Local Plan Issues and Options (Regulation 18)

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Comment

Local Plan Issues and Options (Regulation 18)

Question GI 1

Representation ID: 15776

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16335
NPL notes the suggested policy approach towards green infrastructure, biodiversity and geodiversity. The Environment Act requires 10% Biodiversity Net Gain for new developments and, thus, the new Local Plan should be consistent with the law. It is understood that G1 is intending to retain the Council’s existing planning policy relating to replacement tree planting, but to add detail such as tree species and quantity. Any prospective planning policy relating to tree planting/cover must allow flexibility, as there should not be a ‘one size fits all’ approach to landscaping within new developments. This is equally as important when considering the Council’s intention for all external edges of all new development to have hedgerows, which it is stated “would be secured with an agreement specifying type/species and nature of hedgerow.” A restrictive policy requirement to this effect would not be supported, not least because there may be security or other design-related reasons where external edges of development cannot be planted with hedgerow

Comment

Local Plan Issues and Options (Regulation 18)

Question GI 2

Representation ID: 15777

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16336
NPL notes the suggested policy approach towards green infrastructure, biodiversity and geodiversity. The Environment Act requires 10% Biodiversity Net Gain for new developments and, thus, the new Local Plan should be consistent with the law. It is understood that G1 is intending to retain the Council’s existing planning policy relating to replacement tree planting, but to add detail such as tree species and quantity. Any prospective planning policy relating to tree planting/cover must allow flexibility, as there should not be a ‘one size fits all’ approach to landscaping within new developments. This is equally as important when considering the Council’s intention for all external edges of all new development to have hedgerows, which it is stated “would be secured with an agreement specifying type/species and nature of hedgerow.” A restrictive policy requirement to this effect would not be supported, not least because there may be security or other design-related reasons where external edges of development cannot be planted with hedgerow

Comment

Local Plan Issues and Options (Regulation 18)

Question GI 3

Representation ID: 15778

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16337
NPL notes the suggested policy approach towards green infrastructure, biodiversity and geodiversity. The Environment Act requires 10% Biodiversity Net Gain for new developments and, thus, the new Local Plan should be consistent with the law. It is understood that G1 is intending to retain the Council’s existing planning policy relating to replacement tree planting, but to add detail such as tree species and quantity. Any prospective planning policy relating to tree planting/cover must allow flexibility, as there should not be a ‘one size fits all’ approach to landscaping within new developments. This is equally as important when considering the Council’s intention for all external edges of all new development to have hedgerows, which it is stated “would be secured with an agreement specifying type/species and nature of hedgerow.” A restrictive policy requirement to this effect would not be supported, not least because there may be security or other design-related reasons where external edges of development cannot be planted with hedgerow

Comment

Local Plan Issues and Options (Regulation 18)

Question DS 1

Representation ID: 15779

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16338
NPL notes that the Council is currently preparing a borough-wide Design Code, setting out the design requirements for developments in Cheshire West, which it is intended will form part of the evidence base for the relevant policies relating to design and sustainable construction. NPL reserves the right to comment on this document at the appropriate time.

Comment

Local Plan Issues and Options (Regulation 18)

Question DS 2

Representation ID: 15780

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16339
The Council’s Design Code should be treated as a Supplementary Planning Document, which should be produced in accordance with Regulations 11 to 16 of the Town and Country Planning (Local Planning) (England) Regulations 2012. As explained in the Planning Practice Guidance, “Supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan. They are however a material consideration in decision-making. They should not add unnecessarily to the financial burdens on development.”13 As stated above, NPL reserves the right to comment on the Council’s Design Code at the appropriate time. However, NPL considers that there is no reason to depart from the Planning Practice Guidance. Therefore, it should be made clear that the Design Code is a material consideration in decision-making, but that it does not form part of the Development Plan.

Comment

Local Plan Issues and Options (Regulation 18)

Question DS 7

Representation ID: 15781

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16340
NPL supports the Council’s commitment to mitigating and adapting to climate change. Nevertheless, 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. Further to the above, prospective planning policies relating to sustainable construction should be consistent with, and not go beyond, the requirements of Building Regulations to avoid duplication and inconsistencies. DS 2 refers to carbon/energy off-setting and the potential to allow for a financial contribution to off-set any remaining residual carbon or energy. It also refers to the potential for the prospective policy to require carbon reporting and/or set a target that new buildings must meet. NPL reserves the right to comment on these potential policy requirements once further detail is received.

Comment

Local Plan Issues and Options (Regulation 18)

Question DS 10

Representation ID: 15782

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16341
NPL supports the Council’s commitment to mitigating and adapting to climate change. Nevertheless, 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

Local Plan Issues and Options (Regulation 18)

Question EN 5

Representation ID: 15783

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16342
EN 4 states that, “All major schemes and schemes involving significant generation or use of heat should explore opportunities for linking to district heat networks or other users/providers of heat. All major schemes should consider the potential to use ground source heat from private or public green spaces or water source heat solutions to contribute to heating requirements. All schemes requiring provision of heat should consider use of air source heat pumps or ground source heat pumps as an alternative to fossil fuel based heat sources.” As detailed in NPL’s response to SD 2, NPL would not support an indiscriminate policy requirement for new development to connect to a district heat network or any other Local Plan policies that would threaten the viability and/or delivery of development.

Comment

Local Plan Issues and Options (Regulation 18)

Question MISC 2

Representation ID: 15784

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Asteer Planning

Representation Summary:

I&O_16343
It is understood that the Council proposes to retain the content of LPP2 Policy DM 12 and show the associated consultation zone on the policies map. As demonstrated by the hybrid planning permission granted at the site, built development at scale has already been consented on the site and, thus, can be acceptable at the site in planning policy and technical terms. Furthermore, Jodrell Bank had no objection to the hybrid planning application, subject to electromagnetic screening materials being incorporated into the design of the buildings. As part of any prospective planning application at the site, the impact of the proposed development on Jodrell Bank, both in terms of the potential electromagnetic interference of the proposed development and its impact on the WHS, would be assessed.

Support

Local Plan Issues and Options (Regulation 18)

Question IN 1

Representation ID: 16436

Received: 29/08/2025

Respondent: NPL Group (UK) Ltd

Agent: Pegasus Planning Group Ltd

Representation Summary:

I&O_15471
This site is considered in the Stage One Land Availability Assessment 2025 and given reference 1625. It is identified as being adjacent to the settlement of Northwich and the Gadbrook Park established employment area, and unconstrained by Green Belt, Flood Zone 3 and local greenspace designations. The extent of the site is based on the red line boundary, and it is identified as being potentially suitable for mixed employment development (B2, B8, Eg). No better performing site has been identified in the Stage One Land Availability Assessment 2025.

Missing from the evidence base is a transparent methodology of how the sites with employment potential like this site, have resulted in the spatial strategy options and potential growth options in the Options Regulation 18 Consultation report, which excludes this site. Moving forward we fully expect to see a clear site selection methodology, which will be scrutinised as part of future representations.

Also missing from the evidence base is any information on the safeguarding of the land that was required for HS2 and is no longer required for that purpose. Indeed, the Options Regulation 18 Consultation report or supporting evidence base makes to reference whatsoever to the safeguarding of the route.

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