Comment

Representation ID: 14834

Received: 29/08/2025

Respondent: Bolesworth Estate Co Ltd

Agent: Pegasus Planning Group Ltd

I&O_15385
Bolesworth support the Council’s position (as clarified at paragraph 1, page 22) that: “The new Local Plan must plan to meet the government’s housing target (the standard method number) which was revised in December 2024. The Council has no choice in this.” Indeed, Paragraph 62 of the December 2024 NPPF makes it clear that the local housing need figure represents the minimum number of homes required. The latest standard method (SM) figures have recently been updated following the publication of the latest affordability ratios in March 2025 and 2024 housing stock data (published May 2025). The latest SM for CW&C is now 1,928, which equates to 28,920 dwellings over a 15 - year period (or 38,560 over a 20-year period). In light of the recent data, CW&C therefore need to plan for a minimum of 1,928 dwellings per annum. Notably, NPPF paragraph 69 states that the housing requirement for a Plan may be higher than the identified housing need (standard method) if, for example, it reflects growth ambitions linked to economic development or infrastructure investment. Enterprise Cheshire and Warrington (ECW) have a series of initiatives to grow the regional economy, including CW&C, which will increase housing demand. Accordingly, 1,928 dwellings per annum should very much be viewed as the minimum requirement.

Comment

Representation ID: 14857

Received: 29/08/2025

Respondent: Mr David Stubbs

Agent: Grimster Planning

I&O_15408
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

Representation ID: 14886

Received: 29/08/2025

Respondent: The Oulton Estate

Agent: Grimster Planning

I&O_15437
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

Representation ID: 14941

Received: 29/08/2025

Respondent: Eric Wright Group

Agent: Connollys Planning & Development Limited

I&O_15500
The Council must plan for the full Standard Method requirement (1,914 homes p.a.).

Comment

Representation ID: 14959

Received: 29/08/2025

Respondent: Ainscough Strategic Land

Agent: Turley

I&O_15518
The Government published updated dwelling stock figures in May 2025 which means that CWAC’s local housing need (“LHN”) figure has actually increased to 1,928 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. 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. To assist the Council in ensuring that the emerging Local Plan meets all of CWAC’s housing needs, including in terms of the types and tenures of housing required across the Borough and maintaining an appropriate balance of development, it will be essential for appropriate evidence to be gathered. This should take the form of a local housing needs assessment (including affordable housing) and a viability assessment to determine what types of homes may be needed and can be delivered in CWAC – these documents should be made available for future consultation. Any affordable housing requirements should be clearly defined and evidenced, with flexibility provided within relevant policies where viability challenges exist. The emerging Local Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver CWAC’s housing requirement. This sufficiency of housing land supply should ensure that the Council can meet the housing requirement, ensure the maintenance of a 5-year housing land supply and achieve the Housing Delivery Test. ASL also strongly recommends that the plan allocates more sites than required to meet the minimum housing requirement as a buffer. This buffer should be sufficient to deal with any under-delivery which is likely to occur from some sites and to provide flexibility and choice within the market. Such an approach would be consistent with the NPPF requirements for the emerging Local Plan to be positively prepared.

Comment

Representation ID: 15002

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15561
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 assuming a 2025 start date. 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. Bloor supports the Council’s use of its LHN figure in the emerging Local Plan, as it enables proactive planning to meet housing needs. However, 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 now stands at 1,928 dwellings per year. Accordingly, the policy should reflect the most up-to-date LHN when the draft Local Plan is published as a minimum. Additional flexibility should be built into this figure to reflect the adoption date of the plan, whilst also accommodating any delays that may arise during the plan-making process. Pursuing a 20 year plan period to 2045 would increase the requirement for new homes to over 38,000 dwellings, a more appropriate figure to ensure that needs are met. Additionally, Bloor considers that a 10% buffer should be included to this figure, as recommended by the Local Plan Expert Group, to ensure sufficient flexibility, choice and competition in the market for land, which would require c. 42,000 dwellings be delivered over the 20 year period.  To accommodate this level of development, Chester should be seen as an ideal location for the development of a significant portion of the Borough’s new housing, having been identified to accommodate almost a quarter of the Borough’s residential development in the current plan period. Bloor considers that Chester, being the Borough’s largest settlement with a range of facilities and services and strong transport connectivity, should as a minimum accommodate a similar proportion of residential development as in the adopted Local Plan. Bloor does not support the use of a stepped housing requirement, as efforts should be made to meet the full annual need from the outset of the plan period. A stepped requirement in Cheshire West would be counterintuitive particularly given the immediate need for market and affordable homes in the authority coupled with the high annual delivery, which broadly aligns with the standard method requirement, over the past decade. In light of the national housing shortage, an issue affecting both the Borough and the wider North West too, it would be inappropriate for the Council to delay immediate action by backloading the requirement. This is especially the case as there are numerous deliverable sites, such as Whitchurch Road, being promoted for development which can meet needs in the early years of the plan period. Therefore, Bloor recommends that a fixed annual requirement be adopted to ensure timely delivery of the necessary number of homes.

