Mix and type of housing in new developments and specialist housing
Question HO 1
Do you agree with the suggested policy approach towards mix and type and specialist housing in new developments, as set out in HO 1 'Mix and type of housing in new developments and specialist housing' above? If not please suggest how it could be amended?
109 comments
| Theme | Summary |
| Evidence-led policy / Housing Needs Assessment | Consistent calls for housing mix, size, tenure and specialist housing policies to be based on a robust, up-to-date Housing Needs Assessment, with many respondents’ reserving final judgement until the evidence is published and requesting settlement-level or sub-area analysis. |
| Flexibility vs overly prescriptive policy | Widespread concern that rigid or fixed percentage requirements for housing mix would undermine viability and delivery. Strong preference for indicative targets, ranges, and explicit flexibility to justify alternative mixes based on site and market factors. |
| Site-specific and locational approach | Strong rejection of a one-size-fits-all borough-wide approach. Respondents emphasise differences between urban, rural, town centre and edge-of-settlement locations, as well as the need to reflect scale, character and constraints of individual sites. |
| Viability and deliverability | Strong emphasis from some respondents that cumulative policy requirements must be viability tested at plan-making stage, with concerns that overly prescriptive housing mix, nationally described space standards (NDSS) or accessibility standards could stall delivery or reduce housing supply. |
| Older persons’ housing and downsizing | Very strong support for increased provision of housing for older people, including downsizing opportunities, retirement housing, extra care and care homes. Emphasis on freeing up family housing and reducing NHS and social care pressures. |
| Specialist housing (extra care, supported living, learning disabilities) | Concerns that specialist housing, particularly extra care, often needs to be freestanding and may not be suitable within standard housing estates. Strong objections to policies that could rule out rural or edge-of-settlement locations. |
| Nationally Described Space Standards (NDSS) | Broad agreement that Nationally Described Space Standards (NDSS) are optional and must be justified by evidence of need, viability and timing. Concerns raised about affordability impacts and loss of customer choice if applied as a blanket requirement. |
| Accessible and wheelchair-user housing | General support for increasing accessible and wheelchair-user housing where evidenced, but opposition to blanket or inflexible requirements. Calls for local assessment, site constraints and transitional arrangements. |
| Affordable housing and key worker provision | Strong support for delivery of affordable housing, including social rent and homes for key workers (particularly NHS staff), and alignment with employment locations and services. |
| Self and custom build housing | Mixed views on self and custom build housing. Support in principle, but strong criticism of current monitoring and objections to mandatory percentages on larger sites without clear evidence of demand. |
| Character, design, density and place-making | Emphasis that housing mix policies should not override settlement character or design quality. Mixed views on density, with some support for compact development in accessible locations and others prioritising green space and parking. |
| Green Belt and spatial strategy | Strong resistance to Green Belt release except in exceptional circumstances, with some suggesting very high affordable housing thresholds or a strict brownfield-first approach. |
Question HO 2
Should the housing mix and type and specialist housing be delivered through a percentage policy approach that sets requirements for each category of housing?
83 comments
| Theme | Summary |
| Support for a percentage-based housing mix approach | A number of respondents support a percentage-based housing mix policy, arguing it provides clarity, consistency and helps secure delivery of smaller, affordable and specialist homes where developers might otherwise default to larger market dwellings. |
| Opposition to rigid or prescriptive percentage requirements | The dominant theme is opposition to fixed or rigid percentage requirements for housing mix, type or tenure. Many respondents argue this would undermine flexibility, viability and deliverability, particularly across different settlement types and site circumstances. |
| Preference for indicative targets and flexibility | A large number of respondents support the use of indicative ranges or targets informed by the Housing Needs Assessment, rather than mandatory percentages, allowing scope for site-specific negotiation based on viability, market demand and local character. |
| Evidence-led approach and Housing Needs Assessment | A large number of respondents emphasise that any housing mix or percentage requirements must be underpinned by a robust, up-to-date Housing Needs Assessment and regularly reviewed to reflect changing demographic and market conditions. |
| Older persons’ and specialist housing provision | Some detailed representations emphasise the need for a distinct and flexible approach to older persons’ housing and specialist accommodation, including extra care and retirement housing, arguing this is better achieved through allocations or standalone policies rather than generic percentage splits. |
| Site size thresholds and proportionality | Three respondents argue that any housing mix requirements should only apply above certain development size thresholds, with greater flexibility for small and medium sites to avoid constraining SME builders and rural delivery. |
| Locational differences and rural considerations | Some respondents highlight differences between urban and rural areas, stressing that rural settlements often have specific needs (e.g. bungalows for ageing populations) which a fixed borough-wide percentage approach would not reflect. |
| Viability and cumulative policy burden | Many respondents raise concerns that rigid housing mix percentages, when combined with affordable housing, space standards, accessibility requirements, biodiversity net gain and CIL, could render schemes unviable and stall housing delivery. |
| Green Belt and affordable housing expectations | Some respondents highlight that where Green Belt release occurs, there should be higher affordable housing delivery, while also noting that national policy allows flexibility where viability constraints arise. |
| Self-build, custom build and First Homes | A number of representations object to imposing percentage requirements for self-build, custom build or First Homes, arguing that demand evidence is weak and these tenures are better delivered on specifically allocated sites. |
Question HO 3
Do you agree with the approach to student accommodation, and should additional consideration be given to the University of Liverpool Leahurst campus?
