Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10404
Received: 27/08/2025
Respondent: Mr & Mrs Beverley and Philip Buckley
I&O_10901
We are aware that CWAC is producing a new local plan, which includes increasing the housing allocation to 1,900 properties per year, outlining what kind of development and where it can happen. As a result of which, from a Land Availability Assessment, several areas of the villages of Cuddington and Sandiway have been identified as potential sites, which in total amounts to 3,966 properties. Does this not suggest large scale development in this locality? We are concerned by the unjustified nature of the housing target, which is at a much higher level than household growth projections for the Borough published by the Office for National Statistics, whilst in relation to the villages, it represents an over extension of the village envelope contrary to the expressed preferences of the local community and the principal of plan led development (NPPF) Such developments, were they allowed to proceed, would put immeasurable pressure on already oversubscribed schools.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10556
Received: 24/08/2025
Respondent: Damon Leonard
I&O_11054
in the right place yes.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10615
Received: 28/08/2025
Respondent: Mrs Helen Dodd
FRO01 FRO02 FRO03
I&O_11113
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. When there is an incident on the M56 the entire surrounding area is gridlocked, emergency vehicles find it difficult to access the area. 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. The is road has large sections where there is only a narrow pavement on one side and cars drive at speeds of over 40mph. Traffic through the area is so heavy that a plan to close the Sutton Weaver bridge to allow for repairs had to be abandoned due to the traffic chaos that this would cause. Focussing on the rail line as a centre of transport links is also a poor choice as these trains are often unreliable, have poor times for commuters and so many commuters use their cars, adding to already congested roads.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10642
Received: 28/08/2025
Respondent: Sandra Stonham
Agent: Marrons
I&O_11140
No, there is no justification for not delivering a lower housing requirement than 1,914 dpa. The government updated the NPPF in December 2024, introducing a revised ‘standard method’ for calculating minimum housing need for each local planning authority in England. The rationale behind this update is to support the government’s growth agenda and ambition to deliver the targeted 300,000 dwellings per annum (dpa). Using this new method, the housing target CW&C is a minimum of 1,914 dpa. Over a proposed 15-year period for the new Local Plan, this equates to a total figure of 28,710 new homes. This is a significant increase from the current Local Plan’s minimum of 1,100 dpa, equating to 22,000 new homes over the plan’s 20-year period. Whilst the government has implied that under certain circumstances, LPAs may be able to justify a lower housing requirement than the standard method figure due to local constraints on land and delivery, we understand there to be no clear reason why this would be the case for CW&C. The area that falls within the Council’s administrative boundary is very large, with multiple key settlements and no environmental constraints affecting the district as a whole, only policy constraints. To deliver the new minimum 1914 dpa, the Council will need to consider how to manage constraints to growth and housing delivery, as well as infrastructure provisions. For example, reviewing designated Green Belt land and Key Settlement Gaps. The findings of the Stage One Land Availability Assessment (LAA) (2025) estimate a total capacity of 2,731 units in Northwich, which is the highest figure out of the 4 largest urban areas in the Plan’s spatial strategy (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. Preferential consideration should be given to sites that are strongly aligned with the Local Plan’s objectives, such as our client’s Site at Davenham which is highly sustainable and supported by the local community.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10710
Received: 28/08/2025
Respondent: Roberts Bakery
Agent: SATPLAN Ltd
I&O_11208
No. Meeting identified housing needs is a statutory requirement under national planning policy. The plan must ensure housing delivery aligns with the objectively assessed need (OAN) to avoid underprovision, which could lead to unsustainable pressure on neighbouring authorities and infrastructure. To meet the revised housing target of 28,710 homes by 2040, the Local Plan must plan proactively and effectively distribute growth. Forecasts show continued population growth across the borough, including an ageing population and smaller average household sizes, which increase overall housing demand. In addition, a mix of housing types and tenures supports a diverse workforce and helps sustain local services, schools, and businesses. The significant need to identify suitable land to deliver a minimum of 1,914 dwellings in CWAC each year is substantial. The consultation document acknowledges that previously developed land will be considered for development first but greenfield and Green Belt land may also be necessary to accommodate hosing need. This Site offers the potential to deliver some housing growth alongside maintaining employment uses.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10771
