Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15229

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15788
Barratt Redrow also support the identification of Potential Growth Area NEP02 at this stage of the plan process. Harrow Estates (who form part of the wider Barratt Redrow Group) have land interests in this growth area and are actively promoting it for allocation. Please refer to the site-specific representations prepared by Harrow Estates for full details.

Comment

Representation ID: 15233

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15792
As already explained under question SS 5, Barratt Redrow fully support the elevation of Neston and Parkgate to a ‘Market Town’ in the emerging settlement hierarchy. This will necessitate the allocation of some Green Belt release site(s), with Land at Raby Park Road (NEP04) representing a highly suitable and sustainable housing site. Policy NP 1 notes that the policy approach will generally reflect the objectives and projects identified in the Neston Neighbourhood Plan (NP). We note that the adopted NP was adopted in March 2016 and covers the existing local plan period up to 2030. Therefore, whilst some of its general objectives will remain relevant, it will be important to ensure it is updated such that it remains in general conformity with the new Local Plan and does not undermine its strategic objectives. It’s policies and objectives can therefore not be fully relied upon when drafting the emerging Local Plan, as the plan is now dated and a new planning policy context is emerging.

Comment

Representation ID: 15234

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15793
The draft policy states that current Local Plan policy STRAT 9 may need to be updated if required to set out the approach to grey belt and to reflect Green Belt review evidence in terms of overall approach and to inset areas/washed over settlements. As explained throughout these representations, exceptional circumstances exist to review Green Belt boundaries, namely CW&C’s substantial development requirements and acute five year housing supply shortfall. Barratt Redrow is supportive of the reference to Grey Belt. NPPF paragraph 148 clearly sets out the sequential approach in respect of Green Belt, namely: “Where it is necessary to release Green Belt land for development, plans should give priority to previously developed land, then consider grey belt which is not previously developed, and then other Green Belt locations. However, when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate with particular reference to paragraphs 110 and 115 of this Framework. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary.” It will be important for the Local Plan to follow this approach to Green Belt release, to ensure that plan can be considered sound (justified and consistent with national policy).

Comment

Representation ID: 15236

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15795
Barratt Redrow support the statement that new development will be encouraged in more sustainable locations, recognising that the approach to transport will vary depending on site location. Indeed, we address this in more detail under question SS 19, noting how approaches will vary depending on location with current Spatial Option C being overly focussed on higher frequency bus corridors and proximity to railway stations, when Active Travel is an equally (and arguably more) pertinent consideration. The draft policy then notes that developments and places should maximise any opportunities for people to be able to meet their regular day to day needs within a reasonable (10 minute/800 metres) walking distance of their homes, as well as being able to travel outside of their settlements by a range of sustainable travel choices. Well established guidance, namely the Chartered Institution for Highways and Transportation (CIHT) document entitled ‘Providing for Journeys on Foot’ suggests walking distances outlined below. Town Centres (m) / Commuting/School/Sightseeing (m) / Elsewhere/Local Services (m) Desirable: 200 / 500 / 400 Acceptable: 400 / 1,000 / 800 Preferred Maximum: 800 / 2,000 / 1,200 Noting the above preferred maximum distances, it is considered that more flexibility is required when determining sustainability matters, and that 800m should not represent an upper limit/ cap for site selection. Notwithstanding our general comments above, the submitted Development Frameworks for each of Redrow’s land interests confirms that each site is sustainably located in relation to local services, as summarised below: Land at Lache Road/Wrexham Road Extension, as confirmed in the Delivery Statement at Appendix 1, is sustainably located adjacent to the Kings Moat Garden Village. A range of facilities are located within 1,200m 7, including Kings Moat Local Centre which can be accessed within a 10-minute walk. Land at Hare Lane, as confirmed in the Development Framework at Appendix 2, is sustainably located in relation to local bus services. Land at Chester Road, Hartford, as confirmed in the Development Framework at Appendix 3, has a range of local amenities 8 located within walking distance of the site. This includes Hartford Railway Station being located within 400m (a 5-minute walk), as well as a number of bus stops. Land at Raby Park Road, Neston, as confirmed in the Development Framework at Appendix 4, benefits from an excellent location directly opposite Neston High School. Neston Centre can also be accessed within a 10-minute walk 9 and is home to numerous shops and amenities. Land at Mill Lane, Willaston, as confirmed in the Development Framework at Appendix 5, benefits from a number of services being located within a 400m radius of the site (5-minute walk) 10. This includes a primary school, GP surgery and bus stops. Land at Dunkirk Farm, as confirmed in the Development Framework at Appendix 6, benefits from sustainable access to local bus stops 11 – which provides direct access to Liverpool at an operational frequency of two services per hour. In respect of David Wilson’s land interests at Dig Lane, Frodsham , please refer to the site-specific representations prepared by Turley which demonstrate the sustainability of the site. Similarly, in respect of Barratt’s land interests at Sandy Lane, Weaverham , please refer to the site-specific representations prepared by Savills which demonstrate the sustainability of the site. 7 See Site Context Plan, contained at page 11 of the Delivery Statement. 8 See Facilities and Services Plan, contained at page 6 of the Development Framework. 9 See Facilities and Services Plan, contained at page 16 of the Development Framework. 10 See Facilities and Services Plan, contained at page 22 of the Development Framework. 11 See Facilities and Services Plan, contained at page 21 of the Development Framework.