Comment

Representation ID: 15017

Received: 29/08/2025

Respondent: Grosvenor's Eaton Estate

Agent: Stantec

I&O_15576
Grosvenor welcomes the recognition at paragraph 5.2 of the draft Local Plan that strategic policies should be informed by local housing need conducted using the standard method in national planning practice guidance (NPPF, paragraph 64). The figure for Cheshire West and Chester is a minimum of 1,914 new homes each year, equating to 28,710 new homes over a 15-year plan period. The Council’s emerging Local Plan will, therefore, be required to plan for housing using the new Standard Method which represents a significant step-up from the adopted housing requirement of 1,100 units per annum set out in STRAT2 of the Local Plan Part One. The increased housing requirement within the new Standard Method means that exceptional circumstances will, therefore, exist to justify altering Green Belt boundaries as part of the Local Plan preparation. We consider it will be inevitable that the Council will need to allocate Green Belt sites to meet its new housing requirement which is circa 75% increase from the previous Local Plan requirement upon which previous Green Belt Boundaries were established. The Council suggests that the latest housing land monitoring data identifies undeveloped planning permissions for almost 6,000 homes, and the Land Availability Assessment (Stage One) evidence base document indicates that there is a supply of circa. 5,000 homes for sites on previously developed land, including undeveloped Local Plan allocations, within the main urban areas and Key Service Centres (KSC). However, the draft Local Plan acknowledges that this figure is likely to reduce once a detailed assessment of the constraints of these sites is carried out in Stage Two. Whilst Grosvenor reserves further comments until the Stage Two Land Availability Assessment is undertaken, the Council will clearly need to identify additional sites to address its’ housing supply shortfall so that it can meet its increased housing targets. Those sites should be located in the most suitable locations and be directed to support the sustainable growth of the borough’s settlements. As such, the Local Plan spatial strategy (discussed further below) must consider an appropriate balance of development to ensure that housing needs are met and delivered in the right locations. Furthermore, we consider that the Council will need to undertake a Grey Belt Assessment across the borough to identify the supply of potential Grey Belt Sites available to meet housing and employment needs. The Council will also need to undertake a housing needs assessment to further understand what homes are needed in the borough, and a viability assessment to determine if the Council’s housing land supply is capable of addressing those needs (for example, delivery of affordable homes on previously developed land). On the face of it, Grosvenor does not object to the housing requirement of 1,914 set out in SS1. However, we note that the Council must ensure that the latest standard method figure is used as a minimum and the Council should ensure that it has identified sufficient sites to accommodate residential development and support the vitality and viability of all of its settlements, LSC. We consider that growth should be disaggregated across the settlement hierarchy to ensure that LSC (including those within the Green Belt) are provided with the level of growth they need to maintain their role and function in that hierarchy.

Comment

Representation ID: 15052

Received: 29/08/2025

Respondent: Cheshire Garden Village Ltd

Agent: AshtonHale

I&O_15611
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. The Council must recognise that the delivery of 1,914 homes annually sits within a national context where the Government is seeking to significantly boost the number of homes delivered in order to meet a recognised demand. 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 to achieve these targets. Green Belt sites, much like CGV’s land interests at Chester Way, in sustainable locations 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 Chester Way 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. These aspects make the site particularly suitable for residential development that could provide for affordable housing.