Received: 28/08/2025
Respondent: Hayfield Homes
Agent: AshtonHale
I&O_11269
The Council must plan to meet the Standard Method Requirement of 1,914 new homes per year in full as a minimum. In accordance with Paragraph 62 of the NPPF, “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.” There is no reason for the Council not to plan for delivering this minimum figure. This figure represents a baseline figure for the Council to achieve and there is clear scope to exceed this number where justified. If the Council do not feel that they can meet the Government’s housing targets within the current identified Local Plan settlements, the Council must look to bring forward Green Belt sites for development to achieve these targets. Green Belt sites, much like Land off Church Street, represent Grey Belt land, are in sustainable locations and offer the Council the opportunity to achieve these housing need figures. Paragraph 73 of the NPPF notes that that planning policies should identify a supply of specific, deliverable sites sufficient to provide a minimum of five years’ worth of housing, with an appropriate buffer to ensure choice and competition in the market. The release of Green Belt land in sustainable locations are well-placed to support this objective and contribute to a more resilient and responsive housing land supply. Land off Church Street offers a logical and justified opportunity for Green Belt release, closely related to Northwich and existing service provisions, public transport links, and proximity to centres of employment and amenities.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10859
Received: 28/08/2025
Respondent: Mr and Mrs . Hall
Agent: Urban Imprint Limited
I&O_11357
It is acknowledged that the number of new homes required across the plan area is significant, however, this seems appropriate given the proximity of the larger metropolitan centres within the north-west and the good transportation connections within the area. There are also significant affordability issues within all but a few settlements in the local areas. Whilst there are constraints within the Borough there is still a significant proportion of both greenfield and previously developed land which is free from ‘showstopper’ constraints. If we consider the Borough (as a whole) against the items identified in footnote 7 of the NPPF, notwithstanding some constraints there is still land within and surrounding the main urban centres that would be suitable for accommodating new housing growth. Considering the functional economic market areas (FEMA) which exist within the area (FEMA) alongside the authority’s relationship with surrounding boroughs, there may be further points for consideration. Recent changes to housing figures have affected all the neighbouring authorities – particularly Cheshire East who equally are unable to meet their housing needs with their current plan. Whilst recent plan adoptions in Wirral and Warrington are somewhat immune from these changes (under the transitional arrangements), the fact that their plans still fail to deliver the newly published objectively assessed needs highlights that this demand will still need to be accommodated elsewhere. Given the close relationship between these authorities and the shared FEMA it seems sensible that the Authority speak with neighbours to understand how collectively this can be addressed within both the Chester housing market and the south-Manchester housing market. As a final point, it may help the plan to be understood more logically if the housing requirement was perhaps rounded up to 2000 from 1914.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10929
Received: 28/08/2025
Respondent: Weaverham Parish Council
I&O_11427
Yes, if it means losing Green Belt or Farmland that we need for food security.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 10969
Received: 28/08/2025
Respondent: Mayo Civil Engineering
Agent: Euan Kellie Property Solutions
I&O_11467
support the Spatial Strategy promoted by this policy approach.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11154
Received: 28/08/2025
Respondent: Satnam Investments Ltd
Agent: Satnam Planning Services Limited
I&O_11652
