Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15821

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16380
The I&O Consultation Document confirms that CWAC Council intend to prepare additional evidence to support the emerging Local Plan, including a Housing Needs Assessment, Green Belt Study, Infrastructure Delivery Plan, Strategic Viability Assessment and Land Availability Assessment. The Council must ensure that all proposed policy directions and spatial strategy are thoroughly justified and supported by evidence. The outlined documents, alongside any other necessary studies, will be essential to robustly underpin the policies set out in the emerging Local Plan. It is essential that the evidence base that informs the emerging Local Plan reflects the latest national policy as set out in the NPPF and Planning Practice Guidance (“PPG”). In particular, this includes ensuring that the proposed Green Belt Study aligns with the updated Green Belt PPG published in February 20256, including consideration of grey belt opportunities. In addition to the evidence already identified by CWACC, other evidence that should be produced or updated to ensure it reflects the latest context includes:  Site Selection Paper – to date there is no evidence provided by CWAC Council on the proposed allocations, including FRO03. As set out in these representations, the live planning application for the Site is supported by a full suite of technical documents. BDW are happy to assist CWACC in sharing relevant evidence, as necessary. Places Background Paper 2024, which should be extended to consider all identified Local Service Centres (in addition to the urban areas and Key Service Centres) and the potential for these to be ‘moved up’ the settlement hierarchy. Economic Needs Assessment 2025 Brownfield Land Register Playing Pitch Strategy 2021 Public Open Space Assessment Duty to Cooperate Statement Updated Conservation Area Appraisals and Management Plans for all Conservation Areas in CWAC

Comment

Representation ID: 15822

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16381
The emerging Local Plan should have a clearly defined monitoring framework, which establishes key monitoring indicators for each relevant policy and defines how the objectives / targets established in the Local Plan are being met and, if not, why and what actions will be taken and when to address any issues. It should also confirm the associated data sources and means of reporting. Effective monitoring of housing delivery is particularly critical. If annual monitoring reveals delays in housing delivery across CWAC, prompt action must be taken to rectify this. The Council should monitor housing delivery against a published Housing Trajectory and conduct site-by-site housing monitoring at least annually, in accordance with Paragraph 78 of the NPPF.

Comment

Representation ID: 15824

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16383
The I&O Consultation Document confirms that CWAC Council intends to plan for a period of 15 years. Paragraph 22 of the NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that, where larger scale developments form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.  To ensure a robust approach to the emerging Local Plan, reflecting the anticipated preparation timescales and providing the 15-year plan period post-adoption required by paragraph 22 of the NPPF, BDW considers that the Council should, at a minimum, prepare a Local Plan extending to at least 2045. This would secure the necessary 15- year period following adoption. However, it is also noted that the current adopted Local Plan covers a 20-year period. The Council should therefore consider whether the scale of housing and employment needs, along with the strategic sites identified to meet them, warrant extending the emerging Local Plan beyond 15 years. A 20-year plan period may be more appropriate.

