settlement hierarchy, with an over-concentration of growth in a few towns, continued under-investment in smaller but sustainable settlements (such as smaller settlements like Lostock Gralam) and a lack of flexibility if one or more large extensions stall in delivery. Further, it only addresses housing needs within the large settlements whereas the smaller settlements which still have specific housing requirements, do not see additional development. The strategy should support equal distribution to ensure suitable delivery with supporting facilities as needed. Option A is therefore inappropriate due to the poor distribution across the district and the over reliance on long-term strategic extensions.