Comment

Representation ID: 7820

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

Agent: J10 Planning

I&O_8308
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 7828

Received: 24/08/2025

Respondent: Ruth Giles

I&O_8317
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: 8024

Received: 03/09/2025

Respondent: M & S Lacey

Agent: J10 Planning

I&O_8513
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 8040

Received: 25/08/2025

Respondent: Mr John Giles

FRO01 FRO02 FRO03
I&O_8529
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: 8221

Received: 03/09/2025

Respondent: M and P Jones

Agent: J10 Planning

I&O_8710
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 8281

Received: 25/08/2025

Respondent: Ian Tildsley

I&O_8770
We note also that CPRE Cheshire is concerned about the issues raised in this options paper. They consider the housing need figures excessive and more than the projections published by the Office for National Statistics. They also feel that we need to focus on Brownfield land and protect agricultural land. I understand that National England is investigating whether the Sandstone Ridge area should be designated an Area of Outstanding Beauty. It will be interesting to see their comments on the development Options given in your paper.

Comment

Representation ID: 8415

Received: 26/08/2025

Respondent: Wain Estates (Land) Limited

SS1
I&O_8906
Paragraph 5.2 of the Issues and Options document states that in order to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method to establish a housing requirement figure for the whole area, which shows the extent to which the identified housing need can be met over the plan period [NPPF para. 69].  The local housing need figure for CWaC, calculated using SM3, is 1,928. This is a significant 262% increase from the previous standard methodology figure for CWaC of 532. It also represents a 75% increase from the current Local Plan housing requirement of 1,100. As it stands, the Issues and Options document indicates that the plan will cover a 15-year period which equates to a total figure of 28,710 new homes. NPPF para. 22 states that “strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities”. [Emphasis in bold] Given the significant increase in CWaC’s housing need figure a substantial amount of developable land is going to be required to fulfil the identified need target over the Plan period, from a range of different sites across the administrative area. To meet the identified need of 28,710 new homes, CWaC’s Land Availability Assessment (Stage One) [LAA] report suggests that the assessment has identified a total of 502 potential sites that could deliver in the region of 29,500 units based on an initial assessment against key designations, including ‘Open Countryside’ and ‘Green Belt’ sites, and constraints and applying general, non-site-specific density assumptions to estimate capacity. However, this figure is likely to significantly reduce once a detailed assessment of the constraints, development potential, availability and achievability is carried out in stage two of the process. A shortfall of housing land supply is, therefore, likely to be identified which emphasises the need to allocate deliverable sites including the land at Model Farm, Hartford and Peckmill Farm, Davenham, both of which are included as part of the LAA. Both of Wain Estate’s land interests should be favoured against Green Belt sites considered in the LAA. Wain Estates does not support the concept of a stepped housing requirement that plans for a lower level of housing delivery earlier in the plan period. The Issues and Options document presents no evidence to justify a stepped approach, and Cheshire West has been delivering very high numbers of homes over the past decade in line with the new standard method requirement and a stepped housing requirement would be counterintuitive. The Housing Delivery Test (December 2023) [HDT] identified that CWaC scored 249% which means CWaC exceeded its housing delivery target by 149% over the previous three years which demonstrates a strong record of delivering new homes. Whilst this most recent HDT figure was calculated based on SM3, it demonstrates that positively planning for housing growth through strategic policies can ensure that future housing delivery target are achieved. Sites, including Wain Estates’ land interests, are deliverable within the early years of the Plan period and would make a valuable contribution towards meeting CWaC’s identified need in the short term. Implementing a stepped approach through policy would hinder the delivery of homes and, in the context of the quantum of deliverable sites across the borough, lead to an unjustified shortfall of housing against the SM3 target, especially in context of the Council’s current five year housing land supply position. In addition, a stepped approach could not accord with the national policy to boost the delivery of homes and would impact the delivery and availability of affordable housing, introduce uncertainty for developers, and potentially result in a delay in meeting CWaC’s identified development needs.

