Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15785

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16344
Hilbre Overlea Ltd supports suggested Policy Approach SS 1, which seeks to meet the housing needs of the Borough using the Government’s Standard Method. Unless there are strong reasons why an authority cannot do so, it must seek to, as a minimum, meet its local housing needs, and also meet the needs of neighbouring Authorities if appropriate. 2.10 Paragraph 11 in the NPPF states that: “For plan-making, this means that: b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. There is no reason for restricting development in CWaC, and doing so would not outweigh the benefits of meeting the Borough’s identified housing needs. As such, CWaC should plan for 1,914 new homes per annum, as an absolute minimum (and subject to considering neighbouring Authorities needs as part of its Duty to Co-operate).

Comment

Representation ID: 15786

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16345
No. A fundamental principle of the NPPF is that strategic policies should meet the full objectively assessed housing need over the entirety of the plan period. Hilbre Overlea Ltd considers that introducing a stepped housing requirement, where a lower housing target is set for early years of the plan, would be contrary to this principle and risks undermining housing delivery and consolidating issues associated with previous and ongoing under-delivery. A stepped trajectory would exacerbate any housing undersupply in the early parts of the plan period, rather than ensuring enough housing is delivered at every stage of the plan period. A stepped approach would not only delay the provision of much-needed housing but would also lead to affordability issues; hinder economic growth; and, constrain the local housing market at a time when need is already extremely high. For these reasons, Hilbre Overlea Ltd strongly objects to using a stepped housing requirement but rather, fully supports CWaC’s proposed approach of adopting a housing trajectory that will deliver the full annualised housing needs from the start of the plan period, ensuring an adequate and sustainable supply of housing and helping deliver the plan’s strategic objectives.

Comment

Representation ID: 15787

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16346
The suggested Policy Approach SS 3 outlines that the spatial strategy will follow the principle of directing new development towards previously developed sites within settlements first, as they are the most sustainable locations with the best access to services and facilities. Following this, the sequentially preferable location promoted is an approach that considers development on the edge of existing settlements, in locations with the best access to public transport and existing services and infrastructure, as the next best sustainable option. Development of the site would align with the proposed Policy Approach, being situated on the edge of the Christleton Local Service Centre. The site benefits from proximity to existing amenities and sustainable transport options, making it a logical and well-connected location for future development that supports the Council’s spatial strategy. Hilbre Overlea Ltd therefore supports the Council’s proposed policy approach to spatial strategy principles so long as they maintain the principle that edge of settlement development is sustainable and necessary. This includes settlements such as Christleton, washed over by the Green Belt, where allocating appropriate Grey Belt sites for development will accords fully with the Government’s national policy approach to Grey Belt.

Comment

Representation ID: 15788

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16347
The Policy Approach to SS4 ‘Settlement hierarchy’ sets out the settlement hierarchy, and outlines that an individual place-based policy for each settlement will set out the vision, core features, key issues and a clear strategy for what development will take place in each settlement. Additionally, it recognises that smaller settlements which have a lower level of services and access to public transport could acceptably accommodate development to meet local needs. Hilbre Overlea Ltd generally supports the settlement hierarchy. In smaller settlements, developments that are appropriate in scale and design, to conserve the settlement’s character and setting, are absolutely necessary to deliver the overall housing required. To ensure that high-quality developments in such locations are not unfairly disadvantaged, particularly as viability can be more sensitive in smaller settlements, Hilbre Overlea Ltd recommends that the Local Plan includes clear wording that: requires any planning contributions sought to be underpinned by robust, transparent evidence and methodology; and, sets out that such obligations must comply with the legal tests set out in Regulation 122 of the Community Infrastructure Levy (CIL) Regulations 2010 to ensure that contributions sought are necessary, directly related to the development and fairly and reasonably related in scale and kind to the development.

Comment

Representation ID: 15789

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16348
The Policy Approach to SS4 ‘Settlement hierarchy’ sets out the settlement hierarchy, and outlines that an individual place-based policy for each settlement will set out the vision, core features, key issues and a clear strategy for what development will take place in each settlement. Additionally, it recognises that smaller settlements which have a lower level of services and access to public transport could acceptably accommodate development to meet local needs. Hilbre Overlea Ltd generally supports the settlement hierarchy. In smaller settlements, developments that are appropriate in scale and design, to conserve the settlement’s character and setting, are absolutely necessary to deliver the overall housing required. To ensure that high-quality developments in such locations are not unfairly disadvantaged, particularly as viability can be more sensitive in smaller settlements, Hilbre Overlea Ltd recommends that the Local Plan includes clear wording that: requires any planning contributions sought to be underpinned by robust, transparent evidence and methodology; and, sets out that such obligations must comply with the legal tests set out in Regulation 122 of the Community Infrastructure Levy (CIL) Regulations 2010 to ensure that contributions sought are necessary, directly related to the development and fairly and reasonably related in scale and kind to the development.

