Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15010

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15569
Policy HO2 proposes to set a percentage requirement for affordable housing across the Borough, with the potential for this to vary by sub-area. It is noted that a minimum of 50% affordable housing will be required on Green Belt sites, and that the policy will specify the types of affordable housing to be delivered. Additionally, Policy HO2 proposes that affordable housing will be required on all sites of 10 or more dwellings, with the threshold reduced to three or more dwellings in designated rural areas. Bloor supports the inclusion of affordable housing in new developments and agrees that a threshold of 10+ dwellings is appropriate for triggering this requirement. Bloor also supports the potential for subarea variation, ensuring that affordable housing provision reflects local market conditions and housing needs across the Borough. Viability testing of the proposed affordable housing requirements will be essential and must be undertaken as part of the emerging Local Plan, ahead of the publication of the Regulation 19 version.

Comment

Representation ID: 15011

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15570
HO 3 proposes to retain existing Policy DM 19 (Proposals for residential development), which provides the requirements for residential developments within identified settlements, the countryside, and the Green Belt. Bloor supports the proposed retention of Policy DM 19 on the basis that the flexibility that allows for development within the Green Belt to align with the provisions in the NPPF are retained, ensuring that local policy regarding development in the Green Belt does not become out of date or unreflective of national policy. Bloor does however request that specific references to the development of ‘grey belt’ land are made within the updated policy, ensuring that it is clear that development of such land is appropriate for residential development, subject to requirements of NPPF Paragraph 155 being applied.

Comment

Representation ID: 15012

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15571
GI 1 proposes to create a single policy relevant to green infrastructure, biodiversity and nature, with considerations on biodiversity net gain, tree replacement rates, and agricultural land. Bloor supports the streamlining of the numerous existing policies into one appropriate policy to cover this.  

Comment

Representation ID: 15013

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15572
It is not considered appropriate for the Council to require a biodiversity net gain above the necessary 10% as set out under the Environment Act, however. The PPG noted that plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified (Paragraph: 006 Reference ID: 74-006-20240214). To justify such policies, evidence will need to be provided as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development, which has not been considered at this time. Without sufficient justification, pursuing an increased requirement would not align with the appropriate guidance, and may render development across the Borough unviable, particularly in areas where the market is less strong.

Support

Representation ID: 16761

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15479
LPIO Question IN3 invites comments on the proposed plan period for the new Local Plan. The LPIO document states that the Council believe it should update the Local Plan to plan for a period of 15-years. Adoption of the new Local Plan is unlikely until at least 2027. We would therefore suggest that the plan will need to make provision to meet development needs to at least 2045 to ensure sufficient flexibility.

Support

Representation ID: 16762

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15480
VI 1 states that the vision for Cheshire West and Chester is to be a desirable and attractive place to live, work, learn and visit with vibrant towns and villages, by meeting development needs in sustainable locations. It is proposed that this will be achieved by applying four overarching principles of tackling climate change, promoting wellbeing, providing infrastructure and protecting character. Bloor generally supports the Council’s vision and the four overarching principles which underpin it. However, in the context of a national housing crisis and a local affordability and affordable housing waiting list in Cheshire West and Chester, Bloor suggests that an additional overarching principle centred around housing delivery be added to the Council’s vision. This additional overarching principle would reflect the key issues identified by the LPIO (Paragraph 5.3). In particular, the LPIO identifies a need to do further technical work to assess the size and type of homes needed, and what tenure of homes should be provided, but the Council is aware 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. A strategic focus on housing delivery is imperative for the Council to realise its vision of Cheshire West and Chester being a desirable and attractive place to live. The prioritisation of housing delivery on sites such as Eaton Road will also support the other four overarching principles, ensuring that high quality housing with appropriate infrastructure is delivered across Cheshire West and Chester, providing residents with safe and decent housing.  Policy VI 1 states that the Council would expect the larger settlements in the borough to have an individual vision, including Chester, Ellesmere Port, Northwich, Winsford, Frodsham and Neston and Parkgate. Part 1 of the current Local Plan includes a specific policy for Chester, Ellesmere Port, Northwich and Winsford (Part 1 Policy Strat 3 – 8). It is unclear why Frodsham and Neston and Parkgate have now been identified as settlements requiring a specific policy, and other settlements, including Tarporley, also identified as Key Service Centres under Policy Strat 2 (Strategic Development) of Part 1 of the current Local Plan, have not. Indeed, Paragraph 5.7 of the LPIO appears to suggest that separate policies should be provided for each settlement. Bloor welcomes the inclusion of a settlement specific policy for Tarporley, which recognises the settlement’s importance as a Key Service Centre.

