Comment

Representation ID: 6430

Received: 28/08/2025

Respondent: Thomas Gorsuch

I&O_6844
Council should consider recent years and include housing created where relevent (I believe that housing has been in excess of government targets) Council should adhere to option A, maintain green belt, and explain to government that the unusually large proportion of the LA under green belt warrants an overall reduction in that target.

Comment

Representation ID: 6488

Received: 29/08/2025

Respondent: Philip Marshall

I&O_6903
The 1,914 homes/year figure is arbitrary and unjustified without a proper Housing Needs Assessment. This figure has been calculated based on historic housing delivery performance and not actual local 'Need', derived from forecatsed local demographic changes, local economic / growth strategies and feasibility based on thorough, phased infrastructure assessments. This Government calculation is pure 'performance punishment', and risks unaligned development to satisfy a national statistic.

Comment

Representation ID: 6558

Received: 29/08/2025

Respondent: Will Holden

I&O_6975
These should be trageted in the areas with the existing infrastructure to accept further housing. In areas with a road network that can take additional vehicles (or which could easily be altered to do so). Where local services (GP, school, etc) are not at or near capacity.

Comment

Representation ID: 6632

Received: 29/08/2025

Respondent: Karen Lea-Swain

I&O_7052
Yes, CWaC have already delivered over their quota in previous iterations of local planning, this should be considered in new plans.

Comment

Representation ID: 6669

Received: 29/08/2025

Respondent: Brookhouse Group Ltd

Agent: WSP

SS 1
I&O_7089
There are no reasons for the Council to plan to deliver less than the minimum of 1,914 new homes each year. 

Comment

Representation ID: 6678

Received: 29/08/2025

Respondent: Hooton Estate

Agent: Fisher German LLP

I&O_7098
There is no reason the Council should not plan to deliver a minimum of 1,914 new homes each year. Planning for this level of growth is necessary to address affordability pressures, support economic development, and ensure a steady supply of housing land across the borough. A proactive response will help maintain a five-year housing land supply and ensure the Local Plan is found sound at examination.

Comment

Representation ID: 6743

Received: 29/08/2025

Respondent: Mary Malpeli

ss1
I&O_7169
The A56 and main roads through Frodsham are regularly gridlocked. When the M56 is closed or partially shut, all diverted traffic comes through the town. The Weaver Viaduct carries over 112,000 vehicles daily. That number spikes during roadworks, collisions, or closures. None of this is future risk. It's already happening. Add hundreds of extra vehicles from large building projects and the problem gets worse. Emergency vehicles already struggle to get through. This development will slow response times even more, putting lives at risk.GP Practices and Schools Are Full. There is the added issue of increased air and light pollution. Flood risk is a factor not to be dismissed. Surface water flooding is the biggest threat to homes in England today. Over 4.6 million homes are now at risk from it. That’s double the number at risk from rivers or coastal surge. In Frodsham, those risks already exist. Greenbelt land acts as a sponge. They slow rain and reduce flood peaks. Building on greenbelt means water runs off

Comment

Representation ID: 6940

Received: 29/08/2025

Respondent: Lambert Smith Hampton

I&O_7408
No, this is a minimum, there should also be more emphasis or encouragement to go beyond this target.

Comment

Representation ID: 6969

Received: 29/08/2025

Respondent: Mr John Kerrigan

I&O_7437
No as this aligns with national requirements, although CWaC has done well in delivering the existing Local Plan targets and should not need a new Local Plan

Comment

Representation ID: 7055

Received: 29/08/2025

Respondent: Hugo Deynem

I&O_7524
Yes, insufficient infrastructure in place across the borough and a 'rush to build' at this rate will mean greater impacts on existing infrastruture and communities. We should be considering new, large stand alone developments N of the M56 corridor.

Comment

Representation ID: 7070

Received: 29/08/2025

Respondent: Luke Henley

I&O_7540
The plan must recognise and accommodate the fact that housing targets vary with the whim of the Secretary of State.

Comment

Representation ID: 7081

Received: 29/08/2025

Respondent: Julia Hallett

I&O_7552
Decreasing population trends should be considered, alongside a specified number.

