Cheshire East Council – Development Strategy Consultation Response

Prepared for The Peckforton Estate

February 2013 Jo Lovelady BA (Hons) MCD MRTPI

Contents

Report Consultation Response

Executive Summary 3 1. Introduction 4 2. Submission 5 3. Meeting Growth Requirements 9 4. Sites 10 5. Conclusion 10

Appendices Appendix A Plan of Identified Sites in Bunbury and Peckforton

Park House, 37 Lower Bridge Street, Chester, CH1 1RS ℡ 01244 354888 2

Development Strategy Consultation Response

Executive Summary

Our response concludes that the Preferred Options if unaltered will result in the Core Strategy being deemed “unsound” on the basis that:

The Authority is not proposing to meet the established housing and employment needs.

The Authority proposes to deliver a degree of growth through new isolated settlements before allocating acceptable sites on the edge of or within existing settlements. This means the plan is not “the most appropriate strategy when considered against the reasonable alternatives”.

To rectify this and to help the Authority meet the established housing needs, the identified Key Service Centres, local service centres (including Bunbury), and presently unidentified villages (including Peckforton) have the capacity to deliver more growth than presently planned for.

We have fundamental concerns that the housing needs of Peckforton are not planned to be met by the strategy which is contrary to paragraph 54 of the NPPF which states the need to meet local needs.

We consider that managed growth around the edge and within Bunbury and Peckforton needs to be allowed to deliver their housing needs and to ensure the future sustainability of these settlements.

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Development Strategy Consultation Response

1. Introduction

1.1 This report provides our written response to the “Development Strategy for Jobs and Sustainable Communities”. We understand that this and the “Policies Principle Document” together form the Authority’s Core Strategy Preferred Options stage.

1.2 This report should be read in association with all previous representations submitted in response to the Authority’s emerging Local Plan by Strutt and Parker LLP.

1.3 The report assesses the proposed level of growth (employment and housing) and how this will be delivered. We then focus on Bunbury and Peckforton and explore acceptable sites which could help achieve this growth.

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2. Submission

Development Strategy for Jobs and Sustainable Communities 2.1 This document sets out the degree of new homes and employment land proposed; it suggests levels of development for each town and identifies proposed strategic development sites.

Overall Development Strategy – CS1 Level of Growth 2.2 The Authority proposes to deliver 300 hectares of new employment land and 27,000 new homes up to 2030.

2.3 During the Issues and Options stage three “growth options” were consulted upon:

High growth – 1,600 new homes and 950 new jobs per year (i.e. 32,000 dwellings over 20 years).

Medium growth – 1,350 new homes and 650 new jobs per year (27,000 dwellings over 20 years).

Low growth – 1,150 new homes and 350 new jobs per year (23,000 dwellings over 20 years).

2.4 Despite 59% of consultation responses supporting the high growth option, the Authority have chosen medium growth on the basis that this “balances opposing views and competing factors which constrain or increase the need for development”. However, no further explanation is provided to comprehensively justify this choice which contrasts with the housing needs evidence.

2.5 We disagree with the decision to select the medium growth option and consider that high growth should be selected to ensure that the Local Plan is found to be “sound” at Examination.

2.6 Supporting this, the SHMA identifies an annual need for 3,996 new dwellings which, over 20 years, amounts to a requirement of 79,920 new dwellings. The ONS based sub-national population projections also report the requirement for 1,600 new dwellings per year to meet future population increases (i.e. 32,000 over 20 years). The medium growth option meets neither of these growth scenarios.

2.7 Therefore the Authority need to be aspiring to meet the SHMA requirement on the basis that the very focus and purpose of this report is to establish the Authority’s local future housing need. It should therefore be afforded the most weight when establishing housing targets. However in order to even even meet the lower requirement of the ONS projections the high growth option needs to be chosen.

2.8 If the Authority continues with the medium growth option, we consider the Core Strategy will be found unsound at Examination. Essentially, as Cheshire East’s existing and future housing need will not be met, the plan will not be “positively prepared” (i.e. based on a strategy which seeks to meet objectively assessed development and infrastructure requirements). This is a national requirement for a “sound” plan (section 182 of the NPPF).

