Local plan scoping consultation

Comment

Representation ID: 6863

Received: 28/08/2026

Respondent: Home Builders Federation

The Council’s Scoping Consultation document outlines that the new Local Plan will have a plan
period of 2029 – 2045. It is envisaged that the Local Plan will be adopted in March 2029 and
therefore would have a 16-year plan period at that point in time. This is set against the minimum
plan period outlined in the NPPF of 10 years from adoption (Policy PM2).
Policy PM2 of the NPPF also outlines that a longer plan period can be considered where this would,
for example, help support the delivery of longer-term infrastructure or strategic development. The
HBF considers that the Council should maintain a longer plan period for these reasons and also to
provide certainty for the development industry to invest in the area. This also acts as a contingency
in the event of slippages in timescales.
It is also worth noting that the current adopted Local Plan Strategy is now over 9 years old and as
an authority, Cheshire East currently is not delivering a sufficient supply of new homes and by its
own calculations cannot demonstrate a five year supply of deliverable housing land (currently 3.3
years over the period 2025/26 – 2029/30). The HBF therefore has concerns that by setting the
beginning of the plan period at the point of adoption (2029), it ignores the current unmet need that
is taking place in Cheshire East. As such, the HBF considers the Council should be setting an earlier
start date to its plan period to seek to meet some of this existing shortfall. This should, as a
minimum, be from the start of the preparation of the new Local Plan (2026) but consideration could
be given to an earlier date.

Comment

Representation ID: 6864

Received: 28/08/2026

Respondent: Home Builders Federation

The new Local Plan should include a positive approach to housing growth within its Vision and
Objectives that should seek to meet the housing needs of current and future residents of Cheshire
East in full over the plan period. This should, as a minimum, plan to meet the Council’s Local
Housing Need (LHN), defined by the Standard Method. For Cheshire East this is currently 2,530
dwellings per annum, although this will need monitoring and updating to take into account changes
in housing stock and affordability data.
The HBF also requests that the Council fully examines whether there is a need for an uplift to the
LHN because of requirements to provide a range and choice of sites, the need for flexibility,
viability considerations, alignment of jobs and new homes, unmet need from neighbouring areas,
and whether higher levels of market housing are required to secure an increase in the delivery of
affordable housing (in line with Policy HO2 of the NPPF). The HBF expects all these aspects to be
explored thoroughly through the Council’s evidence base.

Comment

Representation ID: 6865

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF does not comment on specific sites but considers that it is imperative that any Land
Availability Assessment for housing is prepared in as comprehensive way as possible. This should
include an examination of the emerging housing trajectory of the plan to ensure that the Council
will be able to demonstrate a five-year supply of deliverable housing land upon adoption of the
Local Plan and throughout the plan period. This will prevent issues of land supply being raised later
in the plan-making process (e.g. at the Local Plan’s examination). The assessment should also be
informed by the accompanying Local Plan Viability Assessment to demonstrate those sites
identified are in fact viable and deliverable.
It is noted that amongst the Council’s priorities for the Local Plan is the promotion of brownfield
development. Whilst the HBF supports the use of brownfield land, it is considered that, to meet the
needs of Cheshire East in full, it is also likely that greenfield sites and suitable land within the Green
Belt will need to be identified and allocated. Therefore, when identifying and assessing sites, the
Council should be seeking options from all sources (brownfield land, greenfield land, as well as
examining Green Belt sites) with the main driver being the overall sustainability and deliverability
of the site rather than its status.

Comment

Representation ID: 6866

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF supports that the Council is undertaking a borough-wide Green Belt Assessment which
will identify grey belt land and help inform any future decisions on potential Green Belt release.
As outlined in our response to the section above, in order for Cheshire East to meet its housing
needs in full over the plan period, it is highly likely that the Council will need to consider the release
of Green Belt land and so undertaking the Green Belt Assessment at this point in the Local Plan’s
preparation is entirely appropriate. This approach to considering Green Belt release is consistent
with the NPPF, where it is clear that exceptional circumstances to examine Green Belt boundaries
can include instances where an authority cannot meet its identified need for homes solely on land
which is not in the Green Belt and having examined previously developed land and optimising site
densities (Policy GB3 of the NPPF).