Comment

Representation ID: 7117

Received: 29/08/2025

Respondent: Philip Davies

I&O_7589
There is not the investment in insfrastructure to accommodate minimum 1914 houses each year. Roads are already congested in rural areas and are badly maintained. Doctors' appointments are impossible to get without booking 2 weeks in advance. Water resources are scarce - United Utilities issued a "we're running low" warning only a few weeks in to this summer's warm spell despite long periods of wet weather last winter. Cheshire is meant to be a rural county, not a sprawling city. 1914 houses or more every year would change the very nature of the county.

Comment

Representation ID: 7120

Received: 29/08/2025

Respondent: Michael O'Sullivan

I&O_7592
This does seem an incredulous target. 

Comment

Representation ID: 7176

Received: 29/08/2025

Respondent: Nik Darwin

I&O_7651
The Council has been delivering homes well above the previous LHN but may wish to consider whether the level of increase can be achieved from the start of the plan period as it will still require a significant increase in delivery which will need to be shown can be delivered from the start of the plan period, In order to ensure that there is a 5 year land supply and clarity about delivery the Council should consider a stepped trajectory given the substantial increase from the previos LHN and adopted local plan requirement 

Comment

Representation ID: 7268

Received: 29/08/2025

Respondent: Rob Fryer

I&O_7748
This number is a huge increase on what is possible, given the areas suitsble

Comment

Representation ID: 7298

Received: 29/08/2025

Respondent: Alison McKay

I&O_7778
Yes. Has the need for 1,914  new homes to be provided each year been proven? If not, we should aim to provide the number of new homes which evidence suggests are needed in Chester west and Chester. Would people be able to afford these homes on an average salary? If not, there seems little point in building homes which would remain empty.

Comment

Representation ID: 7340

Received: 29/08/2025

Respondent: Councillor Mark Stocks

I&O_7820
YES I BELIVE THIS FIGURE IS UNREALISTIC AND UNDELIVERABLE AND SHOULD BE REDUCED TO 1100 IT CANNOT BE DELIVERED WITHOUT DAMAGING MANY COMMUNITIES ACROSS THE BOROUGH

Comment

Representation ID: 7341

Received: 29/08/2025

Respondent: Councillor Lynn Stocks

I&O_7821
Yes, this figure is completely unachievable and is likely to destroy the character of our rural communities thus impacting the health and wellbeing of our residents. There has not been an assessment to identify this number is required. Infrastructure also has to be a part of every development and cannot be ignored.

Comment

Representation ID: 7449

Received: 29/08/2025

Respondent: Katherine Hague

I&O_7929
We cannot sustain the existing 

Comment

Representation ID: 7493

Received: 29/08/2025

Respondent: Ms Nuala Floyd

I&O_7973
There is no reason not to plan for building new homes as long as they are required

Comment

Representation ID: 7495

Received: 29/08/2025

Respondent: Richard Carden

I&O_7975
It is simply too many homes and they will very likely erode on open countryside and the green belt to an unacceptable extent durig a climate emergency, it will also not work towards making homes more affordable.

Comment

Representation ID: 7532

Received: 30/08/2025

Respondent: Paul Traynor

I&O_8012
The Goverment should refocus on sustainabe growth which brings communities with them rather than setting unrealistic targets for local authorities. CWAC should resist the four fold increase requested by government and instead focus on limiting development numbers that our communities are able to cope without putting undue pressure on local services.

Comment

Representation ID: 7605

Received: 23/08/2025

Respondent: Mr Paul Wintle

I&O_8092
The A56 and main roads through Frodsham are regularly gridlocked. When the M56 is closed or partially shut, all diverted traffic comes through the town. The Weaver Viaduct carries over 112,000 vehicles daily. That number spikes during roadworks, collisions, or closures. None of this is future risk. It's already happening. Add hundreds of extra vehicles from large building projects and the problem gets worse. Emergency vehicles already struggle to get through. This development will slow response times even more, putting lives at risk.GP Practices and Schools Are Full. There is the added issue of increased air and light pollution. Flood risk is a factor not to be dismissed. Surface water flooding is the biggest threat to homes in England today. Over 4.6 million homes are now at risk from it. That’s double the number at risk from rivers or coastal surge. In Frodsham, those risks already exist. Greenbelt land acts as a sponge. They slow rain and reduce flood peaks. Building on greenbelt means water runs off faster into areas that cannot cope.

