Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 15265

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15824
The draft policy is in line with the requirements of Section 14 of the NPPF in respect of the sequential test, however it is important that any emerging policy is also aligned with updated PPG Guidance. The PPG seeks to provide a more practical and pragmatic approach to development within areas of flood risk. Ultimately, the key test in respect of flood risk is to ensure that development will be safe throughout its lifetime and not lead to increased flood risk elsewhere14. This can be achieved through detailed design and an appropriate drainage strategy. We reserve the right to make further detailed comments as Cheshire West and Chester Strategic Flood Risk Assessment evolves through the emerging plan process. Barratt Redrow is 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: 15266

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15825
The draft policy is in line with the requirements of Section 14 of the NPPF in respect of the sequential test, however it is important that any emerging policy is also aligned with updated PPG Guidance. The PPG seeks to provide a more practical and pragmatic approach to development within areas of flood risk. Ultimately, the key test in respect of flood risk is to ensure that development will be safe throughout its lifetime and not lead to increased flood risk elsewhere 14. This can be achieved through detailed design and an appropriate drainage strategy. We reserve the right to make further detailed comments as Cheshire West and Chester Strategic Flood Risk Assessment evolves through the emerging plan process. Barratt Redrow is 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. 14 PPG Paragraph: 029 Reference ID: 7-029-20220825

Comment

Representation ID: 15268

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15827
It has recently been announced that the application for the Cheshire Sandstone Ridge to be designated as an Area of Outstanding Beauty (National Landscape) has been paused due to funding issues 15. There is therefore not a need for planning policy to address this at this point in time and Barratt Redrow would strongly object to the introduction of a policy prior to any formal designation. 15 https://www.sandstoneridge.org.uk/news/aonb-update-2.html

Comment

Representation ID: 15271

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15830
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: 15272

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15831
No - Whilst individual sites may have an ability 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: 15273

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15832
We welcome that this policy is worded flexibly ‘Development should, where appropriate ’ rather than more prescriptively. In respect of the Nationally Described Space Standards please see our response to questions HO 1 – HO 2.

Comment

Representation ID: 15274

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15833
If the Council is to introduce a Borough-wide Design Code, it is important that it is subject to viability testing. This will help to ensure no unnecessary delays to the delivery of development. As the new Local Plan is being prepared, there is likely to be merit in twin-tracking the production of any Borough-wide Design Code, to ensure the two are aligned and that the Local Plan design polices are viable. Any Design Code should include similar flexibility to policy DS 1 above, allowing for site specific circumstances that may require departures from the standard Design Coding.

Comment

Representation ID: 15275

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15834
The PPG 16 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, Barratt Redrow fully support the need for new dwellings to be energy efficient and use sustainable construction methods. However, 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. 16 Paragraph: 012 Reference ID: 6-012-20190315v

Comment

Representation ID: 15276

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15835
Part 5 of the policy notes how new dwellings will be required to meet the optional higher National Housing Standard for water consumption of 110 litres per person per day. This is therefore a higher requirement beyond the 125 litres/person/day set in building regulations. The PPG 17 notes that it will be for a local planning authority to establish a clear need for the introduction of any optional higher standards, based on: existing sources of evidence. consultations with the local water and sewerage company, the Environment Agency and catchment partnerships. consideration of the impact on viability and housing supply of such a requirement. 17 Paragraph: 015 Reference ID: 56-015-20150327

Comment

Representation ID: 15279

Received: 29/08/2025

Respondent: Barratt Redrow Plc

Agent: Pegasus Planning Group Ltd

I&O_15838
The policy notes that as an alternative to the sustainable construction requirements (1-5), positive weight will be given to development proposals that, for residential development, will be certified PassivHaus standard. Barratt Redrow support the policy wording that this is an alternative requirement and not required for all new residential development moving forward.