Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10183

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10680
Developer contributions should only apply to major developments. It is suggested that the definition of ‘major development’ should be consistent with the definition given in the NPPF, as this will aid clarity and consistency between local and national policy. The NPPF explicitly states that for housing, major development relates to development where to or more homes will be provided, or the Site has an area of 0.5 hectares or more.

Comment

Representation ID: 10184

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10681
In the case of housing development, financial contributions can be secured by S106 agreements in order to enable to provision of new site specific infrastructure, or upgrade existing site specific infrastructure, required to make development acceptable in planning terms. These contributions are supplemented by CIL contributions towards non-site specific infrastructure. In this sense, developers already pay the full cost of the infrastructure required to deliver new homes.

Comment

Representation ID: 10185

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10682
It is considered that site specific infrastructure that is essential for delivery should be prioritised. This may require a reduction in affordable housing contributions, or flexibility in affordable tenure mix, to enable this to happen.

Comment

Representation ID: 10186

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10683
The Issues and Options draft document states that the new policy approach will provide detailed requirements for various types and proportions of housing. It is important that the New Local Plan is not overly restrictive as it must allow flexibility to enable sites to come forward that can deliver a range of house sizes in different proportions that reflect both need and market demand. Until the Housing Needs Assessment is updated, comments cannot be made in relation to the housing mix policy details. In terms of specialist and accessible housing (M4(2) / M4(3) the proportion of homes that meet these standards should reflect the evidence. This is not likely to require that all homes meet these standards as a blanket requirement.

Comment

Representation ID: 10187

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10684
As mentioned above, it is important that the policy approach to housing mix taken in the new Local Plan provides for a mix of different types and sized of housing to come forward to meet the diverse housing needs of the District. It is appropriate that the housing mix policy should be informed by an up to date Housing Needs Assessment. Until that Assessment is complete, comments on the details of the policy cannot be made. A percentage policy approach would appear to be a logical approach. However, such percentages would need to be reflective of a robust evidence base. It should be noted however that policies in the New Local Plan must take a flexible approach that takes into consideration site-specific factors. There should be flexibility built into the policy to not restrict housing development from coming forward where sites can make an important contribution to the overall housing delivery in the Borough.

Comment

Representation ID: 10188

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10685
The draft Issues and Options document sets out the policy approach to be taken in the New Local Plan in relation to affordable housing at section HO2. The approach will reflect the government’s requirement for housing development in the Green Belt to provide at least 50% affordable housing, whether land has been released from the Green Belt through a housing allocation, or an application. Affordable housing will be required on all sites of 10 or more dwellings part from in designated rural areas, where the threshold will be three or more dwellings. The general policy approach towards securing affordable housing is supported in principle. As above, it is important that the detailed policy includes sufficient flexibility and takes into consideration site specific factors, such as ground contamination, that could impact viability. The Council should take a pragmatic approach that enables a sufficient supply of affordable housing to come forward as part of housing developments, while taking into account the potential for viability challenges on some sites which may influence the provision of affordable housing. This is particularly the case in terms of affordable housing tenures with an increased percentage of affordable home ownership and intermediate tenures, particularly where the golden rules in relation to Green Belt release apply.

Comment

Representation ID: 10189

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10686
High quality developments can make a positive impact on health and wellbeing. Likewise, development proposals that are poor quality can give rise to adverse impacts on health and quality of life. The Issues and Options draft sets out the Council’s policy approach to health and wellbeing and confirmed that where it is considered likely that a proposal will result in significant environmental effects during the construction phase, a Construction Environmental Management Plan (CEMP) will be required. The document states that proposals should aim to promote access to green space across the borough that widen and strengthen the boroughs cultural, sport, recreation and leisure offer. The Council’s approach to health and wellbeing is supported. The proposals for residential development at Chester Road, Kelsall will create wide-ranging benefits for health and wellbeing and the application will be supported by a Health Impact Statement.

Comment

Representation ID: 10191

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10688
In response to question HW3, while the importance of providing high quality residential amenity is supported, it is important that any policy that prescribes separation distances allows flexibility to consider site-specific factors. Rigid design standards, such as separation distances, can limit site capacity and reduce density. Local variations in separation distance policies also create uncertainty and inconsistency for developers. As such, any design policy, including those related to separation distances should include flexibility to ensure development is context-specific while ensuring a high standard of residential amenity.

Comment

Representation ID: 10192

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10689
The New Local Plan should set out a recommended quantity for outdoor amenity space to be provided in new developments. However it is important that the relevant policy takes due consideration of other existing and future outdoor amenity spaces that are accessible. The open space policy should be flexible to allow constrained sites that are suitable for housing to come forward and contribute to open space via contributions or off site provisions.

Comment

Representation ID: 10193

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10690
The Issues and Options consultation document sets out the Council’s policy approach to open space, sport and recreation. The broad approach will aim to protect, manage and enhance existing open spaces and facilities. This policy approach is broadly supported and is consistent with the NPPF. The draft policy text states that open space provision in new developments should be sought in the following order: on site, off-site, as a financial contribution. It is important that any policy takes into account new development on sites that cannot accommodate open space provision onsite, and in these circumstances, off-site provision or financial contributions are reasonable alternatives. In terms of recreational routeways, the draft policy wording states that proposals that enhance public access and the recreation value of the recreational routeway network will be supported. Savills support this element of the policy and that the routeway network will be identified on the policies map. However it will be important that the routeway policy is applied in a flexible manner insofar that it does not prohibit sustainable residential development from being delivered.