Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9957

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10454
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation documents sets out the following list of additional evidence that is needed to support the new Plan: • Retail and Town Centres Study (in preparation) • Strategic Flood Risk Assessment (in preparation) • Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) • Housing Needs Assessment (to be prepared) • Green Belt Study (to be prepared) • Infrastructure Delivery Plan (to be prepared) • Strategic Viability Assessment (to be prepared) • Transport Assessment (to be prepared) • Land Availability Assessment (in preparation). It is considered that the above list of additional evidence is sufficient to inform the policies of the New Local Plan. Savills is supportive of the production of a new Housing Needs Assessment, Land Availability assessment and Green Belt Study which will inform the policies that relate to housing delivery in the New Plan. It is considered that no further evidence documents are required beyond those already produced or currently being prepared to support the New Local Plan.

Comment

Representation ID: 9958

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10455
In response to question IN3, national policy requires that new Local Plans should set policies for 15 years following adoption, as a minimum. It is considered that the New Local Plan period for CW&C should cover a minimum of 20 years, due to the scale of strategic development that is required to meet the current and future needs of the borough and to reflect the ambitious housing delivery targets set by Government. A plan period of 20 years would ensure that the Local Plan is able to set the strategic policies to meet the current and future needs of the borough. As such it is proposed that the Local Plan period should be 2025 – 2045.

Comment

Representation ID: 9959

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10456
CW&C is a large and diverse borough with distinct towns and settlements that each have specific development needs. As such, the Council’s approach is supported which will establish concise visions for the key settlements, in addition to an overarching vision for the whole District. Local visions for each of the larger settlements (Chester, Ellesmere Port, Northwich, Winsford, Frodsham, Neston and Parkgate) will help to ensure that the specific development objectives of each settlement can be met through the Local Plan policies, which will in turn inform development proposals. It is not considered that local visions for settlements of the scale of Kelsall are required, particularly as there is an option for a neighbourhood plan to be prepared that can set the vision for that scale.

Comment

Representation ID: 9961

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10458
The Issues and Options draft sets out that the Council’s policy approach is to deliver a minimum of 1,914 new homes each year over the Plan period, which would equate to 28,710 new homes in total. Savills notes that the most recent local housing need figure for CW&C is actually 1,928 dpa, which brings the overall 15 year total to 28,920 homes. While this is owing to the incorporation of the latest affordability ratios. In response to question SS1, the new Local Plan should support the delivery of 1,928 homes per year as a minimum . The requirement for the new Local Plan to meet the standard method figure is clearly established in the NPPF and is the necessary approach that must be taken to ensure that the Plan is consistent with national policy. Emphasis is placed on the fact that the national policy requirement is for Local Plans to adopt the standard method figure as a minimum. Savills recommends that the Council should take an ambitious approach and aim to exceed the minimum housing delivery indicated by the standard method, in order to support sustainable growth. National policy provides that in some cases; authorities will be able to justify a lower housing requirement than the standard method on the basis of local constraints on land and delivery (for example where statutory designations such as National Parks are present). Such circumstances do not exist in CW&C that would justify a reduced housing requirement. For example, there are no statutory National Parks in the borough.

Comment

Representation ID: 9963

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10460
The NPPF is clear that authorities are required to set strategic policies to meet their housing need in full across the plan period. To support the Government’s objective to significantly boost the supply of homes, it is important that ‘a sufficient amount and variety of land can come forward where it is needed’. Paragraph 70(b) of the NPPF states that to ensure land is allocated for housing in a way that boosts the supply of homes, plans should allocate ‘a range of sites by size, type and location to meet the housing requirements of different groups in the community’. A stepped housing requirement with reduced delivery in the early parts of the Plan period would, in effect, allow the Council to defer its full housing delivery to later phases of the Plan period. In areas where there are existing acute housing shortages, such as Kelsall, this would prolong existing issues surrounding affordability and access to housing. A stepped requirement would also ignore the opportunities for development sites that are immediately deliverable at the initial phases of the Plan period. Reduced targets in the early stages of the Plan period would risk slowing momentum, which conflicts with national housing objectives of boosting housing growth. As such, it is considered that the housing requirement should be clear and consistent throughout the Plan period, which would encourage market confidence and have a positive impact on overall housing delivery. Finally, the adoption of a stepped requirement would mean that the New Local Plan would have a more limited contribution to the Government’s stated aim of delivering 1.5 million homes during the current Parliament. For these reasons, the New Local Plan should not utilise a stepped requirement.

