Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15766

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16325
EG 1 states that the Borough’s employment land supply “will be met through extant planning commitments, vacant/previously developed land in established employment areas, expansion land for specific employers or new allocations identified to meet strategic development needs.” It is further stated that “Proposals for alternative uses on allocated employment land must not limit the range, type, choice and quality of employment land available to meet future employment needs”, and goes on to explain when the redevelopment to non-employment uses will be permitted. As detailed in the preceding sections of these representations, although the site has extant consent for mixed-use development and has, for this reason, been included within the employment land supply 2025 (allocations and planning permissions), the site does not comprise built-out employment space and was not allocated for employment use through the CWaC LPP2. Therefore, residential-led development on the site would not limit the range, choice and quality of employment sites available to meet future employment needs in the Borough. Furthermore, the site is adjacent to the existing urban area of Middlewich and is not within the Green Belt. To the north-west of the site is a residential allocation (CEC Reference: SADPD Policy MID 2), to the west of which is established residential development. To the west of the site is a restaurant and employment units, which comprise part of the Midpoint 18 allocated employment site (CEC Reference: LPS 44). Therefore, the site is an appropriate and sustainable location for residential-led, mixed-use development, which would be compatible with the neighbouring land uses and the character of the surrounding area, and would make a positive contribution towards meeting the Borough’s substantial housing needs and, thus, the site should be allocated accordingly in the new Local Plan. Notwithstanding the above, any prospective policy relating to economic growth, employment and enterprise must include the necessary flexibility to allow for the redevelopment of employment sites to non-employment uses or employment uses outside of Use Classes B2, B8 and E(g), i.e., retail uses, to ensure that the Borough is able to effectively respond to changes in market conditions and demands over the Plan period.

Comment

Representation ID: 15767

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16326
Paragraph 17.6 of the Issues and Options Document refers to a Retail Study, which is currently in preparation. It is stated that the Retail Study “will identify the need for future retail and leisure floorspace including for food and non-food retail.” It is further stated that, “The new Local Plan will need to reflect this evidence base.” NPL reserves the right to comment on the Retail Study at the appropriate time. The site benefits from an extant planning permission for a major employment-led mixed-use development, which includes some retail uses. The maximum quantum of development approved under the hybrid planning permission is detailed at condition 11 and is provided below for reference. However, it is important to note that the condition details the former Use Classes; the current Use Classes were last updated on 1st September 2020: a) “The business and offices areas (use class B1 and A2) will comprise a maximum of 1,800sqm (gross internal area); b) The starter industrial areas (use class B1 and B2) will comprise a maximum of 2,400sqm (gross internal area); c) The food production areas (use class B1 and B2) will comprise a maximum of 2,650sqm (gross internal area); d) The light industrial, manufacturing and distribution areas (use class B2 and B8) will comprise a maximum of 9,500sqm (gross internal area); e) The veterinary practices (use class D1) will comprise a maximum of 700sqm (gross internal area); and, f) The restaurant and café areas (use class A3 and A5) will comprise a maximum of 232sqm (gross internal area).” The site offers the potential to include retail uses alongside housing. It is well-established that retail uses can be complementary to housing and employment development. Furthermore, NPL has undertaken a Retail Impact Report, which has been submitted to CWaC as part of a recent pre-application request in relation to the site, which considers the retail impact associated with the provision of a foodstore/foodstores on the site.

Comment

Representation ID: 15768

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16327
The supporting text to HO 1 states that a Housing Need Assessment is being prepared, which it is stated “will provide the basis for delivering the mix of homes required and requirement for affordable housing.” NPL reserves the right to comment on the Housing Need Assessment at the appropriate time, particularly as it is noted that the Council intends for this assessment to provide the basis for new Local Plan policies relating to the mix of housing. Nevertheless, it is important that any prospective planning policy relating to housing mix allows for flexibility owing to this being dependent on site and market factors. Therefore, if the Council is intending to “provide detailed policy requirements e.g. % of 1-2 bed dwellings including by tenures; % of plots for self-build and custom housebuilding…” (as detailed in HO 1), these percentages should be labelled as ’indicative’. Furthermore, the future planning policy should acknowledge that the mix should be proportionate to the scale of the development proposed.

Comment

Representation ID: 15769

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16328
The supporting text to HO 1 states that a Housing Need Assessment is being prepared, which it is stated “will provide the basis for delivering the mix of homes required and requirement for affordable housing.” NPL reserves the right to comment on the Housing Need Assessment at the appropriate time, particularly as it is noted that the Council intends for this assessment to provide the basis for new Local Plan policies relating to the mix of housing. Nevertheless, it is important that any prospective planning policy relating to housing mix allows for flexibility owing to this being dependent on site and market factors. Therefore, if the Council is intending to “provide detailed policy requirements e.g. % of 1-2 bed dwellings including by tenures; % of plots for self-build and custom housebuilding…” (as detailed in HO 1), these percentages should be labelled as ’indicative’. Furthermore, the future planning policy should acknowledge that the mix should be proportionate to the scale of the development proposed.

Comment

Representation ID: 15770

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16329
NPL acknowledges the Council’s intention within HO 2 for affordable homes to be sought within all new housing developments unless there are exceptional circumstances which can be demonstrated to justify off-site contributions. The delivery of suitable and achievable sites for residential-led, mixed-use development, such as the site, provide an excellent opportunity to deliver a mix of affordable housing to meet local needs.

Comment

Representation ID: 15771

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16330
The thresholds for affordable housing should be consistent with national planning policy. Therefore, in accordance with paragraph 65 of the NPPF (2024), the provision of affordable housing should not be sought for residential developments that are not major developments, other than in designated rural areas (where policies may set out a lower threshold of 5 units or fewer).

Comment

Representation ID: 15772

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16331
It is understood that the Council intends for LPP2 Policy DM 19 to be retained as a separate policy or the general principles incorporated into other policies of the new Local Plan. NPL reserves the right to comment further on any policy relating to development within the countryside at the appropriate time.

Comment

Representation ID: 15773

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16332
NPL notes the Council’s intention for developer contributions to be required for playing pitches based on additional demand generated by new residential development, and for open space provision in new developments being sought firstly on-site, secondly off-site, and thirdly via a financial contribution. NPL does not object to these policy intentions in principle, however, where the new Local Plan seeks to introduce additional policy requirements that could threaten the viability and/or delivery of development, there must be a robust and flexible mechanism whereby these additional requirements and/or other requirements (such as affordable housing or other developer contributions) can be relaxed if viability is threatened.

Comment

Representation ID: 15774

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16333
NPL notes the Council’s intention for developer contributions to be required for playing pitches based on additional demand generated by new residential development, and for open space provision in new developments being sought firstly on-site, secondly off-site, and thirdly via a financial contribution. NPL does not object to these policy intentions in principle, however, where the new Local Plan seeks to introduce additional policy requirements that could threaten the viability and/or delivery of development, there must be a robust and flexible mechanism whereby these additional requirements and/or other requirements (such as affordable housing or other developer contributions) can be relaxed if viability is threatened.

Comment

Representation ID: 15775

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

I&O_16334
NPL notes the Council’s intention for developer contributions to be required for playing pitches based on additional demand generated by new residential development, and for open space provision in new developments being sought firstly on-site, secondly off-site, and thirdly via a financial contribution. NPL does not object to these policy intentions in principle, however, where the new Local Plan seeks to introduce additional policy requirements that could threaten the viability and/or delivery of development, there must be a robust and flexible mechanism whereby these additional requirements and/or other requirements (such as affordable housing or other developer contributions) can be relaxed if viability is threatened.