Comment

Representation ID: 96

Received: 11/08/2025

Respondent: Neil Cockburn

Sustainable development
I&O_118
For fairer distribution of potential housing development across the borough, green belt land should also be included as target areas for development, especially if that land neighbours a site of industry or commerce where future residents could walk, cycle or take public transport to their potential employment.

Comment

Representation ID: 123

Received: 14/07/2025

Respondent: Mike Mather

I&O_145
A massive NO. Local government has no control over the climate emergency and if we in Cheshire West cut our carbon emissions to zero today, we would not be able to measure any benefit but would be so much poorer for it. Stop the virtue signalling and deal with the issues that you actually can control. Climate change is a global issue not a local one and needs managing at a global level. There's no place for it in this plan.

Comment

Representation ID: 303

Received: 21/07/2025

Respondent: Tim Ashcroft

I&O_334
The policy is fine and a great aspiration. The catch is that it needs people to 'want' to make the changes needed and this must be built in.

Comment

Representation ID: 329

Received: 22/07/2025

Respondent: Chester Archaeological Society

SD 1
I&O_360
Question SD 1 Sustainable development We support the approach set out in SD1.

Comment

Representation ID: 397

Received: 26/07/2025

Respondent: Ms Linda Smith

I&O_472
Yes I agree

Comment

Representation ID: 492

Received: 28/07/2025

Respondent: Historic England

I&O_575
Reference to the historic environment is supported. Heritage asset and settings should also be included.

Comment

Representation ID: 637

Received: 30/07/2025

Respondent: Marc Vannerem

I&O_720
The sustainable development objectives are laudable. However, it is quite artificial to believe that Cheshire West & Chester (CW&C) should redouble its efforts relative to other councils in this area on the basis that CO2 generation is higher than the national average.  CW&C includes a significant amount of heavy industry, which is required nationally for the production of key products.  If they are not produced in CW&C, they will be imported from elsewhere in the UK or internationally, which will have the same impact on the environment.  They will simply not be included in CW&C's CO2 count, but will bne emitted all the same. 

Comment

Representation ID: 673

Received: 01/08/2025

Respondent: Laura Hughes

I&O_759
Generally yes - but not much about ensuring it is appropriately located in a sustainable location and key services can be accessed via public transport/active travel 

Comment

Representation ID: 972

Received: 05/08/2025

Respondent: Julie Smith

I&O_1076
Agree if it's followed

Comment

Representation ID: 1259

Received: 02/08/2025

Respondent: Dr & Mrs JF & GM Higgs

I&O_1364
yes, ensure where development occurs there is tree planting, existing tree are retained and hedges are maintained in a manner beneficial to wildlife and there is central renewable energy supply. Wild life corridors are incorporated into plans before approval.

Comment

Representation ID: 1612

Received: 12/08/2025

Respondent: Roberta Pomponio

I&O_1722
Partially agree. The overall framework is strong, particularly the emphasis on climate change mitigation, renewable energy, active travel, and green/blue infrastructure. However, the policy risks being undermined if the quality of buildings and public spaces is not made explicit and enforceable. Quality over quantity – The plan should explicitly require new buildings to meet high standards of architectural and construction quality, prioritising long-term durability, adaptability, and low maintenance. Speculative, high-density builds focused purely on maximum unit numbers can compromise liveability, sustainability, and social cohesion. Clear design codes and independent quality reviews should be mandatory. Healthier Place-Making – The policy should embed principles from evidence-based approaches such as the TCPA’s “20-minute neighbourhood” or Public Health England’s Healthy Places Framework, ensuring walkability, social interaction, mental wellbeing, and access to everyday amenities are designed in from the outset. Accessible green space – While “multifunctional green and blue infrastructure” is mentioned, the policy should commit to measurable standards: for example, every home within a 5-minute walk of safe, high-quality, inclusive green space. These spaces should be co-designed with the community to meet diverse needs and enhance biodiversity. Safety and inclusivity – Safety for women, girls, and underrepresented groups should be a stated design requirement. Developments must adopt Crime Prevention Through Environmental Design (CPTED) principles, including lighting, sightlines, active frontages, and overlooked public areas, ensuring people feel safe at all times. Recommendation: Strengthen SD 1 by explicitly linking climate resilience and environmental sustainability to human-centred, high-quality placemaking that promotes wellbeing, equity, and safety.

