Save Danes Moss has had a number of queries about the CEC consultation on the draft Interim Housing Strategy 2025-2028. This is an early step before the start of the Local Plan Strategy consultation.
Therefore to help, we have put together some advice to help if you wanted to participate. Feel free to edit and modify to what fits best with your views.
This needs to be done by 25th February 2025
This is the Cheshire East Council webpage where you can access the consultation:
https://surveys.cheshireeast.gov.uk/s/ HousingStrategy24/
Questions 3, 4, 5, 6, and 7 are of most interest with regard specifically to Danes Moss and Peatland in Cheshire East:
Question 3:
How strongly do you agree or disagree that the evidence base for the national context and challenges covers all the relevant information?
Please select one option only
Question 4:
And, how strongly do you agree or disagree that the draft strategy accurately
summarises the local housing context and challenges within Cheshire East?
Please select one option only
Question 5:
How strongly do you agree or disagree that the priorities identified within the draft
housing strategy are the right areas to focus on?
Please select one option per row only
Question 6:
And, how strongly do you agree or disagree that the details within the action plan will
help achieve each strategic priority?
Please select one option per row only
Question 7:
Are there any other housing issues/challenges which should be prioritised during 2025-2028?
The physical/geographical location of housing development is critically important. Unless this is considered at the strategy stage of policy preparation, the mistakes of the past – where housing has been imposed despite infrastructure restrictions, important habitat concerns, social values etc – will be repeated. This aspect of strategy development is completely absent from the draft Interim Housing Strategy.
Question 8:
If you have any further comments to make on the draft housing strategy, please let us know below:
This consultation is seriously flawed in that merely ticking a particular box for each question does not provide opportunities for explaining the respondent’s opinion, or for adding comment and detail to the issues at stake. This response to Q7 is intended to rectify this defect.
The draft Interim Housing Strategy raises numerous issues and challenges. Our comments on priorities included in the Interim Strategy are set out below, and provide a rationale for our tick-box responses to questions 3-6:
Question 3
Strongly disagree reasons:
- There is ample discussion of the policy landscape but no attempt to consider the geographical and physical context within which housing may be proposed within the borough. This is a gross deficiency in the evidence base that impedes effective analysis and underpins an incomplete interim strategy.
- There is limited, if any, discussion of the private/volume housebuilder’s strategies or priorities for development. Much of the affordable housing provision is tied to the activities of the private sector developers and the evidence base does not reflect this situation.
Question 4
Strongly disagree reasons:
- The draft interim strategy fails to consider existing local circumstances such as social infrastructure (access to transport networks, accessible green space, health and education provision, community facilities etc), and physical characteristics (land use, habitat extent and quality, drainage/hydrology etc).
- The primary focus of the strategy should be about creating, or enhancing, mixed and thriving communities rather than simply regarding numbers and general types of units to be constructed.
- Without consideration of the physical and geographical contexts, the key challenges of climate change and land suitability for housing are not addressed. For example, development on floodplains or areas of flood risk will incur direct health and wellbeing impacts as weather conditions become more extreme, while development on peatlands will release greenhouse gases, destroy carbon sinks, and damage or destroy biodiversity. Strategic consideration of these issues will minimise risks of community objection, reduce future adverse impacts, and expedite schemes in the planning system
- Housing has a profound effect on health and well-being and the strategy should consider proximity of accessible, green open space to potential development sites. These are essential to healthy and vibrant communities, the benefits of which are clearly defined in supplementary guidance to the HM Treasury’s Green Book – https://www.gov.uk/ government/ publications/ enabling-a- natural-capital- approach-enca-guidance/ enabling-a-natural-capital -approach-guidance
- The geographical context should include reference to public transport networks, with no housing development being permitted in areas lacking adequate bus, train, or active travel facilities. This is essential for combatting the impacts of climate chaos, and for people without access to cars, either for economic or health-related reasons.
- The Interim Plan period of 3 years is understandable; however, some actions will need to occur over a longer timeframe. For example, the proposed stock condition survey will require long- term commitments to ensure periodic updates are adequately funded, while cross-reference to preparation of the replacement Local Plan will need longer than the 3-year period of the Interim Plan.
Question 5
Reasons:
The first priority should be a commitment to housing development that enhances existing communities, or creates thriving, well-planned new neighbourhoods. This is essential for long-term sustainability of our towns and villages that does not place intolerable stresses on social and physical infrastructure. It cannot be achieved without a wider evidence base, as set out above. In respect of the strategic priorities set out in the interim strategy, our comments are:
Priority 1:
- Discussion of physical/geographical context is absent and is a significant barrier to an effective strategy
- The aim of increasing the number of affordable homes by 355/year during the plan period appears to be commendable, however this needs to be set in the context of a target for open market housing numbers to provide a complete picture of the situation in Cheshire East
- CEC’s current policy (Local Plan Strategy Policy SC5) is to require 30% of all homes on developments of over 15 houses in Crewe, Macclesfield, and Key Service Centres, and 30% of all homes on developments exceeding 11 houses in Local Service Centres, to be affordable. A target of 355 affordable homes per year therefore suggests construction of around 1,100 to 1,800 open market and affordable houses per year (taking smaller windfall and similar developments into account). This appears to be about 650 to 1,350 houses short of the current government’s target for Cheshire East. The Interim Strategy should clearly address this discrepancy.
- For new developments, a commitment to more rigorous enforcement of the council’s 30% affordable homes policy should be included, with binding “viability assessments” being required prior to granting of planning permission
- A comprehensive, and regularly reviewed, register of empty properties (in both public and private ownership) should be included based on physical identification, stock condition, and policy constraints. Parish councils and community groups could contribute to this process
- Reference to longer-term actions should be included
- A comprehensive and regularly reviewed infrastructure assessment should be undertaken, possibly in conjunction with baseline studies for the replacement Local Plan Strategy.
- Town & parish councils, plus local community groups must be included in collaborative working proposals (p.27). Local community groups in particular, must be included in regeneration proposals for Crewe and Macclesfield.
Priority 2:
- The issues seem well considered and achievable
Priority 3:
- The issues seem well considered and achievable
Priority 4:
- A comprehensive, adequately funded, communications plan is required for energy improvements to private ownership properties, encompassing grant funding, policy context, advice on availability of choice of suppliers and technology, cost savings etc.
- New-build housing should be constructed to the highest standard based on available technology through planning policies
Priority 5:
- The issues seem well considered and achievable
Question 6
Reasons:
Taken literally, Q6 is an incomplete question. The described Actions are probably capable of achieving the strategic priorities contained in the draft strategy, however as set out above, there are significant omissions in the definition of “context”, and a number of elements are missing from Priorities 1 and 4.
We consider that the Interim Strategy should have, as its primary priority, a commitment to creating or enhancing communities. The current draft places too much emphasis on numbers of units and omits any attempt at linking affordable housing targets to private sector intentions.
For these reasons the draft Strategy is unlikely to be fully effective.
