Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15736

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16295
NPL supports the overarching vision for Cheshire West and Chester to be “a desirable and attractive place to live, work, learn and visit with vibrant towns and villages, by meeting [its] development needs in sustainable locations.” However, central to achieving this vision will be the delivery of new homes and jobs within the Borough and, yet, no reference is made to the provision of new housing and employment opportunities within the four “overarching principles” that are currently stated in the VI 1 text. Therefore, an additional overarching principle should be added to state: “Providing new housing and employment opportunities – ensuring the provision of new housing and employment opportunities in sustainable and accessible locations within the Borough.” 4.3 VI 1 also explains that, “[CWaC] would expect the larger settlements to have an individual vision”. The “larger settlements” are stated to be: Chester; Ellesmere Port; Northwich; Winsford; Frodsham; and, Neston and Parkgate. However, as acknowledged in CWaC’s LPP1, “to the east the borough borders Cheshire East and has particularly strong links with the town of Middlewich that is surrounded on three sides by Cheshire West and Chester”7. The Borough’s strong connection to Middlewich is also recognised within the CWaC Issues and Options Document, within which it states that, “Middlewich falls within Cheshire East but the built-up area is tightly enclosed to the east, west and north by the borough boundary with Cheshire West and Chester”8. The Issues and Options Document further notes that Middlewich is identified as a Key Service Centre in the Cheshire East Local Plan. Therefore, although Middlewich sits outside of the administrative boundary of Cheshire West and Chester, it is clear that the Borough has strong links to this town and, thus, it is important that Middlewich is recognised within the spatial strategy of the emerging Local Plan (as is currently the case under LPP1 Policy STRAT 7) and that this is also reflected in the ‘vision’ for the Borough.

Comment

Representation ID: 15737

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16296
As detailed above, no reference is made to the provision of new housing and employment opportunities within the four “overarching principles” that are currently referred to in VI 1, despite new homes and jobs being central to achieving the stated vision. Therefore, an additional overarching principle should be added to state: “Providing new housing and employment opportunities – ensuring the provision of new housing and employment opportunities in sustainable and accessible locations within the Borough.” Question VI 3: Do you agree with the approach of establishing concise visions for the key places identified in the new Local Plan? Or do you have an alternative suggestion? In principle, NPL agrees with the approach of establishing concise visions for the key places identified in the new Local Plan. However, as emphasised above, despite being located outside of the Borough, Middlewich is a key place that should also be identified in the new Local Plan owing to its strong connection to the Borough.

Comment

Representation ID: 15738

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16297
As explained at Section 3 of these representations, the new standard method has resulted in a substantial increase in CWaC’s LHN figure from 532dpa to 1,914dpa (259.77% increase). Furthermore, the Council has a five-year housing land supply position of 1.89 years. Therefore, there is clearly a need to develop on suitable sites that are located outside of the current settlement boundaries, such as in the Open Countryside. Consequently, Option A ‘Take forward the current Local Plan objectives’ is not an appropriate approach, particularly as objective SO10 refers to “maintaining the general extent and character of the North Cheshire Green Belt and Cheshire countryside”. Comments pertaining to Option B are provided in answer to Question OB 5 below.

Comment

Representation ID: 15739

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16298
NPL does not agree with the option of taking forward the current Local Plan objectives into the new Local Plan (‘Option A’) for the reasons detailed in NPL’s response to Question OB 1 above.

Comment

Representation ID: 15740

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16299
As detailed above, the new standard method has resulted in a substantial increase in CWaC’s LHN figure from 532dpa to 1,914dpa (259.77% increase). This is a considerable increase when compared to the current Local Plan requirement of 1,100dpa. It is important that the future housing needs of CWaC are rooted in the new standard method to ensure that the new Local Plan is robust. Therefore, the previous Local Plan objectives, particularly objective SO10, cannot be taken forward into the new Local Plan and must instead be updated to reflect the Borough’s substantial housing needs. Question OB 5: Do you feel that the option of using the Sustainability Appraisal objectives in the new Local Plan, as set out in Option B 'Use the Sustainability Appraisal objectives' above, is an appropriate approach? Any approach towards the new Local Plan objectives must ensure that it is reflective of the Borough’s substantial housing needs (as detailed above). Furthermore, any future objectives must include the necessary flexibility to acknowledge that these are for development to comply with “where possible” to ensure that the viability and/or delivery of development would not be threatened.

Comment

Representation ID: 15741

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16300
Please see NPL’s response to Question OB 5 (above).

Comment

Representation ID: 15742

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16301
NPL supports the Council’s commitment to mitigating and adapting to climate change. Nevertheless, where the new Local Plan seeks to introduce additional policy requirements that could threaten the viability and/or delivery of development, there must be a robust and flexible mechanism whereby these additional requirements and/or other requirements (such as affordable housing or other developer contributions) can be relaxed if viability is threatened. Therefore, NPL supports the use of words such as “maximise” and “minimise” within SD 1, which acknowledge that there is flexibility in the delivery of the stated measures to mitigate and/or adapt to climate change and should be incorporated within any prospective planning policy relating to sustainable development.

Comment

Representation ID: 15743

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16302
It is acknowledged that SD 1 currently states that, “Strategic sites should be connected to a district heat network. Where this is not currently feasible, new homes should be built with the necessary infrastructure in place to enable such connections to be easily integrated in the future. Opportunities should be sought to connect commercial development producing sufficient levels of waste heat, with residential development or other developments with demand for heating, where they are located within close proximity.” NPL supports the Council’s acknowledgement that connecting to a district heat network may not be feasible. NPL would not support an indiscriminate policy requirement for new development to connect to a district heat network or any other Local Plan policies that would threaten the viability and/or delivery of development.

Comment

Representation ID: 15744

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16303
There is no reason for the Council not to plan for delivering a minimum of 1,914 new homes each year. It is important that the future housing needs of CWaC are rooted in the new standard method to ensure that the new Local Plan is robust. Further to the above, the Council’s Cabinet recently decided to adopt the Housing Strategy 2025 2035, within which it is acknowledged that “…there are challenging times ahead, there is a national housing crisis, housing is less affordable, and many people have support needs making it even more difficult to access and sustain accommodation.”9 Coupled with these challenges, the Housing Strategy acknowledges that the population of Cheshire West and Chester is forecast to increase by more than 10% by 2038. This further emphasises the clear need for new housing within the Borough.

Comment

Representation ID: 15745

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16304
The new Local Plan is being brought forward in the context of a substantial increase in CWaC’s LHN and a situation whereby the Council has an acute need for housing, with CWaC having 1.89 years’ supply of deliverable housing land. It is, therefore, important that sufficient land is allocated for housing delivery early in the Plan period.