Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9170

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9663
The proposed approach requires major residential development to include provision of open space, sport and recreation in accordance with current policy DM35, and for contributions to be required for playing pitches based on additional demand. The policy will also follow a space hierarchy of: on-site, off-site, financial contribution. We agree with the policy approach to protect, manage and enhance open spaces, sport and recreational facilities, and agree with the spatial hierarchy. However, protection must be balanced with meeting housing needs. Releasing carefully chosen Green Belt land along the urban edge of Chester, such as at the Mannings Lane site, provides an opportunity to secure new and enhanced open space and recreation provision as part of a comprehensive development and provide more direct access to sport and recreation facilities to the benefit of the wider area. However, the required provisions (in line with DM35) must be reviewed and updated in accordance with a new Open Space Assessment. The most recent assessment was undertaken in 2016, covering the period to 2030. As such, the assessment does not reflect the current position, and the emerging plan will extend well over the current period. As such, the evidence base should be updated, and policy requirements reflected.

Comment

Representation ID: 9171

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9664
As previously noted, the Open Space Study requires updating to inform the required provision of open space for new development. This approach is set out under NPPF Paragraph 103 whereby it is clearly set out that Planning policies should be based on robust and up to date (NJL Emphasis) assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from these assessments should then be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate. The Playing Pitch Strategy was updated in February 2025 and as such is considered appropriate to inform the emerging Local Plan.

Comment

Representation ID: 9173

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9666
The proposed approach is supported, in so far as it would protect and enhance green infrastructure, biodiversity and geodiversity. However, the LNRS proposed Hedgerow section should include ‘where possible’ with regards to external hedgerow. Hedgerow boundaries may not be appropriate for a number of reasons, and so the policy must be designed to allow for flexibility where necessary.

Comment

Representation ID: 9174

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9667
The ambition to increase tree cover within the district is supported, and where sites form part of woodland, it is reasonable to require developments to contribute to the maintenance/enhancement elsewhere if this is to be lost. The 2:1 tree replacement policy is supported as a reasonable and realistic measure.

Comment

Representation ID: 9175

Received: 26/08/2025

Respondent: Miller Developments

Agent: NJL Consulting

I&O_9668
The Environment Bill set out to require a 10% net gain as a significant benefit to the protection and enhancement of development sites and where not possible on site, land banks across the country. Achieving a 10% net gain requires significant investment as well as land to deliver required habitat units. An uplift from this baseline figure will result in further development requiring expensive off-site units, which could impact on viability and other essential developer contributions (such as affordable housing) will be lost. As such, the 10% net gain should not be exceeded.