The introduction of a new standard methodology (SM3) by the Government in December 2024 has significantly increased CWaC's local housing need (LHN) from 532 dwellings per annum (dpa) (calculated using SM2) to 1,928 dpa, an increase of +262%. CWaC's current LHN is also significantly higher (+43%) than the Council's currently adopted housing requirement of 1,100 dpa in its Part One Local Plan (LPPl). The National Planning Policy Framework (NPPF) (published in December 2024 and amended in February 2025) sets out the Government's policy in respect of housing and other matters. It states that, to determine the minimum number of homes needed, strategic policies should be informed by a LHN assessment, conducted using the standard method set out in national planning practice guidance (PPG). In this regard, it is important to recognise that SM3 sets only the minimum housing The NPPF goes onto outline that 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. The possible policy approach outlined at SS 1 (Housing Needs) of the LPIO consultation document sets out a policy approach of planning for a minimum of 1,914 new homes each year over the plan period. As this is a minimum housing requirement and can be exceeded, we would strongly recommend that the Council proactively plans to maximise housing delivery across the plan period, putting steps in place now to ensure plan-led development to best achieve the objective of supporting a vibrant, diverse and competitive local economy with sufficient flexibility in the supply to respond to unforeseen circumstances and guard against speculative development in unsustainable locations. This will also help to maximise the longevity of the Council's emerging Local Plan by reducing the likelihood of CWaC's housing requirement needing to be reviewed within five years of the Plan's adoption. Indeed, since the publication of the LPIO consultation document the SM3 figure has already increased to 1,928 dpa having regard to the latest stock and affordability data. This still represents the minimum amount of housing development that should be planned for, but it is likely to continue to increase incrementally over time as housing prices increase due to constrained supply, and wage growth fails to reflect that localised house price inflation. This points to a need to plan for a higher requirement, even without uplifts for other factors such as economic growth and strategic needs. CWaC has not escaped the national housing crisis, with rising house prices worsening the Borough's historic affordability This is in turn making it increasingly difficult for younger residents to remain in the Borough, pricing out the economically active future generations to other areas that offer a wider range of more affordable housing options. For example, house prices have grown by over 225% since 2000 in CWaC, with median average house prices at £245,000 as of December 2024. This is c.19% higher than the regional average of £206,000. The private rental market across the Borough is also becoming increasingly less affordable due to the increasing costs of rental properties driven up by rising demand. Private rents averaged £926 per month in June 2025, an annual increase of 9.3% from £848 in the previous year. 2 This is pricing people out of private-rented accommodation. The Borough is currently failing to meet the requirements of the NPPF to ensure an appropriate size, type and tenure of housing needed for different groups in the community is available, including people who rent their homes. Increasing the supply of a wide range of housing, including affordable properties, is critical to help meet this demand. A key focus of both the Council's current and emerging development plan is to provide opportunities for economic growth and investment, with an emphasis on delivering a range of job opportunities to support sustainable communities. Strong levels of housing delivery are key to a properly functioning, sustainable For example, providing a wide choice of housing, particularly affordable dwellings, will allow the Borough's younger residents to access and move up the housing ladder, enabling them to live and work in CWaC. Additionally, a diversified housing market will attract more skilled workers to live in Chester, promoting sustainable commuting patterns and strengthening CWaC's labour pool. This in turn will help to increase inward investment to the Borough, raising CWaC's profile as a sought-after place to live and bringing with it new job opportunities, particularly within the construction and housebuilding sectors. There is therefore a very strong and fully justified case to be made that CWaC's housing requirement should meet and, in all probability, exceed its current SM3 figure in order to best achieve the area's growth ambitions in accordance with the NPPF. CWaC should be seeking to maximise residential development in the most sustainable locations such as Chester City, across a wide range of tenures in its emerging Local Plan, particularly affordable properties, to reverse the Borough's affordability pressures and improve accessibility to high quality housing. This in turn will help to create inclusive, diverse communities that promote social wellbeing and increased economic productivity.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11156
Received: 28/08/2025
Respondent: Satnam Investments Ltd
Agent: Satnam Planning Services Limited
I&O_11654