22 comments
| Theme | Summary |
| General support for the approach to student accommodation | There is broad support for the overall policy approach to student accommodation, with many respondents answering “yes” or “agree” to Question HO3, subject to appropriate safeguards and evidence. |
| Support for specialist student accommodation at the Leahurst campus | A strong and recurring theme is support for encouraging specialist student accommodation on the University of Liverpool’s Leahurst campus, with respondents viewing this as a logical way to contain student housing within university land and reduce pressure on surrounding communities. |
| Conditional support – evidence of need and infrastructure capacity | Several respondents support student accommodation only where robust evidence of need is demonstrated and where local infrastructure, transport and services can cope, warning against oversupply and unintended impacts on local housing markets. |
| Rural character and landscape sensitivity of Leahurst | Respondents emphasise that Leahurst is a rural campus and should be treated differently from urban university locations. Any student accommodation should respect countryside character, avoid encroachment into sensitive landscapes and be carefully designed. |
| Location constraints and opposition to development south and west of Chester High Road | One specific objection is raised to any student accommodation being located south and west of Chester High Road, citing adverse impacts on Neston, Parkgate and surrounding areas. |
| Impact of students on local housing markets | One detailed representation discusses the extent to which veterinary students currently occupy local housing, arguing that impacts are often overstated and influenced more by low private rental supply and demographic factors than by student demand alone. |
| Balanced communities and relationship with local housing needs | Some respondents caution that student housing should not override local housing needs or displace land required for affordable housing, stressing the importance of maintaining balanced communities. |
| Design, sustainability and affordability of student accommodation | One respondent highlight the need for student accommodation to be high quality, energy efficient and genuinely affordable, noting evidence that students are increasingly priced out of accommodation. |
| Planning tools and management measures (Article 4, Housing MO licensing) | One response calls for wider planning and management tools, such as Article 4 Directions and selective HMO licensing within a defined radius of Leahurst, alongside development of university-owned land to mitigate impacts. |
Delivering affordable housing
Question HO 4
Do you agree with the suggested policy approach towards delivering affordable housing, as set out in HO 2 'Delivering affordable housing' above? If not please suggest how it could be amended?
107 comments
| Theme | Summary |
| General support for affordable housing policy | A substantial number of respondents support the overall approach to delivering affordable housing across the borough, recognising affordability pressures and the need for policy intervention. |
| Need for viability testing and flexibility | This is the dominant theme. Many respondents stress that affordable housing requirements must be viability tested, allow site-specific flexibility, and avoid undermining housing delivery when combined with CIL, infrastructure and sustainability requirements. |
| Green Belt development and affordable housing percentages | Views are strongly divided. Some support high or even 100% affordable housing requirements on Green Belt sites, while many strongly object to fixed 50% requirements unless viability tested, particularly on previously developed Green Belt land. |
| Thresholds for affordable housing (10 units / rural 3 units) | Many respondents object to applying affordable housing requirements to very small schemes, particularly in rural areas, citing lack of Registered Provider interest and impacts on SMEs (Small and Medium-sized Enterprises) builder viability. |
| Affordable housing tenure mix and definition of “affordable” | Respondents emphasise the need to clarify what “affordable” means, with calls for greater emphasis on social rent rather than affordable rent or shared ownership, and for affordability to be secured in perpetuity. |
| Older persons’ and specialist housing exemption from affordable housing | A significant body of representations argue that older persons’, extra-care and specialist housing should be exempt from affordable housing requirements due to distinct viability characteristics, referencing national practice and adopted plans elsewhere. |
| Design, integration and pepper-potting of affordable housing | Strong support exists for affordable homes to be indistinguishable from market housing, well designed, and pepper-potted across sites, while recognising practical tensions with Registered Provider requirements. |
| Location, distribution and balance between communities | Two respondents raise concerns that too much affordable housing is being concentrated in certain settlements and argue for a more even distribution across the borough to maintain balanced communities. |
| Sustainability, energy efficiency and lifetime costs | A smaller number of respondents argue that affordable housing policy should consider lifetime costs, energy efficiency and long-term affordability rather than just upfront delivery numbers. |
| Infrastructure, services and cumulative impacts | Several respondents highlight the need to ensure affordable housing delivery is integrated with provision of GP surgeries, schools, transport and utilities infrastructure. |
| Neutral or no comment responses | A small number of responses provide no comments or simply state yes/no without further detail. |
Question HO 5
Do you have any views on thresholds for affordable housing in relation to applying a lower threshold for designated rural areas and what approach could be taken to parts of the borough not subject to the designation?
