Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 14193

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14737
Taylor Wimpey supports the Council’s overarching vision and the four principles by which this will be achieved. However, there is a lack of focus on new homes within this framework. Given that the Council is seeking to establish the Borough as an attractive place to live, the delivery of new homes is fundamental to ensuring that housing provision is not only planned but also realised. As such, Taylor Wimpey suggests that the overarching principles be amended to provide a more explicit focus on new homes in the Borough.

Comment

Representation ID: 14198

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14742
Taylor Wimpey supports the Council’s use of its LHN figure in the emerging Local Plan as a minimum figure, as it enables proactive planning to meet housing needs. The government has recognised that there is a severe housing crisis in England, characterised by a significant shortage of affordable housing to meet the needs of the population. As such, the government has set a clear objective of significantly boosting the supply of homes in order to meet a target of 1.5 million homes within their 5-year term. The housing shortage is also evident within CWaC, which has experienced affordability issues across the Borough. The Issues and Options Plan recognises this, noting awareness of the  unaffordability of housing in parts of Cheshire West and how many young people and those on lower incomes struggle to access the housing market (page 23). Policy SS1 states that the Council plans to deliver a minimum of 1,914 new homes per year over the plan period. For a 15-year plan, this equates to a total of 28,710 new homes. This minimum figure is based on the Council’s Local Housing Need [LHN] as of December 2024, calculated using the revised stock-based methodology introduced alongside the December 2024 iteration of NPPF. Taylor Wimpey considers that the Council should seek to meet its identified need in full, in line with the NPPF (para. 61), to ensure issues of affordability can be adequately addressed and the objectives of the NPPF can be realised. Furthermore, as set out previously, the 1,914 dwelling requirement is no longer reflective of the current LHN. Following the release of updated housing stock data and March 2025 affordability ratios, the Council’s LHN is now 1,928 dpa. Accordingly, the policy should reflect the most up-to-date LHN when the draft Local Plan is published. Meeting the full LHN will help to ensure that a wide range of housing needs are met across the full extent of the Borough, including market and affordable housing requirements, and all types and tenures of housing to meet the needs of all aspects of the local population including first time buyers, family homes, and those in specialist need. The Borough has not escaped the symptoms of the housing market crisis with rising house prices and worsening affordability ratios that make it increasingly likely that younger residents have to move out of the Borough to find suitable housing choices. However, housing delivery has been healthy since the adoption of the current Local Plan in 2015 (averaging 1,686 dpa). This consistent level of recent delivery demonstrates that the market is capable of achieving the housebuilding needs set by Government, and there is evidence that the recent high level of housing delivery is starting to slow down growth in house prices and affordability ratios in this Borough. Taylor Wimpey does not consider that there is any justification for the Council to seek a lower housing requirement below the LHN. Conversely, the standard method figure of 1,928 dpa should therefore be treated as a minimum. This has been quantified through work on a Research Paper prepared by a Consortium of housebuilders (comprising Taylor Wimpey, Barratt / David Wilson Homes and Redrow Homes). The Research paper has been submitted as a separate representation to this consultation and is appended to these representations for ease of reference (see Appendix 1). The Research Paper concludes that the standard method figure of 1,928 dpa should therefore be treated as a minimum because: 1 The NPPF clearly states that local plans should meet the development needs of their area and as a minimum provide for the objectively assessed needs for housing. Numerous Inspectors at local plan examinations have supported this position. 2 Housing needs can now expressly justify exceptional circumstances for Green Belt release, and it is mandatory for LPAs, if necessary, to alter Green Belt boundaries when they cannot fully meet housing requirements (unless there is evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan). 3 Housing need modelling scenarios which maintain current demographic trends, including an aging population, suggest a housing requirement of at least 1,763 dpa, whilst a scenario which aligns economic growth and housing needs in line with LEP growth aspirations suggests a requirement of at least 2,169 dpa. These two scenarios straddle the SM3 figure of 1,928 dpa. 4 There are potentially significant economic benefits of pursuing at least the 1,928 dpa figure which will not be realised if a lower requirement is set, including: 5 Over £340m in capital investment p.a.;  6 Over 10,000 FTE direct and indirect construction jobs p.a.; 7 Almost £950 million in economic output p.a.; 8 £22m in resident expenditure p.a.; and 9 Council Tax revenue of £4.3m p.a. 10 The benefits associated with pursuing a more positive economic growth-led housing requirement would be even higher. This needs to be considered against a context of CWaC falling behind its neighbours when it comes to job growth over recent years. 11 CWaC's population is projected to grow at a faster rate than any of its neighbouring authorities as well as relative to the wider regional and national projected growth rates. This presents a need to ensure that sufficient housing is provided so that this growth potential is not constrained. 12 Despite high levels of housing delivery over recent years, there remains a crisis of supply nationally and regionally, and a very challenging affordability gap, both of which can be addressed, or at least slowed, by delivering more housing. 13 Despite high levels of affordable housing delivery, there remains an acute need for new affordable homes to address significant housing waiting list numbers and rising levels of homelessness. The cost of temporary accommodation is having an unsustainable impact on the public purse. 14 High levels of homebuilding will create churn in the market, providing opportunities for first time buyers, growing families or downsizers, and new forms of retirement and care for the ageing population. 15 High levels of new home provision will help to deliver better health and wellbeing outcomes for residents – for example, by addressing overcrowding and the associated mental health toll this can generate, providing greater choice in housing tenures, type, size and location, delivered to modern high efficiency standards which in turn reduces the burden on NHS resources and addresses other related issues such as fuel poverty and cost of living.