The effect of the assessment (summarised in Table 2) is that the Council must identify an additional 6,334 dwellings against a 5-year housing requirement of 10,122 dwellings when applying the relevant This is a significant number of houses that the Council must identify to mitigate the ability for speculative residential applications to come forward on the basis of a lack of SYHLS. This shortfall will only increase if the Council takes our advice and plans for a housing requirement that exceeds its LHN. It is therefore essential that the Council allocates a wide range of sites, including both smaller sites as well as larger, more strategic, housing allocations that have high prospects of coming forward within a five year This will need to avoid backloading supply in the later years of the plan period. Smaller sites are less likely to have significant technical or physical constraints to impact delivery and are typically more capable of being brought forward in the early part of the plan period to address identified needs in the shorter term. These 2 land interests on the edge of Chester are available, achievable and deliverable and should therefore be allocated for residential development to come forward in the early part of the plan period. The sites will make a strong contribution to CWaC's SYHLS, accounting for the Council's significantly higher housing requirement. Furthermore, we have concerns that the total housing capacity of sites identified in the Council's Land Availability Assessment (LAA) (Stage One) (April 2025) could fail to meet CWaC's overall housing requirement for the plan period. The LAA estimates a total capacity of 28,924 dwellings, which is only slightly above the Council's total minimum housing requirement of 28,710 homes based on SM3. The Council has failed to incorporate a suitable buffer in its supply should the identified sites not come forward at the rate they expect or fail to come forward at all. The lack of any kind of meaningful buffer to the figures means that the Council's current supply figure will not meet or exceed its housing requirement, which is likely to put additional strain on the Council to allocate a considerable number of housing sites as part of a future Local Plan To mitigate this, the Council should build in sufficient flexibility to its supply to ensure needs are met in full (as a very minimum). We would recommend that the Council takes a more proactive approach and seek to exceed its The Council should therefore review its housing land supply in this context. Whist we welcome the consideration of both these land interests in the Council's LAA under references 1930 (Land at The Dale, west of Liverpool Road, south of Percival Close, Upton, Chester) and 1416 (Land off Warrington Road (A56), Hoole, Chester), it has concerns regarding the methodology used to assess the Borough's land availability. The Council's methodology, which removes sites containing more than 10% of land located in the Green Belt from further assessment in Stage One of the LAA, is clearly flawed. The LAA states that sites may be revisited as a result of the review stage of the LAA, or as part of the plan making process. Regardless of whether sites are located in the Green Belt or not, they should not be discounted at this stage. Instead, they should be taken forward for further consideration on the basis that allocating the most sustainable, least constrained Green Belt sites will be required to ensure the emerging Local Plan has the greatest prospect of being found sound at Examination. It is critical that sites around the edges of Chester in particular (to includes refs. 1930 and 1416) are considered further through the emerging Local Plan, by taking them forward into Stage Two of the Assessment. This will allow the Council to identify the most sustainable sites around Chester, a top-tier settlement already heavily constrained by Green Belt, for a residential allocation through the emerging plan.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11238
Received: 28/08/2025
Respondent: Habiko LLP (c/o Muse)
Agent: Turley
I&O_11736
The Government published updated dwelling stock figures in May 2025 which means that CWAC’s local housing need (‘LHN’) figure has further increased to 1,914 dwellings per annum (‘dpa’); an increase of 14 dpa, which equates to a total of 28,920 dwellings over a 15-year plan period and 38,560 dwellings over a 20-year plan period. The Council is advised to keep the precise figure under review, as further affordability and housing stock data will become available before the Regulation 19 consultation scheduled for autumn 2026.In accordance with the NPPF, the standard methodology for assessing local housing need in England and the July 2024 Written Ministerial Statement – “Building the Homes we need” – this is the minimum housing need figure that should be considered in preparing the emerging Local Plan. Furthermore, in line with paragraph 69 of the NPPF, the Council may also need to consider if it is appropriate to plan for a higher housing need figure than the standard method indicates to reflect growth ambitions linked to economic development or infrastructure investment. In summary, Habiko does not consider there to be any justification in planning for a lesser number of units than the LHN requirement.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11253
Received: 28/08/2025
Respondent: Mary Eveleigh
I&O_11751
I am responding to the Cheshire West Planning ideas for the area. In answer to question SS11. Option A - Retain the Green Belt.