Comment

Representation ID: 8422

Received: 03/09/2025

Respondent: A-M, WR and AJA Posnett

Agent: J10 Planning

I&O_8913
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 8621

Received: 03/09/2025

Respondent: Bellway Homes (North West) Ltd and Bloor Homes Ltd

Agent: J10 Planning

I&O_9112
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 8800

Received: 03/09/2025

Respondent: Trustees of G A Artell

Agent: J10 Planning

I&O_9293
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 8938

Received: 03/09/2025

Respondent: Mrs J Jenkins

Agent: J10 Planning

I&O_9431
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 9078

Received: 26/08/2025

Respondent: Northstone

Agent: NJL Consulting

I&O_9571
The Council should be planning for at least the 1,914 dpa as required under the Standard Method figures published in 2024. Any figure above this base level will ensure CWAC can address the shortfall in affordable housing provision and the need to sustain future economic growth in the borough. Contextually, under the previous NPPF method, the annual housing target for Cheshire West and Chester was 532 dwellings annually. Under the standard method established within the new NPPF and updated figures published in March in line with affordability ratios, the annual housing target for the Council is 1,912 dwellings per year. As the Council’s strategic policies are more than five years old, paragraph 78 is also highly relevant: the Council needs to demonstrate a five-year supply against the standard method (taken from Planning Practice Guidance). Using the Council’s latest land supply figure and published affordability, the 5-year calculation is as follows: • Annual Requirement = 1,912 • 5-year Requirement = 9,560 • Plus 5% buffer = 10,038 • Deliverable Supply = 4,209 • Years Supply = 2.09 years The shortfall in supply is therefore chronic and needs to be addressed through emerging Local Plan. In terms of the figure suggested through the policy, it is important to note how ‘exceptional circumstances’ need to be shown to justify an alternative approach to the standard method. Crucially as the PPG states (summarised below), it is only for a housing need figure which is lower than standard method for which ‘exceptional’ justification needs to be shown. A higher figure is not as rigorously tested. The PPG states “The standard method uses a formula to identify the minimum number of homes expected to be planned for. The standard method…identifies a minimum annual housing need figure. It does not produce a housing requirement figure.” (NJL emphasis). The PPG emphasises how the assessment of need must be carried out separately and prior to the determination of a housing requirement. Furthermore, the PPG refers to exceptional circumstances being required to justify housing need which is below the Standard Method minimum. In contrast the PPG states how a range of circumstances may justify the determination of housing need which exceeds the standard method minimum, and that an assessment of need which establishes a figure which is higher than the standard method minimum will be considered sound if it “adequately reflects current and future demographic trends and market signals.” It is therefore important to consider whether any factors justify an increase in the standard method minimum when determining housing need but at the very least there is no reason as to why the Council should drop below the identified dwellings per year as set out.

Comment

Representation ID: 9110

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9603
The revised Standard Method calculation, which resulted in the 1,914 dpa requirement, was designed to provide a minimum housing need figure in order to address the national shortfall in the supply of homes, and to support and enable growth in local areas. Whilst it is possible for this number to be reduced in constrained locations, where exceptional circumstances can be justified, we do not believe that such justification exists in Cheshire West and Chester. This is demonstrated within the Issues and Options consultation report, which has identified a number of different options for delivering the required minimum figure. Cheshire West and Chester’s Housing Strategy 2025-2035 states that there are 6,735 applicants registered on the housing waiting list. Furthermore, the Economic Needs Assessment shows a significant and steady growth in Employment within the assessment period (up to 2045). The evidence base clearly demonstrates that significant housing is needed, and as such the standard method should be the starting point for delivery. The shortfall in supply is chronic and needs to be addressed through emerging Local Plan. Furthermore, the PPG states how a range of circumstances may justify the determination of housing need which exceeds the standard method minimum, and that an assessment of need which establishes a figure which is higher than the standard method minimum will be considered sound if it “adequately reflects current and future demographic trends and market signals.” It is therefore important to consider whether any factors justify an increase in the Standard Method minimum when determining housing need but at the very least, there is no reason as to why the Council should drop below the identified dwellings per year as set out.

Support

Representation ID: 9115

Received: 27/08/2025

Respondent: Alvanley Parish Council

I&O_9608
We believe in encouraging land-based employment especially farming and agriculture in existing greenbelt and would agree with SS2.

Comment

Representation ID: 9200

Received: 03/09/2025

Respondent: AM Littler, NJM Littler and C Leigh

Agent: J10 Planning

I&O_9693
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 9341

Received: 27/08/2025

Respondent: Ashall Land

Agent: Marrons

I&O_9835
There is no justification for not delivering a lower housing requirement than 1,914 dpa. This figure reflects government policy and supports the growth agenda ambition to deliver 1.5m new homes over the next 5 years (300,000 dpa). The areas within CW&C’s administrative boundary is very large, has sufficient land capacity at multiple key settlements and with no overriding environmental constraints affecting the district as a whole, only policy constraints. The Council must plan to meet this target, which is a 74% increase from the current Local Plan’s target of 1,1000 dpa. Consequently, the Council will need to review designed Green Belt land and key settlement gaps, and considering all development opportunities. Stage One of the Land Availability Assessment (LAA) (2025) identifies Northwich to have the highest potential capacity for new homes out of the 4 largest urban areas, estimated at 2,731 units (although Winsford closely follows). In reference to Table 4.8. (Housing and mixed-use sites by spatial area and type – urban areas), identified opportunities in Northwich include 18 Greenfield sites (978 units), 36 PDL sites (1703 units), 4 mixed sites (GF and PDL) (50 units). It is clear that to meet the proposed housing delivery targets, the Council will need to consider all potential development sites, including those on the periphery of existing settlements such as our client’s site in Davenham, and follow a full and rigorous site selection process.

