Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 1

Received: 04/07/2025

Respondent: Heine Planning

gt1
I&O_1
Policy should be informed by need and as there is no uptodate need assessment it is a bit meaningless to comment until we know how much provision is required. Given the high cost of purchasing land, securing permission, paying for appeals and delivering sites, coupled with the requirements of BNG which is unaffordable for many small schemes, I think Councils will need to increase social provision as it is becoming too expensive for GTs to self provide.  I doubt there is scope for much intensification/ infill on existing sites. If this is relied on we need to see worked up plans to show it is workable and will address the need identified. Most sites are privately owned. The owners can not be expected to meet the needs of other families. Those doing GTAAs do not appreciate this. It is all too easy for them to claim need can be met this way. But it provide little choice of site by tenure, location, security for those needing pitches and the Council can not compel owners to apply for additional pitches or deliver them as and when they are needed. It is essential allocations are identified to provide certainty  for GTs Urban housing allocations are a long term solution they will not deliver in the short term. It is still untried and untested. 

Comment

Representation ID: 2

Received: 04/07/2025

Respondent: Heine Planning

I&O_2
yes with 42% of the district designated Green Belt and demand mostly in the northern part of the district where it is GB, this will be essential to meet need Exceptions to the GB have already been made for housing developments It is expected more exceptions will be required in future as there is little brownfield land for new dev left in settlements This an outofdate historic legacy which fails to accept/ recognise that folks no longer live and work in one settlement. The population is highly mobile. Services have been centralised. Schools/ hospitals/ work places are no longer where people live. The Cheshire GB is simply an inconvenient gap between settlements that most people will drive through regardless to access services/ facilities that are no longer provided where they live.  The way we live is now so different and planning has failed to recognise this. To those who live in the GB it is an excuse to prevent new development and avoid change.  It is far more important that we safeguard green spaces within settlements to safeguard the quality of life for those living there. Much of the Green Belt is unexceptional countryside of v little significance. So yes- review the Green belt and identify areas that could be developed to meet needs that are hard to deliver within settlements.    

Comment

Representation ID: 3

Received: 04/07/2025

Respondent: Heine Planning

GT3
I&O_4
Yes for 4 reasons 1-footnote 57 Framework and need to address this issue against para 13 PPTS 2-GTs are now competing with other developers for land around settlements as there is insufficient land within settlements for other development. Given the low density of caravan sites, GTs can not compete with the high cost offered by other developers for land on the edge of settlements 3-There are already exceptions made for other residential / caravan site developments away from settlements eg barn conversions,essential needs.  4-no where in CWAC is that remote or unduly distant from services/ facilities and GTs do not do home working.They have to travel for work on a day to day basis with their tools and equipment so are car dependent. Even if they had a site in a town centre on a bus route they are still going to need their vehicle to transport equipment.

Comment

Representation ID: 4

Received: 04/07/2025

Respondent: Heine Planning

gt4
I&O_5
Yes and there are a few examples of this but not many. I have been monitoring this for a few years and can send more details eg Epping Forest are doing this around Harlow.  But it is problematic and most developers will find excuses for not doing so and Councils often accept payment in lieu. Needs to be a policy requirement.  Needs to be carefully considered re amount, location, timing, delivery and how it will be managed/ allocated. Happy to share my info on this with you if that would assist.  

Comment

Representation ID: 5

Received: 04/07/2025

Respondent: Heine Planning

gt5
I&O_6
If you do this I guarantee you will get applications for no more than 499 dwellings. You need to agree -how many pitches are needed for years 5 onwards -how many housing allocations are planned that do not already have outline permission (as can not apply retrospectively) and might realistically delivery GT sites, and ensure they are not phased to avoid the threshold for provision (same issues as for affordable housing) -decide what is feasible/ likely. For instance, how many allocations this large are you realistically expecting? How many sites could be delivered with a threshold this high?  -I think you might want to reduce the threshold to 2p for every 200 and / or consider seeking this along the lines of need for affordable housing because it is a similar consideration/ issue.

Comment

Representation ID: 6

Received: 04/07/2025

Respondent: Heine Planning

gt6
I&O_7
No We just need a policy that works, is understood, informs allocations, has workable criteria not designed to thwart every application, is accepted by Councillors and delivers sites without the need for costly appeals.  

Comment

Representation ID: 11168

Received: 22/08/2025

Respondent: Heine Planning

I&O_11666
1.18-Concern that the Reg18 consultation has proceeded ahead of all the Evidence required and the Evidence Base is incomplete. In particular the Council has launched this consultation in advance of an updated Gypsy Traveller Accommodation Assessment to replace the 2018 Study which relied on data gathered in 2017. Having contacted current clients and other agents, I know of no household in CWAC that has been approached by RRR to date and I have contacted RRR to offer to put them in touch with clients. In addition there has been no Green Belt Area Assessment following guidance in the PPG published February 2025. It is far from clear how the Council can be recommending that land in the Green Belt be released for new development when this is not informed by a district wide Green Belt study .