48 comments
| Theme | Summary |
| Support for lower affordable housing thresholds in rural areas | A large number of respondents support applying a lower affordable housing threshold in designated rural areas, typically 3 or more dwellings, citing high rural house prices, limited supply, downsizing constraints and the need to improve affordability within villages. |
| Objection to very low rural thresholds (3 dwellings) | A significant body of respondents object to a 3-dwelling rural threshold, arguing it is inconsistent with national policy, harms viability, discourages SMEs (Small and Medium-sized Enterprises) builders, and results in poor outcomes such as oversized market homes or stalled development. |
| Consistency with the National Planning Policy Framework (NPPF) | Several respondents stress that affordable housing thresholds should align with national policy, particularly National Planning Policy Framework paragraph 65, which allows lower thresholds in designated rural areas but typically references 5 units or fewer rather than a blanket 3-unit trigger. |
| Need for viability testing and policy flexibility | This is a recurring theme. Respondents argue that any lower rural threshold must be supported by robust evidence and include flexibility where viability is an issue, particularly on small sites or where Registered Providers are unwilling to take single units. |
| Concerns about management of single affordable units in rural areas | Registered Providers and landowners highlight that isolated affordable units on very small rural schemes are difficult and costly to manage, supporting higher thresholds or alternative delivery mechanisms such as off-site provision or clustering. |
| Rural housing need, downsizing and demographic pressures | Many representations emphasise strong rural housing need, particularly for smaller homes, downsizing options and affordable units for local people, arguing that without lower thresholds rural communities become less sustainable. |
| Green Belt and higher affordable housing expectations | Some respondents argue that where Green Belt land is released, higher proportions of affordable housing should be required regardless of scheme size, with suggestions ranging from 50% to 70% affordable housing. |
| Local connection and tenure mix | Calls are made for affordable housing delivered under lower thresholds to meet local needs, apply local connection criteria, and provide a balanced tenure mix including social rent, affordable rent and affordable home ownership. |
| Concerns about perception and market impact | One respondent raises concerns that high proportions of affordable housing may deter buyers of market homes, potentially affecting scheme viability or marketability. |
| Support for borough-wide consistency | Two respondents argue for a single borough-wide threshold, with flexibility applied only where clear evidence of unmet affordable housing need exists, rather than a blanket rural-lower threshold. |
Proposals for residential development
Question HO 6
Do you agree with the suggested policy approach for residential development proposals, as set out in HO 3 'Proposals for residential development' above? If not please suggest how it could be amended?
42 comments
| Theme | Summary |
| General support for the proposed policy approach | A large proportion of respondents support the suggested policy approach for residential development proposals, often answering “yes” or “agree”, including broad support for retaining existing Local Plan (Part Two) policies in principle. |
| Retention of Local Plan policy DM19 and related policies (DM21 / DM22) | Many respondents support retaining Local Plan policy DM19 (and related policies DM21 and DM22) as the core framework for assessing residential development proposals, subject to updates to reflect current national policy. |
| Alignment with the National Planning Policy Framework and need for policy updates | A recurring theme is the need to review and update DM19 to ensure full alignment with the latest National Planning Policy Framework, particularly in relation to isolated dwellings in the countryside, rural housing tests, and avoiding duplication of national policy. |
| Countryside protection and resistance to urbanisation | Strong support is expressed for retaining strict controls on residential development in the countryside, with repeated references to preventing creeping urbanisation, suburbanisation of villages, and inappropriate encroachment beyond settlement boundaries. |
| Green Belt protection and limited support for release | Many respondents stress that Green Belt land should remain protected, with some stating support for residential development only where no Green Belt is lost, while others call for careful alignment with national Green Belt policy. |
| Garden land, backland and infill development | A strong and consistent theme is opposition to harmful garden land, backland and piecemeal infill development, with calls for stronger wording to protect character, settlement form, biodiversity and amenity. |
| Role of Neighbourhood Plans and local distinctiveness | Two representations emphasise that residential development should comply with adopted Neighbourhood Plans, design codes and evidence bases, and that local distinctiveness and settlement identity should be given significant weight. |
| Houses in Multiple Occupation and restriction to urban areas | One respondent argues that Houses in Multiple Occupation should be limited to urban areas only, with rural villages and smaller settlements protected through stricter policy controls or Article 4 Directions. |
| Need for flexibility in edge-of-settlement and sustainable locations | One respondent seeks greater flexibility where sites are adjacent to settlements or supported by local communities, arguing that rigid countryside policies may prevent sustainable development meeting local housing needs. |
| Grey Belt and emerging national policy concepts | Some respondents request explicit reference to the emerging concept of “grey belt” land within Green Belt policy, to provide clarity and align local policy with evolving national guidance. |
| Clarity, certainty and policy wording | Some respondents criticise the policy approach as vague or overly complex, arguing that ambiguity increases uncertainty and wastes resources for both applicants and decision-makers. |
| Transport, accessibility and sustainable travel | One respondent highlights the importance of ensuring residential development supports sustainable travel choices and reduces reliance on private cars. |
| Heritage, character and historic environment | Support is expressed for ensuring residential development conserves and enhances the historic environment, heritage assets and their settings, reinforcing character and identity of places. |
Question HO 7
Are Local Plan (Part Two) policies DM 19, DM 21 and DM 22 working effectively; remain relevant; or are all issues covered by current national policy and guidance?
