Comment

Representation ID: 12873

Received: 29/08/2025

Respondent: Hannah Beswick

I&O_13392
Yes, this number should be challenged as far as possible. Whilst it is based on the government’s housing target, it does not account for areas of green belt, flood risk, designated sites or areas of subsidence. Cheshire West and Chester does not have the infrastructure, medical facilities or educational facilities to accommodate such an increase in housing. The level of growth is not sustainable and would not be in line with the proposed policy on sustainable development (SD 1).

Comment

Representation ID: 12888

Received: 29/08/2025

Respondent: Dorothy Gamble

I&O_13407
Empty Homes There are no current accurate figures available from either the government or local council. Therefore, it would follow that it would be impossible to calculate the need and sanction several thousand new build houses across the Borough. According to government figures there are approximately between 700,000 and 720,000 empty houses within the UK.  Recent Property Investment UK data from March 2025 indicates there are over 272,000 long term empty homes across England. Cheshire West and Chester Council stated in their March 2021 Empty Homes Strategy Report that the Borough held 4302 empty homes, with an excess of more than 2000 of which were classed as long-term empty at that time. What are the current figures and why is CWAC sanctioning the building of new houses when they don’t appear to know how many empty houses exist at this moment in time. Unnecessary new builds put an unacceptable extra strain on an already stressed infrastructure in Davenham.  Since 2016 there has been considerable construction of new built homes already in Davenham and surrounding areas.

Comment

Representation ID: 12982

Received: 29/08/2025

Respondent: Alexandra O'Toole

NOR10, NOR11, NOR12
I&O_13501
Proposed Housing Areas NOR10, NOR11, NOR12 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

Representation ID: 13008

Received: 29/08/2025

Respondent: Consortium of Housebuilders

I&O_13527
On behalf of Barratt Homes, Redrow Homes, David Wilson Homes & Taylor Wimpey please accept this email and attached Research Paper as a formal representation to the Local Plan Issues and Options (Regulation 18) Consultation. Given the early stage in the plan preparation process it is essential that the benefits of housing development are fully understood, including the relationship with wider economic growth aspirations. The Paper seeks to objectively assess the benefits of CWaC delivering at least the current standard methodology housing figure of 1,928 dwellings per annum.  

Comment

Representation ID: 13182

Received: 29/08/2025

Respondent: Charlie Parker

I&O_13701
Further to the Council’s consultation on the above, I am writing to set out at a high level my concerns and objections to what is being proposed for Winsford Growth Area and the proposals for Cuddington / Sandiway and Tarpoley. Whilst I acknowledge and accept that we as a country face a significant housing shortage and there is a need to build more housing units, I think the proposals show a lack of understanding about the scale and impact of the proposed expansion /growth proposals. In particular, the encroachment into the green belt is in the majority of cases in direct conflict with some of the key underlying principles such as, the protection and sustainability of agricultural land and food growing opportunities. This impacts on a significant number of sites that are currently in active agricultural use as well as, the need to protect local habitats which is contrary to the HRA Assessment. In particular this impacts on many of the proposed sites identified in the Winsford growth plans and Housing sites in Cuddington and Sandiway along with, those in Tarpoley. Whist I think the concept of building alongside and or on Transport corridor routes has a lot of merit, reading the plans as presented to date, these feel very theoretical and don’t reflect some of the actual challenges around existing uses including extinguishment and relocation costs. It feels like someone has just taken a pen to highlight a line for possible future development. The strategic priority to ensure that any future development is supporting increase in local infrastructure and key community facilities is to be welcomed. Yet, the policy has not been fully implemented in delivering recent local plan housing developments. A lack of which has seriously impacted on local road, utility, health, education and community facilities necessary to keep up with the growth in housing numbers. Indeed a very recent example of which is the planning proposals for the Redrow/David Wilson Homes development along Dalesford Lane. In the recent consultation there are no plans for any infrastructure improvements and when pushed the developers just said that they would ‘negotiate with the planners for a commuted sum to be agreed and allocated’. At no point were they interested in talking about the impact on junctions, access points onto the three sites, the impact on the existing infrastructure or, future education and health services. They had no information that they would share on the EIA or TIA work that they had undertaken and the level of affordable housing proposed was lamentable. If you look at your proposals for Cuddington/Sandiway and Tarpoley they all will exacerbate the already creaking local infrastructure issues and impact on the character and historic nature of many of these rural communities. Again, the plans look as if no one has actually gone out and looked at the key sites and thought through the unintended consequences that would potentially undermine, your four key underlying principles for the revised local plan. Significantly more work needs to be undertaken on the draft plans and proposals. The need to consider the numbers involved, housing types and tenure - for example downsizing and affordable housing requirements - the land use and zoning proposals and the implications for sustainability and future infrastructure all need reviewing.

