Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 9995

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10492
The New Local Plan should set out a recommended quantity for outdoor amenity space, however it is important that the relevant policy takes due consideration of other existing and future outdoor amenity spaces that are accessible. For example, the Site at Chester Road is in close proximity to the Kelsall Green and Kelsall Playground, which are high quality public open spaces for recreation. The Site itself is well-contained and as such, there is an opportunity to create links between the proposed residential development and the Kelsall Green open space. Any proposed policy should therefore take into account existing parks, playgrounds and other open spaces nearby to new developments, which can provide an important source of outdoor amenity space.

Comment

Representation ID: 9996

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10493
The Issues and Options consultation document sets out the Council’s policy approach to open space, sport and recreation. The broad approach will aim to protect, manage and enhance existing open spaces and facilities. This policy approach is broadly supported and is consistent with the NPPF. The draft policy text states that open space provision in new developments should be sought in the following order: on site, off-site, as a financial contribution. It is important that any policy takes into account new development on sites that cannot accommodate open space provision onsite, and in these circumstances, off-site provision or financial contributions are reasonable alternatives. In terms of recreational routeways, the draft policy wording states that proposals that enhance public access and the recreation value of the recreational routeway network will be supported. Savills support this element of the policy and that the routeway network will be identified on the policies map. However, it will be important that the routeway policy is applied in a flexible manner insofar that it does not prohibit sustainable residential development from being delivered.

Comment

Representation ID: 9997

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10494
The thresholds for developer contributions for open space are detailed in the CW&C Council Developer Contributions Technical Guidance Note. That document sets out the onsite and financial contributions required for ‘amenity greenspace’, ‘play children’, play youth’, ‘allotment’, ‘parks and recreation’ depending on the proposed number of residential units. For proposed developments of 10 or fewer units, no contributions are due, which is an appropriate policy approach. For proposed developments of more than 10 units, there are various onsite and off-site requirements depending on the size of the proposals. The broad approach is supported; however, it is important that the policy is applied with sufficient flexibility to enable homes to come forward in sustainable locations. The importance of providing physical and financial contributions to open recreational spaces is acknowledged, however the scale of housing need in CW&C is such that the policy must take a pragmatic approach and prioritise sustainable housing delivery.

Comment

Representation ID: 9998

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10495
The Council’s Playing Pitch Strategy (PPS) was originally produced in 2021 and has since been updated in February 2025. A PPS is said to have a lifespan of three years, although this can be increased if it is kept up to date. Since it has been updated earlier this year, the PPS does not currently require an update, however it should be reviewed annually to ensure it is accurate.

Comment

Representation ID: 9999

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10496
The consultation document sets out at LA 1 that policies should protect and wherever possible enhance landscape character and local distinctiveness. Savills agrees with this policy approach.

Comment

Representation ID: 10000

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10497
In response to question LS2 above, the key settlement gaps should be reviewed in light of the current local housing need, which is a minimum of 1,928 new homes per year. As discussed above, for the Council to make sufficient land available to deliver the required homes, some land will need to be released from the Green Belt. This may also include land that is currently defined in Local Plan (Part Two) Policy GBC 3 as a key settlement gap. On the basis that the Council is required to make enough land available to meet its local housing need in full within the Plan period, the key settlement gaps should be reviewed to ensure the policy does not restrict sustainable residential development from coming forward. This approach would be consistent with the NPPF where it requires local authorities to meet local housing needs in full and to review Green Belt boundaries where necessary.

Comment

Representation ID: 10001

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10498
At GI 1, the Issues and Options consultation document sets out the policy approach towards Green Infrastructure, Biodiversity and Geodiversity. In response to the tree planting ratio specifically, the 2:1 proposed ratio is appropriate and would significantly increase the overall number of trees in the District. An increased requirement for tree replacement would place a substantial cost on developers which can reduce developer confidence and in turn the rate of development. There should be flexibility built into this policy to ensure that if there are site specific reasons why a large number of trees need to be removed, this can be accommodated without an unrealistic replacement programme.

Comment

Representation ID: 10002

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10499
The mandatory requirement for certain developments to deliver a minimum 10% net gain in biodiversity is provided by the Environment Act 2021. Savills consider that the New Local Plan should reflect the 10% requirement and not increase the requirement beyond this. It should be noted that the statutory requirement is for a minimum of 10% net gain to be provided as such, depending on the site specific constrains, viability and other factors, the legislation is designed to set the 10% as a minimum. If the Local Plan adopted a policy requirement above the 10% mandatory requirement, this could risk reducing the number of homes that can be delivered, since an additional cost would be placed on developers, which could impact the viability of potential housing developments. The viability assessment supporting the New Local Plan would have to consider the financial implications of this. The New Local Plan should reflect the national mandatory requirement of a minimum of 10% net gain.

Comment

Representation ID: 10003

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10500
At DS 1, the Issues and Options Consultation document sets out that the New Local Plan will promote sustainable, high quality design and construction. Savills broadly supports the approach to design policy, particularly in relation to making the best use of high quality materials and reducing the opportunity for crime and disorder, and the fear of crime. While the broad policy approach is supported, the New Local Plan should ensure that policies relating to design are flexible and take into account site characteristics. With regards to Nationally Described Space Standards (NDSS) it should be noted that these can only be introduced where there is a clear need and the introduction of the Standards would not impact development viability. The Council will need to demonstrate robust justifiable evidence to introduce the NDSS. It should also be noted that well-designed homes that are below NDSS provide high quality, functional homes, which are appropriate for various budgets. Smaller dwellings play a valuable role in meeting specific needs for both open market and affordable home ownership housing.

Comment

Representation ID: 10004

Received: 27/08/2025

Respondent: Bellway Homes Ltd

Agent: Savills (UK) Limited

I&O_10501
In response to question DS2, if the Council produces a borough-wide Design Code, this should inform the New Local Plan so that design policies are consistent and evidence-based.  Design policy that is clear and consistent and informed by a borough-wide Design Code will help inform development proposals for major development and will add clarity to what is expected of developments in terms of design. This will in turn increase developer confidence, which will have a positive influence on development.