Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15876

Received: 29/08/2025

Respondent: Richborough

I&O_16435
We fully support suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough as mandated by the Government's Standard Method. In accordance with Government policy, Council's must seek to, as a minimum, meet their local housingneeds, informed using the Standard Method (including meeting the needs of neighbouring Authorities if appropriate); unless there are strong reasons why an Authority cannot do this. Paragraph 11 in the NPPF states that: "For plan-making, this means that: b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. We do not consider that there is any strong reason for restricting development in CWaC, nor would doing so outweigh the benefits of meeting the Borough's identified housing needs. As such, CWaC should plan for 1,914 new homes per annum, as an absolute minimum (and subject to considering neighbouring Authorities needs as part of its Duty to Co-operate).

Comment

Representation ID: 15881

Received: 29/08/2025

Respondent: Richborough

I&O_16440
We strongly object to the Council's consideration of a stepped housing requirement that plans for a lower level of housing delivery earlier in the Plan Period. CWaC Council will already be significantly underdelivering on the Standard Method housing requirement in the interim period before the Local Plan is adopted and therefore should be proactive early in the Plan Period to rectify this and ensure that homes are delivered within the Borough to address existing housing needs and meet mandatory targets. Moreover, a 'backloading' of housing delivery presents a serious risk of the Local Plan not delivering its housing requirement throughout the Plan Period, where significant pressure will be placed on the later years of the period with no guarantee of delivery. The Council should identify clearly deliverable sites that will support the required delivery of housing early in the Plan Period, ensuring that CWaC can meet its housing needs and does not fall behind in its delivery.

Comment

Representation ID: 15882

Received: 29/08/2025

Respondent: Richborough

I&O_16441
The suggested Policy Approach SS 3 outlines that the spatial strategy will follow the principle of directing new development towards previously developed sites within settlements first, as they are the most sustainable locations with the best access to services and facilities. SS 3 then promotes an approach that considers urban extensions on the edge of existing settlements, in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option. It states that depending on the settlement, this may require the release of Green Belt land. Richborough fully supports the suggested Policy Approach to SS 3 and in particular the sequential approach to considering deliverable and sustainable urban extensions once CWaC's urban capacity has been exhausted. This policy approach should also give preference and priority to delivering a substantial level of the required growth in CWaC's top tier settlements, in particular around Chester which is the main urban area within the Borough, which have the capacity, sites and existing infrastructure to deliver the level and type of sustainable growth required. The site at Lache Lane would support this policy approach, located on the edge of the City of Chester, and offering a deliverable and sustainable option for an urban extension to this settlement with existing access to services and facilities.

Comment

Representation ID: 15883

Received: 29/08/2025

Respondent: Richborough

I&O_16442
We fully support the designation of Chester as a City at Tier 1 of the settlement hierarchy along with the policy approach to having an individual policy for Chester to enable a strategy for sustainable growth in the settlement to be considered. As the only City in the Borough, Chester should accommodate a level of development and growth that reflects is scale, location and sustainability, which should be reflected in the spatial strategy and land allocations in the emerging Local Plan. We fully support an appropriate level of growth being focussed on Chester as CWaC's top tier settlement.

Comment

Representation ID: 15885

Received: 29/08/2025

Respondent: Richborough

I&O_16444
Policy Approach to CH 1 seeks to combine the existing Local Plan Part 1 STRAT 3 Policy with Part 2 Policy CH 1, as the overarching and locally distinct policy for Chester. This will update the allocations, including any that have been competed or require a new approach, and any new locations for housing and employment development in Chester. Chester is identified inthe Issues and Options Plan as the Borough's largest settlement in terms of population and dwellings; and being the main centre for offices, employment, culture,retail, leisure, higher education,tourism and transport. Within the previous Local Plan, Chester is the only settlement within the Borough where Green Belt release was considered to be justified due to the sub-regional role of the City, high levels of in-commuting, affordable housing need, and delivering a mix of housing. We support the suggested Policy Approach CH 1 in having an overarching and locally distinct policy which sets out the allocations for Chester. This will enable more strategic growth to be identified that can meet housing and employment needs which reflect Chester's role in the settlement hierarchy.  We strongly consider that there is a clear need to review the Green Belt boundary in Chester as part of the emerging Local Plan, as was the case in the previous Local Plan, to ensure that CWaC's housing needs can be met. This is particularly important given the significant increase in CWaC's housing requirement from 1,100 dpa in the last Local Plan to 1,914 dpa in this Local Plan. It is considered that land at Lache Lane should be identified as a residential growth location, being a sustainable urban extension to meet the housing needs of the Borough in the early part of the Plan Period, whilst providing a range of other benefits which align with the proposed policy approach, including improvements to open space and community infrastructure. The deliverability of the site is set out in later in this letter and we strongly consider that the site should be considered as a suitable and deliverable site allocation whichever growth option is pursued.

