Comment

Representation ID: 165

Received: 14/07/2025

Respondent: Mike Mather

I&O_187
There's no doubt a high percentage of affordable housing on a development would put-off buyers for the remaining non-affordable homes. 

Comment

Representation ID: 758

Received: 31/07/2025

Respondent: Cheshire Planning Solutions Ltd

I&O_862
All areas of the borough should maintain a consistent requirement for affordable housing provision on developments of 10 or more homes. Lowering this threshold to 3 or more homes in rural areas risks creating unintended consequences that could undermine both housing delivery and appropriateness. In rural locations, small development sites command premium land values. When developers face affordable housing obligations on such constrained sites, they are incentivised to maximize returns from market housing to offset costs. On a three-unit scheme where one home must be affordable, developers would likely construct two substantially larger, higher-value market homes alongside one minimal affordable unit. This approach would produce housing that is less accessible to a broader range of buyers than three modestly-sized homes at lower price points. The current threshold recognises that smaller rural developments operate under different economic pressures than larger schemes, where affordable housing requirements can be more effectively absorbed. Maintaining the 10-unit threshold ensures that when affordable housing is required, it can be delivered appropriately without distorting the local housing mix or creating perverse development patterns that ultimately serve fewer people's housing needs.

Comment

Representation ID: 1152

Received: 06/08/2025

Respondent: Julie Smith

I&O_1257
No

Comment

Representation ID: 1439

Received: 06/08/2025

Respondent: Mr Les Smith

I&O_1544
The lower level for rural areas is justified. An alternative method could be the square footage of dwellings proposed.

Comment

Representation ID: 2089

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2209
Any thresholds should be fully justified via evidence and flexibility should be provided within the policy where viability may be an issue.  