Comment

Representation ID: 7668

Received: 19/08/2025

Respondent: Jones Homes (North West) Limited

Agent: Emery Planning Partnership

I&O_8155
No. The publication of the revised Framework in December 2024 and the new Standard Method sets out a minimum need for 1,914 dwellings per annum. Paragraph 62 of the Framework states: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” Local Housing Need is defined in Annex 2 of the Framework: “The number of homes identified as being needed through the application of the standard method set out in national planning practice guidance.” Paragraph 0031 of the PPG states: “ Is the use of the standard method for strategic policy making purposes mandatory? The standard method should be used to assess housing needs. However it is recognised that there are some specific circumstances in which an alternative approach could be justified, for example as explained at paragraph 014 below.” Paragraph 14 of the PPG states: “ Where strategic policy-making authority boundaries do not align with local authority boundaries, or data is not available, should the standard method be used to assess local housing need? Where strategic policy-making authorities do not align with local authority boundaries (either individually or in combination), or the data required for the model are not available such as in National Parks and the Broads Authority, or local authority areas where the samples are too small, an alternative approach may have to be used. Such authorities may continue to identify a housing need figure using a method determined locally. In doing so authorities should take into consideration the best available evidence on the amount of existing housing stock within their planning authority boundary, local house prices, earnings and housing affordability. In the absence of other robust affordability data, authorities should consider the implications of using the median workplace-based affordability ratio for the relevant wider local authority area(s). For local authorities whose boundaries cross National Parks or Broads Authority areas, the proportion of the local authority area that falls within and outside the National Park or Broads Authority area should also be considered – for example where only a minimal proportion of the existing housing stock of a local authority falls within the National Park or Broads Authority area it may be appropriate to continue to use the local housing need figure derived by the standard method for the local authority area.” Paragraph 14 is not applicable in Cheshire West as the authority boundary aligns with the local plan boundary. Therefore, the standard method is mandatory in Cheshire West. As to whether the housing requirement can vary from the standard method, paragraph 0402 of the PPG states: “ What is a housing requirement? The housing requirement is the minimum number of homes that a plan seeks to provide during the plan period. Once local housing need has been assessed, as set out in this guidance, authorities should then make an assessment of the amount of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters. The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The National Planning Policy Framework explains that the housing requirement may be higher than the identified housing need, and authorities should consider the merits of planning for higher growth if, for example, this would seek to reflect economic growth aspirations. Where authorities plan for higher growth this should not normally have to be thoroughly justified at examination.” Paragraph 40 states that authorities, once they have made an assessment of need, then need to consider land availability, constraints on development and any other relevant matters. The only meaningful policy restrain in Cheshire West has been Green Belt around Chester, but the Government is clear that “authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”. That is an ongoing process as part of the evidence base but the Government is clear that a Green Belt review must be undertaken. With the potential exception of the Green Belt around Chester, we do not consider that there are any constraints that would result in a conclusion that the standard method cannot be met once the HELAA and Green Belt review has been undertaken given the availability of land around the settlements in the Borough. 3.7 With the standard method as a minimum, the only other alternative in the PPG is a higher requirement which is expressly set out in paragraph 143 of the PPG and paragraph 69 of the Framework which states: “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. As part of the local plan evidence base, a Housing and Economic Needs Assessment will be undertaken and that should form part of the Council’s consideration as to the final housing requirement and that should be the subject to consultation. Therefore, at this stage the housing requirement should be a minimum of 1,914 dwellings per annum with the potential for a higher requirement based on economic development or infrastructure investment.