Comment

Representation ID: 14218

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14762
Taylor Wimpey is fundamentally opposed to the use of a stepped housing requirement to backload housing delivery. In light of the national housing shortage, an issue also affecting CWaC, and a national drive to increase delivery it would not be the correct approach to delay the delivery of housing until later in the plan period. Taylor Wimpey considers that this would be a flawed approach to housing delivery in the Borough. The emerging Plan and its evidence base do not provide any robust justification for including a phased housing requirement which significantly reduces delivery in the first years of the Plan. It is also worth noting that the past annual delivery in Cheshire West broadly accords with the proposed housing requirement and it would be counterintuitive to artificially supress delivery in the early part of the plan period. As set out in the CWaC Housing Land Monitor Summary Report 2025 the Council can only demonstrate a 5YHLS position of 1.89-years. Taylor Wimpey considers that this reduces further to 1.87-years when factoring in the updated LHN of 1,928 dpa. This represents a significant shortfall of 6,334 dwellings. The Council must therefore identify a significant quantum of deliverable housing land supply through new housing allocations as part of the preparation of the new Local Plan. The Council’s inability to demonstrate a 5YHLS should not be used as justification to backload housing delivery, and new housing sites should be identified instead to ensure it can demonstrate a 5YHLS against its full housing requirement set by LHN. The stepped delivery of housing will not enable housing needs to be met in the early years of the plan period, and in turn this will exacerbate affordability issues by ignoring the need to deliver affordable homes which can meet the needs of the population and ensure young people and those on lower incomes can access the housing market. As set out in the introduction to these representations, and the accompanying site specific representations, Taylor Wimpey has a number of deliverable sites in CWaC which can help to deliver dwellings quickly and assist the Council in demonstrating a sufficient supply for the first five years of the plan period. Therefore, Taylor Wimpey recommends that an approach which uses a fixed annual requirement is applied to ensure needs can be met on a consistent basis throughout the plan period.

