Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9147

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9640
Given the housing requirement and ambitions of growth for Chester, it is likely that more than one urban extension site is needed to come forward, particularly in considering the constraints identified for parcels CH01, CH03 and CH04. CH02 provides the most appropriate option to encourage sustainable growth and increase active travel routes into and around Chester.

Comment

Representation ID: 9148

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9641
Specific considerations to the proposed growth areas have been set out in previous responses, in regards of constraints and individual expansion options. The strength of proposed Green Belt boundaries should be carefully considered, to ensure any growth does not encourage urban sprawl, and should increase the defensible boundaries of the settlement. Provision of and access to the transport network, particularly with regards to sustainable transport options (cycleway, rail, bus), should also be prioritised in determining the areas of growth.

Comment

Representation ID: 9152

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9645
The approach to the Green Belt and Countryside proposed is supported, insofar as the inclusion of policy and/or guidance around the approach to Grey Belt land. The Grey Belt is an important part of the Labour Government’s strategy to deliver 1.5 million homes in 5 years. The Grey Belt should be carefully considered and should enable the delivery of land not just previously developed, but also greenfield sites that no longer serve the purposes of the Green Belt, as detailed within the NPPF. However, STRAT 9 is unnecessarily restrictive, and should be amended to reflect the approach within DM 19 and the NPPF, in order to enable appropriate development to meet identified housing need, and regenerate previously developed land. The NPPF sets out clear requirements for land within the Green Belt and should be adhered to within any forthcoming policy.

Comment

Representation ID: 9153

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9646
We agree with the evidence base proposed, however there is a clear need for the evidence base to include an up-to-date Open Space Assessment, to support Policy OS 1. Furthermore, we would expect that the Green Belt Study to be prepared include a parcel-by-parcel assessment of land around Chester, establishing the sites contribution to the Green Belt in accordance with the purposes as defined within paragraph 143 of the NPPF. Each assessment should also consider constraints and opportunities of each parcel, such as capacity, sustainable transport and ecological designations.

Comment

Representation ID: 9154

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9647
The proposed plan period of 15 years is supported, assuming this is 15 years from adoption; however, in order to appropriately plan for housing delivery within this period and longer term aims, further consideration is required. We have previously commented that the proposed options for growth, in particular option A, proposes growth through major extensions, which would not be suitable for delivery with the plan period due to significant infrastructure required, particularly in the case of Winsford.

Comment

Representation ID: 9155

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9648
The proposed principles align with National policy, and we would agree with their inclusion within the Local Plan. However, in addition to the proposed principles, we believe it is necessary to include the delivery of housing as a priority. The provision of dwellings is fundamental to the Local Plan; the NPPF describes the purpose of plans to be “a framework for meeting housing needs and addressing other economic, social and environmental priorities”. It is evident therefore that the Local Plan’s primary purpose is to ensure the delivery of housing in accordance with housing need. As such, we would propose that a principle is required to ensure the delivery of housing, in appropriate locations, in order to meet local housing need, complement and support economic growth and enable local residents a choice in housing.

Comment

Representation ID: 9156

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9649
We agree with the approach to establishing independent visions for each of the key places. With regards to Chester, it is necessary to establish a vision in accordance with the One City Plan, as well as the specific housing and economic requirements as/to be established within the evidence base. Aligning housing growth with economic ambition and Chester’s role as a key service provider within Cheshire West and Chester is critical to sustainable development. We would expect that this vision includes details in relation to urban expansion, as determined through the proposed growth areas within the Spatial Strategy.

Comment

Representation ID: 9157

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9650
Option B is most appropriate, as the Sustainability Appraisal (SA). has considered the impacts of the existing Local Plan objectives against the proposed sustainability objectives. Whilst some overlap is expected, it is clear that a number of objectives within Option A do not positively align with the SA. Therefore, Option B is favoured. The SA objectives more accurately reflect the current environmental and political climate with regards to climate change, sustainable transport and provision of housing.
Option B - use the Sustainability Appraisal objectives

Comment

Representation ID: 9158

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9651
Yes, the Sustainability Appraisal objectives should form the basis of objectives for the emerging Local Plan, in particular, we would support the inclusion of objective 15 (provision of housing) and 22 (Sustainable transport).

Comment

Representation ID: 9159

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9652
Yes, we strongly agree with the approach, in particular the retention of the transport and infrastructure priorities as improvements to the A56 Hoole Road Corridor, and the allocation of land for a new park and ride site.