Comment

Representation ID: 15079

Received: 29/08/2025

Respondent: Wain Homes (North West) Ltd

Agent: Emery Planning Partnership

I&O_15638
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 003  1 of the PPG states: “Is the use of the standard method for strategic policy making purposes mandatory? The standard method should be used to assess housing needs. However it is recognised  that there are some specific circumstances in which an alternative approach could be  justified, for example as explained at paragraph 014 below.” Paragraph 14 of the PPG states: “Where strategic policy-making authority boundaries do not align with local authority  boundaries, or data is not available, should the standard method be used to assess local  housing need? Where strategic policy-making authorities do not align with local authority boundaries (either individually or in combination), or the data required for the model are not  available such as in National Parks and the Broads Authority, or local authority areas  where the samples are too small, an alternative  approach may have to be used. Such authorities may continue to identify a housing need figure using a method determined locally. In doing so authorities should take into consideration the best available evidence on the amount of existing housing stock within their planning authority boundary, local house prices, earnings and housing affordability. In the absence of other robust affordability data, authorities should consider the implications of using the median workplace-based affordability ratio for the relevant wider local authority area(s). For local authorities whose boundaries cross National Parks or Broads Authority areas, the proportion of the local authority area that falls within and outside the National Park or Broads Authority area should also be considered – for example where only a minimal proportion of the existing housing stock of a local authority falls within the National Park or Broads Authority area it may be appropriate to continue to use the local housing need figure derived by the standard method for the local authority area.” Paragraph 14 is not applicable in Cheshire West as the authority boundary aligns with the local plan boundary. Therefore, the standard method is mandatory in Cheshire West. As to whether the housing requirement can vary from the standard method, paragraph 040 2 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  3 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. 1 Reference ID: 2a-003-20241212 2 Reference ID: 2a-040-20241212 3 Reference ID: 2a-014-20241212

Comment

Representation ID: 15089

Received: 29/08/2025

Respondent: Persimmon Homes

Agent: Asteer Planning

I&O_15648
Persimmon fully supports 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 or 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. Persimmon does 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

Representation ID: 15105

Received: 29/08/2025

Respondent: StanleyRed Developments Ltd

Agent: AshtonHale

I&O_15664
The Council is required to plan for at least 1,914 new homes per year, as identified by the Government’s Standard Method for assessing local housing need. Paragraph 62 of the NPPF is clear that this figure must be treated as a minimum, informed by robust assessment, and should not be planned for at anything less. In practice, this represents a baseline that the Council must achieve, with scope to exceed it were justified by evidence of demand or opportunity. Given the scale of this requirement, it is unlikely that the borough’s housing needs can be met solely within existing Local Plan settlements or through brownfield land supply. In these circumstances, the Council must look to bring forward sustainable Green Belt sites to ensure delivery. Sites such as Land at Saltworks Farm are particularly well placed to support this objective. The site is accessible, unconstrained, and located adjacent to existing services and infrastructure. Paragraph 73 of the NPPF further requires that local planning authorities identify a supply of deliverable sites sufficient to provide at least five years’ worth of housing, with an additional buffer to ensure choice and competition. Selective Green Belt release in sustainable locations provides the most realistic way to maintain this supply and deliver a resilient, responsive housing strategy for Cheshire West and Chester. Land at Saltworks Farm offers a logical and justified opportunity for Green Belt release, closely related to Frodsham and existing service provisions, public transport links, and proximity to centres of employment and amenities.

Comment

Representation ID: 15143

Received: 29/08/2025

Respondent: Views Holdings Ltd

Agent: AshtonHale

I&O_15702
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. 8.3 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 sites outside of settlement boundaries for development to achieve these targets. Open Countryside sites, much like Land off London Road, 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 allocation of land in sustainable locations is well-placed to support this objective and contribute to a more resilient and responsive housing land supply. Land off London Road, Davenham offers a logical and justified opportunity for allocation, closely related to Northwich and existing service provisions, public transport links, and proximity to centres of employment and amenities.