Comment

Representation ID: 14223

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14767
Taylor Wimpey supports this general approach to prioritise the development of previously developed land first, in line with a ‘brownfield first’ approach. This aligns with NPPF para. 147a, which sets out that before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development, making as much use as possible of suitable brownfield sites and underutilised land. However, it is clear that there is a significant shortage of deliverable and developable housing land across the Borough and land within the urban area will not suffice. This is acknowledged in the Plan itself at Para 5.3 which states that ‘The Land Availability Assessment (Stage One) report suggests that there are sites on previously developed land without planning permission, including undeveloped Local Plan allocations, within the main urban areas and Key Service  Centres, with a potential capacity of just over 5,000 homes. However, this figure is likely to reduce once a detailed assessment of the constraints, development potential and availability and achievability is carried out in stage two of the process’. Policy SS 3 must therefore include an acknowledgement that Green Belt release is likely to be required across the Borough in order to meet identified housing needs within the plan period. Given the scale of the housing shortfall across the Borough, it is clear that there is a need for greenfield development on the edge of sustainable settlements and Green Belt release where required. It is vital that the Council does not adopt an overreliance on urban and brownfield sites, given the potential viability challenges and the limited range of development types that such sites can accommodate. Brownfield or previously developed land can be subject to significant deliverability and viability issues, due to factors such as land contamination and remediation costs, fragmented landownership and other physical and environmental constraints. Reliance on brownfield land is likely to result in deliverability issues and restrict the Council’s ability to address its deficient housing land supply. Furthermore, the scale of the shortfall is well evidenced by the Council’s current housing land supply position. Although this focuses on the deliverable land supply (first five years of the plan period) it provides a useful indication of the evident lack of supply within the Borough, and highlights an urgent need for new housing sites to come forward for development. The Council can only demonstrate a 5YHLS of 1.87-years, and an overreliance on brownfield land as part of its spatial strategy will only exacerbate this supply position in the short term and also prevent the Council from meeting longer term needs. As such, the Council must ensure that Policy SS 3 facilitates a balanced and realistic spatial approach which fully addresses the need to deliver substantial levels of housing on the edge of sustainable settlements to ensure housing needs are met in full. 

Comment

Representation ID: 14231

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14775
Taylor Wimpey agrees with the suggested approach towards the settlement hierarchy in Cheshire West and Chester. Draft Policy SS 4 designates Chester at the top of the settlement hierarchy as the only ‘City’ within the Borough (Tier 1). Taylor Wimpey fully supports the designation of Chester as a City at Tier 1 of the settlement hierarchy, as well as the inclusion of 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, it is considered that Chester should accommodate a level of development and growth that reflects its scale, location and sustainability, which should be reflected in the spatial strategy and land allocations in the emerging Local Plan. Taylor Wimpey also supports these settlements having individual place based policies in order to set out the vision, core features, key issues and clear strategy for what development will take place. Draft Policy SS 4 also sets out that the following settlements have a level of facilities and services that mean they can meet the day-to-day needs of their residents and those living in surrounding areas: • Cuddington and Sandiway • Farndon • Helsby • Kelsall • Malpas • Tarporley • Tarvin • Tattenhall It is evident from this version of the Plan that these settlements are defined as ‘Tier 2’ settlements. Whilst not defined within Draft Policy SS 4, all of these settlements are currently designated as Key Service Centres in the adopted Local Plan. For the avoidance of doubt, it is considered that future versions of the Local Plan should clarify that these settlements will be retained and defined as Key Service Centres given their established status as main settlements in CWaC. Aside from the larger settlements of Chester and Ellesmere Port, CWaC is a borough characterised by a number of smaller but very sustainable settlements. The most sustainable rural settlements act as Key Service Centres to the local population. Locating most new development within and on the edge of the Borough’s main urban areas and key service centres enables the maximum use of existing infrastructure and resources and allows homes, jobs and other facilities to be located close to each other. Key Service Centres will therefore play a significant role in ensuring that the Council can meet its housing needs over the next plan period, and directing development to these locations will ensure that new residential development is appropriately apportioned across the Borough in a sustainable manner. In particular, Taylor Wimpey supports the continued identification of Helsby, Cuddington and Sandiway, and Tattenhall as Key Service Centres, retaining their status as Key Service Centres in the new Local Plan. These settlements are highly sustainable and suitable locations to accommodate additional levels of growth in the emerging Local Plan, providing a substantial contribution to meeting the housing requirement over the next plan period. Policy SS 4 is currently worded to suggest that only the larger settlements of Chester, Ellesmere Port, Northwich, Winsford, Neston and Parkgate and Frodsham will have an individual place-based policy for each settlement will set out the vision, core features, key issues and clear strategy for what development will take place. It is not clear from the evidence presented why Frodsham and Neston and Parkgate (both Key Service Centres in the previous plan) have been elevated in importance within this version of the Plan.  It is also not clear if the Council will be adopting the approach of having individual policies for the other settlements listed in the policy, though Taylor Wimpey would support these settlements having their own specific place-based policies in order to set out the vision, core features, key issues and clear strategy for what development will take place. This should be justified within the spatial strategy and included within the next iteration of the emerging Local Plan.