Comment

Representation ID: 9395

Received: 03/09/2025

Respondent: Trustees & Beneficiaries of Ms D Bentley dec'd

Agent: J10 Planning

I&O_9890
No – but it could deliver more and the figure should be expressed as a minimum

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: 9468

Received: 27/08/2025

Respondent: Jamie Dodd

I&O_9963
Yes, all the proposed locations (FRO01 FRO02 FRO03 - Frodsham) rely on access specifically to the A56 which runs through Helsby, Frodsham and Sutton Weaver. All designated transport routes, including bus travel in the area, rely on a single carriageway to transport 112,000 journeys across the extremely small Sutton Weaver bridge. This is already an extremely precarious situation with traffic spikes (e.g. M56 closures, accidents), roadworks, collisions etc. In particular FR002 and FR001 would also rely on the B5152 for access to any transport routes which would be wholly unacceptable due to its size and transport carrying capacity.

Comment

Representation ID: 9561

Received: 03/09/2025

Respondent: C, M and R Allsop

Agent: J10 Planning

I&O_10056
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 9675

Received: 03/09/2025

Respondent: Vistry Group and J Whittingham

Agent: J10 Planning

I&O_10171
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 9793

Received: 03/09/2025

Respondent: SA, and SJ Arden, J C Coombs and J Hand

Agent: J10 Planning

I&O_10290
No – but it could deliver more and the figure should be expressed as a minimum

Comment

Representation ID: 9905

Received: 27/08/2025

Respondent: Lyndsey Dodd

I&O_10402
Yes, all the proposed locations (FRO01 FRO02 FRO03 - Frodsham) rely on access specifically to the A56 which runs through Helsby, Frodsham and Sutton Weaver. All designated transport routes, including bus travel in the area, rely on a single carriageway to transport 112,000 journeys across the extremely small Sutton Weaver bridge. This is already an extremely precarious situation with traffic spikes (e.g. M56 closures, accidents), roadworks, collisions etc. In particular FR002 and FR001 would also rely on the B5152 for access to any transport routes which would be wholly unacceptable due to its size and transport carrying capacity.

Comment

Representation ID: 9906

Received: 27/08/2025

Respondent: Paul Jennings

I&O_10403
I support the housebuilding target of 1,914 homes per year.

Comment

Representation ID: 9961

Received: 27/08/2025

Respondent: Bellway Homes Ltd (North West)

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: 10075

Received: 27/08/2025

Respondent: R E, S, E and T Smith, Taylor, Cox and Carter

Agent: Savills (UK) Limited

I&O_10572
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 

Support

Representation ID: 10108

Received: 27/08/2025

Respondent: Geoffrey Thomson and Over Estates (Winsford) Ltd

Agent: Savills (UK) Limited

I&O_10605
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: 10159

Received: 27/08/2025

Respondent: Northern Trust Land Limited

Agent: Savills (UK) Limited

I&O_10656
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. 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 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 designations such as National Parks etc). 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: 10181

Received: 26/08/2025

Respondent: Education and Skills Funding Agency

I&O_10678
The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. Under the provisions of the Education Act 2011 and the Academies Act 2010, new state schools are now academies/new schools and DfE is the delivery body for some of these, rather than local authorities. Local authorities have a statutory responsibility to ensure sufficient education provision and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new education infrastructure. We have published guidance on securing developer contributions for education, and estimating pupil yield from housing development, at https://www.gov.uk/government/publications/delivering-schools-to-support-housing-growth. You will also be aware of the corresponding Planning Practice Guidance on planning obligations, viability and safe and healthy communities.1 We would like to offer the following comments in response to the above consultation document. General Comments 4. The department notes that significant growth in housing stock is expected in the borough; the consultation document anticipates an annual housing requirement of 1,914 homes to the end of the plan period in 2042. This will place additional pressure on social infrastructure such as education facilities. The Local Plan will need to be ‘positively prepared’ to meet the objectively assessed development needs and infrastructure requirements. 5. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 100). 6. The department supports the principle of Cheshire West & Chester borough safeguarding land for the provision of new early years (birth to the September after the child turns 5) settings, schools, and post 16 provision to meet government planning policy objectives as set out in paragraph 100 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary, in accordance with Planning Practice Guidance and DfE guidance on securing developer contributions for education.2 7. Cheshire West & Chester borough should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on Planning for Schools Development3 (2011) which sets out the government’s commitment to support the development of state-funded schools and their delivery through the planning system. 1 https://www.gov.uk/government/collections/planning-practice-guidance 2 https://www.gov.uk/government/publications/delivering-schools-to-support-housing-growth 3 https://www.gov.uk/government/publications/national-planning-policy-framework--2

Comment

Representation ID: 10232

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10729
Central to the NPPF is the need to create strategic policies which set out the overall strategy for the pattern, scale and design quality of places and to make sufficient provision for homes (including affordable housing). The DIO fully supports the approach to deliver a minimum of 1,914 new, high-quality homes across the borough, which would be in line with national planning policy and the new standard housing requirement for the borough. There is clear justification to support the approach for the emerging Local Plan to meet its identified housing need, as failure to do so can result in harm, such as slower economic growth, a lack of labour force mobility, critical affordability issues, disruption to commuting patterns and the delivery of housing choice.