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Representation ID: 16879

Received: 29/08/2025

Respondent: Tesni Properties Ltd

I&O_16616
Growth Options Three broad options have been presented by CW&C within this regulation 18 consultation. While these scenarios explore different distributions of growth, they share a common emphasis on directing the majority of development to the main towns and service centres. Whilst this proposal evidently comes with it’s advantages, it is essential that the plan also recognises the role of smaller settlements in contributing to housing delivery. Over-reliance on large strategic sites or heavily constrained urban areas risks undermining the Council’s ability to maintain a deliverable five-year housing land supply, which is a key test of soundness under national policy. Each of the three potential spatial distribution strategies have been tested through the Sustainability Appraisal process and provides a useful starting point for debate. However, it is important that the Council maintains flexibility and does not commit too rigidly to any single option at this early stage. A hybrid strategy, which combines the benefits of each option while addressing their respective shortcomings, will be required to ensure the new Local Plan is positively prepared, justified, effective, and consistent with national policy. Option A: Protecting the Green Belt This option seeks to minimise Green Belt release by directing the majority of new housing and employment growth to settlements outside the Green Belt, notably Winsford, Northwich, and other non-Green-Belt towns. It also places greater emphasis on expansion within Rural Service Centres. While this approach is consistent with national policy in terms of safeguarding Green Belt land, it creates significant risks. It places undue pressure on a limited number of urban locations, many of which are already contending with regeneration challenges and infrastructure constraints. Relying too heavily on brownfield and regeneration sites can create uncertainty around delivery rates, especially where land assembly, remediation, or market demand issues are complex. From a Tesni perspective, Option A does not provide the necessary flexibility or diversity of supply to maintain a robust five-year housing land supply across the plan period. Option B: Continuation of the Current Approach Option B broadly reflects the adopted spatial strategy, distributing growth across Chester, Ellesmere Port, Winsford, Northwich, and the network of Key Service Centres. Under this scenario, around 11,000 homes would be delivered through Green Belt release. This approach offers a more balanced distribution of growth compared to Option A, aligning new homes with employment opportunities and existing transport networks. It also reduces over-reliance on regeneration sites, recognising the contribution that strategic Green Belt releases can make to overall supply. However, the risk with Option B is that too much emphasis is placed on large strategic sites, which typically require long lead-in times, substantial infrastructure investment, and complex phasing arrangements. This can undermine delivery in the early years of the plan period. To make this option effective, it should be complemented by smaller-scale allocations in a wider range of settlements, ensuring that housing can come forward quickly and steadily throughout the borough. Option C: Transport Corridor Growth This option seeks to concentrate development along established and emerging sustainable transport corridors, particularly rail and bus routes. More than 12,000 homes would be delivered through Green Belt release to support this option. In principle, aligning growth with public transport infrastructure is consistent with the objectives of the National Planning Policy Framework and reflects broader sustainability goals, including reducing car dependency and promoting compact development. However, the deliverability of this option is contingent on significant transport investment being secured and delivered in a timely manner. If these improvements are delayed or scaled back, the housing trajectory could falter. Furthermore, focusing growth so narrowly along transport corridors risks neglecting the role of smaller settlements which, although not served by high-frequency public transport, are still sustainable and capable of delivering early housing supply Individually, each of the three spatial options identified in the Regulation 18 consultation has clear limitations. A more effective and deliverable strategy would combine their positive elements: focusing growth towards the main towns and sustainable transport corridors, while also enabling proportionate expansion at smaller, well-connected settlements. This hybrid approach would diversify the land supply, provide greater resilience against delivery risks, and ensure flexibility across the plan period.