Comment

Representation ID: 14242

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14786
Taylor Wimpey does not consider that any of Options A, B and C set out in Policy SS 5 represent appropriate spatial strategies in their own right, and an alternative approach should be considered. In particular, Option A which seeks to retain the Green Belt is not considered an appropriate strategy. It would be illogical to avoid locations in sustainable settlements solely to protect the Green Belt, particularly when national policy provides a clear framework for its release. Additionally, much of the northern part of the Borough is constrained by Green Belt. This includes the land around Chester, the Borough’s most sustainable settlement. Allowing Green Belt release in these sustainable locations ensures that new homes are positioned close to essential services and amenities. Avoiding Green Belt release would lead to an over-reliance on smaller settlements in the south of the Borough, which often lack the same level of infrastructure and sustainability credentials. While these settlements should accommodate a proportionate level of growth, directing the majority of development to them would not represent a sustainable spatial strategy. An alternative approach, which ensures the Council’s full identified need for housing can be met, and apportions growth to the most sustainable locations across the Borough, should be pursued. As set out previously in these  representations, there are significant recent changes in circumstance that would now justify the release of Green Belt within CWaC. Alongside the revised NPPF (December 2024) a new standard methodology [SM3] for calculating LHN was published. The introduction of SM3 has significantly increased the housing requirement in CWaC which is now 1,928 dpa. CWaC will therefore be required to identify land to accommodate at least 28,710 dwellings over a 15-year plan period in an emerging Local Plan. This is significantly higher than the current Local Plan housing requirement of 1,100 dwellings and is also considerably higher than the previous LHN of 532 dpa.  The new LHN is applied as a minimum requirement for plan-making purposes. It is expected that this increase will lead to a significant shortfall in developable housing land in the Borough. Given the scale of the housing shortfall across the Borough, it is clear that there will be insufficient brownfield land within urban areas to meet housing needs over the plan period. The Council must also adopt a sustainable approach to apportioning growth across the Borough to ensure it is not concentrated on only the largest few settlements. Therefore, there is a need for greenfield development on the edge of sustainable settlements and Green Belt release where required, to ensure economic, social and environmental objectives can be achieved across the whole Borough and housing needs can be met in full.  As set out in the NPPF (para. 145), Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation or updating of plans. Exceptional circumstances in this context include, but are not limited to, instances where an authority cannot meet its identified need for homes, and authorities should review Green Belt boundaries in accordance with the policies in the NPPF (para. 146). The Council will need to adopt a proactive approach to growth and must undertake a full Green Belt review in order to support this process. Policy SS 5 also cites the Examiner’s Report into the Local Plan (Part One) as potential justification for the retention of the Green Belt around Chester. Given the significant increase in housing need for the Borough and the wider aspirations of the Issues and Options proposals (achieving economic and social growth, with the City of Chester acting as the catalyst), the context against which the Examiner made their conclusions in 2014 has significantly and materially changed to the extent that these comments should not be considered in the formulation of Policy SS 5. The Inspector’s report was published in 2014 and considered the adopted Local Plan in a vastly different policy context, and against an objectively assessed need for housing well below the current LHN. The Inspector’s Report was prepared in the context of a previous iteration of the NPPF which has now been superseded, and the content and policies in the 2024 NPPF and updated PPG are materially different in relation to elements of Green Belt policies and the introduction of grey belt. It would therefore be inappropriate to draw out the conclusions from this report and apply this to the emerging Local Plan given the currently incomparable context. The Inspector’s Report (para. 95) states that “a key purpose of the Green Belt around Chester is to preserve the setting and special character of the historic city. Decisions will clearly need to be made regarding the longer term strategy for the scale of growth in the Borough and the role of Chester in meeting development needs beyond 2030 within this context”. Potential alterations to the Green Belt boundary must therefore be assessed against the current policy context including the revised NPPF and the specific guidance set out in the PPG in relation to grey belt and the assessment of land parcels against the relevant Green Belt purposes. There is no justification to use comments made in the Inspector’s Report on Green Belt release around Chester to guide decisions on an appropriate spatial strategy in a new Local Plan.