Comment

Representation ID: 15825

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16384
In accordance with paragraph 13 of the NPPF, “neighbourhood plans should support the delivery of strategic policies contained in local plans or spatial development strategies; and should shape and direct development that is outside of these strategic policies”. Footnote 17 of the NPPF confirms that “neighbourhood plans must be in general conformity with the strategic policies contained in any development plan that covers their area”. Similarly, as set out at paragraph 30 of the NPPF “neighbourhood plans should not promote less development than set out in the strategic policies for the area, or undermine those strategic policies”. Furthermore, they must meet the ‘basic conditions’ set out in paragraph 8 of Schedule 4B to the Town and Country Planning Act 1990 (as amended) (as per paragraph 38 of the NPPF). BDW recognises the value of neighbourhood planning in providing communities with an opportunity to shape a vision for their area. However, it is essential that the emerging Local Plan seeks to meet all housing (and employment) needs in CWAC by allocating sufficient land to accommodate these needs and does not rely on any shortfall to be delivered by neighbourhood plans. Frodsham’s Neighbourhood Plan (‘FNP’) in particular was adopted long after the LPP1 (i.e. 9 years after) as such its housing policies and provision are no longer aligned with the NPPF and are considered out of date in this regard. BDW therefore disagrees with the Council’s assertion at paragraph 1.27 of the Reg 18 Consultation Draft Plan that much of the content of the existing neighbourhood plans across CWAC won’t be affected by the emerging Local Plan. Once the emerging Local Plan has been adopted, it will be necessary for the respective neighbourhood forums to review and update their neighbourhood plans to ensure continued consistency with the strategic policies of the Local Plan. Paragraph 30 of the NPPF states that “Neighbourhood plans should not promote less development than set out in the strategic policies for the area, or undermine those strategic policies”. Neighbourhood plans should not attempt to overtly restrict development where it is necessary to meet local needs and should be informed by an evidence base to support all proposed policies. As such, BDW request that paragraph 1.27 is updated to remove reference to existing neighbourhood plans not being affected by the emerging Local Plan. This is a review exercise each neighbourhood forum will have to undertake once the Local Plan is adopted, to ensure alignment with the new Local Plan. To pre-empt this conclusion is unnecessary nor justified.

Comment

Representation ID: 15852

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16411
VI1 of the I&O Consultation Document sets out the vision for CWAC, including the overarching principles of tackling climate change; promoting wellbeing; providing infrastructure; and protecting character. BDW generally agrees that the key principles outlined in the proposed vision are necessary and demonstrate a commitment to addressing the key challenges facing CWAC. However, in line with paragraph 15 of the NPPF, Local Plans should set out a positive vision for the future of the Plan area. BDW considers that the emerging Local Plan should establish an ambitious yet realistic vision for CWAC’s future, clearly articulating how the Council envisions the area’s growth and development through to the end of the Plan period. A key element of this vision must be a clear commitment to meeting the identified current and future housing needs of the Borough, including market housing, family homes, affordable housing, homes for older people, and homes for first-time buyers. Currently, the I&O vision lacks explicit reference to meeting housing needs, which BDW believes should be addressed—particularly given in the context of the ongoing national housing crisis.

Comment

Representation ID: 15853

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16412
Subject to the inclusion of explicit reference to meeting housing (and employment) needs as above, BDW agrees that the key principles included in the proposed vision (i.e. tackling climate change, promoting wellbeing, providing infrastructure and protecting character) are necessary and show commitment to addressing key challenges facing CWACC.

Comment

Representation ID: 15854

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16413
The key places identified in the new Local Plan include Chester, Ellesmere Port, Northwich, Winsford, Frodsham, Neston and Parkgate. BDW support the proposed approach to establishing specific visions for key places within the Borough, subject to this aligning with the defined Spatial Strategy and Settlement Hierarchy and being informed by the evidence base. BDW are particularly supportive of the Local Plan setting out an individual vision for Frodsham. The I&O Consultation Document recognises Frodsham as a market town, highlighting its important role in providing infrastructure and services to both its relatively large population and the surrounding hinterland. This marks a significant shift from its previous designation in the current Local Plan (Part One) (‘LPP1’) (January 2015), where Frodsham was classified as a rural area key service centre. Given this notable growth, it is essential that future development in Frodsham is guided by a clear and focused vision. BDW support and welcome this approach to Frodsham and trust this elevated status will ensure a proportionate level of growth is allocated to the town.