35 comments
| Theme | Summary |
| General support for retaining countryside and Green Belt policies | A significant number of respondents support retaining Local Plan (Part Two) policies (DM19, DM21 and DM22), citing their role in protecting rural character, preventing sprawl and supporting a plan-led approach. |
| Policies should be strengthened to resist inappropriate development | Two respondents support the policies but argue they should be strengthened to prevent piecemeal Green Belt erosion, speculative development and backland or garden grabbing that communities do not support. |
| Concerns that policies are overly restrictive or flawed | A substantial body of respondents argue that the existing policies are too restrictive, poorly drafted or used defensively to block reasonable development, particularly in rural areas and the countryside. |
| Policy DM19 – previously developed land and infill | Strong criticism is directed at Policy DM19 for applying urban-style requirements (public transport, walking distances, lighting) to rural previously developed land, which respondents argue is unrealistic and inconsistent with the National Planning Policy Framework approach to infill and redevelopment. |
| Policy DM21 – extensions and replacement dwellings | Several respondents argue that limits on extensions and replacement dwellings are unjustified, particularly the 10% allowance in the Green Belt, and should be increased to align with allowances outside the Green Belt (e.g. 30–40%). |
| Policy DM22 – conversion of rural buildings | A very strong theme is objection to the requirement that buildings must be redundant or disused before conversion in the open countryside. Respondents argue this is more restrictive than national Green Belt policy and unjustified. |
| Alignment with national policy (National Planning Policy Framework) | Many representations argue that DM19, DM21 and DM22 are not fully aligned with the National Planning Policy Framework, particularly in relation to Green Belt redevelopment, infilling in villages, replacement dwellings and conversion of buildings in continuing use. |
| Avoiding duplication with strategic policies | One respondent cautions against duplicating strategic policies from Local Plan Part One and suggest that DM19 principles should be absorbed into other policies rather than repeated. |
| Affordable housing distribution concerns | One respondent raises concerns about the concentration of affordable housing in particular villages and suggests a more proportionate distribution across communities. |
Question HO 8
Within this policy approach (or elsewhere) should the new Local Plan set out more detail on what development is appropriate in the Green Belt, with respect to, for example, house extensions; what is small scale/subordinate (not increasing size of a dwelling by more than 30%) etc?
37 comments
| Theme | Summary |
| Need for clearer Green Belt policy and definitions | A dominant theme is the need for clearer, more detailed Local Plan guidance on what constitutes appropriate development in the Green Belt. Respondents seek clearer definitions of terms such as “small-scale”, “subordinate” and emerging concepts such as “Grey Belt” to improve consistency and certainty in decision-making. |
| Limits on extensions to dwellings (commonly 30%) | Very strong support is expressed for setting a clear numerical limit on extensions to dwellings in the Green Belt, most commonly cited as a maximum 30% increase in floorspace, to prevent incremental erosion of openness and character. |
| Preventing cumulative enlargement and “creeping suburbanisation” | Many respondents raise concern about cumulative extensions and replacement dwellings leading to “creeping suburbanisation” of the Green Belt. Calls are made to prevent repeated extensions and to close loopholes where replacement dwellings become significantly larger than the originals. |
| Replacement dwellings becoming oversized new builds | Some objections are raised to existing dwellings being demolished and replaced with much larger houses in the Green Belt. Respondents argue that clearer and tighter controls are needed to prevent replacement dwellings undermining openness. |
| Protection of landscape, views, heritage and village character | Respondents consistently stress that Green Belt development should protect landscape character, important views, heritage assets and the identity of villages, with concerns that poorly controlled extensions are harming character. |
| Enforcement and perceived abuse of the system | One Parish Council express concern that Green Belt policies are being abused and not adequately enforced, leading to inappropriate development being approved or retained. |
| Support for land-efficient and low-impact design solutions | One respondent supports recognising land-efficient design solutions, such as use of roof space, as a way to meet housing needs while minimising land take and visual impact in the Green Belt. |
| Flexibility for special circumstances (e.g. disability adaptations) | One respondent supports limits in principle but stress the need for flexibility in non-standard cases, such as adapting homes for wheelchair users or specific accessibility needs. |
| Concerns about imposing fixed percentages | One respondent argues that a fixed percentage limit (e.g. 30%) should be treated as a trigger for scrutiny rather than an absolute rule, with greater emphasis on proportionality and fit within the community. |
| View that national policy (National Planning Policy Framework) is sufficient | Several respondents object to additional local Green Belt controls, arguing that the National Planning Policy Framework already provides adequate guidance and that the same approach should apply to all dwellings in the countryside and Green Belt. |
| Strategic Green Belt release and sustainable locations | A small number of representations, primarily from developers, support clearer Green Belt guidance but emphasise that the Plan should still allow for strategic and sustainable Green Belt release where exceptional circumstances are demonstrated. |
| Opposition to building in the Green Belt | Some respondents state a clear opposition to any development in the Green Belt, regardless of form, and support maintaining its permanence. |
| Renewable energy and sustainability requirements | One respondent suggests that new housing, including in the Green Belt, should be required to incorporate renewable energy measures such as solar Photo Voltaic and battery storage. |
| General support / agreement with proposed approach | A number of respondents simply state agreement with the principle of setting clearer limits on Green Belt development without further detailed comment. |
Question HO 9
Are there any local/borough specific issues e.g. intensification of garden development, infill or backland development, change of use of garages to residential, that justify additional/continuation of policy?