Comment

Representation ID: 3271

Received: 22/08/2025

Respondent: Antony Fairbanks

I&O_3445
afforable' is inherently subjective, and not a useful term

Comment

Representation ID: 3362

Received: 18/08/2025

Respondent: Cheshire Community Action

I&O_3536
CCA supports the Council’s ambition to develop a new Local Plan that delivers sustainable growth, meets housing needs and protects the character of rural West Cheshire. As an organisation working with rural communities across Cheshire we welcome this opportunity to comment on the consultation with a particular focus on rural, affordable and community-led housing. Our comments also highlight the implications for neighbourhood plans and for rural services and infrastructure. 1. Rural and affordable housing CCA’s position is informed by evidence from the Cheshire West Affordable Housing Needs Survey Summary Report 2021–24. These parish-level studies, covering thirteen areas, identifies a need for 844 additional homes, split 363 affordable (43 %) and 481 market (57 %), with need highest in Neston (281 homes), Frodsham (135) and Davenham, Bostock & Moulton (100). The surveys showed that smaller dwellings dominate demand: 2-bed homes account for 44 % of total need (369 homes) and 47 % of affordable need (167 homes), while 1-bed homes represent 21 % of total need (176 homes) and 29 % of affordable need (111 homes). Three-bed and 4-bed homes together comprise around one third of total need, with a higher share in the market sector. This evidence underpins our view that rural housing policies should prioritise small, energy-efficient homes, particularly 1- and 2-bed properties, to address concealed households, downsizers and affordability constraints. Tenure patterns vary by parish. Some places have majority-affordable profiles—for example Neston (55 % affordable), Tilston (53 %), Farndon (70 %) and Dunham Hill & Hapsford (55 %)—while others such as Christleton & Littleton and Malpas are market-dominated (more than 75 % market housing). This variation underscores the need for a tailored housing mix by parish, rather than a one-size-fits-all target. Affordable housing thresholds and tenure mix. The consultation proposes a borough-wide affordable housing policy that includes at least 50 % affordable housing on Green Belt sites and requires affordable housing on schemes of 10+ homes, with a lower threshold of three or more dwellings in designated rural areas. We support a policy that requires affordable homes in smaller rural schemes, as rural wages are low and market housing is often unaffordable. However, delivering affordable units on schemes of only three or four dwellings can be challenging for small builders; policies should be flexible enough to accept off-site contributions or small clusters of affordable home ownership housing where on-site provision is not viable. A tenure mix that includes social rent, affordable rent and affordable home ownership tenures is needed to meet the variety of rural needs. Design and integration. CCA agrees that affordable homes should be indistinguishable from market housing and dispersed throughout the development. Policies should ensure that smaller schemes maintain rural character and that dwelling sizes reflect local needs (smaller homes for young families and older residents). The plan should encourage community-led design standards and the use of local materials. Rural exception sites. National policy allows small sites next to rural settlements to be developed for affordable housing in perpetuity. The consultation suggests retaining the existing rural exception policy but potentially limiting its application to settlements more remote from large urban areas. We caution against restricting rural exception sites to remote parishes; affordable need exists in villages close to towns, and rural exception policies provide one of the few ways to deliver truly affordable homes where land values would otherwise make this impossible. We support the requirement for parish-led needs assessments and for schemes to remain affordable in perpetuity. The proposed local connection criteria (residents living in the parish for five years, those working locally, or people with close family ties or previous long-term residence) are appropriate but should be widened to include young people who grew up in the parish and wish to return. Essential rural workers dwellings. The plan proposes to retain the existing policy for rural worker dwellings, including a 106 m² limit and a condition that dwellings should remain as affordable housing if the need ceases. We support this approach as it prevents such homes being lost to the open market and ensures they remain available to the farming and forestry community. Older households and accessible homes. The housing needs surveys offer a granular view of the needs of residents aged 65 +. Across the parishes, older households still favour market purchase, but in affordability-pressured areas such as Neston and Frodsham there is a discernible need for affordable/social rent options. Housing type preferences are unambiguous: older respondents overwhelmingly chose bungalows or other level-access homes, most frequently with two bedrooms. The vast majority reported no formal support need, yet the surveys highlighted a notable minority—particularly in Neston, Frodsham and Saughall & Shotwick Park—who require mobility or disability adaptations or warden-assisted schemes. These findings underline the need to deliver age-friendly, energy-efficient bungalows and accessible dwellings across tenure types to enable older residents to ‘right-size’ locally and free up family homes. Schemes should also incorporate flexible support and high energy performance standards to support independent living and reduce fuel poverty. Summary CCA welcomes the Council’s commitment to addressing housing needs and supports many of the suggested approaches in the Issues & Options document. We emphasise that: 1. Affordable housing policy should include lower thresholds for rural areas but allow flexibility in how very small schemes deliver affordable homes. Evidence from parish surveys shows that small dwellings dominate demand—2-bed homes account for nearly half of total and affordable need and 1-beds form a further one-fifth. Policies should therefore prioritise small, energy-efficient homes, particularly 2-bed and 1-bed dwellings, and ensure a robust affordable component across all settlements. Age-friendly bungalows and level-access homes should be encouraged to allow older residents to downsize locally and free up larger homes for families. 2. Rural exception sites must remain available in all rural settlements, not just remote ones, and should be underpinned by parish-led needs assessments, strong Local Connection criteria and affordability in perpetuity. Rural exception policies should be flexible enough to accommodate community-led schemes and to deliver age-friendly bungalows and level-access homes, with a focus on 2-bed and 1-bed properties, across both affordable and market tenures. Design quality, high energy performance and accessibility should be integral to these schemes to maximise community benefit.

Comment

Representation ID: 3730

Received: 23/08/2025

Respondent: Deryn O'Connor

I&O_3912
The development of housing on green belt land should be in exceptional cases and then only with 70 percentage supply of affordable housing. This should apply to all developments no matter the number of houses built if 3 and above

Comment

Representation ID: 4117

Received: 25/08/2025

Respondent: Mr Michael Shipman

HO5
I&O_4346
Yes.  Too often developers have seemingly limited the number of units being built in more rural areas to escape a threshold set too high

Comment

Representation ID: 4168

Received: 27/08/2025

Respondent: Martin Bell

I&O_4397
The lower threshold for Rural Areas is necessary because in small settlements downsizing becomes impossibly restricted and also reduces mobility and availability of houses for families without a supply of Affordable Houses.

Comment

Representation ID: 4236

Received: 25/08/2025

Respondent: Kelsall Parish Council

I&O_4465
Lower threshold requirement for rural areas must be retained. Many rural areas have higher than average house prices and higher living costs. Which means that more affordable housing doesn’t compromise viability

Comment

Representation ID: 4575

Received: 26/08/2025

Respondent: ROBERT MCSWEENEY

I&O_4858
Little Leigh Parish Council will just comment that the threshold of just three dwellings for triggering the requirement for affordable building does seem very low. 

Comment

Representation ID: 4801

Received: 27/08/2025

Respondent: victoria rigby

I&O_5151
All models should have mixed housing including affordable for all generations and needs.

Comment

Representation ID: 4964

Received: 27/08/2025

Respondent: Norley Parish Council

I&O_5323
The lower threshold for rural areas is necessary because otherwise in small settlements downsizing becomes impossibly restricted and also reduces mobility,and restricts availabilty for families. A supply of Affordable homes serves to reduce these problems.