Comment

Representation ID: 7673

Received: 19/08/2025

Respondent: Jones Homes (North West) Limited

Agent: Emery Planning Partnership

I&O_8160
We consider that there should be a buffer of at least 10% which is based on the Local Plans Expert Group report to the Communities Secretary and to the Minister of Housing and Planning where a 20% buffer was recommended. The report recommends at paragraph 11.4 that the Framework should make clear that local plans should be required to demonstrate a five year land supply but also focus on ensuring a more effective supply of developable land for the medium to long term, plus make provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework. The Guildford Local Plan 2019 is relevant to the issue of releasing Green Belt to provide flexibility in the housing land supply. A supply of 14,602 dwellings was provided against a housing requirement of 10,678 dwellings, equating to a flexibility allowance of 37%. Of supply, some 6,742 dwellings were to be provided on sites to be released from the Green Belt. The plan was subject to an unsuccessful Challenge4 which specifically addressed this point. The Judgment draws the following conclusions under Issue 2: Was the conclusion that there were exceptional circumstances justifying the allocations of housing land, released from the Green Belt, to provide headroom of over 4000 dwellings above the 10678 OAN lawful, and adequately reasoned? - Once meeting the OAN is accepted as a strategic level factor contributing to “exceptional circumstances”, it follows that the provision of headroom against slippage and for flexibility to meet changes, “future-proofing” the plan, as the Inspector put it, would also contribute to such circumstances (paragraph 91). - The headroom figure was a judgement based on the sites which were available to meet a requirement figure somewhat over 10,678, and to do so in such a way that, over the initial and subsequent years of the plan, the rolling five year housing supply, with a 20% buffer for some years, would be maintained (paragraph 96). - As part of the total supply, the Inspector was entitled to conclude that the plan should allocate additional sites, that may be sequentially less preferable than other sites, because they were necessary allocations in order to provide the initial five year housing land supply (paragraph 101). We consider that the above key points are broadly applicable to Cheshire West and the Plan must provide sufficient flexibility and there is a need to release additional deliverable sites to provide a five-year housing land supply and ensuring the requirement is met in the plan period. Even if there were to be a degree of over-provision, there would be wider benefits of providing a level of housing in excess of the minimum requirement, namely improving affordability and meeting affordable housing needs.

Comment

Representation ID: 7674

Received: 19/08/2025

Respondent: Jones Homes (North West) Limited

Agent: Emery Planning Partnership

I&O_8161
Option B under SS5 states that “the government’s new housing target of 28,170 homes” which is the 1,914 dwellings multiplied by 15 years. However, based on the above, the plan period should be longer as the start date for a plan (which should be 2025) is not the adoption date and with the need for a plan period to 2045 in our view, the housing requirement that this Plan should be meeting is for a 20 year period and should be 38,280 dwellings. With an added buffer of at least 10%, then the Plan should be meeting at least 42,000 dwellings.

Comment

Representation ID: 7703

Received: 19/08/2025

Respondent: Hollins Strategic Land

Agent: Emery Planning Partnership

I&O_8190
No. The publication of the revised Framework in December 2024 and the new Standard Method sets out a minimum need for 1,914 dwellings per annum. Paragraph 62 of the Framework states: “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.” Local Housing Need is defined in Annex 2 of the Framework: “The number of homes identified as being needed through the application of the standard method set out in national planning practice guidance.” Paragraph 0031 of the PPG states: “ Is the use of the standard method for strategic policy making purposes mandatory? The standard method should be used to assess housing needs. However it is recognised that there are some specific circumstances in which an alternative approach could be justified, for example as explained at paragraph 014 below.” Paragraph 14 of the PPG states: “ Where strategic policy-making authority boundaries do not align with local authority boundaries, or data is not available, should the standard method be used to assess local housing need? Where strategic policy-making authorities do not align with local authority boundaries (either individually or in combination), or the data required for the model are not available such as in National Parks and the Broads Authority, or local authority areas where the samples are too small, an alternative approach may have to be used. Such authorities may continue to identify a housing need figure using a method determined locally. In doing so authorities should take into consideration the best available evidence on the amount of existing housing stock within their planning authority boundary, local house prices, earnings and housing affordability. In the absence of other robust affordability data, authorities should consider the implications of using the median workplace-based affordability ratio for the relevant wider local authority area(s). For local authorities whose boundaries cross National Parks or Broads Authority areas, the proportion of the local authority area that falls within and outside the National Park or Broads Authority area should also be considered – for example where only a minimal proportion of the existing housing stock of a local authority falls within the National Park or Broads Authority area it may be appropriate to continue to use the local housing need figure derived by the standard method for the local authority area.” Paragraph 14 is not applicable in Cheshire West as the authority boundary aligns with the local plan boundary. Therefore, the standard method is mandatory in Cheshire West. As to whether the housing requirement can vary from the standard method, paragraph 0402 of the PPG states: “ What is a housing requirement? The housing requirement is the minimum number of homes that a plan seeks to provide during the plan period. Once local housing need has been assessed, as set out in this guidance, authorities should then make an assessment of the amount of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters. The government is committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth. The National Planning Policy Framework explains that the housing requirement may be higher than the identified housing need, and authorities should consider the merits of planning for higher growth if, for example, this would seek to reflect economic growth aspirations. Where authorities plan for higher growth this should not normally have to be thoroughly justified at examination.” Paragraph 40 states that authorities, once they have made an assessment of need, then need to consider land availability, constraints on development and any other relevant matters. The only meaningful policy restrain in Cheshire West has been Green Belt around Chester, but the Government is clear that “authorities should review Green Belt boundaries in accordance with the policies in this Framework and propose alterations to meet these needs in full, unless the review provides clear evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan”. That is an ongoing process as part of the evidence base but the Government is clear that a Green Belt review must be undertaken. With the potential exception of the Green Belt around Chester, we do not consider that there are any constraints that would result in a conclusion that the standard method cannot be met once the HELAA and Green Belt review has been undertaken given the availability of land around the settlements in the Borough. 3.7 With the standard method as a minimum, the only other alternative in the PPG is a higher requirement which is expressly set out in paragraph 143 of the PPG and paragraph 69 of the Framework which states: “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. As part of the local plan evidence base, a Housing and Economic Needs Assessment will be undertaken and that should form part of the Council’s consideration as to the final housing requirement and that should be the subject to consultation. Therefore, at this stage the housing requirement should be a minimum of 1,914 dwellings per annum with the potential for a higher requirement based on economic development or infrastructure investment.