20 comments
| Theme | Summary |
| Strong support for protecting character and identity of places | Two respondents support policies that seek to conserve and enhance local character, identity and the historic environment, emphasising that cumulative small-scale development can erode settlement form and sense of place if not tightly controlled. |
| Backland development and intensification of gardens | This is the dominant theme. A number of respondents express concern about backland development and intensification of garden land, citing harm to character, overdevelopment, loss of green space, biodiversity impacts and cumulative erosion of amenity. |
| Front garden development and surface water drainage | One respondent highlights that front garden development, while not always classified as backland, can have similar impacts, including visual harm and increased surface water drainage and flood risk, and should be assessed in the same way. |
| Need for clearer definitions of infill and backland development | One respondent notes that “infill” is inconsistently defined and applied, leading to uncertainty and dispute. Calls are made for clearer definitions of infill, backland and acceptable forms of intensification. |
| Local density, settlement character and Neighbourhood Plans | Three representations stress that infill, garden and backland development should respect local density, character and any made Neighbourhood Plans, particularly in rural settlements where impacts can be more pronounced. |
| Opposition to garden grabbing and speculative development | Opposition is expressed to “garden grabbing” and speculative subdivision of plots, with references to past national reforms and evidence that gardens contribute to biodiversity, wellbeing and climate resilience. |
| Change of use and conversion of garages | Mixed views are expressed on garage conversions. Some respondents identify garage conversions as contributing to overdevelopment, parking stress and loss of amenity, while others argue that blanket restrictions on conversion of ancillary buildings are overly prescriptive and should be removed. |
| Objection to blanket restriction on conversion of ancillary buildings | One detailed representation argues that prohibiting conversion of buildings originally ancillary to dwellings (e.g. garages) is overly restrictive, counterproductive and unnecessary given the ability to assess proposals on a case-by-case basis. |
| Parking, amenity and cumulative impacts | Concerns are raised that garden development and garage conversions can lead to loss of parking, overcrowding, and cumulative harm to neighbourhood amenity, even where individual schemes appear modest. |
| Rural settlements particularly sensitive to intensification | One respondent emphasises that rural settlements are especially vulnerable to harm from infill, backland and garden development due to their scale, layout and landscape setting. |
| Parish Council view | Respondes from Parish Councils indicate either support for continued controls or no specific comment, reflecting differing local circumstances. |
| Support for continuation of existing policy approach | A number of respondents state that this area is already well managed under existing policy and see little need for significant change, supporting continuation of current controls. |
Question HO 10
Should living-over shops be included in a new/amended policy?
18 comments
| Theme | Summary |
| General support for “living over the shop” / residential use in centres | Strong overall support for including a policy to encourage residential use of upper floors in town, district and local centres. Respondents highlight benefits including increased housing supply, town centre vitality, regeneration, and more efficient use of existing buildings and land. |
| Town centre vitality, regeneration and sustainability benefits | Respondents emphasise that living-over-shops can help revitalise town centres, increase footfall, support local services, and reduce pressure for greenfield development. Concentrating housing in centres is viewed as a sustainable and compact form of development. |
| Design, amenity, safety and heritage considerations | Support is frequently qualified by the need for good design, protection of residential amenity, safe access arrangements, and respect for heritage assets. Several respondents stress that residential use should not compromise the function or appearance of historic town centres. |
| Protection of active ground-floor uses | Support for policies that retain active retail, commercial or community uses at ground level, with residential development focused on upper floors so as not to undermine the vitality and viability of primary shopping frontages. |
| Policy clarity and consistency with mixed-use development | One respondent states that living-over-shops should be treated as a form of mixed-use development, subject to the same design and amenity considerations, rather than requiring a fundamentally different policy approach. |
Essential rural workers dwellings
Question HO 11
Do you agree with the suggested policy approach towards essential rural workers dwellings, as set out in HO 4 'Essential rural workers dwellings' above? If not please suggest how it could be amended?