Comment

Representation ID: 15189

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15748
Barratt Redrow support the Council’s clarification (at bullet point 1, page 22) that: “The new Local Plan must plan to meet the government’s housing target (the standard method number) which was revised in December 2024. The Council has no choice in this.” Indeed, Paragraph 62 of the December 2024 NPPF makes it clear that the local housing need figure represents the minimum number of homes required. The latest standard method (SM) figures have recently been updated following the publication of the latest affordability ratios in March 2025 and 2024 housing stock data (published May 2025). The latest SM for CW&C is now 1,928 dpa, which equates to 28,920 dwellings over a 15 - year period (or 38,560 over a 20-year period). In light of the recent data, CW&C therefore need to plan for a minimum of 1,928 dwellings per annum 3. On behalf of Barratt Redrow and Taylor Wimpey, Lichfields has prepared an Objectively Assessed Housing Need Research Paper for CW&C. This report is contained in full at Appendix 8, however in summary: The Consortium urges CWaC to adopt a minimum housing target for the new local plan period derived from the standard method figure of 1,928 dpa. 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: Over £340m in capital investment p.a.; Over 10,000 FTE direct and indirect construction jobs p.a.; Almost £950 million in economic output p.a.; £22m in resident expenditure p.a.; and Council Tax revenue of £4.3m p.a. The economic benefits associated with pursuing a more positive economic growth-led housing requirement would be even higher. 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. There is a case to deliver at least 2,169 dpa, based on a scenario which aligns economic growth and housing needs in line with the Cheshire and Warrington Local Enterprise Partnership growth aspirations. In summary, there are no circumstances in which the Local Plan should not deliver the minimum 1,928 requirement, and in order to achieve the Borough’s full potential, a scenario which aligns economic and housing growth generates a requirement to deliver at least 2,169 dpa.   3 We note the Council’s latest ‘Housing Land Monitor Summary Report 2025’ sets out a requirement of 1,912 dpa, which was correct at the base date of 1st April 2025, but has since changed with the 2024 housing stock data (published May 2025) to 1,928 dpa, which is the latest figure that should be used for the purposes of the emerging Local Plan.

Comment

Representation ID: 15231

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

I&O_15790
Chester Zoo do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand in Chester.

Comment

Representation ID: 15338

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_15897
Richborough fully supports 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. Richborough does 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

Representation ID: 15356

Received: 29/08/2025

Respondent: Blueoak Estates

Agent: Paul Nellist

I&O_15915
Blueoak Estates supports suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough using 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. Blueoak Estates agrees with the Council’s view and considers that there is no 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

Representation ID: 15376

Received: 29/08/2025

Respondent: R and C Handley

Agent: Matthew Wedderburn

I&O_15935
The Government has made clear planning reforms are an important part of its plan for growth and have set a national target to build 1.5 million new homes in the current Parliamentary term. As such, the revised National Planning Policy Framework (NPPF) published in December 2024 made significant changes seeking to increase the supply of housing. These include the reintroduction of mandatory targets for the minimum number of homes in each area, with nationally calculated ‘standard method’ figures to be applied. These are no longer to be considered an “advisory starting point” for establishing the plan’s housing figure and the reference in previous NPPF to circumstances where the use of alternative approaches to assessing housing need may be appropriate been removed. National policy (NPPF paragraph 61 refers to the ‘standard method’ housing figures as “the minimum number of homes needed” and any shortfall below this would require the strongest possible justification. It is not considered such circumstances exist in Cheshire West and Chester. It is therefore clear that the Council should plan to deliver 1,914 new homes each year as a minimum.

Comment

Representation ID: 15388

Received: 29/08/2025

Respondent: Barlow Trust Fund

Agent: Cassidy & Ashton Group Ltd

I&O_15947
The Trust do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand across the Borough, most notably for the second-tier settlements such as Northwich. The Trust do not believe the Council should consider a stepped housing requirement, planning for a lower level of delivery earlier in the plan period. Reference is made by the Council to a quantum of undeveloped planning permissions and undeveloped Local Plan allocations, the basis for which they would justify a stepped approach presumably. The counter argument is to ask why permissions haven’t been implemented and why allocations have not been progressed through Planning. Constraints are clearly precluding these development opportunities, the majority of which may be insurmountable and so the quantum may be deemed available but simply not deliverable.  

