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Representations on behalf of: Plant Developments Limited The Orchard, Road, Brereton Heath

CHESHIRE EAST COUNCIL - PRE-SUBMISSION CORE STRATEGY (NOVEMBER 2013)

EPP reference: REPS1-9282-NS-BP

December 2013

Representations on behalf of: Plant Developments Limited The Orchard, Holmes Chapel Road, Brereton Heath East Council - Pre-Submission Core Strategy (November 2013)

1. INTRODUCTION

1.1 Emery Planning Partnership is instructed on behalf of Plant Developments Ltd to make representations to Council’s Pre-Submission Core Strategy, which is currently out for consultation in relation to a site known as The Orchard, Holmes Chapel Road, Brereton Heath.

1.2 We submit that Brereton Heath should be identified in the DDS as a sustainable village/village cluster where appropriate levels of development should be allowed.

1.3 This statement accompanies our overall representations (EPP ref: REPS2-8032-JC-bp).

2. BACKGROUND

Site location and description

2.1 The site is located on the south western side of the A54, Holmes Chapel Road. It comprises two bungalows on the road frontage with three large glass houses and outbuildings to the rear. A site location plan is attached at Appendix EPP1.

Local Plan

2.2 The site is located within the open countryside. The majority of the site lies within the defined settlement of Brereton Heath.

2.3 Policies PS6 and H6 of the adopted Local Plan state that limited development will be permitted within the infill boundary line where it is appropriate to the local character in terms of use, intensity, scale and appearance and does not conflict with the other policies of the local plan.

2.4 The sub-text to Policy H6 states that “limited development is defined as the building of a single or small group of dwellings” . However, no definition is provided for the term “small group”.

Sustainability

2.5 The closest bus stop to the proposed development is located approximately 400 metres from the site on the A54 (Holmes Chapel Road). The bus stops link the site to Holmes Chapel, Congleton, , , , and Altrincham.

2012 Strategic Housing Land Availability Assessment Update

2.6 The site is not currently identified in the SHLAA.

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3. POLICY PG2 – SETTLEMENT HIERARCHY

3.1 As set out in our overall representations, we object to the removal of Sustainable Villages from the Core Strategy.

3.2 In the previous version of the Core Strategy; the Draft Development Strategy (January 2013), policy CS2 identified the following 21 Sustainable Villages: Acton, Alprahram, , Aston, Barbridge, Brereton Green, Brereton Heath, , , , Green, Hough, Mount Pleasant, Mow Cop, , , , Weston, Winterley, and .

3.3 The current consultation document varies from the Draft Development Strategy. The Sustainability Appraisal explains that this category has been replaced by “Other Settlements and Rural Areas”. No justification is included for the removal of this category in the Sustainability Appraisal.

3.4 Paragraph 2.4 of the Housing Background Paper (November 2013) explains that the evidence base does not support the identification of this additional category in the settlement hierarchy and consequently the Sustainable Villages have now been included within the “Other Settlements and Rural Areas”.

3.5 It is unclear what evidence base the Council is referring to when it states that it does not support the identification of Sustainable Villages.

3.6 As discussed below, the “Other Settlements and Rural Areas” are expected to deliver 2,000 new houses between 2010 and 2030. To meet the requirement, the current consultation document suggests that it will be through limited infilling or conversion. We say this change is approach is wholly wrong in planning policy terms and could be fatal to the continued health and vitality of the rural areas. It also represents a complete change of approach to rural planning for the Borough which we say will have, if approved, have a seriously negative effect.

3.7 The previous approach as set out in the DDS was fully endorsed by The Taylor Report and NPPF. We refer to paragraph 4.48 of the Planning Principles document (January 2013), which stated:

“Approximately 30% of Cheshire East’s population live in Local Service Centre (LSCs), Sustainable Villages and rural areas. The provision of additional housing is vital to the creation and maintenance of sustainable communities in rural areas. Further supply is required to address the cost of housing, and to enable newly forming households to remain in their communities. Additional housing can also help to improve the viability of existing or potential local services.”

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3.8 The Council does have a policy base which helpfully informs the need for additional housing. This report, The Cheshire East Rural Housing Guide 2012 contains the results of housing need surveys for affordable housing across the borough. The results concentrate on affordable housing need. This important document has not been referred to in the list of the Council’s core documents for the new Local Plan.

