Local Plan Issues and Options (Regulation 18)

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Comment

Local Plan Issues and Options (Regulation 18)

Question OB 4

Representation ID: 15214

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15773
Chester Zoo are supportive of the retention of objective SO1, which enables Chester to continue to develop as a sub-regional city and therefore, be a suitable place for ongoing development. It is understood that the areas of rural development are dependent on the agreed spatial strategy however, are supportive of Chester remaining as a key area for development in accordance with the settlement hierarchy. Chester Zoo are supportive of the retention of objective SO9 which focuses development within and on the edge of main urban areas and key service centres. This is in accordance with all suggested spatial strategies which focus the largest areas of development on key service centres. Objective SO10 aims to protect the Green Belt. Whilst Chester Zoo are not necessarily against the suggested objective, there are two key points to consider: New national policy regarding Grey Belt opportunities for development within the Green Belt. Given this, and in consideration against the Council’s current housing position aligned with the new NPPF policy, it is submitted that the Council must support those sites that merit consideration as a Grey Belt opportunity, subject to infrastructure improvements in the locality, open space / recreation / BNG improvements, and affordable housing provision 15% above standard LPA policy (will be 45%). The Zoo land at Upton, Chester offers such opportunity. Release of Green Belt to accommodate necessary allocation for development, e.g. housing, is not prohibited by national policy. Through reasoned strategic justification, boundaries can be amended through the Local Plan review process. If such an approach is pursued by the Council, the suggested parcels of land in Upton put forward by The Zoo provide such an opportunity, without compromising the sustainability principles of the Plan.

Comment

Local Plan Issues and Options (Regulation 18)

Question OB 5

Representation ID: 15230

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15789
The Sustainability appraisal objectives are less place specific. It is not clear the impact of these on policy as a whole. Applying the Local Plan objectives (Option A – take forward the current Local Plan objectives) provides a more specific direction for local planning policy.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 1

Representation ID: 15231

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15790
Chester Zoo do not see any reason for the Council not to deliver on their increased housing target over the plan period. An up-to-date housing needs assessment would be welcomed to ensure the target is accurate for the housing demand in Chester.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 2

Representation ID: 15232

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15791
Chester Zoo do not believe the Council should consider a stepped housing requirement, planning for a lower level of delivery earlier in the plan period. Reference is made by the Council to a quantum of undeveloped planning permissions and undeveloped Local Plan allocations, the basis for which they would justify a stepped approach presumably. The counter argument is to ask why permissions haven’t been implemented and why allocations have not been progressed through Planning. Constraints are clearly precluding these development opportunities, the majority of which may be insurmountable and so the quantum may be deemed available but simply not deliverable.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 4

Representation ID: 15235

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15794
Chester Zoo would be in favour of the spatial strategy of development within settlements, then followed by edge of settlement sites which are located sustainably. This ensures that future residential development still follows the hierarchical position as per the adopted Local Plan, with Chester top tier. Grey Belt opportunities can still be accommodated, together with small scale urban extensions on open countryside in other high tier settlements such as Ellesmere Port and Winsford, together with appropriate levels in the key service centres.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 5

Representation ID: 15237

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15796
Chester Zoo supports these spatial strategy principles. This ensures that future residential development still follows the hierarchical position, as per the adopted Local Plan, with the principal focus on Chester as a top tier settlement. Grey Belt opportunities can be accommodated, together with small scale urban extensions on open countryside or Green Belt release, together with appropriate levels in the key service centres.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 9

Representation ID: 15238

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15797
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably Chester, in the first tier of the settlement hierarchy, which is completely enveloped by Green Belt designation. Therefore, Chester Zoo are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Chester Zoo would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt.  Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Chester Zoo would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. It is paramount to allow small scale extension of the Chester settlement boundary, including site-specific Green Belt release. This is opposed to any largescale release of Green Belt, which will only go to compromising the value of the wider Green Belt and weaken its protection. The previous Green Belt Study and its conclusions is a good starting point.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 10

Representation ID: 15239

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15798
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably Chester, in the first tier of the settlement hierarchy, which is completely enveloped by Green Belt designation. Therefore, Chester Zoo are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Chester Zoo would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt.  Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Chester Zoo would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. It is paramount to allow small scale extension of the Chester settlement boundary, including site-specific Green Belt release. This is opposed to any largescale release of Green Belt, which will only go to compromising the value of the wider Green Belt and weaken its protection. The previous Green Belt Study and its conclusions is a good starting point.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 11

Representation ID: 15240

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15799
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably Chester, in the first tier of the settlement hierarchy, which is completely enveloped by Green Belt designation. Therefore, Chester Zoo are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Chester Zoo would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt.  Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Chester Zoo would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. It is paramount to allow small scale extension of the Chester settlement boundary, including site-specific Green Belt release. This is opposed to any largescale release of Green Belt, which will only go to compromising the value of the wider Green Belt and weaken its protection. The previous Green Belt Study and its conclusions is a good starting point.

Comment

Local Plan Issues and Options (Regulation 18)

Question SS 12

Representation ID: 15242

Received: 29/08/2025

Respondent: Chester Zoo

Agent: Cassidy & Ashton Group Ltd

Representation Summary:

I&O_15801
A change in the national government objectives with significantly increased housing targets have changed the circumstances of development in CWAC since the adoption of the Local Plan (Part One). Brownfield land within settlement boundaries is a finite resource and availability is only reducing. Hence, extensions to existing settlements must be a supported option. This can include both open countryside land and Green Belt release, so long as the scale of such extensions is appropriate to the strategic growth of established settlements. Should Green Belt release be justified, which it is in particular locations, as it is the only option geographically for the expansion of some settlements, this is best served by small-scale releases across a series of appropriate locations. Most notably Chester, in the first tier of the settlement hierarchy, which is completely enveloped by Green Belt designation. Therefore, Chester Zoo are in favour of the retention of Green Belt land per se, whilst recognising that some small-scale release of Green Belt is likely to be required in strategic locations to support the new housing target. Large urban extensions are not necessary and are not supported. In order to meet the new housing targets and contribute to boosting the supply of homes, Chester Zoo would consider that areas of the Green Belt which met the Grey Belt definition should be the priority for release from Green Belt designation. What is required is an updated Green Belt Study, comparable to that undertaken for the last Local Plan review. This would allow for development of the small parcels of land which are surrounded by, or well related to, existing development and are not contributing to the purposes of the Green Belt.  Additionally, Green Belt policies should reflect the change in national policy with the recognition of grey belt land and its development as an exception to inappropriate development in the Green Belt. If the council were minded not to release any Green Belt where there is existing development on all sides, this land could be developed under a grey belt policy. Chester Zoo would consider that development on this basis, identifying areas which not contributing to the Green Belt and either releasing them or developing them under a grey belt approach would allow the council to reach their housing targets without large scale Green Belt release which would have an adverse impact on the key settlements and the surrounding area. In summary, none of the three presented Options can be supported, as presented. The suggested spatial strategy approach is a revised Option B, to include consideration of small-scale release of Green Belt (akin to Grey Belt definition) in appropriate locations. It is paramount to allow small scale extension of the Chester settlement boundary, including site-specific Green Belt release. This is opposed to any largescale release of Green Belt, which will only go to compromising the value of the wider Green Belt and weaken its protection. The previous Green Belt Study and its conclusions is a good starting point.

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