Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15033

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15592
Draft Policy HW1 states that proposals will be supported that provide new or improved health facilities across the borough, supports improved links to healthcare in rural areas and promotes safe and accessible environments and developments. We raise no objection to this part of the policy, but we highlight that Grosvenor’s site to the East of Wrexham Road is capable of accommodating a new medical facility which should be viewed favorably by the Council in the context of Policy HW1. This is explained further in the following section of these Representations, and the Primary Health Care Provision Needs Case (included at Appendix 5) demonstrates that there is a clear need for a new medical facility following the development of the adjacent allocation to the west of Wrexham Road which has put significant pressures on existing facilities, which are also outdated. Grosvenor’s site can address this need.

Comment

Representation ID: 15034

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15593
Policy GI1 seeks to improve and maintain tree canopy cover within the borough on a strategic level and rank wards by existing tree cover, where development in these wards will need to provide additional green space as would normally be required. Policy GI1 sets a target of 16% tree cover for all wards. However, there is no information or evidence which confirms what the existing tree cover for each ward is and how the figure of 16% has been arrived at by the Council. There is a risk that this could be onerous to developers and create viability issues, as well as affecting the developable area of sites which would be at odds with the Council’s requirements to meet its minimum housing needs. Therefore, Grosvenor is concerned with the policy approach of GI1 as currently drafted, as developers will be expected to provide different levels of green infrastructure / tree cover depending on the existing tree cover within each ward, irrespective of other benefits associated with the proposed developments. Tree planting should, instead, be considered on a site-by-site basis and take into account tree loss, the condition and maturity of trees, biodiversity net gain, provision of open space, SuDS and a range of other matters which can make up a sustainable development. It is unclear what the proposed tree canopy requirements have been based on, and we raise concerns that the quantum of tree canopy cover across each ward will have implications in relation to other policy requirements of the draft Local Plan, such as housing density and meeting housing requirements. The Council should be seeking to maximise the developable area of sites in order to achieve its minimum housing requirement. Onerous policy requirements in terms of tree canopy cover could affect how many homes can be delivered on each site, particularly in wards with lower tree cover. We consider the policy approach in Policy DM45, which sets out the requirements for replacement tree planting is more appropriate, and still ensures a net gain in tree cover across the borough.

Comment

Representation ID: 15035

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15594
Whilst Grosvenor does not raise any specific comments on the design related policies within the draft Plan, we note that any policy requirement should align with national policy and the not exceed the requirements contained within the latest Building Regulations.

Comment

Representation ID: 15036

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15595
The draft Plan confirms that a borough-wide Design Code is being prepared to inform the design policies of the Local Plan. Grosvenor would welcome being involved in the engagement on the draft Design Code once it is published for consultation. Grosvenor advances a sustainably focused agenda for the long term strategy and stewardship of its holding. This means working with communities to provide a wide number of benefits to residents and the economy in the rural area. The estate has managed the rural environment with the same quality and well considered restraint that it has cared for its built assets. That approach will continue into the future as the estate progresses its Eaton Design Guide, which secures the longevity and sustainability of rural estates within the borough which are not otherwise supported through policy R1 of the Part Two Local Plan.

Comment

Representation ID: 15037

Received: 29/08/2025

Respondent: Eaton Estate

Agent: Stantec

I&O_15596
As per our comments set out in Section 2 of these representations, Grosvenor welcomes the aspiration to plan towards greater energy efficiency and carbon reduction. However, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned building regulations. If the Council is to set an increase of a building’s TER above the building regulations, then it must have a well-reasoned and robustly costed rationale that ensures development remains viable, and the impact on housing supply and affordability is considered in accordance with the NPPF. Otherwise, the increase will be rejected by the Inspector at examination (as confirmed in the 2023 WMS). We also note concerns regarding the requirement within Policy DS2 for on-site renewable energy generation as part of new development. Whilst there may be potential for energy to come from renewable or low carbon sources as part of future proposals, it may be more sustainable and efficient to use larger scale sources. The policy also does not consider the energy efficiency of the development, which may mean small scale renewables or low carbon energy generation are not necessary. The proposed policy will also need to be considered flexibly for situations where the use of renewables such as PV is not appropriate for the building or development. As such, we consider that on-site renewable energy generation should not be a requirement for all new development and should instead be encouraged and included wherever possible / appropriate. Policy DS2 states new dwellings will be required to meet the optional higher National Housing Standard for water consumption of 110 litres per person per day. We suggest this is omitted from the policy and it is considered unnecessarily onerous and does not align with the Building Regulations which requires all new dwellings to achieve a mandatory level of water efficiency of 125 litres per day per person, which is a higher standard than that achieved by much of the existing housing stock. As such, it is not considered that the maximum water consumption limit set out in Policy DS2 is justified by any evidence. As set out in PPG, it will be for a LPA to establish a clear need based on existing sources of evidence, consultations with the local water and sewerage company, the Environment Agency and catchment partnerships and consideration of the impact on viability and housing supply of such a requirement. We consider that requirement for optional water efficiency standard is not justified nor consistent with national policy.