Option A - Retain the Green Belt
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11281
Received: 28/08/2025
Respondent: Frodsham Town Council
I&O_11779
No
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11501
Received: 28/08/2025
Respondent: CPRE Cheshire Branch
I&O_11999
CPRE is aware that local authority minimum housing targets are imposed by central government and are based on a new standard calculation method (which CPRE believes is flawed). In the case of Cheshire West and Chester, their imposed target is now 1,914 homes per year – a total of 28,710 over a 15-year period as stated on page 22 of the consultation document – representing a 260% increase on previous housing growth plans. And, as also explained on page 22, the only way local authorities can hope to lower their housing requirements is if they can make successful, evidenced, arguments about land constraints, protected habitats, flood risk areas and/or the existence of National Parks. CPRE recognises the need to tackle the housing crisis but the new over-arching minimum housing figures imposed for CWaC and many other local authorities make little sense. A fundamental weakness of the Government’s standard method is that it lacks any basis in local demographic data. CPRE is currently looking at this issue nationally with a view to lobbying the Government further on it. In previous years a key “starting point” in identifying a housing target for local authorities has been to look at the household projections for each local authority, published periodically by the Office for National Statistics (ONS). Previous versions of the standard method have done this. Unfortunately, the latest available ONS household projections are still 2018 based, so very dated now. The projections for each district – set out in table 406 - also vary according to which Plan period is assumed, and other factors such as any past under-delivery may need to be taken into account. Despite these reservations however the household projections nevertheless have value as a “sense check” of the proposed target. If one assumes a Plan period of 2027-2042 for CWaC (15 years from CWaC Council’s albeit ambitious adoption date of 2027) the total projected household growth is 15,289 over a 15-year period, or 1,019 dwellings on average per annum1. The current method therefore shows a level of increase (1,914 dwellings per annum) which is almost double that set out in the ONS projections. Despite the reservations about reliance on the projections (set out above) CPRE considers the standard method output of 1,914 dwellings per annum is likely to be excessive. almost double that set out in the ONS projections. Despite the reservations about reliance on the projections (set out above) CPRE considers the standard method output of 1,914 dwellings per annum is likely to be excessive. It is also likely that the increased housing target, whilst being used by developers to justify planning permissions on unsuitable greenfield sites, will not actually increase delivery to the extent envisaged. This is due to the current shortage of materials and trained labour and as local authorities and housing associations are not in a financial position to be able to contribute much via direct provision to the type of housing needed. (We note that, in July, the MHCLG named 10 Councils which will be involved in co-designing a £5.5m programme to increase council-led housebuilding, but how this will work is still not clear and the scheme is far from being rolled out across the country). Meanwhile, commercial providers will only ever supply housing which makes them sufficient profit – and at a pace of their own choosing that does not swamp the market. In other words, CPRE fully comprehends the current complex situation and cannot see how the government’s aspiration to provide 1.5 million homes nationally in the period of this parliament is realistic. As far as CW&C is concerned, we acknowledge that national policy substantially constrains the grounds on which the housing targets may be challenged. However, one factor that should be considered is the flood issue due to the rising sea level and increased rainfall and the low-lying nature of the vast majority of the Borough. The current flood risk areas (taking account of both riverine and surface water flooding as identified on the Government’s flood risk map at https://check-long-term-flood-risk.service.gov.uk/map) are extensive. We would also point to the ‘State of the UK Climate Report for 2024’ which was released in July 2025 by the Met Office (see https://www.metoffice.gov.uk/about-us/news-and-media/media-centre/weather-and-climate-news/2025/annual-climate-stocktake-shows-weather-records-and-extremes-now-the-norm-in-uk-climate and https://rmets.onlinelibrary.wiley.com/doi/10.1002/joc.70010). Whilst this just shows rainfall from one year (2024) it is indicative of the rapidly changing and unstable climate which is likely to increase flood risk in the future. See the image below lifted from figure 20 on page 22 of the report: Met Office – issued 2024 Rainfall Amount [see attachment page 7] 1The figure of 15,289 is derived by deducting the projected household total for 2027 (158,999) from that for 2042 (174,288) from table 406 available at https://www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/populationprojections/datasets/householdprojectionsforengland.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11588
Received: 28/08/2025
Respondent: Landowners (Norley)
Agent: Woodford Land and Planning Limited
I&O_12086
The landowners fully support suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough as mandated by the Government’s Standard Method. In accordance with Government policy, Council’s must seek to, as a minimum, meet their local housing needs, informed using the Standard Method (including meeting the needs of neighbouring Authorities if appropriate); unless there are strong reasons why an Authority cannot do this. Paragraph 11 in the NPPF states that “For plan-making, this means that: b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. The landowners do not consider that there is any strong reason for restricting development in CWaC, nor would doing so outweigh the benefits of meeting the Borough’s identified housing needs. As such, CWaC should plan for 1,914 new homes per annum, as an absolute minimum (and subject to considering neighbouring Authorities needs as part of its Duty to Co-operate).