Comment

Representation ID: 15411

Received: 29/08/2025

Respondent: Consolio Bono

Agent: PWA Planning

I&O_15970
The Council should plan to ensure delivery of at least the local housing need requirement. Moreover, it is not considered that the authority can demonstrate any reason not to plan for meeting these requirements. It is not clear that the authority can reasonably demonstrate and evidence development constraints which would meet the demanding tests expected by national government for delivering lower than the minimum requirement. Although it may be argued that some infrastructure provision lags the delivery of new homes, it is not at all clear that delaying delivery or stepping the requirement will make any material difference. It will simply mean that people in need of homes now, including affordable homes, will continue to be unable to access these homes for a longer period of time, if ever. Moreover, given that the housing requirement, once established, is the minimum number of homes that a plan seeks to provide during the plan period (PPG Paragraph: 040 Reference ID: 2a-040-20241212) there is a clear argument that the housing requirement should be further uplifted to take account of possible slippage of larger strategic sites, as well as other major development sites, over the course of the local plan period. Whilst the buffer is a common theme in the five year supply analysis, increasing the housing requirement by at least 10% above local housing need figure (the minimum) would serve to ensure that possible future slippage is baked into the figures. In the event of no slippage, delivery of homes would exceed the minimum requirement, which would be an entirely positive outcome in broad terms. If there is slippage in the assumed delivery of sites, the evidence of which is apparent over many years of data in across the UK, this will be better accounted for within the requirement, in addition to any supply side assessment. It is then suggested that the overall annual housing requirement to be used in the plan should be increased from 1,914 to 2,105 dwellings, or in total from 28,710 to 31,581 homes. In response to Question SS2, there is no justification for the Council to consider a stepped housing requirement. This would simply serve to compound issues around delivery and meeting needs at the earliest opportunity. There is also no reason that adequate sites cannot be identified to meet needs in full right from the outset. In this regard we are not aware of any overriding constraints to development which are likely to resolve later in the plan period so as to warrant consideration of a stepped housing requirement.

Comment

Representation ID: 15444

Received: 21/10/2025

Respondent: Wirral Borough Council

I&O_16003
No comments at this stage

Comment

Representation ID: 15466

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16025
Shropshire Homes support the Council’s position (as clarified at paragraph 1, page 22) that: “The new Local Plan must plan to meet the government’s housing target (the standard method number) which was revised in December 2024. The Council has no choice in this.” Indeed, Paragraph 62 of the December 2024 NPPF makes it clear that the local housing need figure represents the minimum number of homes required (Pegasus emphasis). The latest standard method (SM) figures have recently been updated following the publication of the latest affordability ratios in March 2025 and 2024 housing stock data (published May 2025). The latest SM for CW&C is now 1,928, which equates to 28,920 dwellings over a 15 - year period (or 38,560 over a 20-year period, which may be more likely to comply with para 22 of the NPPF). In light of the recent data, CW&C currently need to plan for a minimum of 1,928 dwellings per annum.

Comment

Representation ID: 15527

Received: 29/08/2025

Respondent: Liberty Properties plc

Agent: Cassidy & Ashton Group Ltd

I&O_16086
Liberty Properties do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand across the Borough, most notably for the key service centres, such as Cuddington & Sandiway. Liberty Properties do not believe the Council should consider a stepped housing requirement, planning for a lower level of delivery earlier in the plan period. Reference is made by the Council to a quantum of undeveloped planning permissions and undeveloped Local Plan allocations, the basis for which they would justify a stepped approach presumably. The counter argument is to ask why permissions haven’t been implemented and why allocations have not been progressed through Planning. Constraints are clearly precluding these development opportunities, the majority of which may be insurmountable and so the quantum may be deemed available but simply not deliverable.

Comment

Representation ID: 15744

Received: 29/08/2025

Respondent: Northern Powerhouse Land Ltd

Agent: Asteer Planning

I&O_16303
There is no reason for the Council not to plan for delivering a minimum of 1,914 new homes each year. It is important that the future housing needs of CWaC are rooted in the new standard method to ensure that the new Local Plan is robust. Further to the above, the Council’s Cabinet recently decided to adopt the Housing Strategy 2025 2035, within which it is acknowledged that “…there are challenging times ahead, there is a national housing crisis, housing is less affordable, and many people have support needs making it even more difficult to access and sustain accommodation.”9 Coupled with these challenges, the Housing Strategy acknowledges that the population of Cheshire West and Chester is forecast to increase by more than 10% by 2038. This further emphasises the clear need for new housing within the Borough.

Comment

Representation ID: 15785

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16344
Hilbre Overlea Ltd supports suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough using the Government’s Standard Method. Unless there are strong reasons why an authority cannot do so, it must seek to, as a minimum, meet its local housing needs, and also meet the needs of neighbouring Authorities if appropriate. 2.10 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. There is no reason for restricting development in CWaC, and doing so would not 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

Representation ID: 15831

Received: 29/08/2025

Respondent: West Midlands Pension Fund

Agent: Knight Frank

I&O_16390
No, it is not considered that circumstances have been presented in this consultation that would justify this approach.