Comment

Representation ID: 15790

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16349
The Policy Approach to SS4 ‘Settlement hierarchy’ sets out the settlement hierarchy, and outlines that an individual place-based policy for each settlement will set out the vision, core features, key issues and a clear strategy for what development will take place in each settlement. Additionally, it recognises that smaller settlements which have a lower level of services and access to public transport could acceptably accommodate development to meet local needs. Hilbre Overlea Ltd generally supports the settlement hierarchy. In smaller settlements, developments that are appropriate in scale and design, to conserve the settlement’s character and setting, are absolutely necessary to deliver the overall housing required. To ensure that high-quality developments in such locations are not unfairly disadvantaged, particularly as viability can be more sensitive in smaller settlements, Hilbre Overlea Ltd recommends that the Local Plan includes clear wording that: requires any planning contributions sought to be underpinned by robust, transparent evidence and methodology; and, sets out that such obligations must comply with the legal tests set out in Regulation 122 of the Community Infrastructure Levy (CIL) Regulations 2010 to ensure that contributions sought are necessary, directly related to the development and fairly and reasonably related in scale and kind to the development.

Comment

Representation ID: 15791

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16350
The new NPPF states that exceptional circumstances for Green Belt release include situations where an authority cannot meet its identified housing or development needs through other means. The Council has acknowledged in the Issues and Options consultation that such circumstances now exist. Importantly, following the revisions to the Framework, there have been substantial changes to national planning policy that justify a review of Green Belt boundaries. Most notably, the revised NPPF introduces the concept of the Grey Belt, defined as land within the Green Belt that is either previously developed or does not strongly contribute to key Green Belt purposes (specifically purposes (a), (b), or (d) as set out in paragraph 143 of the NPPF). This means that local authorities should identify parcels that may be suitable for development without undermining the overall integrity of the Green Belt. In this context, the emerging local plan must reflect the current national policy landscape and in the context of Christleton, which is currently washed over entirely by the Green Belt designation, it is important to identify appropriate and sustainable Grey Belt sites, such as this one that can make a valuable contribution to Christleton’s and CWaC’s housing needs.

Comment

Representation ID: 15792

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16351
The new NPPF states that exceptional circumstances for Green Belt release include situations where an authority cannot meet its identified housing or development needs through other means. The Council has acknowledged in the Issues and Options consultation that such circumstances now exist. Importantly, following the revisions to the Framework, there have been substantial changes to national planning policy that justify a review of Green Belt boundaries. Most notably, the revised NPPF introduces the concept of the Grey Belt, defined as land within the Green Belt that is either previously developed or does not strongly contribute to key Green Belt purposes (specifically purposes (a), (b), or (d) as set out in paragraph 143 of the NPPF). This means that local authorities should identify parcels that may be suitable for development without undermining the overall integrity of the Green Belt. In this context, the emerging local plan must reflect the current national policy landscape and in the context of Christleton, which is currently washed over entirely by the Green Belt designation, it is important to identify appropriate and sustainable Grey Belt sites, such as this one that can make a valuable contribution to Christleton’s and CWaC’s housing needs.

Comment

Representation ID: 15793

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16352
The new standard method has substantially increased CWaC’s LHN figure, increasing it from 532 dpa to 1,914 dpa (a 259.77% rise). This is also a substantial increase on the current Local Plan requirement of 1,100 dpa. To ensure that the new Local Plan is robust, CWaC must base its housing needs on the new Standard Method. Consequently, the Local Plan will need to allocate land beyond existing settlement boundaries to accommodate this increased level of housing demand. The site is on the edge of Christleton, comprises Grey Belt land (as demonstrated in Section 3 and in the Development Framework at Appendix 2). Accordingly, while Option A seeks to retain the Green Belt, it remains important to recognise that certain sites, such as this one, represent appropriate and sustainable opportunities to meet the borough’s significantly increased housing needs, in a way that fully accords with the national policy approach to Grey Belt, and should therefore be allocated for development.

Comment

Representation ID: 15794

Received: 29/08/2025

Respondent: Hilbre Overlea Ltd

Agent: Asteer Planning

I&O_16353
Option B seeks to follow the existing Local Plan level and distribution of development with reference to the settlement hierarchy, by locating most new development on the edge of main urban areas or around smaller settlements which have adequate services, facilities and access to public transport. It recognises that “a key difference between the Local Plan (Part One) and the new Local Plan is that there is a much more limited supply of previously developed land to accommodate new development, and unlike the last plan, larger areas of Green Belt and/or countryside are likely to be needed”. Option B also identifies that 2,500 homes should be delivered across the rest of the rural area, both within Green Belt and non-Green Belt land. Hilbre Overlea Ltd welcomes this recognition and considers that any growth strategy that follows Option B should reflect this situation and attribute an appropriate level of growth to edge of existing settlements for growth in the adopted Local Plan, including allocating Grey Belt sites such as this on the edges of settlements such as Christleton, where no Green Belt ‘release’ takes place.