Comment

Representation ID: 13335

Received: 29/08/2025

Respondent: Landowner (Manor Park)

Agent: Carden Group

I&O_13854
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

Representation ID: 13418

Received: 29/08/2025

Respondent: Harworth Group

Agent: Turley

I&O_13937
Harworth acknowledges the recent update in the Government’s dwelling stock figures, which now sets the housing need for CWAC at a minimum of 1,928 dwellings per annum. This represents an increase of 14 dwellings per year, totalling 28,920 dwellings over a 15-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. The outcome of the method is currently some 75% higher than the existing housing requirement, adopted in Part One of the current Local Plan. While this has been comfortably surpassed during the plan period to date, it would still require a 29% boost in delivery, albeit not to unprecedented levels as up to 8% more homes have been consistently completed within five-year periods therein. (See Figure 6.1 in attachment) In accordance with the NPPF, the standard method 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. Paragraph 69 of the NPPF recognises that 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. It is recommended that this forms part of the scope for the Housing Needs Assessment (HNA) that is seemingly “ to be prepared ”. Harworth believes that this evidence must be robust and comprehensive so as to ensure that the Local Plan effectively meets the housing needs of the Borough. It should use evidence from the 2021 Census to consider the type and size of housing required, acknowledging that in CWAC all but individuals living alone generally favour larger homes, with at least three bedrooms. Over a third of couples and unrelated adults – captured in the “other households” category shown below – have at least four bedrooms, with a number even having at least five. (See Figure 6.2 in attachment) Compared to the equivalent findings from the 2011 Census, the tendency to live in larger housing in CWAC has notably risen amongst virtually all groups, with lone parents being the only exception. It will clearly be important for any HNA to acknowledge and account for this trend, so that the Local Plan can respond by setting realistic expectations around mix and allocating suitable sites. (See Table 6.1 in attachment) The HNA should also consider the need for affordable housing, to replace what is believed to remain the latest such assessment completed over twelve years ago (Cheshire West and Chester 2013 Strategic Housing Market Assessment (Arc4)). This should aim to tackle a persistently long waiting list, on which some 6,656 households were registered as of March 2024 (Table 600: number of households on local authority housing registers (waiting lists) by district, England, from 1987 (MHCLG)). (See Figure 6.3 in attachment) A viability assessment should also be conducted to determine what types of homes are financially deliverable in CWAC, particularly regarding the provision of affordable homes and other housing demands. Both this and the HNA should be made available for future consultation to ensure transparency and allow stakeholders to provide input on how the housing needs of the Borough can be best addressed.  The emerging Local Plan must also ensure that there is a sufficient supply of deliverable and developable land to both meet CWAC’s housing requirement and deliver the types of homes needed. This will not only help deliver the necessary homes each year but also ensure that the Council maintains a 5-year housing land supply and meets the Housing Delivery Test. Additionally, Harworth strongly recommends that the Local Plan allocates more sites than the minimum required to meet the housing target, creating a buffer to address any potential under-delivery from certain sites and to provide flexibility within the housing market. This approach would align with the NPPF’s requirement for the Local Plan to be positively prepared and would help ensure flexibility, choice, and resilience in the housing market. In summary, Harworth recognises the need for the Local Plan to plan for a minimum of 1,928 new homes per year, as this complies with the NPPF and reflects the updated housing need. However, Harworth is of the view that this should be kept under review given that underlying datasets will be updated again before the next consultation. To ensure the plan’s success, we recommend comprehensive evidence gathering on housing needs and viability, along with the allocation of additional sites to provide flexibility in meeting housing needs and addressing any future shortfalls. This approach will support the long-term development of CWAC, meeting housing demands while supporting economic growth and sustainable development.