Comment

Representation ID: 15887

Received: 29/08/2025

Respondent: Richborough

I&O_16446
The suggested Policy Approach to Green Belt and the countryside identifies the potential to add in other uses appropriate to the countryside. The explanatory text also identifies that there is an option to split the policy into separate policies regarding the countryside and Green Belt. We are supportive of the approach to Green Belt and Countryside, or a separation of the policy, if it provides clarity on the policy differences between Green Belt and open countryside policy.

Comment

Representation ID: 15889

Received: 29/08/2025

Respondent: Richborough

I&O_16448
We support the suggested Policy Approach towards delivering affordable housing, as set out in 'HO 2', which sets out the requirement to provide affordable housing on all new developments that include the provision of new homes, unless there are exceptional circumstances. The delivery of available and achievable housing developments, such as at Lache Lane, provide the most effective way to deliver affordable housing along with the delivery of a mix of housing types to meet local needs. The provision of greater quantities of market housing will also help to alleviate the constraints on supply, and in turn help to reduce the upward pressure on house prices.

Comment

Representation ID: 15890

Received: 29/08/2025

Respondent: Richborough

I&O_16449
The site at Lac he Lane is identified as part of a wider potential growth option, as reference 'CH03', in Options B and C. We consider that Policy Approach SS 5 should identify Green Belt release around Chester (as the Borough's main settlement) in all potential growth options, where the exceptional circumstances exist to amend the Green Belt boundary. Therefore to meet the Borough's significant housing need, potential growth option 'CH03' should be identified as one of the key strategic sites required in Chester in any growth scenario that is pursued. Our comments on each current growth option is provided below. Option A Option A seeks to retain the Green Belt, by focussing development on settlements without Green Belt constraints. Therefore, Option A proposes no potential growth areas for housing or employment for Chester as the settlement is constrained by Green Belt. This is considered to be in conflict with other policies across the Plan, which identify Chester as the only City within the Borough, at the top of the settlement hierarchy. As such, it is considered that Chester should accommodate a proportionate level of growth under any spatial strategy to reflect its role as the Borough's main settlement in terms of population and dwellings, and as the main centre for employment, culture, retail, leisure, higher education, tourism and its role as a sub-regional transport hub - which is supported by further growth across the Borough's Main Towns to deliver a balanced spatial strategy for CWaC. Option B Option B seeks to follow the Local Plan level and distribution of development with reference to the settlement hierarchy, by locating most new development on the edge of main urban areas or around smaller settlements which have adequate services, facilities and access to public transport. The site is identified as a potential location for housing growth under this option under 'CH03'. Option B recognises that "a key difference between the Local Plan (Part One) and the new Local Plan is that there is a much more limited supply of previously developed land to accommodate new development, and unlike the last plan, larger areas of Green Belt and/or countryside are likely to be needed". We welcome this recognition and considers that any growth strategy that follows Option B should reflect this situation and attribute a level of growth to Chester that reflects its status as the main urban area and one of the key areas for growth in the adopted Local Plan. Option c Option C seeks to focus development around settlements on the railway network or main bus route corridors. This identifies housing growth in Chester for around 3,000 - 5,000 homes. The site is identified as a potential location for housing growth within this option under 'CH03'. We support Option C and considers that Chester a sustainable settlement within the Borough for growth, as reflected by the designation at the top of the settlement hierarchy. The City is the main centre for employment, leisure and transport connections and therefore should accommodate an appropriate level of growth to reflect this.

