Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9401

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_9896
The consultation identifies a minimum housing need of 1,914 dwellings per annum, derived from the Government’s Standard Method for assessing local housing need. While the Standard Method provides a consistent baseline across England, the Planning Practice Guidance (PPG) makes clear that this figure should be treated as the starting point, not the final requirement. Local planning authorities are expected to consider whether the baseline should be increased to take account of economic growth aspirations, market signals, affordability pressures, and unmet needs arising from neighbouring authorities. In the case of Cheshire West and Chester, there are compelling reasons to plan for a housing requirement above the Standard Method baseline. Affordability ratios in the borough remain high, particularly in rural and semi-rural areas, where younger households face increasing barriers to home ownership. Delivering a higher level of housing growth would help to address these affordability challenges by boosting supply and increasing the range and mix of homes available. The Council also has ambitious economic growth objectives linked to strategic infrastructure projects, including investment in Chester, Ellesmere Port, and the Cheshire Science Corridor. These initiatives will attract and retain a skilled workforce, but only if sufficient housing is provided in the right locations. Planning to meet only the minimum baseline risks constraining the borough’s economic potential. Furthermore, the Council should recognise the importance of housing delivery trajectories when setting its requirement. A plan that is too heavily dependent on large, complex sites will struggle to maintain a rolling five-year supply, creating exposure to speculative development. To safeguard against this risk, the housing requirement should be set at a level that allows a broad mix of sites — including small and medium-sized allocations in rural settlements such as No Mans Heath — to come forward alongside the larger strategic sites. This diversified approach will not only support delivery but will also strengthen the Council’s ability to demonstrate a sound plan at examination.

Comment

Representation ID: 9888

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_10385
GROWTH OPTIONS Three broad options have been presented by CW&C within this regulation 18 consultation. While these scenarios explore different distributions of growth, they share a common emphasis on directing the majority of development to the main towns and service centres. Whilst this proposal evidently comes with it’s advantages, it is essential that the plan also recognises the role of smaller settlements in contributing to housing delivery. Over-reliance on large strategic sites or heavily constrained urban areas risks undermining the Council’s ability to maintain a deliverable five-year housing land supply, which is a key test of soundness under national policy. Each of the three potential spatial distribution strategies have been tested through the Sustainability Appraisal process and provides a useful starting point for debate. However, it is important that the Council maintains flexibility and does not commit too rigidly to any single option at this early stage. A hybrid strategy, which combines the benefits of each option while addressing their respective shortcomings, will be required to ensure the new Local Plan is positively prepared, justified, effective, and consistent with national policy. Option A: Protecting the Green Belt This option seeks to minimise Green Belt release by directing the majority of new housing and employment growth to settlements outside the Green Belt, notably Winsford, Northwich, and other non-Green-Belt towns. It also places greater emphasis on expansion within Rural Service Centres. While this approach is consistent with national policy in terms of safeguarding Green Belt land, it creates significant risks. It places undue pressure on a limited number of urban locations, many of which are already contending with regeneration challenges and infrastructure constraints. Relying too heavily on brownfield and regeneration sites can create uncertainty around delivery rates, especially where land assembly, remediation, or market demand issues are complex. From a Tesni perspective, Option A does not provide the necessary flexibility or diversity of supply to maintain a robust five-year housing land supply across the plan period. Option B: Continuation of the Current Approach Option B broadly reflects the adopted spatial strategy, distributing growth across Chester, Ellesmere Port, Winsford, Northwich, and the network of Key Service Centres. Under this scenario, around 11,000 homes would be delivered through Green Belt release. This approach offers a more balanced distribution of growth compared to Option A, aligning new homes with employment opportunities and existing transport networks. It also reduces over-reliance on regeneration sites, recognising the contribution that strategic Green Belt releases can make to overall supply. However, the risk with Option B is that too much emphasis is placed on large strategic sites, which typically require long lead-in times, substantial infrastructure investment, and complex phasing arrangements. This can undermine delivery in the early years of the plan period. To make this option effective, it should be complemented by smaller-scale allocations in a wider range of settlements, ensuring that housing can come forward quickly and steadily throughout the borough. Option C: Transport Corridor Growth This option seeks to concentrate development along established and emerging sustainable transport corridors, particularly rail and bus routes. More than 12,000 homes would be delivered through Green Belt release to support this option. In principle, aligning growth with public transport infrastructure is consistent with the objectives of the National Planning Policy Framework and reflects broader sustainability goals, including reducing car dependency and promoting compact development. However, the deliverability of this option is contingent on significant transport investment being secured and delivered in a timely manner. If these improvements are delayed or scaled back, the housing trajectory could falter. Furthermore, focusing growth so narrowly along transport corridors risks neglecting the role of smaller settlements which, although not served by high-frequency public transport, are still sustainable and capable of delivering early housing supply Individually, each of the three options has clear limitations. A more robust and effective approach would combine their positive elements: focusing significant growth on the main towns and transport corridors, while also distributing a proportion of development to smaller rural settlements. This hybrid strategy would diversify the land supply, support delivery in the early years of the plan period and provide resilience against the risks of over-reliance on a small number of large sites.