Comment

Representation ID: 13671

Received: 29/08/2025

Respondent: Mr Alan Latham

I&O_14190
I have looked at the above documentation and my overall conclusion is that, no matter what the view of the average CWAC inhabitant is, the current government's declared intent to build a significant number of additional houses will outweigh anything in comment contribution that is made.

Comment

Representation ID: 13897

Received: 03/10/2025

Respondent: Richard Cheetham

I&O_14417
Cheshire West and Chester must plan for at least 1,914 new homes per year, nearly 29,000 homes over 15 years based on national calculations. This is much higher than the current plan’s target of 1,100 homes per year. The new plan will need to decide how to distribute this housing across the borough in a sustainable way. It must also ensure homes meet different needs e.g. affordable housing, family homes, homes for older people, and Gypsy and Travellers. Sites will need to be assessed for sustainability, i How can you impose this quantity of house building applications when we have no Doctors Surgery,  Dentists full Schools full, Roads full, poor transport infrastructure including no rural bus poor train service and link between bus and train times. Country Roads not fit the increase in volumes proposed. Rat runs develop because A roads full. This is not NIMBY this is NOGS ( not on greenfield sites ) or NWNI ( not with no infrastructure).

Comment

Representation ID: 13957

Received: 29/08/2025

Respondent: Landowner (Forest Road)

Agent: Carden Group

I&O_14477
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

Representation ID: 13995

Received: 29/08/2025

Respondent: Rachael Bourne

I&O_14519
My overall feeling is that there should be pushback on housing no.'s you are expected to provide. Cheshire has historically delivered well above the required level of housing and the number of houses they are expected to provide should take into account the housing credit that Cheshire West is in. 

Comment

Representation ID: 14028

Received: 29/08/2025

Respondent: Landowner (Cogshall Lane)

Agent: Carden Group

I&O_14565
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

Representation ID: 14062

Received: 29/08/2025

Respondent: Caroline Hall

I&O_14605
A careful assessment of the ‘true’ housing needs and population growth within CWAC, for the period of this updated plan, should be carried out. This is required to ensure there are suitable services to support the expansion in housing and that unnecessary housing is not built. CWAC should also have the powers to say no to development if it is not suitable for the area/there are no services to support the additional homes. As part of any planning application, building companies should provide buildings for the community e.g. shops, GP surgeries, schools etc as deemed necessary for the area. There should be no option for a building company to start the build and then submit a request for any previously agreed service provision to be negated upon. I would like to close with the comment that this amount of building seems totally unacceptable and CWAC should be pushing back to the government and stating how this would ruin the natural beauty of the area, which should be valued. 

Comment

Representation ID: 14076

Received: 29/08/2025

Respondent: Caroline Hall

I&O_14619
As CWAC contains large areas of agricultural, the area has the ability to produce a lot of food for the country. Therefore the council should define an argument for having lower housing stock in CWAC and protect the agricultural areas.