Comment

Representation ID: 5514

Received: 28/08/2025

Respondent: Michael Webb

I&O_5886
Thresholds should be lower in rural areas (3+ dwellings) due to smaller site sizes. For non-rural areas, 10+ remains acceptable. However, in all cases, the Council must prove how affordable housing will be delivered without overwhelming existing infrastructure.

Comment

Representation ID: 5989

Received: 29/08/2025

Respondent: Andrew Rowe

I&O_6378
Adopting the NPPF guidance of 50% affordable housing, if land comes out of the Green Belt should be supported and a Local Connction Test should also be applied before the housing opportunity is opened up to the wider public.

Comment

Representation ID: 6513

Received: 29/08/2025

Respondent: Councillor Lucy Sumner

I&O_6928
19 | HO5   Do you have any views on thresholds for affordable housing in relation to applying a lower threshold for designated rural areas and what approach could be taken to parts of the borough not subject to the designation?   In Frodsham and similar market towns, the lower threshold (3 dwellings) should apply. Without it, too many smaller schemes evade obligations, hollowing out affordability in rural areas.   🐝 Frodsham Neighbourhood Plan Evidence Base Too many smaller schemes evade obligations. With most FNHP allocations being modest brownfield or infill, applying the 3-dwelling threshold is vital to secure affordable homes.   🌳 Hob Hey Wood Ancient Woodland Considerations Lower thresholds reduce pressure on speculative large Green Belt releases by ensuring even small brownfield sites contribute.   🌹 Labour Perspective Labour supports closing planning loopholes that allow developers to side-step obligations. This aligns with DCN’s finding that stricter thresholds could add 8,300 affordable homes annually in rural areas.   🧠 Wider Knowledge Gallent/Eaqub: affordability isn’t solved by volume alone – we need the right tenure mix across all scales of development. DCN: rural areas often see affordable provision fall from 34% to 18% due to viability loopholes – smaller thresholds close this gap.   📌 Important Considerations   Apply a 3-dwelling threshold in rural and market towns like Frodsham. Ensure robust monitoring to stop developers segmenting sites to evade affordable requirements. Consider a borough-wide “no loopholes” rule so all communities contribute to tackling the crisis.

Comment

Representation ID: 6784

Received: 29/08/2025

Respondent: Philip Marshall

I&O_7211
A consistent borough-wide threshold should apply, with flexibility to reduce thresholds in areas where high unmet affordable need is evident. Applying a blanket lower threshold to all rural areas would unnecessarily make some smaller developments supported by the new NPPF unviable.   

Comment

Representation ID: 7036

Received: 29/08/2025

Respondent: Lambert Smith Hampton

I&O_7505
Needs to be subject to robust viability analysis

Comment

Representation ID: 7950

Received: 03/09/2025

Respondent: Acresfield Development Discretionary Trust

Agent: J10 Planning

I&O_8439
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 8162

Received: 03/09/2025

Respondent: M & S Lacey

Agent: J10 Planning

I&O_8651
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 8349

Received: 03/09/2025

Respondent: M and P Jones

Agent: J10 Planning

I&O_8838
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 8573

Received: 03/09/2025

Respondent: A-M, WR and AJA Posnett

Agent: J10 Planning

I&O_9064
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 8758

Received: 03/09/2025

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

Agent: J10 Planning

I&O_9251
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 8908

Received: 03/09/2025

Respondent: Trustees of G A Artell

Agent: J10 Planning

I&O_9401
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 9040

Received: 03/09/2025

Respondent: Mrs J Jenkins

Agent: J10 Planning

I&O_9533
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 9301

Received: 03/09/2025

Respondent: AM Littler, NJM Littler and C Leigh

Agent: J10 Planning

I&O_9795
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 9539

Received: 03/09/2025

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

Agent: J10 Planning

I&O_10034
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 9647

Received: 03/09/2025

Respondent: C, M and R Allsop

Agent: J10 Planning

I&O_10143
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.

Comment

Representation ID: 9756

Received: 03/09/2025

Respondent: Vistry Group and J Whittingham

Agent: J10 Planning

I&O_10252
Registered Providers will tell you that Affordable Housing is more easily managed in clusters and in urban areas and that single units in rural areas are difficult to manage. It therefore makes little sense to have a lower threshold in rural areas and certainly not one lower than 5 units (as suggested in NPPF65). The draft Section 157 designation should apply across the entire rural area be this open countryside or Green Belt and not discriminate and create a two-tier rural housing system. The types of Affordable Housing should be identified as including First Homes, Low-Cost Discount for Sale, Shared Ownership, Social Rented, etc.