Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 2083

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2203
Contributions should be proportional to the proposed development. Major development should be defined as per the definition within the NPPF (2024): “For housing, development where 10 or more homes will be provided, or the site has an area of 0.5 hectares or more. For non-residential development it means additional floorspace of 1,000m2 or more, or a site of 1 hectare or more, or as otherwise provided in the Town and Country Planning (Development Management Procedure) (England) Order 2015”.

Comment

Representation ID: 2084

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2204
MCI acknowledges the need for a mix of house types, sizes and tenures and is generally supportive of providing a range and choice of homes to meet the needs of the local area. Any policy in relation to housing mix should include flexibility to ensure that it is workable and ensures that housing delivery will not be compromised or stalled due to overly prescriptive requirements. The policy should allow evidence to be submitted to justify alternative housing mixes as the market requires. As the Council will be aware the Nationally Described Space Standards (NDSS) introduced by Government, are intended to be optional and can only be introduced where there is a clear need, and they retain development viability. They were introduced on a ‘need to have’ rather than a ‘nice to have’ basis. The PPG  (ID: 56-020-20150327) identifies the type of evidence required to introduce such a policy. It states that “ where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies” . The Council will need robust justifiable evidence to introduce the NDSS, based on the criteria set out above. In accordance with the PPG (ID: 56-001-20190626), local planning authorities are expected to establish clear and robust policies to address the specific housing needs of older and disabled people, including the delivery of specialist accommodation where evidence of need exists. Furthermore, the PPG (63-006-20190626 and ID: 63-012-20190626) highlights that the allocation of sites for such provision can offer greater certainty to developers and facilitate delivery in sustainable and accessible locations. It is therefore incumbent upon the Council to engage proactively with providers of all types of older persons’ housing (including but not limited to retirement living, sheltered housing, extra care, and bungalows) to identify suitable sites including integration of older persons’ housing on larger sites to enable those who wish to remain in the area the opportunity to downsize at an appropriate time and to ensure that the Local Plan includes appropriate policy mechanisms to support delivery. The introduction of policies requiring M4(2) and M4(3) standards should be fully evidenced and justified applying the criteria set out in the PPG (ID: 56-007-20150327). The evidence produced should include a local assessment for Cheshire West and Chester and also consideration of the implications for proposed site allocations in relation to site specific factors such as flooding, site topography and other circumstances where M4(2) and M4(3) compliant dwellings may not be achievable or viable. There should also be an appropriate transition period included within the policy.

Comment

Representation ID: 2085

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2205
As highlighted above there should be flexibility within the policy to ensure that it is workable and ensures that housing delivery will not be compromised or stalled due to overly prescriptive requirements. The policy should allow evidence to be submitted to justify alternative housing mixes as the market requires. Any proposed percentages should be justified by robust evidence.

Comment

Representation ID: 2087

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2207
The Local Plan should be fully aligned with the National Planning Policy Framework (NPPF, 2024). Paragraph 36 of the NPPF (2024) highlights the importance of ensuring that local plans are justified, effective, and consistent with national policy. To support the delivery of affordable housing, the Local Plan should: Set out clear, evidence-based affordable housing policies, supported by up-to-date viability assessments. Ensure flexibility within policies to allow for site-specific viability considerations, while still securing meaningful affordable housing contributions. Encourage a mix of tenures and housing types to reflect local needs and promote inclusive communities. Support delivery through public-private partnerships, housing associations, and community-led housing initiatives. Allocate land specifically for 100% affordable housing, particularly in high-demand areas and where market delivery has historically been low. Promote the reuse of brownfield land and underutilised sites for affordable housing development. Incorporating these principles into the Local Plan would help support the delivery of affordable housing and contribute to meeting the needs of local communities more effectively.

Comment

Representation ID: 2089

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2209
Any thresholds should be fully justified via evidence and flexibility should be provided within the policy where viability may be an issue.  

Comment

Representation ID: 2091

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2211
There is a need for affordable housing in all locations of the Borough. Rural exception sites are one way of delivering affordable housing within rural areas however such sites should not be limited to local need as there may be opportunities for these sites to assist in also meeting some of the Borough need. The NPPF is clear that Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this. MCI considers that it is important any policy brought in by the Council reflects this and provides flexibility for changing needs for affordable housing.

Comment

Representation ID: 2093

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2213
The policy approach towards rural exception sites continue to apply to all identified smaller settlements so ensure that affordable housing is delivered in all areas where there is an identified need. Restructuring the policy to remote areas of the borough will result in issues in the future.

Comment

Representation ID: 2095

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2215
A proportion of market housing should be allowed to support delivery of affordable housing on rural sites.

Comment

Representation ID: 2097

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2217
MCI is generally in support of the suggested policy approach towards health and wellbeing. The PPG (ID:53-005-20190722) sets out that HIAs are “a useful tool to use where there are expected to be significant impacts” , but it also outlines the importance of the local plan in considering the wider health issues in an area and ensuring policies respond to these. As such Local Plans should already have considered the impact of development on the health and well-being of their communities and set out policies to address any concerns. Consequently, where a development is in line with policies in the Local Plan a HIA should not be necessary. Only where there is a departure from the plan should the Council consider requiring a HIA. In addition, the HBF considers that any requirement for a HIA should be based on a proportionate level of detail in relation to the scale and type of development proposed. Only if a significant adverse impact on health and wellbeing is identified should a HIA be required, and it should set out measures to substantially mitigate the impact.

Comment

Representation ID: 2098

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2218
The National Planning Policy Framework (NPPF, 2024), at paragraph 96 highlights that planning policies and decisions should aim to achieve health, inclusive and safe places. "Health" is one element of creating a place and therefore should not be considered in isolation but as part of the overall design of a scheme. The consideration of health and well-being should form part of a developments Design and Access Statement. The requirement for a Health Impact Assessment (HIA) should be determined by the scale and type of development and be in line with guidance with PPG. The need for an HIA should be limited to large developments for example 100 dwellings plus. This threshold has been used by Sunderland within their local plan policy HWS1.