Comment

Representation ID: 15855

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16414
As set out in the accompanying Lichfield’s Research Paper7 , the new standard method for calculating housing need is one of the central tenets of achieving the Government’s objective to deliver 1.5 million homes in the current Parliament. The updated standard method results confirm that CWAC’s housing need figure is 1,928 dwellings per annum (‘dpa’), which is considerably higher than the previous standard method demographic-based figure of 489dpa, and also much higher than the 2015 Local Plan figure of 1,100dpa. Applying the updated standard method equates to a total requirement of 28,920 dwellings over a 15-year plan period and 38,560 dwellings over a 20-year plan period. In accordance with the NPPF, the standard methodology for assessing local housing need in England and the July 2024 Written Ministerial Statement – “Building the Homes we need” – this is the minimum housing need figure that should be considered in preparing the emerging Local Plan. Furthermore, in line with paragraph 69 of the NPPF, the Council may also need to consider if it is appropriate to plan for a higher housing need figure than the standard method indicates to reflect growth ambitions linked to economic development or infrastructure investment. To assist the Council in ensuring that the emerging Local Plan meets all of CWAC’s housing needs, including in terms of the types and tenures of housing required across the Borough and maintaining an appropriate balance of development, BDW consider that it will be essential for appropriate evidence to be gathered. This should take the form of a local housing needs assessment (including affordable housing) and a viability assessment to determine what types of homes may be needed and can be delivered in CWAC. These documents should be made available for future consultation. Any affordable housing requirements should be clearly defined and evidenced, with flexibility provided within relevant policies where viability challenges exist. The emerging Local Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver CWAC’s housing requirement, including the maintenance of a 5-year housing land supply. This will also enable the Housing Delivery Test to be achieved. BDW strongly recommends that the plan allocates more sites than necessary to meet the minimum housing requirement as a buffer. This buffer should be sufficient to deal with any under-delivery which is likely to occur from some sites and to provide flexibility and choice within the market. Such an approach would be consistent with the NPPF requirements for the emerging Local Plan to be positively prepared.

Comment

Representation ID: 15856

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16415
At this stage of plan preparation and until the Spatial Strategy is confirmed (including the scale of individual site allocations), BDW do not consider that it will be necessary for the Council to plan for a stepped housing requirement. To be proactive and avoid delaying delivery too late in the Local Plan period, the Council should be planning as a minimum to meet its annual housing requirement of 1,928 dwellings.  

Comment

Representation ID: 15857

Received: 29/08/2025

Respondent: Barratt David Wilson Homes

Agent: Turley

I&O_16416
The Council’s proposed spatial strategy seeks to direct new development firstly towards previously developed sites within settlements, and then where there are not enough planning permissions and opportunities for redevelopment within urban areas and towns, the approach will be to develop on the edge of existing settlements in locations with the best access to public transport, existing services and infrastructure. The Council suggests that this may require the release of Green Belt land, depending on the settlement. To ensure the delivery of sufficient homes across all types and tenures, BDW considers it necessary to plan for development on land outside of existing settlement boundaries. Given the extent of Green Belt designation in CWAC, particularly in the north of the borough where many key settlements such as Frodsham are significantly constrained, some Green Belt release will be essential. The I&O Consultation Document identifies around 6,000 homes from existing planning permissions and a further 5,000 homes on previously developed land without permission within main urban areas and Key Service Centres. However, this combined capacity of approximately 11,000 homes falls significantly short of the housing need identified over both a 15-year (28,920 dwellings) and 20-year (38,560 dwellings) plan period. This leaves a shortfall of 17,920 and 27,560 dwellings respectively. Furthermore, the deliverability of the identified supply has not yet been fully tested.  Paragraph 146 of the NPPF confirms that exceptional circumstances for Green Belt release can arise where housing needs cannot otherwise be met. In order to justify such release, the Council must produce robust evidence on the capacity of brownfield land and urban sites, building on existing monitoring data. This evidence must consider both deliverability and viability. When assessing sustainable locations for growth, the Council should not be unduly constrained by existing Green Belt boundaries. In some cases, development within the Green Belt adjacent to urban areas may be more sustainable than development further afield beyond the Green Belt, particularly where the latter would result in greater car dependency and infrastructure demands. It is clear that development beyond current settlement boundaries will be required to meet both housing and employment needs. This will inevitably include Green Belt release in the north of the borough. The Council’s approach should be informed by an up-to-date and robust Green Belt Assessment (GBA), prepared in line with the NPPF and Planning Practice Guidance, including consideration of ‘grey belt’ opportunities. Finally, in accordance with paragraph 148 of the NPPF, the Council must consider not only currently sustainable sites but also those that could become sustainable or help improve the sustainability of existing settlements, as part of the Land Availability Assessment process.