25 comments
| Theme | Summary |
| General support for essential rural workers dwellings policy | The majority of respondents support the proposed approach to essential rural workers dwellings, including retention of Local Plan policy DM25 or its equivalent, and agree with the principle of allowing such dwellings where a functional need is demonstrated. |
| Safeguards, size limits and prevention of abuse | Strong support for retaining and strengthening safeguards to prevent essential rural workers dwellings becoming over-sized or drifting into unrestricted market or luxury countryside housing. Respondents emphasise size controls linked to functional need. |
| Tying dwellings to rural or agricultural use | Some respondents stress the importance of legal mechanisms, such as planning conditions or legal agreements, to ensure dwellings remain tied to land-based or rural businesses and continue to serve an essential rural worker need. |
| Use of dwellings if rural need ceases / affordable housing | Mixed views are expressed on the requirement that dwellings revert to affordable housing if the rural worker need ceases. Some support this approach, while others suggest alternative rural occupancy or local needs use before conversion to affordable housing. |
| Affordability and rent levels | Specific comment raises concerns about affordability, including that any subsequent affordable housing use should be genuinely affordable, with preference expressed for Local Housing Allowance (LHA) rent rather than affordable rent. |
| Environmental and water quality considerations | Natural England highlights the need for careful consideration of foul and surface water drainage, particularly in sensitive catchments, and recommends clear requirements for design, treatment and mitigation to avoid harm to designated sites. |
| Home working and wider rural sustainability | One response suggests broadening the policy’s perspective to recognise home working as supporting rural communities, local economies and sustainability objectives. |
| Living over shops / town centre comments (out of scope) | One representation comments on living-over-shops and town centre regeneration, which relates primarily to HO10 rather than essential rural workers dwellings and is not directly relevant to HO11. |
Question HO 12
How can it be ensured that if the use ceases the property can meet affordable housing needs?
15 comments
| Theme | Summary |
| Use of covenants, conditions and legal agreements | Strong and repeated support for the use of planning conditions, restrictive covenants and/or Section 106 agreements to control the future use of rural workers dwellings and ensure policy objectives are secured in perpetuity. |
| Retention of rural worker occupancy / prevention of open market sale | Respondents emphasise that rural workers dwellings should remain tied to rural or agricultural occupancy and must not be allowed to be sold on the open market, as this would undermine the original justification for development in the countryside. |
| Reversion to affordable or social housing if rural need ceases | Strong support for a requirement that, if the rural worker need ceases, the dwelling should automatically transfer into the affordable or social housing stock, rather than becoming an unrestricted market dwelling. |
| Management by housing associations or registers | Two respondents suggest that dwellings should be placed under the management of a local housing association or tied to affordable housing registers to ensure proper allocation, long-term affordability and local connection. |
| Marketing tests before removal of restrictions | One respondent supports requiring robust marketing tests (often suggested as at least 12 months at a discounted value reflecting the occupancy restriction) before any relaxation or removal of rural worker conditions is considered. |
| Alternative financial contributions | A minority of respondents propose that, where continued restriction is not possible, a lump sum or annual financial contribution should be paid to the Council to fund alternative affordable housing provision elsewhere. |
| Environmental and wider policy considerations | One response raises broader concerns including ecological impacts, avoidance of speculative commuter housing, and alignment with national policy and manifesto commitments on rural and affordable housing. |
Question HO 13
Would it be useful for elements of the Council’s Rural Worker Dwellings - Advice Note to be added to the policy approach? Please specify which elements?
11 comments
| Theme | Summary |
| Support for incorporating Rural Worker Dwellings Advice Note into policy | The majority of respondents support incorporating elements, or the entirety, of the Council’s Rural Worker Dwellings – Advice Note directly into Policy HO13 to provide clarity, certainty and stronger development management control. |
| Functional and financial need tests | Strong support for embedding functional and financial tests within the policy to demonstrate genuine need for on-site presence, ensure business viability, and avoid speculative or unjustified applications. |
| Dwelling size limits and proportionality | Some respondents support explicit size limits to ensure dwellings remain proportionate to the needs of the rural enterprise, with specific reference to a maximum floorspace of around 106m². |
| Occupancy restrictions and tying dwellings to enterprises | Strong emphasis on clear and robust occupancy conditions to ensure dwellings remain tied to agricultural, forestry or rural enterprises in perpetuity, preventing loss to the open market. |
| Temporary permissions and new enterprises | One respondent supports a staged approach whereby new or unproven enterprises are required to demonstrate need through temporary or mobile accommodation for a defined period before permanent dwellings are permitted. |
| Retention and referencing of the Advice Note | Two respondents stress that, at a minimum, the Rural Worker Dwellings Advice Note should be retained and explicitly referenced within the policy to avoid ambiguity and weaken control. |
| Neutral or no comment responses | A number of respondents either made no comment, stated they did not know, or indicated that they had no observations to make on the proposed approach. |
| Objection or lack of support | One respondent indicated that they did not support the proposal, without providing further detailed reasoning. |
Community-led housing
Question HO 14
If a policy for community-led housing is required, what should it include, and do you agree that the Local Plan should not increase the maximum size limit for these developments as set out in national guidance?
