Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15408

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15967
The “vision – principles” narrative at VI1 should be clear in that the plan is essentially a tool to ensure that the identified development needs of the authority area are fully met. This should be front and centre of the vision, whilst acknowledging that in meeting this principal aim it will do so in a manner consistent with the overarching principles. Where there is tension between these principles and the principal aim of the plan, the latter should of course prevail. It should be clear that NOT meeting the development needs of the authority is not an option.

Comment

Representation ID: 15409

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15968
Given the changes in national planning policy, it would not be appropriate to simply roll forward objectives which are inherently out of date and inconsistent with much of the new guidance and priorities laid down in the new NPPF and national guidance. Accordingly, only Option B has any true legitimacy. In this regard, the sustainability appraisal objectives appear to reflect those in national guidance. Provided the objectives are underpinned by the primary objective which is to meet in full the development needs of the authority, use of these objectives makes the most sense and is supported.

Comment

Representation ID: 15410

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15969
Any policy which attempts to be over prescriptive or does not accept that technological changes will occur and cannot necessarily be foreseen at this stage will ultimately carry little or no ultimate weight and will simply be worked around and will reduce the importance and impact of the policy. Policies in the plan ought not to repeat or rework guidance which exists in the Framework or national guidance; the best solution is that the plan remains silent on matters which are adequately covered in national guidance. Perhaps more importantly, the plan should not seek to go behind national guidance and seek to apply more onerous restrictions on development than might otherwise apply. For example, in respect of the “additional environmental and social requirements” being considered, national guidance does not seek to “avoid development in locations of high environmental value and on high grade agricultural land”. National guidance is more nuanced and acknowledges that meetingdevelopment needs is vital whilst recognising the intrinsic character and beauty of the countryside and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland (NPPF 187 b). Importing greater level of controls using words such as avoid / reject / refuse is simply inconsistent with most of the national guidance and should not be the approach taken if the plan is to be shown to be consistent with national guidance and hence sound. It should then be considered whether the plan needs to provide additional guidance, particularly where this seeks to require adherence to certain specific technologies, e.g. district heat networks, beyond that in national guidance. Simplicity in the plan making process and avoidance of conflicts with national guidance remains crucial to local plans being vital land use planning tools.

Comment

Representation ID: 15411

Received: 29/08/2025

Respondent: Consilio 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: 15412

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15971
It should be explicitly clear that there is no prospect of the needs of the authority being met through redevelopment or development of previously developed land (PDL) within urban areas. It seems entirely wrong to set up a policy which indicates that this even has the potential to meet all needs. The ‘urban extensions’ (second tier) should be stated to be an essential strategy in meeting needs, particularly for housing. This will help to avoid the idea that this is some form of sequential approach to land release, where greenfield or other sites on the edges of urban areas are only to be released once the stock of PDL sites in urban areas has been exhausted. The policy should be crystal clear that all forms of development (PDL and greenfield / green belt) within and out with existing settlement boundaries is essential to meeting needs. 