3.9 This report combined with the 2013 SHMA shows an increasing need for homes in the rural areas and not just in the local service centres. To now restrict housing in the sustainable villages to conversions and limited infill would mean little or no opportunity for what is an increasingly aging population to remain in the villages and restrict availability of much needed family homes.

3.10 Brereton Heath either on its own or with Brereton Green and Somerford should be identified in the Core Strategy as a sustainable village/ village cluster.

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4. OPEN COUNTRYSIDE CONSIDERATIONS

4.1 As set out above, the site is in the open countryside, but falls within the Infill Boundary Line. The current policy PS6 in the Congleton Local Plan seeks to restrict development in Brereton Heath to within the Infill Boundary Line. Sites outside of the IBL are not considered suitable for infill development, due to the “loose-knit pattern of development”.

4.2 The current consultation document is not clear on what will happen to those settlements within the open countryside but with IBLs. Paragraph 8.62 of the consultation document states that the open countryside boundaries will be redefined on the proposals map. It is not clear therefore whether:

a) those settlements with IBLs will be excluded from the open countryside designation as a whole (i.e. they become “inset”);

b) whether the IBLs themselves are to be removed; or

c) whether the IBLs will remain and limited development will continue to be directed to within them.

4.3 Further clarification is required on this issue.

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5. BRERETON HEATH’S HOUSING REQUIREMENT

5.1 Our overall representations (EPP ref: REPS2-8032-JC-bp) set out our objections to the Council’s overall housing requirement figure. The Council’s own evidence base demonstrates that the overall housing requirement should be higher than the preferred option.

5.2 Our overall representations also object to the council’s spatial distribution on the basis that the proposed new settlement at East has been included. Notwithstanding this, according to Policy PG6 of the current consultation document, the Council is expecting 2,000 dwellings to be delivered in “other settlements and rural areas” by 2030.

5.3 Table A.5 of the consultation document explains that this will comprise:

Source Dwellings Completions 2010-13 308 Commitments 691 Site Allocations 1000 Total 1999

5.4 In relation to this, we requested a breakdown of the completions and commitments of the figures. This confirmed that the completions include some dwellings at sites such as Havannah Mill (31 dwellings), which we consider to be an extension of Congleton (a Key Service Centre) rather than development in the “rural area”. Further clarification is required from the Council.

5.5 Notwithstanding this, the consultation document relies on 1,000 dwellings being delivered through the site allocations process.

5.6 Of course if the overall housing requirement is increased as a result of the current consultation and/or the distribution is amended so that the “other settlements and rural areas” are expected to accommodate further development due to the redistribution of the requirement, then the 1,000 figure would be increased.

5.7 The site allocations process is due to take place between 2014 and 2015. This would present an opportunity for our client to promote their site through that process.

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6. SUSTAINABILITY CONSIDERATIONS

6.1 We note that draft policy SD2 of the current consultation document seeks to apply a checklist to new residential development in terms of access to services and amenities. On behalf of our clients, we object to this approach for the following reasons:

• Firstly, it does not accord with paragraph 7 of the NPPF, which explains that there are three dimensions to sustainable development (social, economic and environmental). This means that sustainable development does not simply mean applying a checklist approach to sites.

• Secondly, for rural areas, it does not accord with paragraph 55 of the NPPF, which states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It specifically goes on to state: “where there are groups of smaller settlements, development in one village may support services in a village nearby.”

• Thirdly, and related to the above point, it is difficult to see how this approach would deliver the minimum 2,000 dwellings required in the “other settlements and rural areas” as required by draft policy PG6.

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7. SUMMARY AND CONCLUSIONS

7.1 Emery Planning Partnership is instructed by Plant Developments Ltd to make representations to Cheshire East Pre-Submission Core Strategy, which is currently out for consultation, in relation to their land The Orchard, Holmes Chapel Road, Brereton Heath.

7.2 This statement accompanies our overall representations (EPP ref: REPS2-8032-JC-bp).

7.3 Brereton Heath should be identified in the Core Strategy as a settlement where new residential development would be acceptable. This should not be limited to small scale infill development.

7.4 This concludes our representations. Should you wish to discuss, please do not hesitate to contact us.

8. APPENDICES

EPP1. Site location plan

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