Comment

Representation ID: 6868

Received: 28/08/2026

Respondent: Home Builders Federation

In a similar manner to the approach to Green Belt, the Council should also undertake an assessment
of its Strategic Green Gap to establish whether there are any opportunities to identify land for new
homes within it in a way that would not fundamentally undermine its role.

Comment

Representation ID: 6869

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF supports the establishment of a settlement hierarchy in Cheshire East, as this can help
shape and inform the Council’s spatial strategy. The HBF also agrees that the existing settlement
hierarchy should be reviewed to establish its effectiveness for the new plan period.
Within the Scoping Consultation document, the Council mentions in undertaking this review, it will
consider provision of services and facilities, population, jobs, sustainable transport, retail provision
and settlement form. The HBF would request that alongside looking at existing facilities, that the
Council should also assess settlements based on their future capacity to accommodate further
development. This can be done by analysing how future development may be able to enhance the
role, function and sustainability of these settlements through improved infrastructure provision and
helping to underpin and attract new services and facilities in specific towns and villages.

Comment

Representation ID: 6870

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF considers that the Council is correct in identifying that a range of factors will influence
the distribution of development put forward in the Local Plan. In relation to housing in particular,
this should be driven by ensuring the needs of the whole of Cheshire East can be met in full, taking
into account specific site and area constraints and the need to secure sustainable patterns of
development. This should also be informed and based upon the settlement hierarchy that has been
established.
Consequently, the HBF agrees with the Council that this will likely result in the need to pursue a
range of options including further development within existing settlements, edge of settlement
growth, large scale urban extensions and new settlements. In this respect, the HBF would emphasise
that the Council should avoid being wedded to any one single option and instead consider a variety
of options used in combination.

Comment

Representation ID: 6871

Received: 28/08/2026

Respondent: Home Builders Federation

The way in which development proposals within and outside of settlements should be determined
is covered in Policies S4 and S5 of the NPPF and as such, the Council will not need to replicate
these in the Local Plan.
Nevertheless, the Council will still need to determine what should be classified as ‘in settlements’
and what should be classified as ‘countryside’. In examining this, the HBF considers that the
Council should avoid the use of overly restrictive settlement boundaries/development limits which
could hamper and stymie future growth options in key settlements over the plan period. For this
reason, the Council should recognise that sites which are adjacent to and well-related to existing
settlements may also be sustainable options for growth and meeting housing needs. Therefore,
having a more flexible approach to settlement boundaries/development limits will assist boosting
windfall development and introduce additional flexibility into the Council’s future housing supply.

Comment

Representation ID: 6872

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF supports the Council in undertaking a Housing Needs Assessment (HNA) and considers
that this is a key part of the evidence base of the new Local Plan. It will be important that in
translating its outputs into policies, that a degree of flexibility is maintained. We detail this further
below.

Comment

Representation ID: 6873

Received: 28/08/2026

Respondent: Home Builders Federation

For the new Local Plan to be effective, it will need to be clear on the quantum of affordable housing
required across different areas of Cheshire East. This will need to be based on an assessment of
need from the HNA but also ensure that the requirement is not set at a level which would undermine
the deliverability of the Plan (see Policy PM12 of the NPPF). As such, the Council’s viability work
will also need to assess the appropriate level of affordable housing, taking into account other
planning obligations and planning policy costs.
It is also anticipated that the HNA will provide an analysis of the types of housing tenure that will
be required from development. However, any tenure requirement included in the Local Plan should
be flexible in nature to take into account site specific circumstances, characteristics and viability,
as well as local requirements of Registered Providers. It will also need to be cognisant of the fact
that tenure requirements may shift over the plan period and so any policy will need to be able to
react to changing circumstances in the future.