Comment

Representation ID: 14251

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14795
Taylor Wimpey considers that there should be a separate policy for Green Belt and countryside areas, and this should consolidate policy wording set out in CWaC Local Plan Part One and Part Two. Taylor Wimpey also consider that this policy should reflect the current policy approach required in relation to grey belt land, and should also include the approach taken to reflect Green Belt review evidence (to be prepared). The Council must ensure that it is informed by an overall application of the relevant policies in the NPPF, and follows the guidance set out in the PPG when reviewing Green Belt boundaries. The Council must also seek to identify grey belt land to inform this review and the prioritisation detailed in paragraphs 147 and 148 of the NPPF.

Comment

Representation ID: 14253

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14797
Taylor Wimpey supports the general principles set out in Policy TA 1 and agrees that new development should come forward in the most sustainable locations (particularly Tier 1 and 2 settlements) to accommodate a reduced reliance on cars and facilitate travel by sustainable modes of transport. Taylor Wimpey also supports the intention to seek opportunities to extend and improve access to local footpath and cycle networks, and new well designed development can help to achieve this. In relation to parking standards, Taylor Wimpey supports the flexible approach outlined in TA1 and the consideration of future connectivity needs. However, Taylor Wimpey requests that sufficient flexibility is maintained by avoiding the imposition of restrictive maximum parking standards across the Borough.

Comment

Representation ID: 14257

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14801
The suggested approach is to amend the Local Plan (Part One) policy STRAT 11 to ensure educational needs, including contributions to school transport provision will be required. The policy approach will clarify that where infrastructure is needed to sustain a new development, that off-site contributions may not be acceptable and that the Council will not be expected to fund any shortfall in provision. The NPPF (para. 35) is clear that local plans should set out the contributions expected from development and that such policies should not undermine the deliverability of the Plan. The Council will need to be able to demonstrate that the infrastructure needed to support new development in the Plan for is viable, which is essential for deliverability. It will also be important to ensure that any increase in viability pressures do not place too high a burden on developer contributions which may serve to undermine the deliverability of Local Plan policies. Taylor Wimpey considers that it is important for any potential financial contributions to be fully justified and based on a credible and robust evidence base, reasonable in terms of the relationship to the development, and not unduly restrictive so as to affect the viability and deliverability of the development. The financial contributions requested should meet the tests as set out in NPPF para. 57: • Necessary to make the development acceptable in planning terms; • Directly related to the development; and, • Fairly and reasonably related in scale and kind to the development. The policy should make direct reference to the above CIL tests and ensure that the policy is clear that any financial contributions required by the Council will be considered in this context. Development should only be required to mitigate its own impact and cannot be required to address existing deficiencies in infrastructure or services. It is therefore essential for an Infrastructure Development Plan (IDP) to clearly highlight existing deficiencies in the current infrastructure. It is also unclear whether the Council will be undertaking a review of the adopted CIL Charging Schedule and Regulation 123 list as part of the emerging Local Plan process, and Taylor Wimpey would welcome clarity on this matter.

Comment

Representation ID: 14262

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Asteer Planning

I&O_14806
Taylor Wimpey supports the Council’s intention to deliver an appropriate mix of housing to meet the needs of the wider community. However, it is essential that this policy is applied with flexibility to ensure that individual sites can respond to market conditions. Certain locations may be better suited to a housing mix that differs from the recommendations of the HNA particularly in a location such as Chester where the majority of the units coming forward in the urban area are likely to be smaller apartment type developments.  A rigid application of percentage-based requirements would not reflect the diverse local conditions across the Borough. Taylor Wimpey expects the Council to ensure that the policy is applied flexibly and makes allowances to provide alternative housing mixes as is required by the market. If specific percentage targets are pursued, Taylor Wimpey recommends that these are expressed as ranges, with additional wording included to allow for flexible interpretation where justified. Furthermore, viability testing of the proposed housing mix policy will be necessary as part of the emerging Local Plan particularly given the high CIL charge in Cheshire West and Chester. This testing should be completed in advance of the Regulation 19 version of the Plan to ensure that the policy is deliverable and does not undermine the viability of development.