Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 2101

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2221
MCI are generally, support the approach to open space and recreation.

Comment

Representation ID: 2102

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2222
The Playing Pitch Strategy was updated in February 2025 and is therefore up to date evudnce which can be utilised to inform the Local Plan.

Comment

Representation ID: 2104

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2224
MCI consider that the key settlement gaps should be reviewed to determine if there are any areas which should be removed from this designation as they have the potential to accommodate sustainable growth. 

Comment

Representation ID: 2107

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2227
MCI are generally in agreement with the suggested policy approach towards green infrastructure, biodiversity and geodiversity, as set out in GI 1 'Green infrastructure, biodiversity and geodiversity'. It is important that the Council identifies any links with the LNRS and how these can be linked to development. The LNRS should not be used to restrict the choice of provision made in relation to BNG or other green infrastructure provision. In relation to tree cover the 16% minimum canopy cover for all wards has the potential to be onerous dependent on the base level found on the site and the wider ward. The HBF considers that it is important that any policy considers the impact this may have on developable areas and BNG. MCI recognises the benefits of tree planting however consider that this should be considered on a site-by-site basis having regard to the need for BNG, open spaces, SuDs etc. rather than looking to create a fixed percentage.

Comment

Representation ID: 2108

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2228
A minimum 2: 1 tree replacement ratio is sufficient and is based on best practice across most LPAs. If the Council are minded to seek a contribution towards woodland in Cheshire West and Chester this should be tested via a viability assessment and fully justified.

Comment

Representation ID: 2110

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2230
The new Local Plan policy should align with the 10% mandatory biodiversity net gain set nationally. The PPG (ID:53-005-20190722) is clear that plan-makers should be aware of the statutory framework for biodiversity net gain, but they do not need to include policies which duplicate the detailed provisions of this statutory framework. It goes on to state that it will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework. The PPG (ID: 74-006-20240214) also states that: “… plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented”. The need to deliver BNG in accordance with the BNG hierarchy has also affected the gross to net ratios for sites, particularly where new on-site habitats are proposed. The Council should look to factor in delivery of BNG on site when looking at the indicative capacity of sites and if required allocate additional sites if this has implications for housing numbers.  

Comment

Representation ID: 2112

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2232
MCI are generally in agreement with regards to the approach to the historic environment.

Comment

Representation ID: 2113

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2233
MCI are generally in agreement with regards to the approach to achieving high quality design.

Comment

Representation ID: 2114

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2234
Paragraphs 132 of the National Planning Policy Framework (NPPF, 2024) confirms that Local Plans should “set out a clear design vision ” and be developed with local communities in mind. Paragraph 133 states that “To provide maximum clarity about design expectations at an early stage, all local planning authorities should prepare design guides or codes consistent with the principles set out in the National Design Guide and National Model Design Code” As such, it is particularly important that the design guidance for the Local Plan encourages consideration of site-specific characteristics, allowing flexibility of design standards where necessary whilst not being overly prescriptive.   An ‘umbrella’ approach to design should be adopted which would allow sufficient design flexibility and innovation to adapt to market trends and local community requirements. Given the size of the Borough a cautious approach is suggested as it may be difficult to have Design Codes.

Comment

Representation ID: 2115

Received: 15/08/2025

Respondent: MCI Developments Ltd

I&O_2235
Whilst MCI absolutely agrees that there is a need to tackle climate change and action should be taken locally by the Council, their view is that this action should be restricted to issues associated with the location of development, ensuring that growth is located close to services and facilities or where there are high levels of access to public transport and active travel options which allow residents to pursue a lower carbon lifestyle. We also agree that other measures to address climate change such as the inclusion of SuDS, tree planting and appropriate public open space and habitat creation should be planned for. Whilst MCI recognises the urgency to move at pace to address climate change this needs to be led centrally and rolled out nationally. The Council should seek to ensure that they produce a sustainable Plan which supports a balance of homes and employment and is in line with the guidance provided by the NPPF (2024) and the PPG. The Council should ensure that any climate change policy is only implemented in line with the December 2023 Written Ministerial Statement which states that “a further change to energy efficiency building regulations is planned for 2025 meaning that homes built to that standard will be net zero ready and should need no significant work to ensure that they have zero carbon emissions as the grid continue to decarbonise. Compared to varied local standards, these nationally applied standards provide much-needed clarity and consistency for businesses, large and small, to invest and prepare to build net-zero ready homes” . It goes on to state that “ the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current, or planned building regulations, should be rejected”. A policy requirement for the optional water efficiency standard must be justified by credible and robust evidence and consistent with national policy. If the Council wishes to adopt the optional standard for water efficiency of 110 litres per person per day, then the Council should justify doing so by applying the criteria set out in the PPG (ID: 56-014-20150327) which states that where there is a “clear local need, Local Planning Authorities (LPA) can set out Local Plan Policies requiring new dwellings to meet tighter Building Regulations optional requirement of 110 litres per person per day” . The PPG (ID: 56-015-20150327) also states the “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”’ .