Comment

Representation ID: 15254

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15813
Barratt Redrow support the identification of the Chester Western Relief Road in Policy T2. It is considered that this long-standing infrastructure aspiration should be retained as a priority. Barratt Redrow would welcome further details on the proposed route of the Relief Road.

Comment

Representation ID: 15255

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15814
It is important that any proposed infrastructure and developer contributions are properly costed and assessed through the emerging Viability Assessment and Infrastructure Delivery Plan to ensure that they do not undermine delivery of the plan, in accordance with NPPF paragraph 35. Furthermore any developer contributions should only mitigate their own impacts as per the CIL tests set out at NPPF paragraph 58 of the NPPF, and should not be sought to address existing deficiencies or shortfalls in local infrastructure or services. It will also be important to ensure no overlapping with the Community Infrastructure Levy (CIL) Charging Schedule that is already in force in the Borough. Finally, we endorse the HBF’s position on the following matters: Digital connectivity – that any requirement on developers should not go beyond that set out in Building Regulations. Maximising employment opportunities for residents – that this needs careful consideration in dialogue with the HBF and wider industry and that the costs associated with such a policy are properly accounted for in the emerging Viability Assessment.

Comment

Representation ID: 15257

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15816
It is important that any proposed infrastructure and developer contributions are properly costed and assessed through the emerging Viability Assessment and Infrastructure Delivery Plan to ensure that they do not undermine delivery of the plan, in accordance with NPPF paragraph 35. Furthermore any developer contributions should only mitigate their own impacts as per the CIL tests set out at NPPF paragraph 58 of the NPPF, and should not be sought to address existing deficiencies or shortfalls in local infrastructure or services. It will also be important to ensure no overlapping with the Community Infrastructure Levy (CIL) Charging Schedule that is already in force in the Borough. Finally, we endorse the HBF’s position on the following matters: Digital connectivity – that any requirement on developers should not go beyond that set out in Building Regulations. Maximising employment opportunities for residents – that this needs careful consideration in dialogue with the HBF and wider industry and that the costs associated with such a policy are properly accounted for in the emerging Viability Assessment.

Comment

Representation ID: 15258

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15817
Barratt Redrow 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. Barratt Redrow object to this suggested approach. Prescriptive housing mix requirements often generate viability and deliverability issues. Instead, a 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. In respect of self-build and custom housing, this type of product is generally best delivered on small-medium scale sites that have been specifically allocated for that purpose, rather than as part of larger traditional housing allocations. Such housing is also contingent on there being a demonstrable need. In the case of CW&C’, their self-build and custom house building register12 confirms that only 36 new registrations for self/custom build housing were made between 31st October 2023- 30th October 2024, which does not indicate particularly strong demand given the Borough’s size, meaning a specific % requirement for self-build housing is not justified. In terms of introducing the nationally described space standards, this would need to be justified and follow the guidance within the PPG13, 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. We also note the HBF comments that there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. The HBF recommends that the policy approach should recognize that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and affect customer choice 12 https://consult.cheshirewestandchester.gov.uk/kpse/event/A4F1351D-DE17-4B0E-9967-E36E7154D9F0 13 Paragraph: 020 Reference ID: 56-020-20150327

Comment

Representation ID: 15261

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15820
Barratt Redrow 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. Barratt Redrow object to this suggested approach. Prescriptive housing mix requirements often generate viability and deliverability issues. Instead, a 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. In respect of self-build and custom housing, this type of product is generally best delivered on small-medium scale sites that have been specifically allocated for that purpose, rather than as part of larger traditional housing allocations. Such housing is also contingent on there being a demonstrable need. In the case of CW&C’, their self-build and custom house building register12 confirms that only 36 new registrations for self/custom build housing were made between 31st October 2023- 30th October 2024, which does not indicate particularly strong demand given the Borough’s size, meaning a specific % requirement for self-build housing is not justified. In terms of introducing the nationally described space standards, this would need to be justified and follow the guidance within the PPG13, 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. We also note the HBF comments that there is a direct relationship between unit size, cost per square metre (sqm), selling price per sqm and affordability. The HBF recommends that the policy approach should recognize that customers have different budgets and aspirations. An inflexible policy approach to NDSS for all new dwellings will impact on affordability and affect customer choice 12 https://consult.cheshirewestandchester.gov.uk/kpse/event/A4F1351D-DE17-4B0E-9967-E36E7154D9F0 13 Paragraph: 020 Reference ID: 56-020-20150327

Comment

Representation ID: 15262

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15821
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 the current blanket approach of 50% affordable housing on Green Belt sites released through Local Plans, 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. 50% affordable housing should not be seen as a set rate to be achieved across the Borough – as this will not be viable. The reference in draft policy HO 2 to how affordable housing could potentially be determined by sub-area aligns with this and is therefore welcomed. Any affordable housing requirement on Green Belt release sites must be viability tested through a robust evidence base. We reserve the right to make further comments at the next stage of the process, once the relevant PPG viability guidance is updated.