Comment

Representation ID: 14198

Received: 29/08/2025

Respondent: Taylor Wimpey

Agent: Lichfields

I&O_14742
Taylor Wimpey supports the Council’s use of its LHN figure in the emerging Local Plan as a minimum figure, as it enables proactive planning to meet housing needs. The government has recognised that there is a severe housing crisis in England, characterised by a significant shortage of affordable housing to meet the needs of the population. As such, the government has set a clear objective of significantly boosting the supply of homes in order to meet a target of 1.5 million homes within their 5-year term. The housing shortage is also evident within CWaC, which has experienced affordability issues across the Borough. The Issues and Options Plan recognises this, noting awareness of the  unaffordability of housing in parts of Cheshire West and how many young people and those on lower incomes struggle to access the housing market (page 23). Policy SS1 states that the Council plans to deliver a minimum of 1,914 new homes per year over the plan period. For a 15-year plan, this equates to a total of 28,710 new homes. This minimum figure is based on the Council’s Local Housing Need [LHN] as of December 2024, calculated using the revised stock-based methodology introduced alongside the December 2024 iteration of NPPF. Taylor Wimpey considers that the Council should seek to meet its identified need in full, in line with the NPPF (para. 61), to ensure issues of affordability can be adequately addressed and the objectives of the NPPF can be realised. Furthermore, as set out previously, the 1,914 dwelling requirement is no longer reflective of the current LHN. Following the release of updated housing stock data and March 2025 affordability ratios, the Council’s LHN is now 1,928 dpa. Accordingly, the policy should reflect the most up-to-date LHN when the draft Local Plan is published. Meeting the full LHN will help to ensure that a wide range of housing needs are met across the full extent of the Borough, including market and affordable housing requirements, and all types and tenures of housing to meet the needs of all aspects of the local population including first time buyers, family homes, and those in specialist need. The Borough has not escaped the symptoms of the housing market crisis with rising house prices and worsening affordability ratios that make it increasingly likely that younger residents have to move out of the Borough to find suitable housing choices. However, housing delivery has been healthy since the adoption of the current Local Plan in 2015 (averaging 1,686 dpa). This consistent level of recent delivery demonstrates that the market is capable of achieving the housebuilding needs set by Government, and there is evidence that the recent high level of housing delivery is starting to slow down growth in house prices and affordability ratios in this Borough. Taylor Wimpey does not consider that there is any justification for the Council to seek a lower housing requirement below the LHN. Conversely, the standard method figure of 1,928 dpa should therefore be treated as a minimum. This has been quantified through work on a Research Paper prepared by a Consortium of housebuilders (comprising Taylor Wimpey, Barratt / David Wilson Homes and Redrow Homes). The Research paper has been submitted as a separate representation to this consultation and is appended to these representations for ease of reference (see Appendix 1). The Research Paper concludes that the standard method figure of 1,928 dpa should therefore be treated as a minimum because: 1 The NPPF clearly states that local plans should meet the development needs of their area and as a minimum provide for the objectively assessed needs for housing. Numerous Inspectors at local plan examinations have supported this position. 2 Housing needs can now expressly justify exceptional circumstances for Green Belt release, and it is mandatory for LPAs, if necessary, to alter Green Belt boundaries when they cannot fully meet housing requirements (unless there is evidence that doing so would fundamentally undermine the purposes (taken together) of the remaining Green Belt, when considered across the area of the plan). 3 Housing need modelling scenarios which maintain current demographic trends, including an aging population, suggest a housing requirement of at least 1,763 dpa, whilst a scenario which aligns economic growth and housing needs in line with LEP growth aspirations suggests a requirement of at least 2,169 dpa. These two scenarios straddle the SM3 figure of 1,928 dpa. 4 There are potentially significant economic benefits of pursuing at least the 1,928 dpa figure which will not be realised if a lower requirement is set, including: 5 Over £340m in capital investment p.a.;  6 Over 10,000 FTE direct and indirect construction jobs p.a.; 7 Almost £950 million in economic output p.a.; 8 £22m in resident expenditure p.a.; and 9 Council Tax revenue of £4.3m p.a. 10 The benefits associated with pursuing a more positive economic growth-led housing requirement would be even higher. This needs to be considered against a context of CWaC falling behind its neighbours when it comes to job growth over recent years. 11 CWaC's population is projected to grow at a faster rate than any of its neighbouring authorities as well as relative to the wider regional and national projected growth rates. This presents a need to ensure that sufficient housing is provided so that this growth potential is not constrained. 12 Despite high levels of housing delivery over recent years, there remains a crisis of supply nationally and regionally, and a very challenging affordability gap, both of which can be addressed, or at least slowed, by delivering more housing. 13 Despite high levels of affordable housing delivery, there remains an acute need for new affordable homes to address significant housing waiting list numbers and rising levels of homelessness. The cost of temporary accommodation is having an unsustainable impact on the public purse. 14 High levels of homebuilding will create churn in the market, providing opportunities for first time buyers, growing families or downsizers, and new forms of retirement and care for the ageing population. 15 High levels of new home provision will help to deliver better health and wellbeing outcomes for residents – for example, by addressing overcrowding and the associated mental health toll this can generate, providing greater choice in housing tenures, type, size and location, delivered to modern high efficiency standards which in turn reduces the burden on NHS resources and addresses other related issues such as fuel poverty and cost of living.