Comment

Representation ID: 1772

Received: 13/08/2025

Respondent: Michael Byrne

I&O_1882
Broadly, yes.  But, I think you can go further for large developments.  For example, cycle parking outside every public building.  On street car charging where this is not provided at EVERY dwelling, i.e. if there are social housing flats, there should be on street charging sufficient for every home to be able to charge their vehicle irrespective of whether they have parking or not.

Comment

Representation ID: 1878

Received: 14/08/2025

Respondent: Ashton Hayes Parish Council

I&O_1990
yes

Comment

Representation ID: 1978

Received: 12/08/2025

Respondent: Home Builders Federation

I&O_2094
The HBF continues to recognise the need to move towards greater energy efficiency and carbon reduction via a nationally consistent set of standards and timetable, which is universally understood and technically implementable. This is in line with the Written Ministerial Statement of December 2023 (WMS) [1] , which states that the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned building regulations. The WMS clearly states that any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures: that development remains viable, and the impact on housing supply and affordability is considered in accordance with the NPPF; and the additional requirement is expressed as a percentage uplift of a dwellings Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). National planning policy is silent on the issue of embodied carbon standards as are building regulations. The HBF would therefore question why the Council consider that this policy is necessary. The HBF considers it is best that such matters are addressed at a national level to avoid different approaches and standards being set in different areas. The housebuilding industry is working with the Future Homes Hub to develop a roadmap to reducing embodied carbon and whilst Councils may want to go further and faster the HBF have concerns that this will impact on the deliverability of development with a disproportionate impact on SME developers. Given that the Government has been clear that it does not want to see a proliferation of different standards across the country, the HBF would suggest that the approach being taken by the Council in setting such a standard is not consistent with the approach advocated in the WMS [2] . The HBF is also concerned that planning may be too early in the building process to fully assess the carbon impact of a design. It may be that further decisions are made post planning, which do not require further consent which would impact on the carbon emissions. The HBF considers that if the Council is to introduce a policy in relation to embodied carbon it will have to closely consider how it will be monitored and what the implications are for the preparation of any assessment, particularly in relation to how easily accessible any data is. The Council will also have to consider how the policy will interact with other policies, for example, in relation to design, energy efficiency or resilience to heat, as well as the viability and delivery of development. AECOM, on behalf of MHCLG, has completed a research report on the practical, technical and economic impacts of measuring and reducing embodied carbon in new buildings [3] . This report highlights issues with the lack consistency in reporting on carbon assessment outputs, the quality of carbon assessments, large gaps in the availability of both product specific EPDs and generic data, the variation in product carbon results for similar building products, and lack of consistency across carbon tools. The report also highlights issues with the uptake of lower embodied carbon materials and products due to costs, risks and insurance, the need to upskill the industry and access to carbon tools. Whilst this report makes recommendations as to how all of the challenges they identify can be addressed, they have not been addressed yet and are not likely to be ad-dressed in the short term. The HBF is concerned that as such, there are significant challenges with introducing a policy in relation to embodied carbon, for many of the reasons identified in this research. Without consistent data and information, it will be almost impossible for applicants to provide decision makers with reliable information on which to base a decision. The HBF does not consider that it is a reasonable requirement for development to maximise opportunities to generate energy from renewable sources. The HBF recognises that there may be potential for energy to come from renewables, however, it may not always be the most sustainable, efficient or effective approach. [1] WMS December 2023 https://questions-statements.parliament.uk/written-statements/detail/2023-12-13/hcws123 [2] https://questions-statements.parliament.uk/written-statements/detail/2023-12-13/hcws123 [3] https://assets.publishing.service.gov.uk/media/6823078e53add7d476d8194c/The_Practical__Technical_and_Economic_Impacts_of_Measuring_and_Reducing_Embodied_Carbon_in_New_Buildings.pdf

Comment

Representation ID: 2055

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2175
Whilst MCI absolutely agrees that there is a need to tackle climate change and action should be taken locally by the Council, their view is that this action should be restricted to issues associated with the location of development, ensuring that growth is located close to services and facilities or where there are high levels of access to public transport and active travel options which allow residents to pursue a lower carbon lifestyle. They also agree that other measures to address climate change such as the inclusion of SuDS, tree planting and appropriate public open space and habitat creation should be planned for. Whilst MCI recognises the urgency to move at pace to address climate change this needs to be led centrally and rolled out nationally. The Council should seek to ensure that they produce a sustainable Plan which supports a balance of homes and employment and is in line with the guidance provided by the NPPF (2024) and the PPG. The Council should ensure that any climate change policy is only implemented in line with the December 2023 Written Ministerial Statement which states that “a further change to energy efficiency building regulations is planned for 2025 meaning that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes” . It goes on to state that “ the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current, or planned building regulations, should be rejected”. National planning policy is silent on the issue of embodied carbon standards as are building regulations. MCI therefore question why the Council consider that this policy is necessary. MCI considers it is best that such matters are addressed at a national level to avoid different approaches and standards being set in different areas.