Comment

Representation ID: 15413

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15972
Option A is to promote an updated spatial strategy but without any Green Belt release. Given the evidence set out in the consultation regarding the scale of housing need, limited urban capacity, and the geographic constraints of the Borough, we do not believe Option A can deliver the required growth. The consultation documents acknowledge that Green Belt boundaries will need to be reviewed to identify sustainable, well-contained, and defensible sites that leave the remainder of the Green Belt capable of continuing to perform the functions set out in NPPF. This is reinforced by the consultation’s recognition that meeting future housing requirements will almost certainly require Green Belt release.  If this option were chosen it would mean that development around Winsford and other larger settlements which are not constrained by Green Belt would be considerable. This would expressly include the land being promoted by our client, so in terms of the effect on the delivery of this site, selecting this option would support our client’s aspirations and beyond. However with an increase in the overall housing requirement and a challenging target of more than 11,000 homes to be delivered at Winsford, given a number of the significant site constraints which affects much of the peripheral land around Winsford, there is a real risk that the targets cannot be achieved. Not only does this increase the need to ensure that deliverable sites around Winsford are prioritised (including our client’s land) but that other options need to be considered which do not preclude allocations of Green Belt land elsewhere. Notwithstanding this we consider that a failure to review and consider Green Belt release could render the plan’s delivery targets unachievable and could call into doubt the soundness of the plan. It is for this reason that we prefer option B, which maintains the delivery of significant development at Winsford, including our client’s site in whole. Option B is to follow the current local plan distribution of development with levels adjusted to achieve the increased housing and other requirements. This would continue the approach to locating most new development in, or on the edge of the main urban areas, with other developments focused on those smaller settlements which can support delivery of sustainable development. This option maintains the spatial approach accepted in the earlier plan and which was founded on sound principles. It will result in considerable development around the main key settlements, including Winsford as well as considerable Green Belt release where justified. In our opinion this option remains the most balanced strategy which has the greatest prospect of delivering the housing requirements laid down in NPPF. For this reason we endorse this option as the most appropriate and sound approach to the local plan spatial strategy. Option C promotes development around sustainable transport corridors. This would see development focused at nodes in the transport network, with particular emphasis on railway and bus corridors. In our opinion whilst this approach has the potential to achieve positive results in more urban authorities with a network of urban rail, tram and bus services which can ensure good service at all times, it will not perform well in authorities with large rural areas, networks of smaller settlements and much more limited public transport opportunities, regardless of the efforts to enhance service levels. Access to rail and bus networks is only one element of delivering sustainable development. It is much more important for people to be located close to existing facilities and services and to be able to walk or cycle to these facilities, accepting that the majority of travel beyond 1 – 2km will be made by private vehicles. The urban extension approach to spatial development has a much greater opportunity to deliver sustainable development than nodal developments in locations which, save for access to some level of public mass transit, do not otherwise perform well in sustainable development terms. We do not then favour the sustainable transport corridor approach to the spatial strategy and believe that it would be counterproductive and likely in overall terms to deliver lower levels of sustainable developments. From the perspective of our client with interests in land at Chester Lane, Winsford, it is notable that each of the spatial options requires the delivery of the site WIN07 (which encompasses all of our client’s land) by reference to Map 5.7 Winsford Growth Options at page 47 of the draft document. We agree that the site WIN07 will be a crucial contributor to meeting the housing requirements of the authority and is appropriately included as an allocation in any spatial scenario.

Comment

Representation ID: 15414

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15973
As previously indicated we support the potential growth areas to the west and north west of Winsford, including our client’s land which makes up the majority of site WIN07. The site offers the greatest opportunity to deliver housing development at an early stage (within the next 5 years) in a manner which does not require extensive infrastructure improvements, is not within Green Belt and where there are no other significant constraints, including drainage and flood risk, which considerably affects some of the other options around Winsford. We would support the early allocation and release of development at WIN07 and our clients will be progressing with a planning application for development of the main part of this site in short order. The application will further demonstrate that the site is largely unconstrained and has the potential to deliver much needed new homes in a sustainable manner in a location where significant development is inevitable.  We would support the early allocation and release of development at WIN07 and our clients will be progressing with a planning application for development of the main part of this site in short order. The application will further demonstrate that the site is largely unconstrained and has the potential to deliver much needed new homes in a sustainable manner in a location where significant development is inevitable. We would strongly support the allocation of the site identified as WIN07 as the most appropriate of the suggested allocations around the perimeter of Winsford.