Comment

Representation ID: 11219

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_11717
Settlements such as No Mans Heath have an important role to play in the delivery of housing across Cheshire West and Chester. While modest in scale, the village benefits from strategic road connections via the A41 and A49, access to local services including a shop and public house, and proximity to a primary school and higher-order facilities in Malpas and Whitchurch. These factors make No Mans Heath more sustainable than its size might suggest and capable of accommodating modest growth in the short term. Allocating small to medium-sized sites in No Mans Heath would support the vitality of local services, broaden housing choice for families and older households seeking village living, and provide early deliverable housing to contribute to the borough’s overall trajectory. Such growth could come forward quickly, often requiring minimal infrastructure, and can be sensitively masterplanned to respect the settlement’s rural character. More broadly, smaller rural settlements can complement growth in larger towns by providing a steady, achievable supply of housing. Incorporating proportionate development across these villages increases resilience, flexibility, and certainty in delivery, helping the Council to maintain a rolling five-year housing land supply and meet the tests of soundness. In preparing the new Local Plan, the Council should adopt a balanced approach that combines urban expansion with sustainable growth in smaller settlements. No Mans Heath is a clear example of where proportionate growth would be both appropriate and beneficial. A strategy that embraces both larger and smaller settlements will ensure that housing needs are met in full, support the vitality of local communities, and produce a plan that is positively prepared, justified, effective, and consistent with the National Planning Policy Framework.

Comment

Representation ID: 11287

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_11785
Policy Approach to Local Service Centres [See attached] Tesni considers that the absence of defined housing requirements for each Local Service Centre has undermined the sustainability of smaller settlements. We disagree that such settlements have only a limited level of sustainability and maintain that new development is critical to supporting and retaining existing community services. The four-year gap between adoption of the Part One and Part Two Plans meant that the 4,200-dwelling requirement for the rural area was largely met before the matter could be addressed comprehensively through plan-making. By the time the Part Two Plan was prepared—almost a decade into the plan period—there was no longer a requirement to direct development to Local Service Centres, contrary to the intentions of Policies STRAT 2 and STRAT 8. As a result, the level of development in Local Service Centres has not been considered strategically. Tesni believes that any Local Plan Review must properly assess the role and needs of Local Service Centres and examine the effect of minimal or no growth on the viability of local services. Since the start of the plan period, more than thirty pubs have closed within the CW&C area—losses that might have been mitigated through the benefits of new development. The impact of the pandemic has further accelerated such decline. Without sustainable growth, smaller settlements that are otherwise viable places to live will continue to lose essential services.