Comment

Representation ID: 2205

Received: 15/08/2025

Respondent: Sue Stanley

I&O_2325
Yes I agree with SD1

Comment

Representation ID: 2315

Received: 18/08/2025

Respondent: claire hepworth

I&O_2444

Comment

Representation ID: 2400

Received: 18/08/2025

Respondent: Jack Hubert Mayhew

I&O_2529
Supporive. However, it should include more reference to the design code: Point 3 should also recognise public transport networks. And recognise that the delivery of this is through adherence to the design code. The climate adaptation section should also include reference to delivering streets which adhere to the Design Code - e.g. SuDS and trees

Comment

Representation ID: 2430

Received: 19/08/2025

Respondent: Mary Clarke

I&O_2559
I agree with the approach but there needs to be a clearly defined set of assumptions on which proposals are based. 

Comment

Representation ID: 2704

Received: 20/08/2025

Respondent: Clare Birtles

I&O_2860
Yes. It's imperative that planning conditions relating to this policy are imposed and that where developers breach these conditions they are penalised and made to rectify any breaches 

Comment

Representation ID: 2748

Received: 20/08/2025

Respondent: Mr Martin Smith

Policy SD1
I&O_2914
SD1: The Policy is laudable but in my opinion is too heavily weighted towards climate change and does not adequately balance the other aspects of sustainability. The final section: 'Additional environmental and social requirements' Should be the core of the Policy and be at the beginning of the text. The climate change elemnts should follow and be seen in the context of the need to 1) Protect, enhance or improve the natural and historic environment whilst enhancing or restoring degraded and despoiled land and seeking opportunities for habitat creation; 2) Encourage the use and redevelopment of previously developed land and buildings and minimising the development of greenfield land as much as possible; 3) Avoid development in locations of high environmental value and on high-grade agricultural land ; and 4) Support development that achieves regeneration of the most deprived areas of the borough. Finally the Policy is prefaced by "where relevant". This is an enormous loop-hole that cdould undermine the Policy ever being effective. If the view is that some caveat is required the Policy should give some indication of the limited set of circumstanaces where it will not be relevant.

Comment

Representation ID: 2854

Received: 21/08/2025

Respondent: The Woodland Trust

I&O_3025
Yes - the only improvement I would suggest is by ensuring that sustainable development protects existing habitats and features, such as long-established and ancient woodland. 

Comment

Representation ID: 2932

Received: 21/08/2025

Respondent: Castle Green Homes

I&O_3106
Adapting to climate change Point 7 states that ‘areas at risk of flooding, both now and in the future, should be avoided’.  This wording should be amended to closer align with national planning policy and guidance.  Paragraph 170 of the NPPF states that: ‘inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future)’ . The reference to inappropriate development allows flexibility for certain types of development to be located within areas of flood risk where this is appropriate. Additional environmental and social requirements Whilst we encourage the use and redevelopment of previously developed land, as set out in the second bullet, the Local Plan should not seek to minimise ‘the development of greenfield land as much as possible’. The housing requirement of 28,710 homes is far in excess of the identified capacity of available previously developed sites, which is estimated at approximately 5,000 homes.  The development of greenfield sites will therefore be inevitable in order for the housing need to be met. It should also be recognised that greenfield sites are often in sustainable locations, offering good opportunities for development, which both mitigates and is resilient to climate change.  The policy should seek to ensure the efficient use of land in accordance with Paragraph 129 of the NPPF, for both brownfield and greenfield land.  It should encourage development on sustainable greenfield sites with the least environmental or amenity value, as guided by Sections 11 and 15 of the NPPF.  We propose the following wording for the second bullet: ‘Encourage the use and redevelopment of previously developed land and buildings and the efficient use of greenfield land in sustainable locations.’