25 comments
| Theme | Summary |
| Need for a dedicated community-led housing policy | Some respondents support the inclusion of a specific policy for community-led housing, recognising its potential to deliver locally supported, affordable, and design-led housing that responds directly to identified local needs. |
| Scale of development and national size limits | Strongly divergent views are expressed on whether national size limits (1 ha or 5% of settlement size) should be retained. Some respondents argue limits must remain to protect settlement character and affordability, while others seek flexibility to enable viable delivery and community infrastructure. |
| Flexibility to exceed size limits where justified | Some respondents consider that strict adherence to national thresholds may prevent schemes from being economically viable or delivering wider community benefits, and therefore support flexibility to allow larger schemes where robust local evidence exists. |
| Local housing need and Local Connection criteria | There is strong emphasis on ensuring community-led housing meets evidenced local housing needs only, with robust Local Connection criteria to prioritise people with demonstrable links to the parish or settlement. |
| Location, site selection and environmental constraints | Respondents stress that community-led housing should be located on suitable, sustainable sites, prioritising brownfield land or sites close to existing services, and avoiding sensitive landscapes, Green Belt and biodiversity assets. |
| Design quality, sustainability and accessibility | Support is expressed for community-led schemes to be design-led, energy-efficient and accessible, incorporating low-carbon construction, good layouts, and safe management of traffic and parking impacts. |
| Role of Parish and Town Councils | Some respondents emphasise that Parish and Town Councils should have an equal and meaningful role in determining the size, location and design of community-led housing schemes. |
| Viability, delivery and subsidy mechanisms | Some respondents highlight the importance of economic viability and suggest allowing limited open market housing within community-led schemes to cross-subsidise affordable housing and wider community benefits. |
Rural exception sites
Question HO 15
Do you agree with the suggested policy approach towards rural exception sites, as set out in HO 5 'Rural exception sites' above? If not, please suggest how it could be amended?
48 comments
| Theme | Summary |
| General support for rural exception sites policy | A significant proportion of respondents support the principle of a rural exception sites policy to help meet affordable housing needs in rural areas, subject to appropriate safeguards and local control. |
| Application to settlements and spatial scope | Two respondents argue the policy should apply only to smaller rural settlements and not to key service centres, while others seek clarity on how rural exception sites are defined if settlement boundaries are removed. |
| Local housing need versus wider Borough need | Divergent views are expressed on whether rural exception sites should meet strictly local needs or also contribute to wider Borough affordable housing needs, with several respondents citing flexibility encouraged by national policy. |
| Scale, proportionality and character | Strong emphasis on schemes being small-scale, modest, edge-of-settlement, and in keeping with the character of the host settlement, with some respondents seeking clearer guidance on scale. |
| Role of Parish and Neighbourhood Plans | Many respondents stress the importance of Parish Councils and Neighbourhood Plans leading or strongly influencing the identification of need, site selection and assessment, though others caution against placing overly onerous responsibilities on parishes. |
| Independent housing needs assessments | Mixed views are expressed on the requirement for independent local housing needs assessments, with some supporting independence to avoid developer bias and others citing cost and practicality concerns. |
| Affordable housing definition and perpetuity | Respondents emphasise that homes delivered should be genuinely affordable, often referencing Local Housing Allowance levels, and that affordability should be secured in perpetuity to prevent market capture. |
| Market housing element to support delivery | Two representations support allowing a limited amount of market housing within rural exception sites where this is necessary to cross-subsidise affordable housing delivery, in line with national policy. |
| Green Belt and sensitive locations | Concern is expressed about rural exception sites being delivered in the Green Belt or environmentally sensitive locations, with calls to explicitly exclude such areas, including ancient woodland and flood-prone land. |
| Land ownership and potential abuse of policy | One respondent suggests introducing a minimum land ownership period to reduce the risk of land speculation, profiteering or abuse of the rural exception policy. |
| Mineral safeguarding considerations | One response requests explicit reference to Mineral Safeguarding Areas to avoid sterilisation of mineral resources through rural exception housing development. |
| Opposition or lack of support | One respondent does not support the policy or express significant reservations. |
Question HO 16
Should the policy approach towards rural exception sites continue to apply to all identified smaller settlements or just those in more remote areas of the borough?
38 comments
| Theme | Summary |
| Apply rural exception sites to all smaller settlements | The dominant view is that the rural exception sites policy should continue to apply to all identified smaller settlements, not just remote areas, to ensure affordable housing delivery where development opportunities are otherwise constrained. |
| Restrict rural exception sites to remote settlements only | A minority of respondents argue that rural exception sites should be limited to the most remote rural settlements, contending that settlements closer to urban areas already have better access to housing opportunities. |
| Green Belt constraints and limited development opportunities | Two respondents emphasise that many settlements are tightly constrained by Green Belt designations, limiting housing delivery and increasing the importance of rural exception sites as a mechanism to meet local affordable housing needs. |
| Affordable housing need across the borough | Respondents highlight widespread affordability pressures across the borough and argue that restricting rural exception sites to remote areas would unnecessarily exclude communities with clear unmet affordable housing needs. |
| Settlement size thresholds and definitions | Some respondents propose defining eligibility by settlement size (e.g. settlements of 5,000 people or fewer), while others argue the policy should apply regardless of settlement size. |
| Inclusion of Local Service Centres | Two representations state that rural exception sites should apply to Local Service Centres as well as smaller settlements, reflecting their role in meeting local housing needs. |
| Concern about undermining settlement strategy or Neighbourhood Plans | One respondent cautions that applying rural exception sites to larger or less remote settlements could undermine the settlement hierarchy, Green Belt purposes or adopted Neighbourhood Plans, particularly where housing opportunities are already identified. |
| Policy clarity and criteria-based approach | One response supports limiting rural exception sites to cases where local needs cannot be met within or adjacent to settlement boundaries, and seeks clarification that peripheral sites should be considered before exceptions are permitted. |
| Parish Council position | One Parish Council explicitly supports restricting rural exception sites to remote areas only. |
Question HO 17
Should market housing still be allowed through the policy on rural exception schemes?