Comment

Representation ID: 9964

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10461
The Issues and Options consultation document sets out that the spatial strategy will follow the principle of directing new development and allocating land towards previously developed (‘brownfield’) sites within settlements first. It is acknowledged that previously developed sites within settlements are often sustainable locations to support new development, therefore consideration should be given to the allocation of reasonable previously developed sites. However, it should be noted that not all brownfield land can be considered deliverable or reasonable alternatives to undeveloped sites. A detailed consideration of the deliverability and availability of each brownfield opportunity will be required to inform the urban capacity of the Distrct. The spatial strategy principles state that where there are not enough opportunities for redevelopment within urban areas and towns, the approach will be to direct development to the edge of existing settlements in locations with the best access to public transport, services and infrastructure, as the next best sustainable option. The document also states that depending on the settlement, this may require the release of land that is currently designated as Green Belt. The principles of the spatial strategy as set out in the consultation document are broadly supported. It is a fundamental purpose of the Local Plan to ensure that the development needs of the District are met and that development is directed to the most appropriate and sustainable locations. While a brownfield-first approach is supported and is consistent with national policy, the scale of development that is required in CW&C (i.e. at least 1,928 new homes per year), and the relative lack of appropriate previously developed sites, means it will be essential for development to be directed to other sites in sustainable locations on the edge of existing settlements. This will necessitate the release of land from the Green Belt. It follows that the Council will need to provide evidence to demonstrate that exceptional circumstances exist to amend Green Belt boundaries. The NPPF states that such exceptional circumstances can include where an authority cannot meet its identified need for homes through reasonable non-Green Belt alternatives.

Comment

Representation ID: 9965

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10462
The Issues and Options document proposes that the New Local Plan will set out a settlement hierarchy based on the status and role of each settlement. The proposed settlement hierarchy is as follows: • City – Chester • Main Towns – Ellesmere Port, Northwich, Winsford • Market Towns – Neston and Parkgate, Frodsham • Other Settlements – Including Kelsall Chester is the only City within the borough and therefore performs a principal function and should be placed at the top of the settlement hierarchy. The consultation document states that other settlements, including; Cuddington and Sandiway; Farndon; Helsby; Kelsall; Malpas; Tarporley; Tarvin and Tattenhall have a level of facilities and services that means they can meet the day-to-day needs of their residents and those in surrounding areas. It is acknowledged in the Issues and Options draft that smaller settlements, including those listed above, could ‘acceptably accommodate infill development and small previously developed sites to meet local needs. In ‘smaller settlements’, such as Kelsall, the draft document sets out that development should be appropriate in scale and design to conserve that settlements’ character and setting and should not exceed the capacity of existing services and infrastructure unless the required improvements can be made. To address the acute needs for housing in CW&C (namely 1,928 new homes per year), smaller settlements have an important role to play in making contributions to housing delivery. There are sites in CW&C that can make a significant contribution to meeting local housing needs that are located within smaller settlements on the edge of the existing settlement. Land at Chester Road, Kelsall is considered to be one such site. It is acknowledged that residential development in smaller settlements must be appropriate in scale and design, while ensuring the most efficient use of land in order to deliver a range of housing across the District. It is also noted that residential development in settlements can deliver a variety of local benefits, such as infrastructure provision, biodiversity net gain and ecological enhancements, and enhanced local services. Wording in terms of the spatial strategy should make it clear that some settlements, such as Kelsall, will also be able to accommodate suitable allocations for residential and employment growth. This is in accordance with the options maps at Appendix 1 of the Consultation Draft where all of the options shown state that Kelsall will accommodate circa 500 new homes. It would be appropriate for sustainable settlements of the scale of Kelsall to have their own tier in the settlement hierarchy in order to differentiate them from other settlements that are less suited for residential development. This level would be similar to the Key Service Centres category of the extent Local Plan.

Comment

Representation ID: 9966

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10463
In response to question SS6 above, all settlements should receive a level of development since it is essential that the New Local Plan includes policies that enable the delivery of a variety of homes in various location throughout the District. Smaller settlements, such as Kelsall, are not identified in the proposed settlement hierarchy, however this should not preclude the opportunity in Kelsall to make a contribution to the overall local housing delivery and provide a choice of homes for local communities. The New Local Plan should plan for a mix of homes in different locations and the amount of housing apportioned should be broadly proportionate to the existing and future capacity of infrastructure and services in local towns and settlements. Kelsall, for example, is a settlement that has a level of services, facilities, and public transport links that could comfortably accommodate a suitable level of growth. 

Comment

Representation ID: 9968

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10465
The New Local Plan should embrace and take advantage of opportunities to deliver much-needed homes in smaller settlements. However, this does not require specific place based policies for each settlement. Rather, the apportionment of homes to these areas could be set by the general spatial strategy policy. This level of the settlement hierarchy, it is considered that compliance with general development management policies that will require the design of schemes are in keeping with the townscape and landscape character of the surroundings. In the case of Kelsall, detailed information set out by the Supplementary Planning Document: Kelsall Parish Landscape and Design Statement and successor documents provides settlement specific guidance.

Comment

Representation ID: 9971

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10468
The principle of protecting the prevailing character of smaller settlements through the New Local Plan is supported, however it is important that the Plan takes into account the significant opportunities for development in smaller settlements that can enhance the existing provision of services and infrastructure, such as healthcare and connectivity. Residential development brings a substantial opportunity to expand the capacity of existing services and infrastructure, so the New Local Plan should enable and promote sustainable growth in settlements where new housing can contribute to improvements to infrastructure.