Local Plan Issues and Options (Regulation 18)

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Local Plan Issues and Options (Regulation 18)

Question SS 4

Representation ID: 16767

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15485
Policy SS3 (Spatial Strategy Principles) states that the spatial strategy will follow the principle of directing new development and allocating land towards previously developed sites within settlements first. Policy SS3 states that where there are not enough planning permissions and opportunities for redevelopment within urban areas and towns, the approach will be to develop on the edge of existing settlements in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option. Bloor recognises the importance of bringing underutilised brownfield sites back into use. The northwestern extent of Land at Eaton Road is brownfield, and Bloor intends to bring this underutilised land forward for residential development as part of the forthcoming application for outline planning permission on the site. Bloor also supports the Council acknowledging that there is a need for greenfield development on the edge of settlements. The Council should ensure that the strategy for housing delivery does not place an over reliance on the redevelopment of brownfield sites, especially in the context of large shortfalls of housing in the borough and a national housing crisis. The strategy for housing delivery should recognise the constraints associated with brownfield delivery, including viability, which can impact on the delivery of family and affordable homes in particular. Furthermore, there is a constrained supply of suitable brownfield sites, with the most suitable already developed or subject to planning applications. Greenfield development is necessary to ensure that a sufficient number, and the required types and tenures of homes, is delivered to meet the needs of the borough. The spatial strategy should reflect the varied characteristics of the Borough and incorporate sufficient flexibility to respond to local circumstances.

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Local Plan Issues and Options (Regulation 18)

Question SS 5

Representation ID: 16768

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15486
As set out above, Part 1 of the Current Local Plan (Policy Strat 2) identifies Neston and Parkgate and Frodsham as Key Service Centres, in addition to several other settlements including Tarporley. It is unclear why Neston and Parkgate and Frodsham have been included as Market Towns under LPIO Policy SS4, and other settlements such as Tarporley are excluded from this list. Bloor suggests that the proposed settlement hierarchy be amended to reflect the current hierarchy, and development be directed across the borough proportionally. Bloor recognises the merit in new development being directed towards the largest settlements,including Chester. However, the Council’s approach should recognise the role of Key Service Centre settlements, including Tarporley, which have the services and facilities to accommodate residential development growth. This will ensure sustainable patterns of development across the borough, and ensure that there is an adequate choice of land to meet housing requirements.

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Local Plan Issues and Options (Regulation 18)

Question SS 57

Representation ID: 16769

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15487
Bloor supports the identification of land within TARP01 by Map 5.15 as a development option for future growth. For the reasons set out throughout these representations, Bloor consider that land at Eaton Road should be allocated for residential development. Should land at Eaton Road be allocated for residential development, the settlement hierarchy should recognise the role of Tarporley in helping deliver development growth. An individual place, or allocation-based, policy for Tarporley should be provided within the Local Plan to guide development. Any policy requirements for development in Tarporley should be appropriately viability tested through the Local Plan process.

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Local Plan Issues and Options (Regulation 18)