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Supply 2.9 Whilst the latest SHLAA (2013) does not provide a summary breakdown of the ratio between brownfield and greenfield house supply, the 2011 SHLAA does. This highlighted that of the sites assessed as “suitable over the next 15 years” only “7000 homes would be delivered on brownfield sites with a further 3,700 on sites that are a mix of brownfield and greenfield”. Therefore, under any of the Authority’s growth options strategic greenfield land would need to be developed which is reflected in the latest SHLAA (2013).

2.10 Under the preferred medium growth option 9,500 dwellings would need to be realised on purely greenfield sites over the next 15 years with the high growth option requiring 13,300 dwellings to be delivered this way.

Conclusion 2.11 The high growth option needs to be selected to meet the Authority’s housing needs and ensure the Core Strategy is “sound”.

2.12 As the Authority’s potential brownfield supply is extremely limited a portion of this growth will need to be met through greenfield sites (strategic and smaller sites on the edge of or within settlements) (reflecting the medium growth strategy but to a higher degree). Accordingly some of the Authority’s discounted sites need to be reconsidered as well as sites within rural settlements identified (section 4).

2.13 Section 4 sets out sites which are acceptable for development and so should either be allocated at this stage or at least identified as sites to be allocated within the forthcoming Site Allocations DPD. This is to help the Authority meet their housing needs and ensure that the Core Strategy is deemed “sound” at Examination (i.e. “positively prepared”).

Settlement Hierarchy and Spatial Distribution – CS2 Principal Towns and Key Service Centres

2.14 We agree with the Authority’s settlement hierarchy in its identification of Principle Towns and Key Service Centre acknowledging their sustainability and critical mass.

Local Service Centres (e.g. Bunbury)

2.15 We support the Authority’s identification of Local Service Centres to meet localised needs and the inclusion of Bunbury as such. This reflects the settlements critical mass and sustainability in terms of strategic location between Nantwich and Tarporley and local services/amenities (see Section 4).

2.16 However in order to build flexibility into the Local Plan and promote sustainable growth, instead of being restrictive the target growth for these settlements should be “at least” “5 hectares of employment land and 2,000 homes” (i.e. there should not be an upper limit). This reflects the wording of the “Development Strategy” which sets out the level of growth to be a “minimum”.

2.17 The policy’s wording needs to allow for each settlement’s individual housing needs to be delivered at the very least, as required by Paragraph 54 of the NPPF. For example Bunbury’s established housing requirement is 120 dwellings (SHMA, September 2010) which needs to be met.

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Development Strategy Consultation Response

Sustainable Villages and Open Countryside (CS6)

2.18 We disagree with the Authority’s approach to development within “Sustainable Villages” and the “Open Countryside” and in particular the proposal that growth in Sustainable Villages should only be delivered through infill, change of use/conversions or affordable dwellings on the edge of the settlement. We consider that many of the settlements do not have the capacity to deliver their established growth needs purely through these measures, and so if market housing on the edge of the settlements is not permitted their local growth requirements will not be met.

2.19 The current grouping of settlements into either “villages” or “open countryside” (where development is restricted) ignores some settlements need for growth as well as capacity to deliver sustainable development.

2.20 Peckforton has an established need for 80 dwellings over the next 20 years (SHMA, 2010). However being presently identified within open countryside where even “infill” development would only be permitted on an exceptional basis, it is clear that the villages housing needs are not planned to be met. This is contrary to Paragraph 54 of the NPPF which seeks to meet local housing needs.

2.21 Therefore the Authority’s strategy needs to be amended to either; include villages with an identified housing need into the “Sustainable Villages” category (e.g. Peckforton), or; be more flexible and undefine the “Sustainable Village” category, instead stating that new development will be permitted within existing villages where sustainable development can be achieved. This would reflect the NPPF’s main aim to deliver the “presumption in favour of sustainable development” by assessing applications on a site by site basis, instead of resisting potential housing and employment delivery without considering their individual sustainability merits.

2.22 This amended strategy will still achieve the aims of Policy CS6 as development schemes will still need to ensure that “the appearance and distinctiveness of the Cheshire countryside is preserved and enhanced” through high quality design, landscaping an managed growth.

2.23 If the Authority do not amend this part of the strategy the plan will be found “unsound” as it will not seek to meet Peckforton’s development requirements (i.e. “positively prepared”).

New Settlements

2.24 We generally disagree with the Authority’s proposal to meet some of its housing and employment needs through the creation of three “new settlements” and particularly object to those proposed at Stowford (1,000 dwellings) and Barthomley (1,000 dwellings) for the reasons set out below.