Comment

Representation ID: 15855

Received: 29/08/2025

Respondent: Barratt David Wilson Homes North West

Agent: Turley

I&O_16414
As set out in the accompanying Lichfield’s Research Paper7 , the new standard method for calculating housing need is one of the central tenets of achieving the Government’s objective to deliver 1.5 million homes in the current Parliament. The updated standard method results confirm that CWAC’s housing need figure is 1,928 dwellings per annum (‘dpa’), which is considerably higher than the previous standard method demographic-based figure of 489dpa, and also much higher than the 2015 Local Plan figure of 1,100dpa. Applying the updated standard method equates to a total requirement of 28,920 dwellings over a 15-year plan period and 38,560 dwellings over a 20-year plan period. 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. To assist the Council in ensuring that the emerging Local Plan meets all of CWAC’s housing needs, including in terms of the types and tenures of housing required across the Borough and maintaining an appropriate balance of development, BDW consider that it will be essential for appropriate evidence to be gathered. This should take the form of a local housing needs assessment (including affordable housing) and a viability assessment to determine what types of homes may be needed and can be delivered in CWAC. These documents should be made available for future consultation. Any affordable housing requirements should be clearly defined and evidenced, with flexibility provided within relevant policies where viability challenges exist. The emerging Local Plan’s policies should ensure the availability of a sufficient supply of deliverable and developable land to deliver CWAC’s housing requirement, including the maintenance of a 5-year housing land supply. This will also enable the Housing Delivery Test to be achieved. BDW strongly recommends that the plan allocates more sites than necessary to meet the minimum housing requirement as a buffer. This buffer should be sufficient to deal with any under-delivery which is likely to occur from some sites and to provide flexibility and choice within the market. Such an approach would be consistent with the NPPF requirements for the emerging Local Plan to be positively prepared.

Comment

Representation ID: 15876

Received: 29/08/2025

Respondent: Richborough

I&O_16435
We 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 housingneeds, 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. We 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

Representation ID: 15923

Received: 29/08/2025

Respondent: Lexwood Developments

Agent: HK Planning

I&O_16482
The Government has issued many statements recognising there is a national housing crisis, and has updated the NPPF and increased housing requirements to reflect this. Therefore, it seems inconceivable why a reduced supply of housing land would be suggested in the early years of a new Local Plan. Please see Enclosure 4, a letter from The Ministry for Housing, Communities and Local Government dated 18th August confirming ‘All areas of the country must play their part in building the homes we need’. In all likelihood given the Council's current position (and time it will take to get the Local Plan adopted) inevitably there will be a lower amount of development delivered in the early years of an emerging plan. In order to avoid a lag in delivery and actually achieve the Government aims of addressing the housing crisis, rather than defer them, Sites which are relatively unconstrained, well located to existing settlements and not of such a scale to cause significant issues on local infrastructure should be considered for release ahead of the emerging Local Plan adoption. Overall phasing delivery of Housing may be required, but if proposed such policies should not stifle potential early delivery of housing in the Local plan period. Any phasing policies for the delivery of housing must remain extremely flexible as delivery of the likely required large-scale sites will need large infrastructure inputs, alterations and complex Section 106 agreements, and these have historically been shown to take significant time to come forward. Therefore, it would only seem appropriate to phase large scale allocations rather than smaller ones which again meet the NPPF’s aim for SMEs and small-medium sites that can typically be delivered quicker.

Support

Representation ID: 15960

Received: 29/08/2025

Respondent: Northern Trust Land Limited

Agent: Savills (UK) Limited

I&O_16541
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. It is noted that the most recent local housing need figure for CW&C is actually 1,928 dpa, which brings the overall 15 year total to 28,920 homes. While this is owing to the incorporation of the latest affordability ratios. In response to question SS1, the new Local Plan should support the delivery of 1,928 homes per year as a minimum. The requirement for the new Local Plan to meet the standard method figure is clearly established in the NPPF and is the necessary approach that must be taken to ensure that the plan is consistent with national policy. Emphasis is placed on the fact that the national policy requirement is for Local Plans to adopt the standard method figure as a minimum. Savills recommends that the Council should take an ambitious approach and aim to exceed the minimum housing delivery indicated by the standard method, in order to support sustainable growth. National policy provides that in some cases, authorities will be able to justify a lower housing requirement than the standard method on the basis of local constraints on land and delivery (for example designations such as National Parks etc). Such circumstances do not exist in CW&C that would justify a reduced housing requirement. For example, there are no statutory National Parks in the borough.

Comment

Representation ID: 16049

Received: 29/08/2025

Respondent: Richborough Estates

Agent: Asteer Planning

I&O_16630
Richborough fully supports 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. Richborough does 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).