Question SS 11

Representation ID: 16770

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15488
Land at Eaton Road forms the western-most parcels of the larger ‘TARP01’ land parcel identified by Map 5.12 of the LPIO. TARP01 is identified as a potential development site under all three spatial strategy options set out in Policy SS5. Bloor welcomes the Council’s recognition that the site could be suitable for residential development under all proposed spatial options. The identification of TARP01 as a suitable development site under all proposed spatial options demonstrates the sustainability of the site’s location and appropriateness for residential development. Bloor is supportive of Spatial Strategy Options B and C, as they allow development to be directed to the most sustainable locations. Whilst TARP01 does not sit within the Green Belt, and is identified under Option A, Bloor does have concerns with Option A as an approach. Option A has the potential to prevent housing delivery in sustainable locations as a result of them currently being located within the Green Belt. National policy provides a clear framework for the release of suitable land within the Green Belt to deliver homes. Bloor considers that this approach should be reflected in the Council’s Spatial Strategy and that Green Belt boundaries should be reviewed to ensure that the most suitable and sustainably located sites are considered for residential allocation. Spatial Strategy Option B seeks relatively limited development in Key Service Centres, including Tarporley, of 3,000 homes across the plan period in total. Bloor considers Tarporley to be sustainably located and home to a number of key services and facilities which would indicate that it is capable of accommodating more than this share of development. Indeed, Options A and C identify Tarporley as being capable of accommodating further development. Bloor consider that whichever option is chosen, Tarporley should be identified for accommodating further growth to ensure that sustainable sites on the edge of the settlement, such as Eaton Road, can come forward for residential development.  For the reasons stated throughout these representations, Land at Eaton Road represents an ideal opportunity for housing delivery under all three options. Whichever Spatial Strategy Option the Council choose to adopt, these representations have demonstrated that the site is suitable and available, and should be allocated for residential development as part of the emerging plan.

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Local Plan Issues and Options (Regulation 18)

Question SS 57

Representation ID: 16771

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15489
Land at Eaton Road forms the western-most parcels of the larger ‘TARP01’ land parcel identified by Map 5.12 of the LPIO. TARP01 is identified as a potential development site under all three spatial strategy options set out in Policy SS5. Bloor welcomes the Council’s recognition that the site could be suitable for residential development under all proposed spatial options. The identification of TARP01 as a suitable development site under all proposed spatial options demonstrates the sustainability of the site’s location and appropriateness for residential development. For the reasons stated throughout these representations, Land at Eaton Road represents an ideal opportunity for housing delivery under all three options. Whichever Spatial Strategy Option the Council choose to adopt, these representations have demonstrated that the site is suitable and available, and should be allocated for residential development as part of the emerging plan.

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Local Plan Issues and Options (Regulation 18)

Question GB 1

Representation ID: 16772

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15490
Policy GB 1 (Green Belt and Countryside) guides development on land designated as being within Green Belt and Countryside. The wording of Policy GB 1 should provide sufficient flexibility to recognise that windfall sites within the Green Belt and Countryside may need to come forward within the plan period to ensure that housing need is met in Cheshire West and Chester. Bloor considers that it is crucial for the wording of this policy to encourage residential development in sustainable locations in the Green Belt and Countryside in accordance with national policy where the Council cannot demonstrate a fiveyear supply of housing land. This will help to ensure that the Council can facilitate the delivery of the required number of homes to meet the needs of its residents in circumstances where some of the plan’s allocations do not come forward as planned.

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Local Plan Issues and Options (Regulation 18)

Question ID 1

Representation ID: 16773

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15491
Policy ID 1 (Infrastructure and Developer Contributions) sets out the suggested approach with respect to infrastructure and developer contributions. The suggested approach is to amend the Local Plan (Part One) Policy Strat 11 to ensure that educational needs, including contributions to school transport provision will be required, increase environmental protections and provide greater detail regarding the safeguarding of social infrastructure. It is unclear whether Cheshire West and Chester will review its CIL Charging Schedule as part of this process. Bloor would welcome clarity on this matter. Bloor supports the principle of developer contributions being used to mitigate the impact of development in accordance with NPPF paragraph 58. This means they should only be sought where they are directly relevant to the development, necessary to make it acceptable in planning terms, and reasonable, related in scale and kind to the development. Sufficient flexibility should be incorporated into Policy ID 1 to recognise that the challenges and needs of development varies from site to site. The Council’s approach should be cognisant of viability challenges and allow for contributions to be directed to where they are most needed. Paragraph 35 of the Framework states that policies associated with development contributions should not undermine the deliverability of the plan. Policy ID 1 should be worded with sufficient flexibility to ensure that contributions are directed effectively and the delivery of much-needed homes in Cheshire West and Chester is not undermined through onerous contributions. This is particularly important in Cheshire West and Chester given the presence of an adopted CIL Charging Schedule which has a proportionately high cost.

