Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 11154

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11652
The introduction of a new standard methodology (SM3) by the Government in December 2024 has significantly increased CWaC's local housing need (LHN) from 532 dwellings per annum (dpa) (calculated using SM2) to 1,928 dpa, an increase of +262%. CWaC's current LHN is also significantly higher (+43%) than the Council's currently adopted housing requirement of 1,100 dpa in its Part One Local Plan (LPPl). The National Planning Policy Framework (NPPF) (published in December 2024 and amended in February 2025) sets out the Government's policy in respect of housing and other matters. It states that, to determine the minimum number of homes needed, strategic policies should be informed by a LHN assessment, conducted using the standard method set out in national planning practice guidance (PPG). In this regard, it is important to recognise that SM3 sets only the minimum housing The NPPF goes onto outline that the requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas or reflects growth ambitions linked to economic development or infrastructure investment. The possible policy approach outlined at SS 1 (Housing Needs) of the LPIO consultation document sets out a policy approach of planning for a minimum of 1,914 new homes each year over the plan period. As this is a minimum housing requirement and can be exceeded, we would strongly recommend that the Council proactively plans to maximise housing delivery across the plan period, putting steps in place now to ensure plan-led development to best achieve the objective of supporting a vibrant, diverse and competitive local economy with sufficient flexibility in the supply to respond to unforeseen circumstances and guard against speculative development in unsustainable locations. This will also help to maximise the longevity of the Council's emerging Local Plan by reducing the likelihood of CWaC's housing requirement needing to be reviewed within five years of the Plan's adoption. Indeed, since the publication of the LPIO consultation document the SM3 figure has already increased to 1,928 dpa having regard to the latest stock and affordability data. This still represents the minimum amount of housing development that should be planned for, but it is likely to continue to increase incrementally over time as housing prices increase due to constrained supply, and wage growth fails to reflect that localised house price inflation. This points to a need to plan for a higher requirement, even without uplifts for other factors such as economic growth and strategic needs. CWaC has not escaped the national housing crisis, with rising house prices worsening the Borough's historic affordability This is in turn making it increasingly difficult for younger residents to remain in the Borough, pricing out the economically active future generations to other areas that offer a wider range of more affordable housing options. For example, house prices have grown by over 225% since 2000 in CWaC, with median average house prices at £245,000 as of December 2024. This is c.19% higher than the regional average of £206,000. The private rental market across the Borough is also becoming increasingly less affordable due to the increasing costs of rental properties driven up by rising demand. Private rents averaged £926 per month in June 2025, an annual increase of 9.3% from £848 in the previous year. 2 This is pricing people out of private-rented accommodation. The Borough is currently failing to meet the requirements of the NPPF to ensure an appropriate size, type and tenure of housing needed for different groups in the community is available, including people who rent their homes. Increasing the supply of a wide range of housing, including affordable properties, is critical to help meet this demand. A key focus of both the Council's current and emerging development plan is to provide opportunities for economic growth and investment, with an emphasis on delivering a range of job opportunities to support sustainable communities. Strong levels of housing delivery are key to a properly functioning, sustainable For example, providing a wide choice of housing, particularly affordable dwellings, will allow the Borough's younger residents to access and move up the housing ladder, enabling them to live and work in CWaC. Additionally, a diversified housing market will attract more skilled workers to live in Chester, promoting sustainable commuting patterns and strengthening CWaC's labour pool. This in turn will help to increase inward investment to the Borough, raising CWaC's profile as a sought-after place to live and bringing with it new job opportunities, particularly within the construction and housebuilding sectors. There is therefore a very strong and fully justified case to be made that CWaC's housing requirement should meet and, in all probability, exceed its current SM3 figure in order to best achieve the area's growth ambitions in accordance with the NPPF. CWaC should be seeking to maximise residential development in the most sustainable locations such as Chester City, across a wide range of tenures in its emerging Local Plan, particularly affordable properties, to reverse the Borough's affordability pressures and improve accessibility to high quality housing. This in turn will help to create inclusive, diverse communities that promote social wellbeing and increased economic productivity.