Comment

Representation ID: 7716

Received: 19/08/2025

Respondent: Hollins Strategic Land

Agent: Emery Planning Partnership

I&O_8203
We consider that there should be a buffer of at least 10% which is based on the Local Plans Expert Group report to the Communities Secretary and to the Minister of Housing and Planning where a 20% buffer was recommended. The report recommends at paragraph 11.4 that the Framework should make clear that local plans should be required to demonstrate a five year land supply but also focus on ensuring a more effective supply of developable land for the medium to long term, plus make provision for, and provide a mechanism for the release of, sites equivalent to 20% of their housing requirement, as far as is consistent with the policies set out in the Framework. The Guildford Local Plan 2019 is relevant to the issue of releasing Green Belt to provide flexibility in the housing land supply. A supply of 14,602 dwellings was provided against a housing requirement of 10,678 dwellings, equating to a flexibility allowance of 37%. Of supply, some 6,742 dwellings were to be provided on sites to be released from the Green Belt. The plan was subject to an unsuccessful Challenge4 which specifically addressed this point. The Judgment draws the following conclusions under Issue 2: Was the conclusion that there were exceptional circumstances justifying the allocations of housing land, released from the Green Belt, to provide headroom of over 4000 dwellings above the 10678 OAN lawful, and adequately reasoned? - Once meeting the OAN is accepted as a strategic level factor contributing to “exceptional circumstances”, it follows that the provision of headroom against slippage and for flexibility to meet changes, “future-proofing” the plan, as the Inspector put it, would also contribute to such circumstances (paragraph 91). - The headroom figure was a judgement based on the sites which were available to meet a requirement figure somewhat over 10,678, and to do so in such a way that, over the initial and subsequent years of the plan, the rolling five year housing supply, with a 20% buffer for some years, would be maintained (paragraph 96). - As part of the total supply, the Inspector was entitled to conclude that the plan should allocate additional sites, that may be sequentially less preferable than other sites, because they were necessary allocations in order to provide the initial five year housing land supply (paragraph 101). We consider that the above key points are broadly applicable to Cheshire West and the Plan must provide sufficient flexibility and there is a need to release additional deliverable sites to provide a five-year housing land supply and ensuring the requirement is met in the plan period. Even if there were to be a degree of over-provision, there would be wider benefits of providing a level of housing in excess of the minimum requirement, namely improving affordability and meeting affordable housing needs.

Comment

Representation ID: 7718

Received: 19/08/2025

Respondent: Hollins Strategic Land

Agent: Emery Planning Partnership

I&O_8205
Option B under SS5 states that “the government’s new housing target of 28,170 homes” which is the 1,914 dwellings multiplied by 15 years. However, based on the above, the plan period should be longer as the start date for a plan (which should be 2025) is not the adoption date and with the need for a plan period to 2045 in our view, the housing requirement that this Plan should be meeting is for a 20 year period and should be 38,280 dwellings. With an added buffer of at least 10%, then the Plan should be meeting at least 42,000 dwellings.