Comment

Representation ID: 15415

Received: 29/08/2025

Respondent: Consilio Bono

Agent: PWA Planning

I&O_15974
We support the overarching policy approach for Winsford, which promotes regeneration, town centre living, improved accessibility, and the efficient use of previously developed land. This aligns closely with the objectives of the Winsford Neighbourhood Plan and Winsford Development Framework. In particular, the allocation of sites capable of delivering significant housing growth in the short term should be explicitly recognised. Site WIN07 represents a deliverable opportunity to provide a substantial contribution to the town’s housing supply within the first five years of the plan period. We recommend that the policy text be updated to specifically recognise that site WIN07 is capable of providing immediate housing delivery, supporting both the regeneration objectives and the Council’s housing delivery targets. WIN07 is a viable candidate to significantly support early-phase housing delivery. Its inclusion would reinforce the Council’s commitment to addressing short-term housing targets while supporting Winsford’s regeneration agenda. Acknowledging site WIN07 in the policy wording will help give certainty and clarity to stakeholders. The consultation highlights the significant housing land shortfall that Cheshire West and Chester is currently facing. The latest evidence confirms that the Borough is unable to demonstrate a five-year housing land supply, with provision falling substantially below the minimum requirement set by the NPPF at 1.98 years. This presents a pressing issue that must be addressed through the emerging Local Plan to ensure that the authority can meet both its objectively assessed needs and its wider obligations to deliver housing choice and affordability. In this context we support the proposed allocation of WIN07 for housing development in the short term. The site is actively being promoted and has considerable interest from national housebuilders. This reflects both its commercial appeal and deliverability. Supporting technical documents will be submitted with the forthcoming planning application, at the time of writing there are no known constraints which would hinder development. Importantly, WIN07 is unconstrained by significant environmental or infrastructure barriers. It is capable of delivering housing within the first five years of the plan period, helping to address immediate housing needs and helping to deliver and maintain a five-year housing land supply. The site offers a logical extension to the built-up area of Winsford, reinforcing settlement patterns and the strategic aim to concentrate growth around existing urban infrastructure. The site lies entirely within Flood Zone 1, indicating the lowest risk of fluvial flooding, with only a very small area affected by surface water flooding, which is minor and easily manageable through standard drainage design. Figure 2 below shows the Environment Agency’s surface water flood maps for the area. This site presents one of the most favourable flood risk profiles, further supporting its suitability for development. This is in contrast to some of the other proposed allocations which suffer from significant constraints from flood risk as well as other infrastructure issues. Site WIN07 occupies a sustainable location on the edge of the existing built-up area, with easy access from the established road network. It represents a logical and well-contained extension that rounds off the existing settlement pattern, making efficient use of available infrastructure and reducing the need for major new connections. The site’s proximity to existing homes, services, and transport routes makes it well suited for integration into the wider community, supporting sustainable growth. The Winsford Development Framework identifies key objectives for the town, including: regeneration of the town centre and old High Street, increased town centre living, enhancements to open space and the waterfront, improved leisure routes, and better accessibility to the railway station. Site WIN07 is ideally located to support these aspirations. Its position on Chester Lane places it within relatively easy reach of the town centre, enabling it to contribute to population growth that supports retail and service vitality. Additionally, the site offers opportunities to incorporate green infrastructure and new active travel links, aligning with the framework’s ambitions for improved leisure routes and accessibility to public transport, including the railway station. Site WIN07 is capable of delivering housing without significant upfront infrastructure constraints. The site benefits from direct access to Chester Lane and can be readily connected to existing utility networks. It is surrounded by existing residential development, minimising the need for off-site enabling works. Where required, appropriate contributions to local transport improvements, education, and open space will be made in accordance with CIL or Section 106 obligations. Given its advanced stage of promotion and ease of delivery, WIN07 represents a low-risk, high-impact housing allocation, offering a practical and sustainable solution to both short-term housing pressures and long-term regeneration objectives. We therefore consider that site WIN07 represents a highly deliverable allocation that supports the Council’s strategic housing and regeneration objectives with minimal infrastructure risk. It is also feasible that WIN07 could contribute positively to the further development of land within close proximity, by delivering access solutions which avoid less appropriate routes. It could then act as a catalyst and precursor to wider plan-led development in this part of Winsford.