Support

Representation ID: 16763

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15481
Draft Policy SD1 (Sustainable Development) sets out the principles which new developments “must, where relevant”, meet. Bloor generally supports the principles set out in Policy SD1 and recognises the importance of new development in mitigating and adapting to climate change. Policy SD1 states that the redevelopment of previously developed land should be encouraged, and the development of greenfield land should be “minimised” as much as possible. Policy SD1 continues to state that proposals that fundamentally conflict with the above principles or policies within the Local Plan will be refused.  The Cheshire West and Chester Council Housing Land Monitor Summary Report (2025) [the HLM] states that on 1 April 2025, the Council can demonstrate a deliverable five-year housing land supply of 3,788 dwellings, equivalent to 1.89-year supply against a stated requirement of 10,038 dwellings. It should be noted that the Council has based its housing need on 2023 dwelling stock and 2024-2024 affordability ratios. Using the latest housing stock figures, the Council’s claimed supply actually represents a 1.87-year supply of housing land. The LPIO document recognises that some greenfield release will be required to meet housing need in the plan period. Bloor recognises the merits of a ‘brownfield first’ approach to development. The forthcoming application for residential development at Eaton Road will deliver homes on land which is in part previously developed. Bloor also acknowledges that it is imperative that sustainable greenfield sites also come forward to ensure that the Council can meet its housing requirement and the Government’s objective of significantly boosting the supply of homes (NPPF §61). Paragraph 5.3 of the LPIO document suggests that there are sites on previously developed land without planning permission within the main urban areas and Key Service Centres, with a potential capacity of 5,000 units. The LPIO recognises that this figure is however likely to reduce once a detailed assessment of developability has been undertaken. It will therefore be essential for greenfield land to be released for the Council to meet its housing requirement. Furthermore, brownfield development is often associated with significant viability constraints. An approach which seeks to ‘minimise’ greenfield development could hamper housing delivery and may not necessarily align with the spatial strategy of the Plan. The viability constraints associated with brownfield development means that this approach could be particularly harmful towards the delivery of affordable housing. Bloor suggests that the wording of this policy be amended to recognise that greenfield development on sustainable sites such as Eaton Road will be required in order for the Council to meet its housing need. Bloor welcomes the Council’s commitment in Policy SD1 to work proactively with applicants to find solutions which mean that proposals can be made sustainable and approved where possible. The wording of Policy SD1 should incorporate more flexibility to recognise that there will be instances where site specific constraints prevent accordance with all of the principles set out, and that this should not necessarily lead to a refusal but should instead be weighed against the positives of the scheme in the planning balance.

Support

Representation ID: 16764

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15482
Policy SS1 states that the Council plans to deliver a minimum of 1,914 new homes per year over the plan period. This equates to a total of 28,710 new homes over a 15-year plan period but adoption is unlikely until at least 2027, therefore we would suggest that the plan will need to make provision to meet development needs to at least 2045 to ensure sufficient flexibility. As such, a housing requirement of 38,280 is required as a minimum. Coupled with that, additional flexibility should be built into this figure to reflect the adoption date of the plan and the fact that the SM3 figure may increase slightly again before the adoption of the Plan. 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. In terms of ensuring that the minimum housing requirement is met, Bloor considers that a 10% buffer on the supply of land 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. As such, we would recommend that the identified supply of housing over the plan period should be 42,000 dwellings. The policy should, as a minimum, reflect the most up-to-date LHN when the draft Local Plan is published. When setting the plan period, the Council should also ensure that it allows sufficient scope to ensure that at least 15 years remain on the plan period from the point of adoption of the plan as required by national policy. As set out above, this is likely to require a plan period to run to 2045 and additional flexibility should be built into this period to accommodate any additional delays.

Support

Representation ID: 16765

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15483
When setting the plan period, the Council should also ensure that it allows sufficient scope to ensure that at least 15 years remain on the plan period from the point of adoption of the plan as required by national policy. As set out above, this is likely to require a plan period to run to 2045 and additional flexibility should be built into this period to accommodate any additional delays.

Support

Representation ID: 16766

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

I&O_15484
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 particularly given the housing and affordability issues in Cheshire West. In light of the national housing shortage and the significant current shortfall of housing delivery in the borough, it would be inappropriate for the Council to delay housing delivery. This is especially the case as there are numerous deliverable sites, such as Eaton Road, being promoted for development which can meet needs in the early years of the plan period. There are no reasons which would justify the Council not planning to meet the minimum housing requirement. Introducing a stepped requirement would go against the Government’s stated ambitions of boosting delivery of homes in this parliament, the Council has in the past regularly delivered sufficient homes on an annual basis to meet the SM3 figure and there are no overarching constraints in Cheshire West and Chester which would preclude the delivery of this quantum of homes. Therefore, Bloor recommends that a fixed annual requirement be adopted to ensure timely delivery of the necessary number of homes.