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Local Plan Issues and Options (Regulation 18)

Question HO 1

Representation ID: 16774

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15492
The LPIO states that the current Local Plan policies will be substantially amended to reflect the evidence of the Housing Needs Assessment (to be prepared). It is proposed that the revised policy will provide detailed, prescriptive requirements for matters including housing mix and self-build housebuilding. Whilst Bloor supports the delivery of an appropriate housing mix to meet the needs of the residents of Cheshire West and Chester, the policy approach should be revised to ensure more flexibility to enable individual sites to respond to market conditions, site constraints and the character of the local area. Bloor has concerns about a one-size fits all approach, that relies on the findings of a forthcoming Housing Needs Assessment for housing delivery across the region over the next 15-years. Prescriptive policies will act as a barrier for housing delivery and will not enable developers to respond to the diverse range of local conditions in the borough. Policy H01 should allow for applicants to depart from the suggested tenure and housing mix guidelines, where it can be clearly justified. Given that the Plan is likely to try and maximise development opportunities in urban areas at higher densities, this approach will deliver a higher proportion of smaller units (1 and 2 bed apartments). As such, other site will need to meet the needs for family homes so an overly prescriptive policy may hinder the ability to provide sufficient quantum of family homes. Bloor also has concerns over the inclusion of self-build and custom housebuilding on large allocations. Whilst Bloor recognise that there is a market and a need for this form of housing, there are difficulties associated with its delivery, and it has the potential to affect the design character of the wider scheme. Self-build homes are more effectively delivered on urban sites identified through the brownfield register. Viability testing of the proposed housing mix policy will be necessary as part of the emerging Local Plan. This testing should be completed in advance of the Regulation 19 version of the Plan to ensure that the policy is deliverable and does not undermine the viability of development.

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Local Plan Issues and Options (Regulation 18)

Question HO 4

Representation ID: 16775

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15493
Policy HO 2 (Delivering Affordable Housing) sets out the proposed policy approach with regard to affordable housing. The draft policy does not state the percentage of affordable housing that will be required across the borough but does indicate that this may vary by sub-area. Bloor recognises the importance of providing affordable homes and remain committed to the delivery of affordable homes as part of its developments where possible. The potential for sub-area variation is welcome, ensuring that affordable housing provision reflects local market conditions and housing needs across Cheshire West and Chester. Bloor considers that the wording of Policy HO 2 should provide sufficient flexibility for developers to bring sites forward with non-policy compliant levels of development contributions, including affordable housing, in circumstances where robust evidence can be provided to demonstrate that site-specific constraints mean that it is not viable to do so. Without this flexibility, there is a concern that the policy could undermine housing delivery across the plan period and prevent sites which would otherwise be wholly acceptable from coming forward. Viability testing of the proposed level of affordable housing will be necessary as part of the emerging Local Plan. Again, this testing should be completed in advance of the Regulation 19 version of Plan to ensure that the policy is deliverable and does not undermine the viability of development in the borough.

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Local Plan Issues and Options (Regulation 18)

Question HO 7

Representation ID: 16776

Received: 29/08/2025

Respondent: Bloor Homes North West

Agent: Lichfields

Representation Summary:

I&O_15494
Policy HO 3 (Proposals for Residential Development) states that Local Plan (Part Two) Policy DM 19 will either be retained as a separate policy or the general principles will be incorporated into other policies in the new Local Plan. With regard to residential development on land designated within the Countryside, Bloor consider that the wording of Local Plan (Part Two) Policy DM 19 should be amended to facilitate development in sustainable locations that would otherwise be wholly acceptable. In the context of current under delivery in Cheshire West and Chester, and a national housing crisis, the proposed policy should be less restrictive to enable development on Countryside land to come forward where the Council is currently unable to meet its housing need. This will ensure that there is sufficient choice and supply of land for new homes and be critical for the Council to meet its housing requirement.

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