Local plan scoping consultation

Comment

Representation ID: 6874

Received: 28/08/2026

Respondent: Home Builders Federation

Whilst it is anticipated that the HNA will assess the need for different sizes and types of dwellings
to inform the policies of the Local Plan, in a similar way to matters relating to housing tenure, it is
important that any recommendations are not translated into policy in an inflexible and rigid way
and that the Local Plan should recognise that other site-specific factors will also influence the types
of homes that can be accommodated on a site. This includes the site’s location and character, market
and commercial considerations, as well as matters of viability.

Comment

Representation ID: 6875

Received: 28/08/2026

Respondent: Home Builders Federation

Any requirement for specialist housing should be based on robust evidence (see Policy HO1 of the
NPPF). Where need is identified, the HBF considers that positively worded policies can be
introduced that can encourage such specialist housing where sites and operators are identified. If
the Council opts to identify specific sites and allocate them, given that these types of development
are highly specialised and have specific operator requirements, then it is imperative that this is done
in conjunction with a specific developer or operator so as to avoid allocating sites which the sector
simply does not want or cannot deliver.
The HBF would recommend avoiding apportioning areas of general needs housing sites to
accommodate specialist housing. The operational and locational requirements for specialist housing
are very specific and often are not the same as that for general needs housing and without a specific
operator on board, there is a significant risk that the site becomes undeliverable. Furthermore, as
viability considerations for specialist housing are different to general needs housing, apportioning an area of a general needs housing site for specialist housing also risks the overall site becoming
unviable.

Comment

Representation ID: 6876

Received: 28/08/2026

Respondent: Home Builders Federation

To help inform the approach to self and custom build housing, the Council will need to assess the
need in Cheshire East in line with the requirements set out in the Planning Practice Guidance (PPG,
Reference ID: 57-018-20210208).
The HBF considers that unless significant demand can be demonstrated, then the Council should
not need to identify specific sites for self and custom build homes or require serviced plots on larger
market housing sites. Rather the Local Plan should instead seek to create a positively worded policy
that can encourage self and custom build housing where such demand is demonstrated. This will
also take into account that such demand may not be evenly spread across the authority.

Comment

Representation ID: 6877

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF considers that it is important that the Council identifies and allocates a wide range of
housing sites that are different sizes and are in different locations.
This includes larger sites which can deliver a significant portion of the area’s housing need and do
so in a sustainable and holistic manner. Many of the HBF’s members who are active in Cheshire
East have experience in developing strategic sites and the HBF would encourage the Council to
engage with these house builders at an early stage to ensure that any associated policies are shaped
in a way to ensure site deliverability.
Alongside larger strategic sites, the Council should also identify and allocate smaller sized sites as
well (in line with the requirements in Policy HO6 of the NPPF). Whilst larger sites can contribute
significantly to meeting the Council’s needs over the plan period, such sites often have longer lead
in times and usually require a notable amount of infrastructure to be installed prior to new homes
being delivered.
By identifying and allocating smaller sites, this allows delivery of homes in the earlier part of the
plan period as often such sites have much shorter lead-in times. This will help even out the Council’s
housing trajectory and avoid housing land supply issues early on in the plan period prior to large
strategic sites delivering units.
Smaller sites will also ensure a more diverse housing market in Cheshire East, ensuring more choice
and competition. To this end, it is important that the Council not only identifies such sites but also
ensures that they are allocated. Whilst the Council has highlighted that this would present a
challenge for them, the reason why it is needed is that often small and medium house builders
struggle to secure developer finance, with banks often needing to assess in detail the risk of lending
to such businesses. Having a site allocated provides much more certainty that development can
come forward on a site and so assists small and medium builders in obtaining funding.

Comment

Representation ID: 6878

Received: 28/08/2026

Respondent: Home Builders Federation

In the Scoping Consultation document, the Council has committed to exploring whether it should
be adopting enhanced standards in relation to:
• Accessible and adaptable dwellings (Under part M4(2) and M4(3) of the building
regulations).
• Increased water efficiency standards.
• Nationally Described Space Standards (NDSS)
It should be noted that Policy HO5 of the NPPF now requires that no less than 40% of homes on
major developments should be delivered to M4(2) standards. Nevertheless, in all instances the
Council will need to justify anything over and above this requirement with reference to the relevant
tests outlined in the PPG, as well as exploring the viability implications of introducing these
standards.
Whilst it is understood that standards such as NDSS and accessible dwellings are already found in
the existing development plan for Cheshire East, it will still be necessary to review the effectiveness
of these policies and establish whether there is still justification for their inclusion and any
associated thresholds.

Comment

Representation ID: 6879

Received: 28/08/2026

Respondent: Home Builders Federation

The Scoping Consultation document correctly outlines that the approach to transport should be
vision-led and seek to promote sustainable travel options. In this regard, where there are
opportunities, the Local Plan should seek to promote sustainable transport initiatives and there is
clearly potential to provide a strategy which encourages growth where it can support sustainable
patterns of development. Nevertheless, it should be acknowledged that the right balance needs to
be struck between the shift towards sustainable modes of travel and recognising that for some
people the use of private car will remain an essential part of their ability to move around the area
and in particular in the more rural areas of Cheshire East.
In relation to infrastructure more generally, the Council will need to produce an Infrastructure
Delivery Plan (IDP). It is worth highlighting that the development identified in the Local Plan can
only be required to mitigate its own impact and cannot be required to address existing deficiencies
in infrastructure or services. It is therefore essential for the IDP to clearly show the existing and
known deficiencies in the current infrastructure, before reaching any conclusion on the cumulative
effects of new development, and any contribution that is needed from new development to mitigate
any additional individual and/or cumulative impacts.
Therefore, whilst it is appreciated that an IDP is a ‘live’ document that needs to be updated
throughout the plan period, the HBF would nevertheless seek that for the preparation of the Local
Plan that it provides as comprehensive list and cost of infrastructure as possible. This is so that it
can feed into the Local Plan Viability Assessment and therefore provide an accurate picture of how
this may impact on the delivery of development.

