Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15419

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15978
Shropshire Homes fully support the list of evidence, but also recommend that a settlement hierarchy paper is prepared to ensure that rural sustainable settlements which support a wider catchment and are not constrained by Green Belt are directed appropriate levels of development moving forward. Shropshire Homes also note the Tree Coverage Policy (G1) and the potential around higher water efficiency standards and request that a suitable evidence base is prepared to justify any policy approach

Comment

Representation ID: 15421

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15980
It will be critical for the monitoring framework within the plan to closely monitor housing land supply at regular intervals. NPPF paragraph 34 is clear that policies in local plans should be reviewed to assess whether they need updating at least once every five years. Due to CWAC’s significant housing requirements (which as a minimum will comprise the local housing need figure of 1,928 dwellings per annum1 ), it is important for housing delivery to be regularly monitored and appropriate trigger points inserted into the monitoring framework in respect of a potential early Local Plan Review. We reserve the right to comment on this matter further – as the Local Plan progresses and the quality of the evidence base in respect of land supply and proposed allocations is made available.

Comment

Representation ID: 15425

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15984
At paragraph 1.23, it is noted that the Council think that the updated Local Plan should plan for a period of 15 years. Shropshire Homes agree with this and note that NPPF para 15 expects strategic policies to look forward 15 years from adoption.

Comment

Representation ID: 15426

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15985
At paragraph 1.23, it is noted that the Council think that the updated Local Plan should plan for a period of 15 years. Shropshire Homes agree with this and note that NPPF para 15 expects strategic policies to look forward 15 years from adoption.

Comment

Representation ID: 15430

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15989
At Table 5.2, the SA contains a high-level assessment of spatial options A, B and C against key objectives – which score the same against all objectives, with the following (not all) notable exceptions: • Option A (Retain the Green Belt) scores worse (amber) than the other two options in respect of infrastructure – reducing the need to travel and encouraging sustainable modes of transport. • Options B (current LP level and distribution) and C (sustainable transport corridors) score worse (red) in respect of conserving and enhancing the historic environment objective. • Options B & C score better than option A under climate change and reduction of air pollution objectives. o single spatial option, in isolation, will be sufficient. Clearly, the SA also takes a very high-level approach, when in reality, development and allocations should be settlement capacity and site-led, to deliver the best and most suitable options for development across the plan area. In respect of the settlement specific policies assessed in the SA, we do not have any particular comments to make at this stage, given allocations have not yet been formally identified or assessed. Due to the early stage of the Local Plan making process, we note the SA (and Consultation Paper) at this stage only refer to delivery of a minimum of 1,914 dwellings per annum. As required at NPPF paragraph 36, Local Plans must be justified – taking into account reasonable alternatives. One such alternative will be to explore a higher growth option which is higher than the standard method figure, which is a minimum starting point.

Comment

Representation ID: 15432

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15991
Shropshire Homes are generally supportive of the Neighbourhood Plan process and the role it plays in delivering community led development. It is important to note that Neighbourhood Plans should not promote less development than set out in strategic policies for the area, or undermine those strategic policies, as it is noted that this may be the case with the current drafting of the new NP for Malpas.

Comment

Representation ID: 15433

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_15992
Shropshire Homes are supportive of the general principles of Policy SD 1, with the only comment at this stage being the importance of the need for flexible wording. At times, the current wording of Policy SD 1 reads as stringent – and it is important to recognise that there may be site-specific instances where all of the criteria cannot be met. We therefore recommend the first sentence of the policy is amended as follows: “New developments must, where possible, feasible and relevant”

Comment

Representation ID: 15463

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16022
The potential use of such networks can be appropriately considered as part of the energy strategy for each individual site and should be considered on a site-by-site basis. Indeed, Shropshire Homes understand that over 90% of district networks are gas fired. As 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas emissions to net zero will require a transition from gas-fired networks to renewable or low carbon alternatives such as large heat pumps, hydrogen or waste-heat recovery, but at the moment, one of the major reasons why heat network projects do not install such technologies is because of the up-front capital cost. It is therefore considered that heat networks requiring the installation of low-carbon technologies will remain uneconomic for the foreseeable future. As such, district heat networks are not a feasible and viable option, certainly in a location such as Malpas.

Comment

Representation ID: 15466

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16025
Shropshire Homes support the Council’s position (as clarified at paragraph 1, page 22) that: “The new Local Plan must plan to meet the government’s housing target (the standard method number) which was revised in December 2024. The Council has no choice in this.” Indeed, Paragraph 62 of the December 2024 NPPF makes it clear that the local housing need figure represents the minimum number of homes required (Pegasus emphasis). The latest standard method (SM) figures have recently been updated following the publication of the latest affordability ratios in March 2025 and 2024 housing stock data (published May 2025). The latest SM for CW&C is now 1,928, which equates to 28,920 dwellings over a 15 - year period (or 38,560 over a 20-year period, which may be more likely to comply with para 22 of the NPPF). In light of the recent data, CW&C currently need to plan for a minimum of 1,928 dwellings per annum.

Comment

Representation ID: 15493

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16052
Shropshire Homes do not support a stepped/staggered approach to housing delivery over the plan period. An even distribution of delivery throughout the plan period is achievable when a mixture of small, medium and large sites are appropriately allocated. Furthermore, it is notable that as CW&C can currently only demonstrate a 1.89 years housing land supply following the December 2024 NPPF. Given the need to maintain a suitable supply of homes, it is anticipated that a number of planning applications will be submitted to deliver housing immediately and plug the supply shortage within the next few years, such as the application by Shropshire Homes in Malpas. Therefore, delivery is likely to be strong early on in the Plan Period – and a staggered approach to housing delivery will not be necessary.