Comment

Representation ID: 14212

Received: 29/08/2025

Respondent: Judith Critchley

I&O_14756
No

Comment

Representation ID: 14490

Received: 29/08/2025

Respondent: Steven Edwards

I&O_15035
Very broad

Comment

Representation ID: 14522

Received: 29/08/2025

Respondent: Arden Enterprises Group LLP

Agent: Bidwells

I&O_15068
Policy SS1 sets out the suggested policy approach for the Council to deliver a minimum of 1,914 new homes each year, over the duration of the plan period. The housing need over the plan period (15 years) is 28,710 units. The Council is proposing to meet the housing need in full which we support in principle. While the proposals to meet the housing need in full are welcomed, the strategy must be informed by up-to-date evidence of housing needs, including the needs of the rural population which make up over one third of the total population of the borough.  The Council’s rural housing evidence base is now considerably outdated, and the Rural Regeneration Strategy and Action Plan (2011) is in need of updating to inform the growth strategy for the new Local Plan to ensure it is positively prepared and justified. Surveys carried out by Cheshire Community Action in 2021-2024 for example have identified the need for least 844 additional homes in thirteen areas assessed at Parish level, with significant local need highlighted at Bostock and Moulton. There also needs to be a credible and deliverable pipeline of sites to meet the housing need. In our informed professional view, the housing estimates in the Reg-18 plan and the LAA are overly optimistic and investigation into the deliverability of specific sites will reduce capacity significantly. Therefore, additional sites and multiple growth options are required to meet the housing need in full. 

Comment

Representation ID: 14536

Received: 29/08/2025

Respondent: Mr John Dyne

Agent: Emery Planning Partnership

I&O_15082
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 and there are no exceptional designations such as a National Park which apply to Cheshire West. The existence of Green Belt within the authority area does not justify any deviation from Local Housing Need and the Standard Method. Therefore, the standard method is mandatory in Cheshire West. As to whether the housing requirement can vary from the standard method, paragraph 040 (Reference ID: 2a-040-20241212) 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 restraint 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. This is the point at which Green Belt may be relevant and not when establishing the minimum housing figure. 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, including the assessment and role of relevant Grey Belt land in addressing needs as per the advice in the updated Framework, has been undertaken given the availability of land around the settlements in the Borough.  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 14 (Reference ID: 2a-014-20241212) 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 of 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: 14582

Received: 30/08/2025

Respondent: Sarah Roderick

I&O_15128
Apologies but we assumed that the available questionnaire would be available on the evening of 29th August but it appears to have already been withdrawn at 7:00pm. Therefore we are emailing our points to you. Please note the comments below when deciding on the options available. We request that the council, as our representatives, challenge the quota of houses that the Government has asked CWaC to build per year. This is being done by other local authorities and the notes on the plan state that 'authorities would be able to justify a lower housing requirement' This is based on a) CWaC have exceeded their agreed housing quotas in recent years and this has not been allowed for in the new requirements b) A large area of CWaC is designated Green Belt (42%), other areas are agricultural/ rural land and designated commercial land. This leaves very little area that can take the number of dwellings demanded and will therefore destroy rural villages which have already taken a large amount of development in recent years with no allowance for improvement of roads or public transport or walking/ cycling routes.  C)Demand for extra housing is not being generated from within the CWaC area. The demand is a desire to migrate from other local urban areas to enjoy the more rural & village way  of life Cheshire can offer. Demand is not need generated due to a lack of housing for current CWaC residents or their families.

