Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15978

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16559
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.


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

Comment

Representation ID: 15979

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16560
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.


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

Comment

Representation ID: 15980

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16561
It is important that the policy approach to housing mix taken in the New Local Plan provides for a mix of different types and sizes 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.


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

Comment

Representation ID: 15981

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16562
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 apart 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.


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

Comment

Representation ID: 15982

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16563
High quality developments can make a positive impact on health and wellbeing. Likewise, developments 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 confirms 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.


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

Comment

Representation ID: 15983

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16564
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.


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

Comment

Representation ID: 15984

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16565
The New Local Plan should set out a recommended quantity for outdoor amenity space, 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. 


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

Comment

Representation ID: 15985

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16566
The Issues and Options consultation document sets out the Council’s policy approach to open space, sport and recreation. The broad approach aims 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.


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

Comment

Representation ID: 15986

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16567
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. 


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

Comment

Representation ID: 15987

Received: 29/08/2025

Respondent: Northern Trust Land Limited

I&O_16568
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.


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