Comment

Representation ID: 16034

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16615
The consultation identifies a minimum housing need of 1,914 dwellings per annum, derived from the Government’s Standard Method for assessing local housing need. While the Standard Method provides a consistent baseline across England, the Planning Practice Guidance (PPG) makes clear that this figure should be treated as the starting point, not the final requirement. Local planning authorities are expected to consider whether the baseline should be increased to take account of economic growth aspirations, market signals, affordability pressures, and unmet needs arising from neighbouring authorities. In the case of Cheshire West and Chester, there are compelling reasons to plan for a housing requirement above the Standard Method baseline. Affordability ratios in the borough remain high, particularly in rural and semi-rural areas, where younger households face increasing barriers to home ownership. Delivering a higher level of housing growth would help to address these affordability challenges by boosting supply and increasing the range and mix of homes available. The Council also has ambitious economic growth objectives linked to strategic infrastructure projects, including investment in Chester, Ellesmere Port, and the Cheshire Science Corridor. These initiatives will attract and retain a skilled workforce, but only if sufficient housing is provided in the right locations. Planning to meet only the minimum baseline risks constraining the borough’s economic potential. Furthermore, the Council should recognise the importance of housing delivery trajectories when setting its requirement. A plan that is too heavily dependent on large, complex sites will struggle to maintain a rolling five-year supply, creating exposure to speculative development. To safeguard against this risk, the housing requirement should be set at a level that allows a broad mix of sites — including small and medium-sized allocations in rural settlements such as No Mans Heath — to come forward alongside the larger strategic sites. This diversified approach will not only support delivery but will also strengthen the Council’s ability to demonstrate a sound plan at examination.


Email from samuel.leuty.milner@wind2.co.uk

Comment

Representation ID: 16035

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16616
Growth Options Three broad options have been presented by CW&C within this regulation 18 consultation. While these scenarios explore different distributions of growth, they share a common emphasis on directing the majority of development to the main towns and service centres. Whilst this proposal evidently comes with it’s advantages, it is essential that the plan also recognises the role of smaller settlements in contributing to housing delivery. Over-reliance on large strategic sites or heavily constrained urban areas risks undermining the Council’s ability to maintain a deliverable five-year housing land supply, which is a key test of soundness under national policy. Each of the three potential spatial distribution strategies have been tested through the Sustainability Appraisal process and provides a useful starting point for debate. However, it is important that the Council maintains flexibility and does not commit too rigidly to any single option at this early stage. A hybrid strategy, which combines the benefits of each option while addressing their respective shortcomings, will be required to ensure the new Local Plan is positively prepared, justified, effective, and consistent with national policy. Option A: Protecting the Green Belt This option seeks to minimise Green Belt release by directing the majority of new housing and employment growth to settlements outside the Green Belt, notably Winsford, Northwich, and other non-Green-Belt towns. It also places greater emphasis on expansion within Rural Service Centres. While this approach is consistent with national policy in terms of safeguarding Green Belt land, it creates significant risks. It places undue pressure on a limited number of urban locations, many of which are already contending with regeneration challenges and infrastructure constraints. Relying too heavily on brownfield and regeneration sites can create uncertainty around delivery rates, especially where land assembly, remediation, or market demand issues are complex. From a Tesni perspective, Option A does not provide the necessary flexibility or diversity of supply to maintain a robust five-year housing land supply across the plan period. Option B: Continuation of the Current Approach Option B broadly reflects the adopted spatial strategy, distributing growth across Chester, Ellesmere Port, Winsford, Northwich, and the network of Key Service Centres. Under this scenario, around 11,000 homes would be delivered through Green Belt release. This approach offers a more balanced distribution of growth compared to Option A, aligning new homes with employment opportunities and existing transport networks. It also reduces over-reliance on regeneration sites, recognising the contribution that strategic Green Belt releases can make to overall supply. However, the risk with Option B is that too much emphasis is placed on large strategic sites, which typically require long lead-in times, substantial infrastructure investment, and complex phasing arrangements. This can undermine delivery in the early years of the plan period. To make this option effective, it should be complemented by smaller-scale allocations in a wider range of settlements, ensuring that housing can come forward quickly and steadily throughout the borough. Option C: Transport Corridor Growth This option seeks to concentrate development along established and emerging sustainable transport corridors, particularly rail and bus routes. More than 12,000 homes would be delivered through Green Belt release to support this option. In principle, aligning growth with public transport infrastructure is consistent with the objectives of the National Planning Policy Framework and reflects broader sustainability goals, including reducing car dependency and promoting compact development. However, the deliverability of this option is contingent on significant transport investment being secured and delivered in a timely manner. If these improvements are delayed or scaled back, the housing trajectory could falter. Furthermore, focusing growth so narrowly along transport corridors risks neglecting the role of smaller settlements which, although not served by high-frequency public transport, are still sustainable and capable of delivering early housing supply Individually, each of the three spatial options identified in the Regulation 18 consultation has clear limitations. A more effective and deliverable strategy would combine their positive elements: focusing growth towards the main towns and sustainable transport corridors, while also enabling proportionate expansion at smaller, well-connected settlements. This hybrid approach would diversify the land supply, provide greater resilience against delivery risks, and ensure flexibility across the plan period.