Comment

Representation ID: 11170

Received: 22/08/2025

Respondent: Heine Planning

I&O_11668
As the only GB area assessment is for Chester I fail to understand how any proposals can be advanced to amend the Green Belt and identify possible Grey Belt land without a comprehensive assessment of the whole Green Belt and its purpose. Without such an assessment and review of the role of the Green Belt the Reg18 consultation is premature and will achieve little. This is a sub regional issue. It is intrinsically linked to development issues in neighbouring districts. Given that STRAT9 deals with the Countryside and Green Belt is there really a need for the Green Belt designation? Somewhat ironically, with the introduction of the Grey Belt it is probably now easier to secure permission for some developments, where need has not been met, within the Green Belt than in other parts of ordinary countryside. By definition (land around main settlements) much of the land in the Green Belt is more accessible to services/ facilities/ settlements and transport networks than countryside elsewhere. I question where the evidence is to back up the following statement?: 13.4 The countryside of Cheshire West and Chester and the high quality of its landscape and environment is recognised as a key asset and is highly valued by the borough’s residents.  The quality of the environment attracts a highly skilled workforce, businesses and visitors therefore it is important to continue to protect this asset. Having lived in Northwich for over 20 years,  I do not know of any one who has chosen to live/ remain living in Cheshire West and Chester for these reasons. The fact house prices were (may still be) much lower than Gt Manchester, with a greater choice of housing than in Gt Manchester has to the best of our knowledge been the key reason many have chosen to live here combined with access to the strategic road network. The landscape/ environment is typical of  countryside areas across much of  England and  could hardly be described as high quality. None of it is currently designated as a National Landscape. It is disappointing that the emerging Local Plan fails to challenge the relevance of the North Cheshire Green Belt given present day land uses? Settlements have grown so much and are now so heavily connected by strategic highways and railways and complex commuting patterns, that the perceived necessity to retain separation is a nonsense.  This is not how we live our lives nowadays. Settlements are not self contained. People are willing and often have no choice but to travel for services/ work/ facilities in other settlements often through the Green Belt. The Green Belt  is simply the area we have to pass through (often on busy roads which in themselves are urbanising features) to reach the towns/ services/facilities it  separate. It is clear we can not prevent the expansion of existing built up areas into parts of the Green Belt. This is often the only land available to ensure new development has access to existing services and facilities within settlement boundaries. We need land for more development. We need to safeguard the amenity of those living with existing settlements and must not develop every green space within settlements just to protect the countryside surrounding settlements for the benefit of those who live within the Green Belt or on the edge of settlements.  The role of Green Belt in North Cheshire is  obsolete. What exactly are we saving it for?  Is it really so vital that neighbouring towns do not merge when functionally they are so interconnected and dependent on each other for services and facilities whether for commuting, leisure, shopping or hospital/ airport journeys.   The recreation role of the Green Belt is very limited. The Green Belt has not safeguarded the countryside from encroachment. Policies STRAT9 and DM19 confirm how many exceptions are made for new residential developments in the countryside. AMR reports confirm how many exceptions have been permitted and much of this (eg barn conversions to residential uses) have clearly had an urbanising impact on rural areas and have changed the character of farm buildings, encouraging and normalising new residential areas in locations that are anything but sustainable. Settlements in the Green Belt need more development to support what few facilities are left eg village schools, pubs and shops.  Other policies are better able to ensure urban regeneration. Given the scale of development in Chester it is hard to see how the Green Belt serves any purpose  in preserving the setting and special character of its historic core. Surely our planning needs and choice of land for new development would be better informed if it were based on other far more important, fundamental and relevant land use issues such as: -need to identify and protect our best and most versatile farm land -protection of ancient woodland -safeguard important habitats/ SAC/ SPA/ Ramsar sites -flooding issues -reduce commuting distances by ensuring new housing is located where it is needed -designated landscape areas -air pollution/ noise pollution concerns/ hazardous zones/ HSE pipeline concerns -contamination -mineral needs

Comment

Representation ID: 11171

Received: 22/08/2025

Respondent: Heine Planning

I&O_11669
Yes-it needs more thought but it is worrying that this is not clear at the reg18 stage. I worry that it will be too late to introduce changes at reg19 and will not give the public proper opportunity to comment. sorry to say-but it does feel like this reg18 consultation has been rushed through far too quickly in advance of more detailed and considered thought to the nppf changes made december 2024 and ppg dated feb 2025. if the council is unsure how to proceed how can the public be expected to comment?.

Comment

Representation ID: 11173

Received: 22/08/2025

Respondent: Heine Planning

I&O_11671
yes-it is very confusing to have this combined policy given the need to defer to nppf for green belt areas. can you not simply defer to NPPF for green Belt policy?