2.25 The NPPF states that “the supply of new homes can sometimes be best achieved through planning for larger scale development” citing examples such as “new settlements or extensions to existing villages”. Therefore, whilst the NPPF provides a mechanism whereby new settlements may be acceptable this is not a preference to extending existing settlements which we consider is more sustainable and should first be explored before creating new settlements isolated from existing built form.

2.26 The “Focus in UK Planning Policy” is to deliver “urban extensions, rather than new towns” because “as a general rule it is better to add on to the facilities, amenities and infrastructure of an existing town than to start a new one” (Town & Country Planning Association, Best Practice in Urban Extensions and New Settlements, 2007). We support this view, as does the University of

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Development Strategy Consultation Response

Westminster, who state that “urban extensions with proximate connections to existing towns and cities are more likely to achieve sustainable communities and housing growth than new standalone garden cities. They are more likely to have access to employment opportunities and to existing transport and social infrastructure” (Garden Cities, Garden Suburbs and Urban Extensions, 2012).

2.27 In contrast, the new settlements at South East Crewe are isolated and will not link into an existing centre. Their creation will require an entirely new level of infrastructure from transport, power, drainage and services/amenities and for this reason their deliverability is questionable. Clearly harmful landscape impacts will be caused by developing a “sensitive”, “typical Cheshire landscape, characterised by a flat topography” (page 116 of Development Strategy for Jobs and Sustainable Communities).

2.28 For these reasons, sites which link into existing established settlements should be preferred before considering “new settlements”.

2.29 However, this process has not been followed. As section 4 highlights, sites at Peckforton have been discounted by the Local Authority through Policy CS6 despite being sustainable locations for a degree of new growth. We consider these and other sites identified within existing villages and towns are more preferable for development than isolated new settlements.

2.30 If the Authority do not reconsider this part of their preferred strategy there is a real risk that the subsequent Core Strategy will be found unsound at Examination as it will neither be “justified” (i.e. “the most appropriate strategy when considered against the reasonable alternatives”) nor consistent with national policy in terms of sustainable development (NPPF). “Effectiveness” is also likely to be questioned (i.e. deliverability).

Planning for Sustainable Development

Policy CS9

2.31 We generally support the Authority’s active promotion of the NPPF’s “presumption in favour of development” as reflected within policies CS7, CS8 and CS9 to “deliver successful sustainable development and support the growth of vibrant sustainable communities”.

2.32 Policy CS9 “Sustainable Development Principles” proposes a list of distances to different services and amenities which new residential development will be expected to meet. For example, it states that “a post box should be within 500 metres”.

2.33 Whilst we support the spirit of the policy (i.e. to ensure development is within walking distance to amenities and services), the criteria are too stringent, do not acknowledge the variance between sites and settlements and does not allow for a reasonable, common sense approach to delivering sustainable development. For example, just because a proposed dwelling does not have a post box within 500 metres does not mean it would be an unsustainable location.

2.34 This policy, if strictly applied, will not “positively” plan to achieve sustainable development and achieve housing needs which is contrary to Paragraph 182 of the NPPF and could result in the plan being found “unsound”.

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Development Strategy Consultation Response

2.35 A more sensible approach would be to adopt a similar stance to neighbouring Cheshire West and Chester Council who state that a location is sustainable if it is within a mile of local amenities (Supplementary Planning Document: Sustainable Development, July 2008).

Rural Sustainability

2.36 The NPPF outlines that in respect of rural areas planning authorities should “plan housing development to reflect local needs” (Paragraph 54). The NPPF goes on to state at paragraph 55 that “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”.

2.37 The Authority’s strategy does not presently meet this requirement, especially in regards to Peckforton village where despite there being an established need for 80 dwellings (over the next 20 years) market housing is to be restricted through policy C56.

3. Meeting Growth Requirements

3.1 This section assesses the Authority’s strategy for delivering growth.

Development Requirements 3.2 For each settlement the degree of housing and employment growth to be delivered is set out.

3.3 We disagree with the proposed degree of new housing for the identified settlements and consider this needs to be increased for a number of reasons.

3.4 Section 2 highlights that the Authority’s housing need is greater than that presently being planned (i.e. there is a need to deliver between 32,000 and 79,920 dwellings across Cheshire East instead of 27,000). Accordingly this needs to be reflected within the Authority’s strategy, with additional growth directed towards sustainable existing settlements.