Email from samuel.leuty.milner@wind2.co.uk

Comment

Representation ID: 16036

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16617
The proposed allocation east of Davenham (NOR06) is well placed to contribute to such a strategy. The site represents a logical and defensible extension to the existing settlement, adjoining established residential areas and benefitting from excellent accessibility to the A556 corridor, nearby public transport routes, and wider strategic connections. Davenham also has access to a range of local services including shops, schools, and community facilities, with Northwich town centre providing higher-order services less than two miles away. Allocating NOR06 would deliver a scale of development that is proportionate to the settlement and capable of supporting local services, improving housing choice, and strengthening sustainable transport connectivity. The site can come forward early in the plan period, supported by deliverable infrastructure and a clear trajectory. Importantly, development can be sensitively designed to respect the village’s character and integrate high-quality green infrastructure, ensuring that growth enhances rather than detracts from local distinctiveness. From a strategic perspective, the allocation of NOR06 complements larger urban extensions by providing a steady, deliverable supply of homes in a location with strong sustainability credentials. Its inclusion reduces reliance on a small number of major sites, enhances flexibility, and strengthens the Council’s ability to demonstrate a rolling five-year housing land supply. It also supports the delivery of infrastructure-led growth in line with national policy, with phased development ensuring that impacts on local services and highways can be managed effectively. In preparing the new Local Plan, the Council should adopt a balanced hybrid strategy that combines significant growth in larger towns and along transport corridors with proportionate development in sustainable settlements such as Davenham. The NOR06 site provides a clear opportunity to deliver this vision, supporting housing needs in full, boosting local services, and contributing towards a plan that is positively prepared, justified, effective, and consistent with the National Planning Policy Framework.


Email from samuel.leuty.milner@wind2.co.uk

Comment

Representation ID: 16037

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16618
Davenham comprises a large village of approximately 3,000 people and is located to the south of the larger settlement of Northwich. Davenham includes a central core which provides a full range of facilities including shops, petrol station, post office, takeaways, restaurants and pubs. The village also includes sports clubs, a primary school and places of worship. There are also several bus routes which provide regular services to Northwich, Winsford, Sandbach and Crewe. The town of Northwich is located on the opposite side of the A556 and provides an even greater range of facilities including access to rail services to major cities. POLICY APPROACH TO NORTHWHICH AND DAVENHAM Policy STRAT 5 of the Local Plan Part One identifies, for the purposes of plan-making, that Davenham is defined as comprising part of the town of Northwich, along with Anderton, Barnton, Hartford, Lostock Gralam, Lower Marston, Lower Wincham, Rudheath and Weaverham. Policy STRAT 2 confirms that Northwich comprises one of the four major settlements in the Borough where the majority of new development will be directed. Policy STRAT 5 identifies that Northwich will provide a key focus for development in the east of the borough and will provide at least 4,300 new dwellings within the plan period up to 2030. Policy STRAT 5 also confirms that the North Cheshire Green Belt runs along the northern edge of Northwich and that this is to be maintained. It is also identified that the character and individuality of the settlements that form the wider built-up area of Northwich is to be safeguarded. Tesni acknowledges that Davenham is inextricably linked to the town of Northwich, and if the Local Plan is to be reviewed, they would support the continued inclusion of the outer lying settlements within the context of ‘Wider Northwich’. Tesni would also support the continued focus of development around Northwich, and its identification as one of the four principal settlements in the Borough.


