Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15724

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16283
Shropshire Homes fully understand and support the need to provide a mix of house types, sizes and tenures on site to deliver sustainable, mixed communities. However, the draft policy states that the new policy approach will provide detailed policy requirements e.g. % of 1-2 bed dwellings including by tenures, % of plots for self-build and custom housebuilding and requirements to meet the needs of an ageing population. Shropshire Homes object to this suggested approach.  Prescriptive housing mix standards often lead to viability and deliverability issues. Instead, a more flexible approach should be taken to housing mix which recognises that needs and demand will vary from area to area and site to site. A flexible approach also helps to ensure that housing schemes are viable and appropriate for the local market, i.e. housing mix is a matter which should be considered on a site-by-site basis but guided by an overarching framework. In respect of self-build and custom housing, these are best delivered on specific small-medium scale sites allocated for such a purpose, rather than as part of wider allocations. It is also very much dependent on demonstrating a need – we note that CW&C’s self-build and custom house building register4 indicates only 36 new registrations for self/custom build housing were made between 31st October 2023- 30th October 2024. This does not indicate particularly strong demand given the Borough’s size, therefore a specific % requirement for self-build housing on sites is also not supported. In respect of the potential introduction of nationally described space standards, this would need to be justified and follow the guidance within the PPG5, which notes that local planning authorities must provide justification taking into account the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions. Clearly there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. As Shropshire Homes’ customers have different budgets and aspirations, an inflexible policy approach to NDSS for all new dwellings will impact on affordability and will affect customer choice.

Comment

Representation ID: 15725

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16284
Shropshire Homes support the Council’s initiative in securing affordable housing. We reserve the right to comment further on this once housing need evidence is available. With regards to development in the grey belt, the government is still yet to publish additional guidance in the PPG in respect of whether there are circumstances in which site specific viability assessments may be taken into account in respect of the ‘golden rules’ for Green Belt sites. The awaited publication of this additional guidance may alter a standard/blanket approach to 50% affordable housing on Green Belt release sites, as confirmed at NPPF paragraph 67: “As part of the ‘Golden Rules’ for Green Belt development set out in paragraphs 156- 157 of this Framework, a specific affordable housing requirement (or requirements) should be set for major development involving the provision of housing, either on land which is proposed to be released from the Green Belt or which may be permitted on land within the Green Belt. This requirement should: a) be set at a higher level than that which would otherwise apply to land which is not within or proposed to be released from the Green Belt; and b) require at least 50% of the housing to be affordable, unless this would make the development of these sites unviable (when tested in accordance with national planning practice guidance on viability). NPPF paragraph 68 then notes that the affordable housing requirement for land within or released from the Green Belt may be set as a single rate or be set at differential rates, subject to the criteria above. The reference in draft policy HO 2 to how affordable housing could potentially be determined by sub-area falls in line with this.

Comment

Representation ID: 15726

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16285
Shropshire Homes fully understand and support the need to provide a mix of house types, sizes and tenures on site to deliver sustainable, mixed communities. However, the draft policy states that the new policy approach will provide detailed policy requirements e.g. % of 1-2 bed dwellings including by tenures, % of plots for self-build and custom housebuilding and requirements to meet the needs of an ageing population. Shropshire Homes object to this suggested approach. Prescriptive housing mix standards often lead to viability and deliverability issues. Instead, a more flexible approach should be taken to housing mix which recognises that needs and demand will vary from area to area and site to site. A flexible approach also helps to ensure that housing schemes are viable and appropriate for the local market, i.e. housing mix is a matter which should be considered on a site-by-site basis but guided by an overarching framework. In respect of self-build and custom housing, these are best delivered on specific small-medium scale sites allocated for such a purpose, rather than as part of wider allocations. It is also very much dependent on demonstrating a need – we note that CW&C’s self-build and custom house building register4 indicates only 36 new registrations for self/custom build housing were made between 31st October 2023- 30th October 2024. This does not indicate particularly strong demand given the Borough’s size, therefore a specific % requirement for self-build housing on sites is also not supported. In respect of the potential introduction of nationally described space standards, this would need to be justified and follow the guidance within the PPG5, which notes that local planning authorities must provide justification taking into account the following areas: • need – evidence should be provided on the size and type of dwellings currently being built in the area, to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes. • viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted. • timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions. Clearly there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. As Shropshire Homes’ customers have different budgets and aspirations, an inflexible policy approach to NDSS for all new dwellings will impact on affordability and will affect customer choice.

Comment

Representation ID: 15727

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16286
The draft policy is in line with the requirements of Section 14 of the NPPF, in respect of the sequential test, and therefore we have no comments at this stage. We reserve the right to comment on future drafts of the Cheshire West and Chester Strategic Flood Risk Assessment update(s) in due course. Shropshire Homes are however supportive of multi-functional, nature-based drainage solutions, where feasible – noting that some drainage solutions have significant overlaps in respect of ecological mitigation and biodiversity net gain.

Comment

Representation ID: 15728

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16287
The draft policy states the following: “New policy wording will broaden the current policy approach and improve and maintain tree canopy cover within the borough on a strategic level. This would refer to a ‘league table’ of wards with low tree cover, where development in these wards will need to provide additional green space as would normally be required, with low performing wards prioritised for new tree planting. The aim is to get all wards to a minimum of 16% tree cover” It is considered that further evidence will need to be provided to justify the above approach, including aim for 16% tree cover in all wards. There will also be a need to understand any viability implications of additional green space provision in certain wards, which will also provide additional clarity to developers who will be bringing schemes forward. This is particularly important in respect of understanding the implications this will have on the developable areas within individual schemes.

Comment

Representation ID: 15729

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16288
No - Whilst individual sites may have an ability or choose to deliver in excess of the 10% mandatory BNG requirement, it is not considered justified to introduce a higher requirement above the nationally set requirement. This will lead to deliverability and viability issues, which would undermine the emerging plan and its ability to meet its massively increased housing needs and address its acute five-year housing supply shortfall.

Comment

Representation ID: 15730

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16289
Please see response to questions HO 1 – HO 2 in respect of nationally described space standards.

Comment

Representation ID: 15731

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16290
No – any such document would take the form of a Supplementary Planning Document, which would be a material consideration in the determination of planning applications and would not comprise a Development Plan document. This approach would then comply with Annex 2 of the NPPF and the relevant planning practice guidance (ref: 008 reference ID: 61- 008-20190315) which is clear in stating: “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.”

Comment

Representation ID: 15732

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16291
The PPG6 notes that local planning authorities can set energy performance standards for new housing higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes. As a responsible housebuilder, Shropshire Homes fully support the need for new dwellings to be energy efficient and use sustainable construction methods. Although Shropshire Homes are aware of the emerging Future Homes Standards, should the Council look to introduce a higher local standard, this will need to be duly considered and tested in the viability evidence supporting the Local Plan, to ensure it will not lead to delays in delivery or viability concerns.

Comment

Representation ID: 15733

Received: 29/08/2025

Respondent: Shropshire Homes

Agent: Pegasus Planning Group Ltd

I&O_16292
The PPG6 notes that local planning authorities can set energy performance standards for new housing higher than the building regulations, but only up to the equivalent of Level 4 of the Code for Sustainable Homes. As a responsible housebuilder, Shropshire Homes fully support the need for new dwellings to be energy efficient and use sustainable construction methods. Although Shropshire Homes are aware of the emerging Future Homes Standards, should the Council look to introduce a higher local standard, this will need to be duly considered and tested in the viability evidence supporting the Local Plan, to ensure it will not lead to delays in delivery or viability concerns.