Comment

Representation ID: 15897

Received: 29/08/2025

Respondent: Richborough

I&O_16456
We consider that land at Lache Lane as part of growth location CH03 represents an appropriate location for growth in Chester. The site forms a logical and sustainable extension to the settlement of Chester, it does not strongly meet any of the purposes of the Green Belt and is wholly deliverable. Summary n summary, Rich borough consider that land at Lache Lane and location CH03 represents a very suitable and deliverable location for a sensitive urban extension in Chester, and should be identified as a key location for growth under Option B and C. For Chester, Option A is not a realistic proposition as it is inconceivable that there could be no land released from the Green Belt around this top tier settlement. Delivery The NPPF seeks to ensure that deliverable sites are provided in appropriate locations to meet housing needs and support economic growth. To be considered deliverable, sites should be available, suitable, and achievable and should be available to be brought forward within a realistic timeframe once a Local Plan is adopted. The landowner is fully committed to the whole site and consider that it could be brought forward immediately to meet the housing needs of the Borough. Available Richborough is a national land promoter with a strong track record of bringing sites through the development plan system and the landowner is supportive of the site coming forward for development. Upon the grant of outline planning permission, the site would be sold to a preferred development partner who will be responsible for securing reserved matters approval and then commencing construction and delivering new homes at the earliest opportunity. We have a proven track record of facilitating the delivery of high-quality housing developments on suitable and sustainable sites and can confirm that the site is capable of delivering housing within the early phases of the Local Plan period. Richborough are strong advocates of the plan-led system and are committed to promoting land for residential development by engaging actively with local authorities, parish councils and other neighbourhood forums through local and neighbourhood plans. Suitable The site is entirely suitable for a residential development for the following reasons: ■ It forms a logical extension for housing growth in Chester that would accommodate the required housing growth, with existing defensible boundaries. ■ It offers an accessible and sustainable location for development that would support a balanced spatial strategy and which could be brought forward early in the plan period. ■ There are no environmental or technical constraints that would prevent the development of the site, subject to suitable mitigation and a sensitive approach to design. ■ It offers the potential for significant accessibility and biodiversity improvements to the countryside. Achievable An assessment of the site constraints illustrates that delivery of the entire site is achievable, and a professional team of technical experts will support the detailed design of the site moving forward.Where any potential constraints have been identified, we have considered the necessary mitigation measures and required investment in order to overcome any deliverability barriers. We have reviewed the economic viability of the scheme in terms of the land value, attractiveness of the locality, level of potential market demand and projected rate of sales in Chester; as well as the cost factors associatedwith the site including site preparation costs and site constraints. In addition, we have extensive experience working with nationally significant development partners, as well as SME housebuilders. Developer partners who have built out our sites include Bellway, Barratt David Wilson, Bloor, Castlegreen, GALA, Miller, Mulberry, Kier, Lion Court, Persimmon, Taylor Wimpey, and Vistry. On Richborough's sites, the average completion rate per sales outlet is a combined rate of 50 dpa for bothmarket and affordable housing provision. We can confirm that the development of the site is economically viable, deliverable and achievable in accordance with the NPPF. Illustrative Concept Plan We have prepared two proposed illustrative concept masterplans (Illustrative Concept Option 1 enclosed at Appendix 2 and Illustrative Concept Option 2 enclosed at Appendix 3) to illustrate flexibility in the potential options for how development on the site can come forward as part of the wider growth location of CH03. The site has the capacity to accommodate up to approximately 815 dwellings alongside community infrastructure and green space, which can be delivered within a walkable, green network that promotes active travel. The illustrative concept options propose a primary vehicular access to the site from Wrexham Road and Lache Lane, which will form the primary road and bus access and create a spine road that links these two highways. A network of secondary streets complement the spine, creating a permeable layout that supports safe movement for pedestrians, cyclists and vehicles. Pedestrian and cycle connectivity opportunities will be explored to directly link the development with Wrexham Road Park & Ride facility, which will provide direct access to the City of Chester for residents. The existing landscape structure would be retained and enhanced to reinforce local character and deliver an uplift in biodiversity. The majority of the land to the west of Lac he Lane will form a major new Community Park, creating a significant amount of green, public open space, for new and existing nearby residents to benefit from. The site's topography provides the opportunity to incorporate Sustainable Drainage Systems (SuDS) at low points throughout the site, contributing to a robust and sustainable surface water management strategy. The site has the capacity to deliver local infrastructure to support new residents, including the potential to deliver a 1 Form Entry Primary School, which located to the south of the site on the illustrative concept plans. Additionally a local centre is identified centrally within the site and in close proximity to the primary school, which could potentially provide a range of local services and amenity. Play spaces are distributed throughout the site and there is the potential to provide communal food growing opportunities with allotments, which are also