Comment

Representation ID: 14598

Received: 05/09/2025

Respondent: Geoffrey Lane Nicholls

I&O_15148
I was present at the public meeting on the 19th of August 2025 and I read my basic view of why there should be challenge to the building of more housing anywhere in this country whether it is on Green Belt or Brown listed sites. Below is precisely what I said! "This planning meeting is about advising the residents of Neston what the Council are planning in response to Central Governments plan to build 300000 new homes per year, in this Country. Given the rise in population it is not surprising that there is a shortage of Housing. But Economic growth appears to be sole driver of all  Government policy. Net migration for just 2024 was allegedly 431000. This alone will require us to build 100k new homes just for that years increase. This was after 517000 who left including 77000 Brits. Any Brits who left in 2024 might choose to come back. These figures could easily be an estimate. This at a time when we have between 5 and 10 million people already living in Britain of working age who are not making a contribution to the workforce, many of whom are on benefits! On our current course assuming 1200 new homes were built in our Village, its not difficult to imagine that in 20 years time, assuming that world war 3 doesn't kick off, there will be another planning meeting to decide which happy Landowners are about to become the next recipients of planning permission. Once upon a time there was a Green Belt Council here in the Wirral. During Margaret Thatchers reign I think it was, planners were told the Presumption had to be to development. After that and the retirement of one Ron Huby the secretary, the group gave up the cause. This country is only 55% self sufficient in Vegetables. We are covering whole Food producing fields and allotments with houses, solar panels and crops intended for energy production and as 2025 is testifying Rainfall can no longer be guaranteed to fall when it is needed! Food production will become more unreliable! Despite further Computerisation and  mechanisation which shed jobs, Economic growth is the excuse for encouraging more migration! It was Albert Einstein who declared that: Insanity is doing the same thing over and over again and expecting different results"! So today I need to put some more meat on the bones of the argument. The only thing that I can agree with Sir Keir Starmer on is the need to get lots of the 5 million + people of working age that are not working, many of them claiming benefits, back to work! With the cost of living so high and the minimum wage set where it is its not surprising that many of them "swing the lead"! Whilst there are 5 million not working this only creates demand for immigrant labour, much of which is hard working but as I said in my "speech" if you wish to call it that, in the absence of any apparent incentive to get people off benefits or deterrence to stop the population growing, Neston will be having another planning "consultation" in a few years to come ! So net migration was 431k for 2024. Currently lots of discussion about illegal immigration but little about legal! Much of the economic growth that we currently create is building houses with some immigrant labour so that we can house the new immigrants. The same applies to immigrant Nurses! Meanwhile the businesses that can best afford to be in the high streets of this country at the moment are mainly Estate Agents, Betting shops and Vape shops! Will it be 431k increase in population every year? What if lots of Brits living across the world choose to come home, they have every right to. What if lots of Brits abandon Hong Kong or Jews fleeing so-called Israel, where will they all go? So then there is the business today of where will the new housing be built? Not only will we quickly run out of Brown field sites, builders like to build on nice Green Belt with nice views. Today so-called Green belt is effectively Land waiting for planning permission! There is the need for more lower value properties. It is of course more profitable to build more expensive housing. Will it only be minor promises from the likes of Redrow Builders that the planning department be able to secure in relation to smaller builds for single occupiers or small families? We are covering food producing land with Solar panels and crops intended for energy production and building 300k new homes every year. The UK is only 55% self-sufficient in Vegetables now, not dissimilar to Germany. This is because our labour is too expensive to produce it (and food is too cheap) and not only that the Education system is encouraging too many people to go to University and use what they have between their ears rather than earn a living using their hands! We recently had one of the wettest years on record in 2023 which reduced yields and spoilt soil structure on Arable Farms. This year rainfall has been so low that there will be a shortfall in winter feed for cattle and sheep resulting possibly in farm livestock and horses being slaughtered before their time. I am of the understanding that the Potato famine of 1845 to 1852 was made worse when we the English, confiscated Irish food at gunpoint. The food shortages were Europe wide (the proof being in the ships ladings)! Given the chaos during Covid when selfish people were stripping the shelves of bread and toilet paper, how does the planning department think we would cope with food shortages? Where would we send the Army next time? Where is food going to come from in the future? When I was at the meeting, I did not have my hearing aid with me so heard very little of what was said, from either the presenter or the public. Presumably there would have been discussion about the pressure that will be put on Schools, Clinics, Surgeries and the Sewage systems. Have the council already done an appraisal of those needs and if so can I have a copy? So what would Albert Einstein made of the colossal debt that humanity is now saddled by? This tiny Island is the fifth most debt ridden country on the planet due to government waste, Imperial ambition and strict adherence to the Banking system, warts and all ! Its because of debt we will sacrifice Food producing land to economic growth!  The United Nations should be a democratic institution embarking on a programme whereby every country should be on a path to self-sufficiency not Globalisation particularly in the light of Climate Change. Enclosed detail of where I get the debt figures from - World Debt Clock.