Email from samuel.leuty.milner@wind2.co.uk

Comment

Representation ID: 16038

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16619
CONSTRAINTS AROUND NORTHWICH It is evident from studying the adopted Policies Map that there are significant constraints present around Northwich and the surrounding villages. These have been indicated on the appended Constraints Plan and are summarised below. As noted within Policy STRAT 5, the North Cheshire Green Belt is located to the north of the settlement and is tightly wrapped around the boundary of Northwich and several neighbouring villages including Weaverham, Hartford, Maston and Lostock Gralam. At present, Exceptional Circumstances have not been demonstrated to realign the Green Belt and Tesni would therefore support maintaining the Green Belt boundary in this location. This is particularly the case given that there are likely to be sustainable locations for new development outside of the Green Belt to the south of Northwich. There are also environmental constraints to development in this location. These include the presence of the River Weaver and the River Dane which meet in the centre of Northwich. To the south of the settlement, the two rivers flow within relatively steep sided valleys which present constraints in regard to flooding and landscape impact. Policy GBC 3 of the Local Plan Part Two identifies several Key Strategic Gaps in this location, several of which acknowledge the importance of the keeping villages separate, as well as the presence of the Dane Valley. Davenham is particularly impacted by these settlement gaps, with three identified to the north, northeast and west of the village. The aim of this policy is to safeguard the character and individuality of the settlements that form the wider built up area of Northwich. Policy DM 32 and paragraph 13.36 highlights the issue of instability of land across mid-Cheshire, particularly around Northwich and Marston. This is largely due to historic rock salt mining and brine extraction and means that areas may be at risk of subsidence. Tesni are of the view that this matter should a major consideration in the identification of sites around Northwich. It is also the case that there are large areas of contaminated land, some of which are currently in use, on the outskirts of Northwich. Tesni is of the view that the viability of delivering for housing should be investigated thoroughly prior to identifying housing allocations in these areas. LAND EAST OF LONDON ROAD, DAVENHAM This section outlines the land within our client’s control and confirms that the site represents a sustainable and suitable location for residential development. The site was previously considered within the HELAA (2017) and assessed as suitable, available, and achievable.  [See attached].


Email from samuel.leuty.milner@wind2.co.uk

Comment

Representation ID: 16039

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16620
The Part Two Plan emphasises the role of Neighbourhood Plans in identifying sites for development. However, the Neighbourhood Plan for No Mans Heath was adopted in June 2018, over a year before the Part Two Plan was finalised. As such, it contains only limited reference to the settlement’s designation as a Local Service Centre. While Tesni supports the principle of identifying development sites through neighbourhood planning, we consider that the overall need for development within Local Service Centres must be addressed strategically. In accordance with the NPPF. Any review of the Neighbourhood Plan should therefore take full account of strategic policies, ensuring that local needs are addressed through the allocation of sites supported by the community. At the time of preparing the Local Plan Part Two, CW&C undertook a settlement review. Tesni considers this assessment overly simplistic, as it failed to account for the presence of facilities in the wider hinterland. For example, primary schools located within 2km of No Mans Heath were not factored into the analysis. The latest SHMA identifies a significant borough-wide need for affordable housing. Allowing a greater scale of development within Local Service Centres would help meet this need by delivering both affordable and market housing in locations attractive to developers. Small schemes of fewer than ten homes cannot contribute meaningfully to this requirement. Tesni therefore considers this a key factor when establishing development parameters for Local Service Centres. Of the 28 Local Service Centres identified under Policy R1, 18 are affected by Green Belt designation. Tesni supports the prioritisation of settlements in open countryside over those constrained by Green Belt, as such land is both sustainable and deliverable, and capable of contributing to a coherent development strategy. Until new evidence demonstrates exceptional circumstances, the case for Green Belt release has not been made.