34 comments
| Theme | Summary |
| Support for allowing market housing to enable delivery | A large proportion of respondents support allowing a limited amount of market housing on rural exception sites where it is necessary to cross-subsidise affordable housing delivery. This is seen as essential to viability, private sector involvement and ensuring schemes come forward. |
| Alignment with national policy (National Planning Policy Framework) | Numerous respondents explicitly reference national policy support for allowing market housing on rural exception sites where required for viability, citing consistency with the National Planning Policy Framework approach. |
| Viability and cross-subsidy evidence | Strong emphasis is placed on the need for robust viability evidence to justify any market housing, with many respondents stressing that purely affordable schemes are often undeliverable without cross-subsidy. |
| Capping and limiting market housing proportion | While supportive in principle, many respondents argue that market housing should be strictly limited, capped at a low proportion, and permitted only where demonstrably essential to enable affordable housing delivery. |
| Opposition to market housing on rural exception sites | A number of respondents object to allowing any market housing, arguing it would undermine the purpose of rural exception sites, encourage speculative development and reduce affordable housing delivery, particularly in the Green Belt. |
| Concerns about speculative development and policy abuse | Several respondents warn that allowing market housing risks creating a loophole for speculative developers unless tightly controlled, with calls for strong safeguards and enforcement. |
| Mixed communities and social integration | One supporter highlights that mixed-tenure schemes can create more balanced, integrated communities and avoid segregation or stigma associated with wholly affordable housing developments. |
| Size, design and restrictions on market homes | Some respondents suggest that any market housing should be modest in size and design, with restrictions on extensions to prevent loss of affordability over time, particularly for smaller starter homes. |
| Green Belt and environmental sensitivity | Concern is expressed about rural exception sites with market housing being used to justify development in the Green Belt or environmentally sensitive locations. |
| Requests for further evidence or clarification | One respondent requests additional evidence on the pros and cons of allowing market housing on rural exception sites before a firm policy position is taken. |
Houses in Multiple Occupation
Question HO 18
Do you agree with the suggested policy approach towards Houses in Multiple Occupation, as set out in HO 6 'Houses in Multiple Occupation' above? If not please suggest how it could be amended?
25 comments
| Theme | Summary |
| General support for Houses in Multiple Occupation policy and retention of controls | A large proportion of respondents support the proposed approach to Houses in Multiple Occupation, including retention of existing policy controls (e.g. Local Plan policies DM28 / HO6), recognising the role Houses in Multiple Occupation play in meeting housing needs while requiring careful management. |
| Preventing over-concentration and protecting community balance | The dominant theme is the need to prevent over-concentration of Houses in Multiple Occupation to avoid destabilising communities, creating transient populations and undermining residential character. Many respondents support concentration thresholds and separation distances. |
| Urban focus and resistance to rural Houses in Multiple Occupation | Views are expressed that Houses in Multiple Occupation should be focused in urban areas only, with resistance to Houses in Multiple Occupation in villages and smaller rural settlements. Some respondents call for Article 4 Directions in rural areas to restrict further Houses in Multiple Occupation development. |
| Local needs, local connection and use for local people | Two respondents argue that Houses in Multiple Occupation should primarily meet the needs of people already living or working in the area, including supported living, rather than attracting residents with no local connection. |
| Standards of accommodation, management and maintenance | There is strong emphasis on the need for higher standards of accommodation, effective management, and ongoing maintenance of Houses in Multiple Occupation, with particular focus on avoiding poor conditions that negatively impact both occupants and neighbours. |
| Waste, parking and amenity impacts | Many respondents raise concerns about waste storage, recycling provision, bicycle storage, parking pressure and general amenity impacts associated with Houses in Multiple Occupation, especially in areas with existing high concentrations. |
| Licensing, monitoring and enforcement | Two respondents stress the importance of linking planning policy with mandatory and additional Houses in Multiple Occupation licensing regimes, robust monitoring of concentrations, and effective enforcement to prevent policy creep and poor standards. |
| Evidence requirements and policy clarity | Concern is raised by one respondent about policy requirements that are considered difficult to evidence in practice, particularly demonstrating lack of demand for a dwellinghouse before Houses in Multiple Occupation use. Calls are made for clear, proportionate and well-publicised policy wording. |
| Infrastructure, transport and strategic road network impacts | One response supports Houses in Multiple Occupation controls as a means of reducing pressure on local infrastructure, parking and car use, with indirect benefits for the Strategic Road Network. |
Please note: this summary contains content generated by Artificial Intelligence (AI). AI generated content has been reviewed by the author for accuracy and edited/revised where necessary. The author takes individual responsibility for this content.