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11674
Received: 28/08/2025
Respondent: Beck Homes Limited
Agent: NJL Consulting
I&O_12172
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 Cheshire West and Chester (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
Local Plan Issues and Options (Regulation 18)
Representation ID: 11983
Received: 28/08/2025
Respondent: Welsh Water
I&O_12497
We note that the suggested policy approach is to plan for the delivery of a minimum of 1,914 new homes each year with 3 options (A, B & C) under consideration regarding how best to spatially distribute this growth. To ensure development is deliverable it is essential that there is adequate sewerage infrastructure. Welsh Water’s capital investment is undertaken through a five-yearly Asset Management Plan (AMP) programme. The AMP8 programme is currently being delivered which covers investment for the period 2025-30, this will be followed by AMP9 for 2030-2035, AMP10 for 2035-2040 etc. Funding for capital investment is raised through customers’ bills. We aim to ensure that sufficient infrastructure exists for domestic development, and we seek to address deficiencies through capital investment in our AMP. We must put forward a business plan for investment for each AMP cycle, and to ensure that customer’s money is invested appropriately we require some certainty in terms of growth areas and site development proposals. An adopted Local Plan with allocated growth helps strengthen the case Welsh Water can put forward to our regulator Ofwat in relation to projects requiring AMP funding. The Local Plan is anticipated to have a 15-year timeframe therefore any infrastructure investment required at our Wastewater Treatment Works (WwTWs) can be considered for delivery in future AMPs. The impact of new housing on our sewerage networks will be dependent on the spatial distribution of this proposed growth, and the impact of development on our Wastewater Treatment Works (WwTW) will be dependent on the amount of growth within their catchment areas. Where the total growth identified exceeds the theoretical design capacity of our WwTWs then reinforcements to provide further capacity will be required during the Local Plan period.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 11999
Received: 29/08/2025
Respondent: Mr and Mrs R Basford
Agent: Grimster Planning
I&O_12513
No. The Council’s new Local Plan should plan positively for growth consistent with paragraph 36(a) of the NPPF. The latter is clear that Local Plans should provide a strategy which “as a minimum seeks to meet the area’s objectively assessed needs.” Based on the Local Housing Needs Figures published by the Government in December 2024, the Council should therefore plan for the Local Plan’s development and spatial strategy to deliver 1,914 dwellings per year across at least a 15-year period, as a minimum (and any subsequent adjustments to this figure). Given that the adopted Local Plan covers a period of 20 years, there is no reason why a new 20-year Local Plan period could not be advanced.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12053
Received: 29/08/2025
Respondent: Beneficiaries of E C Francis
Agent: Grimster Planning
I&O_12567
No. The Council’s new Local Plan should plan positively for growth consistent with paragraph 36(a) of the NPPF. The latter is clear that Local Plans should provide a strategy which “ as a minimum seeks to meet the area’s objectively assessed needs.” Based on the Local Housing Needs Figures published by the Government in December 2024, the Council should therefore plan for the Local Plan’s development and spatial strategy to deliver 1,914 dwellings per year across at least a 15-year period, as a minimum (and any subsequent adjustments to this figure). Given that the adopted Local Plan covers a period of 20 years, there is no reason why a new 20-year Local Plan period could not be advanced, particularly given the considered need for strategic Green Belt release across the Borough; this would allow for amended Green Belt boundaries to endure for a longer period.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12254
Received: 28/08/2025
Respondent: Gary Rogers
NOR10, NOR11, NOR12
I&O_12768
Will housing be based on a local need assessment and not a central government target. Will there also be provision for housing for the elderly? Census data shows that over 55’s are an increasing population. Census data shows 67.3% over 16’s in the area are not in employment and have not worked in the last 12 months. Who are the houses being built for?
