Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 10195

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10692
The thresholds for developer contributions for open space are detailed in the CW&C Council Developer Contributions Technical Guidance Note. That document sets out the onsite and financial contributions required for ‘amenity greenspace’, ‘play children’, play youth’, ‘allotment’, ‘parks and recreation’ depending on the proposed number of residential units. For proposed developments of 10 or fewer units, no contributions are due, which is an appropriate policy approach. For proposed developments of more than 10 units, there are various onsite and off-site requirements depending on the size of the proposals. The broad approach is supported, however it is important that the policy is applied with sufficient flexibility to enable homes to come forward in sustainable locations. The importance of providing physical and financial contributions to open recreational spaces is acknowledged, however the scale of housing need in CW&C is such that the policy must take a pragmatic approach and prioritise sustainable housing delivery.

Comment

Representation ID: 10196

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10693
The Council’s Playing Pitch Strategy (PPS) was originally produced in 2021 and has since been updated in February 2025. A PPS is said to have a lifespan of three years, although this can be increased if it is kept up to date. Since it has been updated earlier this year, the PPS does not currently require an update, however it should be reviewed annually to ensure it is accurate.

Comment

Representation ID: 10198

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10695
The consultation document sets out at LA 1 that policies should protect and wherever possible enhance landscape character and local distinctiveness. Savills agrees with this policy approach.

Comment

Representation ID: 10199

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10696
In response to question LS2 above, the key settlement gaps should be reviewed in light of the current local housing need, which is a minimum of 1,928 new homes per year. As discussed above, for the Council to make sufficient land available to deliver the required homes, some land will need to be released from the Green Belt. This may also include land that is currently defined in Local Plan (Part Two) Policy GBC 3 as a key settlement gap. On the basis that the Council is required to make enough land available to meet its local housing need in full within the Plan period, the key settlement gaps should be reviewed to ensure the policy does not restrict sustainable residential development from coming forward. This approach would be consistent with the NPPF where it requires local authorities to meet local housing needs in full and to review Green Belt boundaries where necessary.

Comment

Representation ID: 10200

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10697
At GI 1, the Issues and Options consultation document sets out the policy approach towards Green Infrastructure, Biodiversity and Geodiversity. In response to the tree planting ratio specifically, the 2:1 proposed ratio is appropriate and would significantly increase the overall number of trees in the District. An increased requirement for tree replacement would place a substantial cost on developers which can reduce developer confidence and in turn the rate of development. There should be flexibility built into this policy to ensure that if there are site specific reasons why a large number of trees need to be removed, this can be accommodated without an unrealistic replacement programme.

Comment

Representation ID: 10201

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10698
The mandatory requirement for certain developments to deliver a minimum 10% net gain in biodiversity is provided by the Environment Act 2021. Savills consider that the New Local Plan should reflect the 10% requirement and not increase the requirement beyond this. It should be noted that the statutory requirement is for a minimum of 10% net gain to be provided as such, depending on the site specific constrains, viability and other factors, the legislation is designed to set the 10% as a minimum. If the Local Plan adopted a policy requirement above the 10% mandatory requirement, this could risk reducing the number of homes that can be delivered, since an additional cost would be placed on developers, which could impact the viability of potential housing developments. The viability assessment supporting the New Local Plan would have to consider the financial implications of this. The New Local Plan should reflect the national mandatory requirement of a minimum of 10% net gain.

Comment

Representation ID: 10202

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10699
At DS 1, the Issues and Options Consultation document sets out that the New Local Plan will promote sustainable, high quality design and construction. Savills broadly supports the approach to design policy, particularly in relation to making the best use of high quality materials and reducing the opportunity for crime and disorder, and the fear of crime. While the broad policy approach is supported, the New Local Plan should ensure that policies relating to design are flexible and take into account site characteristics. With regards to Nationally Described Space Standards (NDSS) it should be noted that these can only be introduced where there is a clear need and the introduction of the Standards would not impact development viability. The Council will need to  demonstrate robust justifiable evidence to introduce the NDSS. It should also be noted that well-designed homes that are below NDSS provide high quality, functional homes, which are appropriate for various budgets. Smaller dwellings play a valuable role in meeting specific needs for both open market and affordable home ownership housing.

Comment

Representation ID: 10203

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10700
In response to question DS2, if the Council produces a borough-wide Design Code, this should inform the New Local Plan so that design policies are consistent and evidence-based. Design policy that is clear and consistent and informed by a borough-wide Design Code will help inform development proposals for major development and will add clarity to what is expected of developments in terms of design. This will in turn increase developer confidence, which will have a positive influence on development.

Comment

Representation ID: 10204

Received: 27/08/2025

Respondent: Northern Trust Land Limited

I&O_10701
Northern Trust acknowledges the importance of advancing energy efficiency through a nationally consistent set of standards and a timetable that is universally understood and technically feasible. This aligns with the Written Ministerial Statement of December 2023 (WMS), which states that the Government does not expect plan-makers to set local energy efficiency standards for buildings that exceed current or planned building regulations. The WMS clearly indicates that any planning policies proposing local energy efficiency standards for buildings that go beyond current or planned building regulations should be rejected at examination if they lack a well-reasoned and robustly costed rationale. This rationale must ensure that development remains viable and considers the impact on housing supply and affordability in accordance with the NPPF. Additionally, any extra requirements should be expressed as a percentage uplift of a dwelling's Target Emissions Rate (TER), calculated using a specified version of the Standard Assessment Procedure (SAP). Therefore, if the Council wishes to pursue this policy, it should use the TER and ensure that they have a well-reasoned and robustly costed rationale that fully considers viability and the potential impact of the policy on housing supply and affordability.

Comment

Representation ID: 15957

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16538
The New Local Plan must be based on up to date and robust evidence. The Issues and Options consultation document sets out the following list of additional evidence that is needed to support the new Plan: ▪ Retail and Town Centres Study (in preparation) ▪ Strategic Flood Risk Assessment (in preparation) ▪ Gypsy Traveller Accommodation Assessment (GTAA) (in preparation) ▪ Housing Needs Assessment (to be prepared) ▪ Green Belt Study (to be prepared) ▪ Infrastructure Delivery Plan (to be prepared) ▪ Strategic Viability Assessment (to be prepared) ▪ Transport Assessment (to be prepared) ▪ Land Availability Assessment (in preparation). The above list of additional evidence is sufficient to inform the policies of the new Local Plan. Savills is supportive of the production of a Housing Needs Assessment, Land Availability Assessment and Green Belt Study which will inform the policies that relate to housing delivery in the new Local Plan. It is not considered that there is additional evidence that is required that is not already in preparation or due to be prepared that would be necessary to support the new Local Plan.


Original email from Jonathan Ainley with draft response. Final version received 23/10/2025 from Joel Austin to replace original draft version.