Comment

Representation ID: 6880

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF agrees that the new Local Plan will play an important role in protecting and enhancing
the natural environment. It should be noted that many of the requirements in relation to ecology and
biodiversity are already enshrined in national legislation, policy and guidance (such as Biodiversity
Net Gain, BNG) and this includes the draft NPPF. Consequently, the HBF considers that, as
planning policies should not replicate existing national policies (see Policy PM6 of the NPPF), the
Council should focus on policies which assist in translating these requirements to a local level to
help applicants address the mandatory ecological and biodiversity requirements for their
developments.
The HBF notes that the Cheshire and Warrington Local Nature Recovery Strategy (LNRS) has now
been published. The LNRS will likely play an important role in ensuring development in the Local
Plan can contribute towards conserving and enhancing the natural environment and, following
recent legislative changes, will also assist in achieving BNG.

Comment

Representation ID: 6881

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF agrees with the benefits of incorporating active travel within new development.
Nevertheless, the ability to incorporate the infrastructure that supports active travel (such as those
outlined in the Government’s Local Transport Note 1/20) will depend on a site’s location and its
capacity to safely and feasibly incorporate such features. This means whilst it can be encouraged,
the Council should stop short of mandating it on all sites as it may not be appropriate in all cases.

Comment

Representation ID: 6882

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF agrees that the Local Plan can play a key role in tackling climate change. However, it
considers that the policies of the Local Plan should align with the Government’s overall net zero
strategy and the national standards that it has set to achieve this policy goal. This is because these
standards are universally understood and technically implementable.
Over recent years the HBF has worked collaboratively with the Government and other bodies to
ensure future homes are as energy efficient as possible to help address climate change. To this end,
the Future Homes Standard (with its associated implementation period) was published in March
2026. The WMS that was published alongside the Future Homes Standard (reference: UIN
HCWS1445) clearly states:
“Implementing these standards marks a pivotal step for the sector in our pursuit of net zero. It sets
out a clear route towards delivering homes and buildings that are prepared for the future in their
enhanced energy efficiency, low carbon heating, and improved protection against overheating. This
approach supports the transition to a cleaner, greener built environment, ensuring new homes are
‘zero carbon ready’ and resilient to the impacts of climate change.”
This demonstrates the ambitions of the Government concerning the move towards net zero and this
is what should be reflected in the Local Plan.
It is also noted that the Scoping Consultation document mentions other associated areas which can
help tackle climate change including electric vehicle charging infrastructure, digital infrastructure
and embodied carbon.
The Council will be aware that matters relating to electric vehicle charging and broadband are
already covered by Parts R and S of the building regulations and so will not need to be replicated
in the Local Plan (see Policy PM6 and PM13 of the NPPF). With regards to embodied carbon, the
HBF considers that measures to address this in construction clearly has merit, however the
Government has yet to provide a national standard for measuring and benchmarking this that can
apply across all local planning authorities, so that a consistent approach can be followed. As a result
of this, the HBF considers that whilst considering embodied carbon could be promoted in the Local
Plan, the Council should stop short of requiring a detailed assessment at this time.

Comment

Representation ID: 6883

Received: 28/08/2026

Respondent: Home Builders Federation

The HBF considers that in setting design policies in the new Local Plan, the Council should set the
broad parameters of what it considers to be good design for Cheshire East in the policy (aligned to
the NPPF and other national guidance) but seek to avoid overly detailed policies, as the specific
design of a site will need to be informed by an individual analysis of its constraints and
opportunities. The Council should therefore seek to resist a ‘one size fits all’ approach to design
and whilst previous examples of good design in Cheshire East can be noted, it may not be possible,
practical, viable or desirable to simply replicate that on other sites.
The HBF agrees with the Council that Design Codes could prove to be a useful tool in setting out
clear design expectations for an area or site and ensure a cohesive and coherent design is achieved
(as per Policy DP2 of the NPPF). However, the Council should avoid setting Design Codes over
too wide an area (such as authority-wide) as this can either lead to homogenisation of design and a
loss of local vernacular and character or create a document which is excessively complicated and
difficult to implement. Similarly, the Council will need to ensure any Design Codes produced have
enough flexibility so that they can address and adapt to changes throughout the lifetime of the
development of the area in question and not seek to impose certain design solutions that could
stymie innovation.
The Council also mentions in the Scoping Consultation document that it is considering the
production of a Supplementary Plan or a Design Framework in the Local Plan to establish clear
placemaking expectations for new development. Irrespective of which option is chosen, the HBF
considers it is important that a consistent approach to design is maintained which takes into account
individual site constraints and opportunities and where there are future changes put forward, that
any additional costs that may occur from those changes are accurately reflected in the Local Plan
Viability Assessment.