shown to the south of the site. The two proposed concept masterplan options demonstrate a flexible approach to meeting the Council's needs for development, with Option 1 (enclosed at Appendix 2) illustrating a residential-led development to meet the housing needs of CWaC, which would have the capacity to deliver approximately 815 dwellings across 21.2 ha of land. The new homes would be a mix of higher density, outward facing development to the south and eastern edges of the site which would provide a strong residential frontage and new gateway to Chester (including the incorporation of potential mitigation measures to address traffic noise). Lower density residential development would be provided towards the north of the site, to create a sensitive integration with the proposed area for ecology and nature enhancements. Alternatively, Option 2 (enclosed at Appendix 3) demonstrates an alternative approach to meeting the Council's needs for development, with the opportunity to provide around 2.5 ha of employment space alongside the ASS junction, alongside approximately 720 dwellings. The employment land is shown as being located in the south east corner of the site, closest to the intersection of ASS (North Wales Expressway) and the A483 (Wrexham Road). This would provide an opportunity to promote a sustainable, mixed-use community, locating jobs near to homes which will help to reduce reliance on cars and promote active travel. Overall, the site offers an opportunity to deliver a well-connected, landscape-led development that would complement the wider growth location that its sits within. Rich borough and the landowner would be open to discussing these concept options and the potential mix of uses with the Council as the Local Plan is progressed. Key Benefits The development of the site will support new housing in an appropriate location and ensure that a quantity, quality and mix is provided that supports economic growth in Chester and the east of the CWaC Borough. The delivery of the site will provide significant benefits to the Borough, to Chester and the existing community. These are summarised as follows: Economic Benefits The development of the site will have significant economic benefits, both from its construction and occupation, and in the catalytic impact it would have within Chester. Key economic benefits include: Generating investment during the construction phase of development through construction cost, Full Time Equivalent construction jobs and an increase in Gross Value Added. The scheme will generate construction investment and sustain construction jobs for the length of the construction programme, offering a recognised pathway into employment for registered unemployed residents in CWaC. ■ The potential to provide employment uses to generate long term jobs for the south of the Borough. ■ Providing long term occupation benefits including new resident expenditure, attracting new and high earning residents to Chester, generating flow on and supported jobs and, overall, generating increased economic output in the Borough. ■ Generating significant revenue for the Local Authority, with a development of new homes generating significant annual Council Tax revenue, and a New Homes Bonus. ■ Providing the quality of housing that will underpin the retention of skilled workers in Chester and support high value jobs in knowledge-led industries. Creating Social Benefits and Social Inclusion The delivery of the site will have clear socialbenefits for existing and future residents, by providing greater choice for housing and amenities, improving access to amenities and meeting a variety of identified housing needs. The key social benefits include: ■ Delivering up to approximately 815 high quality market homes to meet the needs of the Borough's existing and future employees. ■ Delivering viable and deliverable affordable homes to address the Borough's acute affordability crisis and support the housing of key workers and first time buyers. ■ Delivering new and accessible multifunctional open space, including a new community park, amenity space and green infrastructure to benefit existing and future residents and to improve connectivity to amenities to the south of Chester. ■ New primary school provision to support existing and future residents. ■ The provision of a new bus route along with improvements for pedestrians. ■ Providing a highly permeable settlement layout with continuous routes throughout the site. ■ Providing new residents to sustain demand for good quality public services and local social infrastructure in the south of Chester. This increase in housing and inflow of investment will further encourage the retention of a working-age population in Chester which will encourage the realignment of the demographic disparity, providing long-term security for the settlement. Environmental Benefits The site is currently arable farmland with limited biodiversity or recreational value. The development of the site has the potential to significantly uplift the biodiversity, accessibility and overall enjoyment and environmental value of the site. The Illustrative Concept Plan proposes a significant area for nature and ecology enhancements. Key environmental benefits include: ■ The site is extensively farmed and has limited ecology value at present, which provides an opportunity to create new habitats for a range of species and deliver an uplift in biodiversity to meet Government targets. ■ The provision of multi-functional green infrastructure and open space that will benefit existing residents. ■ The protection and enhancement of existing features on the site that add value, including mature trees, hedgerows on the site boundary. ■ Exploring the potential for improved accessibility to the open countryside and biodiversity enhancements to the wider site. ■ Embedding energy efficiency and zero carbon ready by design into the fabric of the development, and employing cutting edge new net zero technologies. Summary In summary, Rich borough fully supports the identification of Lache Lane as part of growth location 'CH03' in the Local Plan Issues and Options Consultation. We strongly support the principle of allocating the site within the emerging Local Plan and the landowner is fully committed to bringing forward the site for development. We would welcome further engagement with the Council and would be happy to discuss the site at the Council's convenience.