Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9983

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10480
The Issues and Options consultation draft sets out that the Councils overall approach to transport is to minimise the need for travel, particularly by single-occupancy cars and vans, by locating development so it is accessible to local services and facilities by a range of transport modes. The draft document sets out a sustainable transport hierarchy, which is as follows: ▪ People walking or wheeling ▪ People cycling or riding ▪ People using public Transport ▪ People driving ultra-low emission and shared vehicles ▪ Delivery and logistics in internal combustion engine vehicles ▪ People driving other private motor vehicles. In terms of new development, the draft Local Plan document sets out that new development will be encouraged in more sustainable locations. This means that developments should maximise opportunities for people to be able to meet day-to-day needs within a reasonable (10 minute/ 800 metre ) walking distance of their homes, as well as being able to travel outside of their settlements by a range of sustainable transport choices. In response to question TA 1, the Council’s suggested policy approach towards transport and accessibility is broadly supported. The element of the draft policy that encourages new development in sustainable locations that benefit from existing connections to sustainable transport modes is particularly supported, since these locations can make a significant contribution to sustainable development. The land at Chester Road, Kelsall is in a highly sustainable location that is consistent with the key principles of the draft policy TA 1. It is in a location where everyday services and facilities can be reached on foot or by cycle and is nearby to a bus stop which is served by the 82 service that runs between Chester and Northwich.

Comment

Representation ID: 9984

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10481
The NPPF states at Paragraph 35 that Plans should set out the contributions expected from development. At the same paragraph, the NPPF makes clear that such policies should not undermine the deliverability of the plan. Savills broadly supports the proposed infrastructure and developer contributions policy under section ID1. However, the issues and options draft states that the policy approach will clarify that where infrastructure is needed to sustain a new development, off-site contributions may not be acceptable, and this approach is questioned. It is considered that this approach could fail to take due consideration of smaller sites that are constrained and therefore may not be able to deliver necessary infrastructure on-site. In these circumstances, off site contributions are a way of mitigating the impacts of development through financial contributions, established under a legal agreement tied to a planning permission.

Comment

Representation ID: 9985

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10482
Developer contributions should only apply to major developments. It is suggested that the definition of ‘major development’ should be consistent with the definition given in the NPPF, as this will aid clarity and consistency between local and national policy. The NPPF explicitly states that for housing, major development relates to development where to or more homes will be provided, or the Site has an area of 0.5 hectares or more.

Comment

Representation ID: 9986

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10483
In the case of housing development, financial contributions can be secured by S106 agreements in order to enable to provision of new site specific infrastructure, or upgrade existing site specific infrastructure, required to make development acceptable in planning terms. These contributions are supplemented by CIL contributions towards non-site specific infrastructure. In this sense, housebuilders already pay the full cost of the infrastructure required to deliver new homes.

Comment

Representation ID: 9987

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10484
It is considered that site specific infrastructure that is essential for delivery should be prioritised. This may require a reduction in affordable housing contributions, or flexibility in affordable tenure mix, to enable this to happen.

Comment

Representation ID: 9989

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10486
The Issues and Options draft document states that the new policy approach will provide detailed requirements for various types and proportions of housing. It is important that the New Local Plan is not overly restrictive as it must allow flexibility to enable sites to come forward that can deliver a range of house sizes in different proportions that reflect both need and market demand. Until the Housing Needs Assessment is updated, comments cannot be made in relation to the housing mix policy details. In terms of specialist and accessible housing (M4(2) / M4(3) the proportion of homes that meet these standards should reflect the evidence. This is not likely to require that all homes meet these standards as a blanket requirement.

Comment

Representation ID: 9991

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10488
As mentioned above, it is important that the policy approach to housing mix taken in the new Local Plan provides for a mix of different types and sized of housing to come forward to meet the diverse housing needs of the District. It is appropriate that the housing mix policy should be informed by an up to date Housing Needs Assessment. Until that Assessment is complete, comments on the details of the policy cannot be made.  A percentage policy approach would appear to be a logical approach. However, such percentages would need to be reflective of a robust evidence base.  It should be noted however that policies in the new Local Plan must take a flexible approach that takes into consideration site-specific factors. There should be flexibility built into the policy to not restrict housing development from coming forward where sites can make an important contribution to the overall housing delivery in the Borough. There is clear case law that confirms the nature of such indicative mixes as guidance and the Policy should accord with this.

Comment

Representation ID: 9992

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10489
The draft Issues and Options document sets out the policy approach to be taken in the New Local Plan in relation to affordable housing at section HO2. The approach will reflect the government’s requirement for housing development in the Green Belt to provide at least 50% affordable housing, whether land has been released from the Green Belt through a housing allocation, or an application. Affordable housing will be required on all sites of 10 or more dwellings part from in designated rural areas, where the threshold will be three or more dwellings.  The general policy approach towards securing affordable housing is supported in principle. As above, it is important that the detailed policy includes sufficient flexibility and takes into consideration site specific factors, such as ground contamination, that could impact viability. The Council should take a pragmatic approach that enables a sufficient supply of affordable housing to come forward as part of housing developments, while taking into account the potential for viability challenges on some sites which may influence the provision of affordable housing. This is particularly the case in terms of affordable housing tenures with an increased percentage of affordable home ownership and intermediate tenures, particularly where the golden rules in relation to Green Belt release apply.

Comment

Representation ID: 9993

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10490
High quality developments can make a positive impact on health and wellbeing. Likewise, development proposals that are poor quality can give rise to adverse impacts on health and quality of life. The Issues and Options draft sets out the Council’s policy approach to health and wellbeing and confirmed that where it is considered likely that a proposal will result in significant environmental effects during the construction phase, a Construction Environmental Management Plan (CEMP) will be required. The document states that proposals should aim to promote access to green space across the borough that widen and strengthen the boroughs cultural, sport, recreation and leisure offer.  The Council’s approach to health and wellbeing is supported. The proposals for residential development at Chester Road, Kelsall will create wide-ranging benefits for health and wellbeing, and the application will be supported by a Health Impact Statement.

Comment

Representation ID: 9994

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10491
In response to question HW3, while the importance of providing high quality residential amenity is supported, it is important that any policy that prescribes separation distances allows flexibility to consider site-specific factors. Rigid design standards, such as separation distances, can limit site capacity and reduce density. Local variations in separation distance policies also create uncertainty and inconsistency for developers. As such, any design policy, including those related to separation distances should include flexibility to ensure development is context-specific while ensuring a high standard of residential amenity.