Comment

Representation ID: 11155

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11653
a stepped housing requirement is not considered appropriate in this instance given the significant scale of housing delivery required across the Borough and the immediacy of CWaC's need. The Council should be seeking to maximise housing delivery from the very start of the plan period, particularly by identifying housing sites such as these, that are capable of coming forward in the short term.

Comment

Representation ID: 11156

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11654
The effect of the assessment (summarised in Table 2) is that the Council must identify an additional 6,334 dwellings against a 5-year housing requirement of 10,122 dwellings when applying the relevant This is a significant number of houses that the Council must identify to mitigate the ability for speculative residential applications to come forward on the basis of a lack of SYHLS. This shortfall will only increase if the Council takes our advice and plans for a housing requirement that exceeds its LHN. It is therefore essential that the Council allocates a wide range of sites, including both smaller sites as well as larger, more strategic, housing allocations that have high prospects of coming forward within a five year This will need to avoid backloading supply in the later years of the plan period. Smaller sites are less likely to have significant technical or physical constraints to impact delivery and are typically more capable of being brought forward in the early part of the plan period to address identified needs in the shorter term. These 2 land interests on the edge of Chester are available, achievable and deliverable and should therefore be allocated for residential development to come forward in the early part of the plan period. The sites will make a strong contribution to CWaC's SYHLS, accounting for the Council's significantly higher housing requirement. Furthermore, we have concerns that the total housing capacity of sites identified in the Council's Land Availability Assessment (LAA) (Stage One) (April 2025) could fail to meet CWaC's overall housing requirement for the plan period. The LAA estimates a total capacity of 28,924 dwellings, which is only slightly above the Council's total minimum housing requirement of 28,710 homes based on SM3. The Council has failed to incorporate a suitable buffer in its supply should the identified sites not come forward at the rate they expect or fail to come forward at all. The lack of any kind of meaningful buffer to the figures means that the Council's current supply figure will not meet or exceed its housing requirement, which is likely to put additional strain on the Council to allocate a considerable number of housing sites as part of a future Local Plan To mitigate this, the Council should build in sufficient flexibility to its supply to ensure needs are met in full (as a very minimum). We would recommend that the Council takes a more proactive approach and seek to exceed its The Council should therefore review its housing land supply in this context. Whist we welcome the consideration of both these land interests in the Council's LAA under references 1930 (Land at The Dale, west of Liverpool Road, south of Percival Close, Upton, Chester) and 1416 (Land off Warrington Road (A56), Hoole, Chester), it has concerns regarding the methodology used to assess the Borough's land availability. The Council's methodology, which removes sites containing more than 10% of land located in the Green Belt from further assessment in Stage One of the LAA, is clearly flawed. The LAA states that sites may be revisited as a result of the review stage of the LAA, or as part of the plan making process. Regardless of whether sites are located in the Green Belt or not, they should not be discounted at this stage. Instead, they should be taken forward for further consideration on the basis that allocating the most sustainable, least constrained Green Belt sites will be required to ensure the emerging Local Plan has the greatest prospect of being found sound at Examination. It is critical that sites around the edges of Chester in particular (to includes refs. 1930 and 1416) are considered further through the emerging Local Plan, by taking them forward into Stage Two of the Assessment. This will allow the Council to identify the most sustainable sites around Chester, a top-tier settlement already heavily constrained by Green Belt, for a residential allocation through the emerging plan.

Comment

Representation ID: 11157

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11655
CWaC set out its proposed vision in VI 1 of the LPIO consultation document (it is assumed that this is not proposed to form a Policy in the future). It sets out the vision for CWaC in order for it to be a desirable and attractive place to live, work, learn and visit. The vision is made up of four overarching principles, one of which is to ensure the provision of appropriate infrastructure in suitable locations to make CWaC a good place to Whilst it appears that 'appropriate infrastructure' is intended to include the provision of housing, the vision does not currently make specific reference to the need to deliver new homes. This is concerning given the scale of housing growth CWaC should be planning for going forward, which is vital for promoting economic growth and development across the Borough. The provision of new, high quality, housing to include a range of types, sizes and tenures is paramount to ensuring the Borough remains a desirable and attractive place to live. We are of the view that the four principles should be expanded to include a further principle that focuses solely on the provision of new housing, so that the right homes are delivered in the right places at the scale required to meet identified needs. We also support the creation of specific visions for the larger settlements, particularly Chester, where a large concentration of the Borough's overall housing requirement should be focused towards. This should include the Satnam and Hillmarch land interests.