Comment

Representation ID: 14602

Received: 29/08/2025

Respondent: Bloor Homes, Diane Martin, Peter Martin & Brunel Trustees Limited

Agent: Emery Planning Partnership

I&O_15152
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. (See attachment - NPPF paragraph 62; Annex 2; PPG paragraph 003, 14) 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 040 (Reference ID: 2a-040-20241212) 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. 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 14 (Reference ID: 2a-014-20241212) 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: 14633

Received: 29/08/2025

Respondent: Andrews

I&O_15183
I did read that empty homes are already included in the current housing stock, even though they remain empty / out of use.  Personally if you are choosing Brownfield sites first you should be choosing to refurbish / renovate properties that are empty / out of use first also.   Where is the impetus to bring these back and to make them available?  Do that first then see how many of the 1914 homes you need to build.  Renovate / Refurbish out of use houses / properties AND  businesses – do an assessment on that.   If they are not in use they should not be included in the figures.   There are some great examples of buildings that have had investment and are now great houses / businesses.  This approach would be met positively by residents in my opinion.

Comment

Representation ID: 14662

Received: 29/08/2025

Respondent: Miller Homes North West Ltd

Agent: NJL Consulting

I&O_15212
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 the LPA 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. Under the standard method established within the latest NPPF and the updated figures published March 2024/2025 in line with affordability ratios, the annual housing target for the Council is 1,912 dwellings per year. 3.4 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 chronic and needs to be addressed through emerging Local Plan. In terms of the housing figure proposed in the policy, it is important to highlight that ‘exceptional circumstances’ must be demonstrated to justify any deviation from the standard method. As clarified in the PPG, this requirement applies specifically to proposals for a lower housing need figure than that generated by the standard method. A higher figure is not as rigorously tested. Our emphasis is based on the statement written in the PPG: “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.” 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 deliver below the identified dwellings per year as set out.

Comment

Representation ID: 14704

Received: 02/09/2025

Respondent: Darnhall Parish Council

I&O_15254
Darnhall Parish Council notes the following areas of policy set out for the Local Plan. Spatial Strategy (where should growth go) – Darnhall Parish Council notes that national policy states that strategic policies in Local Plans should set out an overall strategy for the pattern, scale and design quality of places and make sufficient provision for: homes, employment, retail, leisure and other commercial development. Darnhall Parish Council notes CWAC figures which show that there are undeveloped planning permissions for almost 6,000 homes and sites on previously developed land in the main settlements, with capacity for just over 5,000 homes. There is almost 77 ha of employment land with planning permission, plus 158 ha of land in established employment areas in the main settlements, that could be developed.

