Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10230

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10727
Overall, the DIO are supportive of draft Policy SD 1 (Sustainable Development) as it is reflective of national planning policy in regard to mitigating and adapting for climate change. It is however noted that it is important to ensure flexibility within the policy as not all forms of renewable energy or other climate changes measures are suitable on all sites. It is also important to ensure that the policy is not over onerous to ensure that development is still viable.

Comment

Representation ID: 10231

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10728
Policy SD 1 requires that all strategic sites should be connected to a district heat network. This policy should allow for flexibility, should this not be a feasible option for developers. The policy should be reworded as follows: “Strategic sites should be connected to a district heat network, where feasible and viable.”

Comment

Representation ID: 10232

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10729
Central to the NPPF is the need to create strategic policies which set out the overall strategy for the pattern, scale and design quality of places and to make sufficient provision for homes (including affordable housing). The DIO fully supports the approach to deliver a minimum of 1,914 new, high-quality homes across the borough, which would be in line with national planning policy and the new standard housing requirement for the borough. There is clear justification to support the approach for the emerging Local Plan to meet its identified housing need, as failure to do so can result in harm, such as slower economic growth, a lack of labour force mobility, critical affordability issues, disruption to commuting patterns and the delivery of housing choice.

Comment

Representation ID: 10233

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10730
It is our position that the Council should wait until they have undertaken a full housing land supply review and established the level of land available and potential delivery rates prior to considering if a stepped housing requirement can be justified. Notwithstanding this we would raise some concerns about the utilisation of a stepped housing approach, as there is a clear unmet housing needs in the Borough and an acute affordability issue, that needs to be addressed as early as possible in the plan period. As such we would propose that a stepped approach is not taken forward for the new Local Plan, to avoid any worsening of the current position.

Comment

Representation ID: 10234

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10731
The DIO fully supports the proposed Spatial Strategy approach which seeks to direct new development to previously developed land (‘PDL’) first, which is clearly in line with national planning policy. However it is noted that whilst the draft approach reference existing settlements first, this should be expanded to include all PDL within, adjacent or in close proximity to existing settlement boundaries. With regards to urban extensions, the DIO supports the approach of development on sites on the edge of existing settlements in locations with good levels of access to transport, services and infrastructure, as these are considered the next best sustainable option for growth. In terms of larger scale strategic sites such as Dale Barracks, the site is considered to be a sustainable growth option, due to its location on the boundary of Chester settlement with good access to public transport, existing services and infrastructure; re-use of previously developed land; and the site is large enough to accommodate a cohesive and well-coordinated development. This large strategic site is considered a preferred option to come forward, on par with various PDL within settlement boundaries which may be fragmented across the borough. With regards to releasing Green Belt land to provide opportunity for urban extensions to come forward, the DIO are wholly supportive of this and are seeking their land asset to be considered a residential-led allocation for housing and potentially other supporting uses.

Comment

Representation ID: 10235

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10732
Policy SS 4 (Settlement Hierarchy) states that Chester (city) is the highest-ranking settlement on the settlement hierarchy, based on its status and role in providing local infrastructure and services its local population. As such, it is the DIO’s position that large scale strategic development should be focussed on the largest settlement and surrounding areas adjacent to this settlement boundary. The policy states that an individual place-based policy for each settlement will set out the vision, core features, key issues and clear strategy for what development will take place in each settlement. The DIO would support a policy which focusses on supporting development with a preference of accommodating this in the largest settlements first. Within the new policy for Chester, there should be reference to the DIO’s land interest (Dale Barracks) and the ambition to eventually repurpose the site for a residential-led development which would see the provision of new homes, with the opportunity to provide care homes, public open space, local centre, landscaping and active transport routes.

Comment

Representation ID: 10236

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10733
It is our position that there is a clear and justified need to consider Green Belt release as part of the new Emerging Local Plan. The current Local Plan (Part One) sought to deliver the borough objectively assessment need, which was calculated as 1,100 homes per year at the time of adoption, however it is noted that the new housing targets released in December 2024, now set a minimum figure of 1,914 new homes a year, which is a significant increase. Whilst further evidence will be provided to underpinned the new Local Plan, it is clear from the council’s own initial assessment (Land Availability Assessment Stage One, 2025 Update) that there is a significant shortfall of housing land that is available within the existing urban area to meet the proposed housing target and as such exceptional circumstances do exist for the release of Green Belt land. The emerging Local Plan must consider the implications and the harm that will occur from failing to meet identified needs in the Borough, such as slower economic growth, a lack of labour force mobility, critical affordability issues, disruption to commuting patterns and the delivery of housing choice.

Comment

Representation ID: 10237

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10734
For the reasons previous set out under our response to Question SS9, it is our position that Option A is not an appropriate spatial strategy. It is clear from the council’s own initial assessment (Land Availability Assessment Stage One, 2025 Update) that there is a significant shortfall of housing land that is available within the existing urban area to meet the proposed housing target. As such it appears from the evidence presented to date that it would not be possible to meet the identified housing needs in the Borough under Option A, which would have significant impacts and harm including, slower economic growth, a lack of labour force mobility, critical affordability issues, disruption to commuting patterns and the delivery of housing choice.

Comment

Representation ID: 10238

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10735
For the reasons given in response to Question SS9 and SS14 it is our position that there aren’t any changes to Option A that could be made to ensure that it would be an effective or justified approach.

Comment

Representation ID: 10239

Received: 28/08/2025

Respondent: Defence Infrastructure Organisation

Agent: Avison Young

LAA ref 1403
I&O_10736
Based on the evidence available to date, it appears that Option B could be an appropriate strategy for the new Local Plan as it ensures that the plan meets the new standard housing requirement figures and focusses development in the most sustainable locations in and on the edge of main urban areas and smaller settlements which have adequate services and facilitates which clearly accords with national policy and has already been established as a sound spatial strategy under the current Local Plan.