Comment

Representation ID: 11158

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11656
The possible policy approach outlined at SS 3 (Spatial Strategy Principles) focuses on directing new development and allocating land towards previously-developed sites within settlements first, before developing on the edge of existing settlements in locations with best access to public transport and existing services and infrastructure. The Policy states that depending on the settlement this may require the release of Green Belt land. We support the broad principles of CWaC's spatial strategy, given its alignment with national planning policy's brownfield first approach. However, an overreliance on brownfield land to deliver new housing is a risky strategy given the increased likelihood of technical and viability constraints delaying residential development coming forward on such sites. Given the scale of housing growth required across the Borough, allocating deliverable and unconstrained housing sites in and around Chester will be fundamental due to the City's scale and sustainability. However, the supply of brownfield sites within Chester is limited; the settlement edges are heavily constrained by the Green Belt; and other constraints largely within the city centre (including heritage and flood risk) are apparent, therefore extensions to the current urban area will be This will therefore involve revisions to Chester's existing Green Belt boundaries.

Comment

Representation ID: 11159

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11657
The possible policy approach outlined at SS 4 (Settlement Hierarchy) states that the emerging Local Plan will set out a settlement hierarchy, based on their status and role in providing local infrastructure and services for their relatively larger populations and the surrounding hinterland. Chester, the only City in the Borough, is rightly at the top of the settlement hierarchy, due to its scale and the wide range of services and infrastructure it has to offer its large We support the Council's settlement hierarchy and ask that the Council allocate sustainable sites for housing on the edge of Chester's existing settlement boundary, particularly to the north and east of the city to include Satnam's land Housing growth should be prioritised in and around Chester to maximise its potential as a sub­ regional settlement.

Comment

Representation ID: 11160

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11658
Option A comments: This option is reliant on the significant expansion of existing settlements outside of the Green Belt to meet the Council's identified housing needs. It fails to identify any potential housing growth areas in the most sustainable settlements higher up on the Council's settlement hierarchy, particularly the City of Chester and Ellesmere Port, a main Satnam has very serious concerns that this option will create considerable infrastructure pressures on a small number of settlements, particularly Northwich and Winsford, alongside a handful of villages where existing facilities and services are relatively limited. The option is likely to result in less sustainable sites coming forward within the existing settlement limits to avoid releasing land within the Green Belt, but on the edge of much more sustainable settlements in the Borough, most notably Chester. The possible policy approach outlined at SS 5 references the findings of the Inspector's Report into the LPPl to seek to justify the retention of Green Belt land around the edges of Chester. The significant increase in the Council's housing requirement since the Examination of LPPl in 2014 has materially changed the context in which the Inspector's findings were made. These findings, which are now out-of-date, can no longer provide the necessary justification for preventing Green Belt release around The scale of growth required to meet the Borough's housing needs is so substantial that it is considered unrealistic that it can be accommodated within the Borough without any Green Belt release. The NPPF states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified [§145). Exceptional circumstances include where an authority cannot meet its identified need for homes [§146). If this is the case, the NPPF sets out a sequential approach to the release of Green Belt land, giving priority to previously developed land, then grey belt land which is not previously developed, and then other Green Belt locations [§148). We strongly consider that Option A, proposing no Green Belt release, will prevent the Council from meeting its housing needs in This is an unsound strategy. In accordance with the NPPF, exceptional circumstances therefore exist to allow the Council to review and amend its Green Belt boundaries through the Local Plan process. Additionally, not only should CWaC be seeking to maximise development in the emerging plan period, paragraph 145 of the NPPF requires any Green Belt boundaries to be amended so they can endure beyond this In accordance with national policy, CWaC must safeguard land for development that is capable of coming forward for housing beyond the plan cycle. Whilst the spatial strategy options claim to be able to accommodate a minimum of 29,000 homes, CWaC has failed to account for the development needs of the Borough beyond this plan period. CWaC should not only be accounting for needs within the emerging plan period, but also beyond the plan period to ensure Green Belt boundaries endure. We respectfully ask that the Council does not pursue this option further and instead takes a more proactive approach to meeting needs now, in and around the most sustainable settlements in the Borough. This will avoid a position where the Council cannot demonstrate a SYHLS going forward and reduce the risk of planning by appeal as speculative housing applications continue to come forward in the short It will also help to mitigate the need for the Council to release further land (particularly land within the Green Belt) in future local plan cycles.