Comment

Representation ID: 2995

Received: 21/08/2025

Respondent: Beryl Prior

I&O_3169
Green belt land should also be included for development if it is close to employment areas 

Comment

Representation ID: 3026

Received: 21/08/2025

Respondent: Ian Madej

I&O_3200
The overall intent of SD 1 is fine, but I cannot support the draft wording as it currently stands. The structure of the policy risks treating environmental safeguards and Green Belt protection as additional considerations , when in fact they should be the primary tests of sustainable development . This is inconsistent with both the December 2024 NPPF and with the evidence of the Sustainability Appraisal (June 2025) and Habitats Regulations Screening (June 2025) . Required amendments: Green Belt and brownfield-first principle must be primary The policy currently states that development should “encourage the use of previously developed land and minimising greenfield development as much as possible,” but places this under “additional requirements.” This must be elevated to the core principle of SD 1 : “Development will prioritise brownfield and urban regeneration. Green Belt land will only be released in genuinely exceptional circumstances and after all brownfield and urban capacity has been fully utilised, in accordance with the NPPF golden rules.” Environmental limits as core, not optional Protecting habitats, biodiversity, water quality, air quality, and farmland  should be stated up front as fundamental requirements of sustainable development, not listed as “additional.” This aligns with the precautionary principle in the Habitats Regulations and ensures compliance with legal duties. Transport sustainability test The current wording emphasises walking and cycling but does not test whether locations are genuinely sustainable. SD 1 should require that development is only located where safe and accessible walking, cycling and public transport infrastructure already exists or can viably be provided. Infrastructure-first principle Infrastructure delivery (schools, GP surgeries, utilities, transport) should also be a primary requirement . Development should not proceed unless infrastructure is available or committed in step with growth. Conclusion: I cannot support SD 1 in its current form, because it presents environmental and Green Belt protections as additional factors rather than primary principles of sustainable development. The policy must be amended so that Green Belt safeguarding, brownfield-first development, habitat protection and infrastructure provision sit at the heart of SD 1, alongside climate and design measures. 

Comment

Representation ID: 3085

Received: 18/08/2025

Respondent: National Highways

I&O_3259
Reflective of the declaration of a climate emergency by Cheshire West and Chester and the policy approach currently adopted by National Highways to mitigate the impacts of climate change and build in climate resilience to the SRN, we are supportive of this approach. Policy SD1: Sustainable Development In line with the approach identified through the Climate Change and the Strategic Road Network (ARP4) report, and the Environmental Sustainability Strategies, we are supportive of this policy approach to ensure appropriate resilience of the SRN and associated infrastructure to climate change and future climate resilience.

Comment

Representation ID: 3226

Received: 22/08/2025

Respondent: Antony Fairbanks

I&O_3400
Yes

Comment

Representation ID: 3289

Received: 22/08/2025

Respondent: claire hepworth

I&O_3463
it needs strengthening to protect green belt/greenfields, and only have housing in areas with sustainability like areas mentioned above and not willaston or Hooton.Needs to protect green fields/greenbelts and smaller villages as these have significant parking/congestion/Flooding problems already. The character of smaller villages should be protected. Protecting green areas/greenfield should be a primary principle. green field sites store carbon in soil/hedgerows and trees- building on these means loss of carbon sinks and release of stored carbon.green field and green belt land is climate change infrastructure. We have a climate emergency, need to reduce carbon emissions and improve biodiversity.

Comment

Representation ID: 3348

Received: 22/08/2025

Respondent: Daniel Simpson

I&O_3522
I find it hard to disagree with SD1. However, I worry that given many people are also feeling a cost of living crisis that we don't create policies that require larger outlays of funds which would prohibit people on low (and frankly good above average salaries) from being able to deliver the wellbeing they need. If we are going to decline a development that delivers wellbeing to many on the basis that it needs an EV charger in a place that doesn't have the electricity supply to support it, I think SD1 has gone too far and would like to suggest that it is softened slightly to allow for the "cost of living crisis" to also factor in decisions

Comment

Representation ID: 3393

Received: 22/08/2025

Respondent: John Edward Holmes

I&O_3567
No, the way that you suggest that climate control is to be dealt with is to place obligations on the shoulders of developers which will lower the impact of fresh development.  This does not tackle the problem it just mitigates slightly the impact of fresh development.  In fact you should be looking to limit unecesary new development.  The more you build the more impact it will have.  By all means place obligations on new development so its impact is limited but this should very much be the second line of defence