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12371
Received: 28/08/2025
Respondent: Mr James Caldwell
I&O_12887
What are the combined authority needs, limited vision costs in the long term.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12403
Received: 29/08/2025
Respondent: Muller Property Group
Agent: Walsingham Planning
I&O_12920
No. The Council should provide for at least the required minimum number of homes over the plan period.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12429
Received: 28/08/2025
Respondent: Barbara Rogers
I&O_12946
Will housing be based on a local need assessment and not a central government target. Will there also be provision for housing for the elderly? Census data shows that over 55’s are an increasing population. Census data shows 67.3% over 16’s in the area are not in employment and have not worked in the last 12 months. Who are the houses being built for?
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12449
Received: 29/08/2025
Respondent: Carden Group
I&O_12966
We welcome the Council’s acknowledgment of the need to meet the housing requirement identified by the Government’s standard method. However, we strongly urge the Council to plan for a housing requirement above the 1,928 dwellings per annum (dpa) baseline figure (based on the latest May 2025 affordability ratios). This position is entirely consistent with the NPPF which makes clear at paragraph 11(b) that the standard method provides only a minimum starting point for assessing housing need. Planning for a higher figure is not only justified by national policy but essential to delivering a robust Local Plan. In the case of Cheshire West and Chester, there is clear and compelling evidence that a higher figure can be delivered sustainably. For example, according to the Council’s latest 2025 Housing Land Monitor report, between 2014/15 and 2024/25, annual completions have consistently exceeded the 1,100 dpa housing target, peaking at 2,542 dwellings in 2017/18. Over this 11-year period, the Council has over-delivered by more than 9,000 dwellings against the adopted Local Plan target, evidencing both market appetite and delivery capability. In light of the evidence, we recommend that the Local Plan sets a housing requirement of at least 2,200 dwellings per annum. This represents a modest uplift of around 15% above the standard method figure, which is substantially lower than the average over-delivery of 54% the borough has achieved since 2014. This proposed figure is both realistic and deliverable, based on the area's consistent track record of strong housing delivery. Setting a higher requirement not only reflects market capacity but ensures the Local Plan remains robust, responsive to change, and capable of supporting long-term economic growth and housing affordability.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12475
Received: 28/08/2025
Respondent: Vicky and Michael Mainwaring
I&O_12992
- Will housing be based on a local need assessment and not a central government target. - Will there also be provision for housing for the elderly? Census data shows that over 55’s are an increasing population. - Census data shows 67.3% over 16’s in the area are not in employment and have not worked in the last 12 months. Who are the houses being built for?
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12578
Received: 28/08/2025
Respondent: Mr Ronald Jones
I&O_13095
Will housing be based on a local need assessment and not a central government target. Will there also be provision for housing for the elderly? Census data shows that over 55’s are an increasing population. Census data shows 67.3% over 16’s in the area are not in employment and have not worked in the last 12 months. Who are the houses being built for?
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12612
Received: 28/08/2025
Respondent: David Varley
I&O_13129
The target of building 1,914 homes each year is a massive increase in the house building targets set in recent years; development on this scale is going to have a radical effect on the size, nature and characters of settlements in the area. It will, inevitably, lead to the destruction of Green Belt land and other valuable natural areas, and will transform character-filled towns and villages into characterless acres of urban sprawl. The house building target should be significantly reduced to allow limited development that is sustainable, in keeping with the area, does not overload local services, and does not destroy the essential nature of our towns and villages.
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12690
Received: 28/08/2025
Respondent: C Harvey
I&O_13207
YES there is already property available they could use, houses currently for sale, derelict houses, brown belt land. The council just needs to investigate this more properly and not work on set targets and key performance indicators (KPI’s).
Comment
Local Plan Issues and Options (Regulation 18)
Representation ID: 12751
Received: 28/08/2025
Respondent: Andrew Paterson
I&O_13269
The council should not build houses if it has adverse or detrimental effects on the areas which they are proposed to be built on. Building new housing should be done in a sustainable way which allows them to be integrated easily. There should be adequate local amenities available to cope with any additional housing and if not the council should mandate developers provide this facilities if there is insufficient capacity to support any new housing. Housing should be built on brownfield sites first and any underdeveloped/underused land. Large housing developments on greenbelt land should not go ahead due to loss of more local green space and habitats.