Comment

Representation ID: 11161

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11659
Option B and C comments: Both options propose the urban expansion of Chester, which we fully This is reflective of Chester's identification as the top tier settlement in the possible policy approach outlined at 55 4 (Settlement hierarchy) due to its status, scale and role in providing local infrastructure and services for its residents. We consider that housing growth should be concentrated in sustainable locations in and around the settlement boundary of Chester rather than directing development to smaller settlements that will more likely require significant infrastructure investment to support this scale of growth. Table 1 sets out the four potential growth areas identified around Chester, three of' which are identified solely for housing and one for mixed-use development, specifically: CH0l: Chester North - Upton Triangle (Mixed-use); CH02: Chester East - Piper's Ash (Housing); CH03: Chester South - Wrexham Road (Housing); and, CH04: Chester North - North of Blacon (Housing). Both land interests are identified as possible growth areas for residential development within Options B and C, with Daleside Nursery located in CH0l and Land at Hoole located in Going forward, we consider that CWaC should progress with a strategy (either of the two options or a combination of both) that involves the release of Green Belt land, particularly on the northern and eastern edges of Chester. Both sites are well placed adjacent to the strategic highway network, specifically the AS116 Liverpool Road and the A56 Warrington Road, that offer a number of bus stops adjacent to the The stops provide services into Chester city centre. A wide range of local services and facilities within the suburbs of Upton-by-Chester and Hoole are within walking distance. The sites are sustainable ones capable of meeting the development needs of the Borough.

Comment

Representation ID: 11162

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11660
We broadly support the suggested approach of CH 1, particularly the need to provide the right mix of housing and create high quality places. Chester, being the sole top tier settlement in the Borough should accommodate a significant proportion of development relative to its size and However, the wording implies a need to focus residential development towards the City Centre, where available and deliverable urban sites are more limited and will likely take much longer to come forward, if at all. Given the need to protect the City's historic environment, which is recognised in CH 1, and the urgency of the housing crisis facing the Borough, the wording should be amended to reference the importance of sites on the edge of Chester's settlement limits to facilitate residential development, where heritage and viability constraints are less likely to be a material consideration. As mentioned above, Chester's settlement limits should be reviewed in light of the need to meet and exceed the Council's housing requirement informed by SM3. Sites in and around Chester should be a focus for housing development, given these locations can accommodate the scale of growth without straining existing infrastructure provision and

Comment

Representation ID: 11163

Received: 28/08/2025

Respondent: Satnam Planning Services Limited

I&O_11661
Although these percentages are yet to be defined, we understand that they will be informed by the findings and recommendations of a Housing Needs Assessment (HNA) to be prepared in due The HNA should not only consider the mix and housing type requirements at a Borough- wide level but should also consider the requirements of smaller sub-areas to inform the approach to be taken at a more local level. We support the suggested policy approach as long as the policy requirements are fully evidenced and justified. We ask that CWaC does not apply the policy requirements rigidly to bevery new housing site across the Instead, there should be a degree of flexibility in the application of the Policy which should be applied on a site-by-site basis to account for market factors, viability, constraints and locational requirements. This is in recognition of the fact that a different housing mix may be more appropriate in a specific location e.g. 1- and 2-bedroom dwellings may be more suited to Chester City centre whereas larger 3- and 4-bedroom properties may be more suitable in edge-of­ settlement locations. We request that the wording of the policy accounts for a suitable level of flexibility in the percentage mix and tenure This will ensure that residential proposals on sites address the housing requirements of the local area specifically, rather than a 'one size fits all' borough-wide requirement.