Comment

Representation ID: 14706

Received: 29/08/2025

Respondent: Barratt Homes

Agent: Savills (UK) Limited

I&O_15256
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, whichbrings the overall 15 year total to 28,920 homes. 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. The Research Paper prepared by Lichfield’s on behalf of Barratt Redrow that is submitted in response to this Issues and Options consultation presents the various benefits of the Council delivering at least the current standard methodology housing figure of 1,928 dwellings per annum given the early stage in the plan preparation and how housing development can assist in addressing the Council’s main topics for reviewing their Plan. That document, as well as the associated infographic, should be read in conjunction with these representations.

Comment

Representation ID: 14708

Received: 02/09/2025

Respondent: Darnhall Parish Council

I&O_15258
Darnhall Parish Council further notes the following areas of policy. • Policy Approach SS 1 – Housing Needs – Darnhall Parish Council notes that Cheshire West and Chester must plan for at least 1,914 new homes per year, nearly 29,000 homes over 15 years based on national calculations. This is much higher than the current plan’s target of 1,100 homes per year. Darnhall Parish Council notes that the new plan will need to decide how to distribute this housing across the borough in a sustainable way, and that the Local Plan must also ensure homes meet different needs e.g. affordable housing, family homes, homes for older people, and Gypsy and Travellers.

Comment

Representation ID: 14746

Received: 29/08/2025

Respondent: The Smith Family

Agent: NJL Consulting

I&O_15296
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 the LPA 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. Under the standard method established within the latest NPPF and the updated figures published March 2024/2025 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 chronic and needs to be addressed through emerging Local Plan. In terms of the housing figure proposed in the policy, it is important to highlight that ‘exceptional circumstances’ must be demonstrated to justify any deviation from the standard method. As clarified in the PPG, this requirement applies specifically to proposals for a lower housing need figure than that generated by the standard method. A higher figure is not as rigorously tested. Our emphasis is based on the statement written in the PPG: “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.” 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 deliver below the identified dwellings per year as set out.

Comment

Representation ID: 14772

Received: 29/08/2025

Respondent: United Utilities Property Services

Agent: Lichfields

I&O_15322
Policy SS1 (Housing Needs) suggests that the Council should plan to deliver 1,914 new dwellings per annum [dpa], as a minimum, over the plan period (15 years). This is based upon the SM3 figure and represents a significant 260% increase from the previous SM figure, and a 74% increase from the current Local Plan housing requirement (1,100 dpa). Over the 15 year period this equates to 28,710 dwellings. A substantial amount of development will be necessary to meet this requirement. The Council’s Stage One Land Availability Assessment [LAA] report suggests that 502 potential sites have been identified that could deliver approximately 29,500 units. However, this figure is based upon the application of generic site density assumptions and has not taken into consideration site-specific constraints which may reduce the developable area and hence reduce realistic capacity. Additionally, land availability and achievability were not factored in. Therefore, it is anticipated that this figure will reduce significantly once a Stage Two assessment is completed. This would suggest the need for additional, deliverable sites, such as Land at Beach Road, to be allocated for residential development. Further to this, the Council’s housing need figure has increased to 1,928 dpa since the initial release of SM3 figures last year. This reflects updated housing stock data and affordability ratios released in March 2025. UUPS requests that Policy SS1 is updated prior to publishing the draft plan to reflect the most up-to-date figures. Paragraph 22 of the National Planning Policy Framework [the Framework] 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” [my emphasis]. It is noted that some of the sites indicated for development to date are large and complex. It is therefore anticipated that delivery timescales may be lengthy and extend beyond the suggested plan period. To increase the potential for the necessary housing delivery, UUPS would support an extended plan period. UUPS does not support a stepped housing requirement and does not believe that this approach is justifiable. Given the high quantum of housing needed, it is believed that the Council should plan to deliver in full the annual housing requirement from the beginning of the plan period. There are available and achievable sites, such as Land at Beach Road, which could be delivered early in the plan period to contribute towards the need for nearly 30,000 dwellings. A stepped approach poses a danger of falling short of this need. The Council should plan positively to deliver the necessary housing growth to avoid this possibility.

Comment

Representation ID: 14801

Received: 29/08/2025

Respondent: Mark Mitchell

Agent: Grimster Planning

I&O_15352
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.