3.5 We consider that sites within existing villages have the capacity to help towards delivering this increased growth, albeit through small scale developments. Section 4 sets out a number of sites within Bunbury and Peckforton which are acceptable for development. This also demonstrates that more reasonable and acceptable “alternatives” have not been properly considered by the Authority.

3.6 Overall the level of growth beyond that currently planned for key service centres local service centres and villages needs to be increased in order to meet the Authority’s future housing needs and to deliver an acceptable spatial distribution of new development.

3.7 If the Authority does not action this we consider the subsequently submitted Core Strategy will be found to be “unsound” at Examination as it will not be “positively prepared” (i.e. based on a strategy which seeks to meet development requirements), “justified” (i.e. the most appropriate strategy when considered against the reasonable alternatives) or “consistent with national planning policy” in terms of delivering sustainable development.

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Development Strategy Consultation Response

4. Sites

4.1 To assist the Authority in their decision making process we have considered sites within Bunbury and Peckforton to ensure that “all reasonable alternatives” have been assessed and the “correct sites” chosen. This section establishes which sites should be allocated for development (either within the Core Strategy or Site Allocations DPD) to help meet the Authority’s housing needs and ensure the Local Plan is “sound”.

Bunbury (Sites A – D)

4.2 Sites A-D lie directly adjacent the presently defined settlement boundary of Bunbury which is strategically located between Nantwich and Tarporley (both provide a range of services and amenities).

4.3 In particular sites A, B and D are situated between the two main areas “built” areas of the village. Therefore development at these sites clearly has the capacity to “tie into” and visually complement the existing settlement pattern of Bunbury. The sites are also within walking distance to local services and amenities which includes a Post Office, local shops, restaurants, a church and a doctors surgery.

4.4 Moreover, other than being located within a Conservation Area development in and around Bunbury would be relatively unconstrained as it is not subject to any other environmental designations.

Peckforton (Sites E – G)

4.5 Peckforton is also advantageously located only 3 miles from Tarporley and 7 miles from Nantwich and whilst the village itself does not contain and immediate services and amenities there a number of surrounding villages which do and area within circa 1 mile (i.e. Bunbury, Bulkeley and Burwardsley).

4.6 The NPPF acknowledges that rural settlements are interconnected and so Peckforton’s relationship with neighbouring Bunbury, Bulkeley and Burwardsley should be recognised in accordance with Paragraph 55. This highlights that “housing should be located where it will enhance or maintain the vitality of rural communities, for example where there are groups of smaller settlements, development in one village may support services in a village nearby”.

4.7 Sites E – G are all contained between or directly opposite existing dwellings within Peckforton, thus their development would mainly comprise “infill” or development at the edge of the existing settlement. The sites would help deliver the villages housing needs by delivering houses which sensitively knit into and respect the village’s historic character and form through layout, density and design.

4.8 Conclusion

4.9 This demonstrates that Sites A - D within Bunbury and E – G within Peckforton have the capacity to help the Authority meet their growth needs through the delivery of high quality, managed, small scale growth.

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Development Strategy Consultation Response

5. Overall conclusion

5.1 The capacity and acceptability for development within Cheshire East’s rural villages as well as their growth needs has been overlooked by the Authority.

5.2 We have shown the need for rural settlements growth to be delivered (to meet their growth requirements and comply with the NPPF) as well as demonstrating that some of this need can be acceptably delivered at identified sites within Bunbury and Peckforton.

5.3 By overlooking the needs and benefits of achieving rural growth, this has incorrectly led the Authority to conclude that growth such as new isolated settlements is appropriate and justified.

5.4 To rectify this, we advise that the Authority reconsiders the growth strategy for rural settlements by allowing villages to “at least” achieve their housing needs, and building flexibility into policies to permit small scale sustainable development in villages.

5.5 In addition to increasing the general level of growth proposed and amending the distribution strategy this will help the Authority ensure the Local Plan is deemed “sound” at Examination.

5.6 If this is not undertaken we consider the subsequent Core Strategy will be found unsound on the basis that the plan will not be “justified” (i.e. the most appropriate strategy when considered against the reasonable alternatives), “positively prepared” (i.e. based on a strategy which seeks to meet development requirements) or consistent with “national policy”.

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