Local plan scoping consultation

I am a resident of Knutsford, responding as a private individual.

My full representation is attached. It sets out twenty numbered requests, R1 to R20, covering the distribution of growth and cumulative capacity, infrastructure, the natural environment and nature recovery, the evidence base, and engagement. I have also entered the individual requests as comments against the relevant parts of Sections 5 and 6, so that each can be considered in its proper place.

I recognise that this consultation asks what the new plan should contain, and not where development should go. My representation is framed accordingly. It does not object to any site, and it does not ask the Council to plan for fewer homes than the Government's standard method requires. It asks for specific policies, specific tests and specific pieces of evidence to be built into the plan now, so that the decisions taken in 2027 and 2028 can be made, and judged, against a proper framework.

Paragraph 5.4 invites views on priority matters for the vision, aims and objectives. Mine is this.

The vision and objectives should include an explicit objective that growth is infrastructure-led — that the timing and location of development is governed by the capacity of the infrastructure that must support it — together with a measurable outcome against which that objective can be monitored.

Residents' experience of the current plan period has been that housing arrives first and infrastructure arrives late, partially, or not at all. An objective of this kind, with a measurable outcome attached, is what would allow that to be tracked and challenged over the life of the plan rather than only regretted at the end of it.

Two requests on the site assessment methodology.

First, the methodology should include, as an explicit criterion, the Cheshire and Warrington Local Nature Recovery Strategy's Local Habitat Map — Core Local Nature Sites, Opportunity Areas for Nature Recovery, and mapped connectivity. Sites that would sever or degrade mapped connectivity should be identified as such at the sifting stage, with the reasoning published.

Second, and more urgently: every candidate site should be subject to a proper ecological assessment before it is allocated, not after. The Council has direct experience of what happens otherwise. LPS 38 at Longridge was allocated in the current Local Plan Strategy. Only afterwards was the land found to qualify as a Local Wildlife Site — meeting eight of the selection criteria where only one is needed, which the Inspector who heard the subsequent appeal described as very unusual. It was common ground between the Council and the appellants that the ecological baseline had not changed since allocation. The value was there all along; the allocation process simply did not establish it.

The Council refused permission. On appeal (APP/R0660/W/24/3347883, 9 December 2024) permission was granted despite a finding that around 40% of the Local Wildlife Site would be lost. The allocation did much of the work: the argument that the housing could go elsewhere was answered on the basis that the allocation had already been through the local plan process; the protected species test was satisfied because an allocated site carries an overriding public interest; and when it was argued that the site should not have been allocated at all, the Inspector's answer was that it was not his role to review its inclusion in the development plan. None of it was driven by a shortfall — the Council could demonstrate an 11.68-year housing land supply.

I therefore ask that the methodology require, for each site taken forward, a field-based ecological survey covering habitats, protected and priority species, and the site's role in habitat connectivity; that the survey be published with the evidence base at the point the site is proposed; that sites be screened against the Local Wildlife Site criteria and the LNRS habitat map before allocation; and that where a site's ecological value cannot be established, it is not allocated until it has been assessed.

The plan should apply a genuinely sequential approach to land: brownfield and urban capacity first, then non-Green-Belt greenfield, and only then Green Belt release.

Where grey belt assessment is used, I ask that the assessment methodology and its outputs be published and consulted upon in full at the 2027 Plan Content and Evidence stage, rather than appearing for the first time alongside proposed allocations in 2028. The public cannot comment meaningfully on a Green Belt release if the reasoning that produced it is disclosed at the same moment as the conclusion.

The review of the settlement hierarchy should be based on the actual current capacity of services, not merely on the presence of a facility.

A town with a secondary school at capacity, GP lists closed or under strain, and a constrained highway network is not, in any practical sense, as capable of absorbing growth as a raw count of its facilities would suggest. I ask that the hierarchy methodology explicitly distinguish between the existence of a service and its available headroom.

Two requests on how growth is distributed.

First, the distribution should be tested against the absorptive capacity of each settlement, and not derived solely from a settlement's position in the hierarchy or from a proportionate share of the borough total. I ask that the plan contain a cumulative capacity assessment at settlement level, covering highway network capacity, school places, primary care capacity, wastewater and water supply headroom, green space provision and community facilities, and that the distribution of growth be justified against it. Development pressure on a town is cumulative, and a series of individually defensible decisions can produce a collectively indefensible outcome.

Second, the baseline should count completions and extant commitments since the adoption of the current plan, and those figures should be published for each settlement. A distribution exercise that begins from a clean sheet, asking only what each town's share of the new total should be, takes no account of what each town has already delivered. Views will differ on whether any given town has had a large or a small share, and I do not ask the Council to adopt my view of it — I ask that the question be settled by published evidence rather than by assertion on any side.

Five requests on infrastructure.

Infrastructure first. The plan should contain a policy requiring that the transport, education, primary care, green space and wastewater capacity needed to serve a development is demonstrably available or firmly committed before occupation, secured by phasing conditions where necessary. Contributions secured through section 106 are not the same thing as delivered capacity, and a framework that treats them as equivalent will reproduce the outcomes of the current plan period at a larger scale. This should be a policy with teeth, not an aspiration in supporting text.

A settlement-level Infrastructure Delivery Plan. The IDP should be disaggregated to settlement level and published alongside the 2027 consultation, so residents of each town can see what is proposed and whether it is deliverable and funded. A borough-wide schedule does not allow that judgement to be made.

Evidence. I ask that the following be commissioned or updated and published, with each town identified separately: transport capacity and modelling, including local pinch points and the interaction of local traffic, visitor traffic and strategic through-traffic; rail capacity and station accessibility, and the practical scope for modal shift; school place forecasting mapped by catchment rather than reported as a town-wide total; primary care capacity, prepared with the Integrated Care Board; wastewater, sewerage and water supply capacity, prepared with United Utilities, including headroom at the receiving works; green space and recreation provision measured against the standards the plan proposes; and town centre capacity, including traffic, parking, servicing and pedestrian movement.

School places must be within walking distance of the housing they serve. School capacity cannot meaningfully be assessed for a town as a whole. Primary schools serve the housing immediately around them, and a surplus place on the far side of a congested town is not, in practice, a place at all. Where the arithmetic balances at town level but the geography does not, the result is not a shortage of places but a shortage of places people can walk to — and the difference is measured in car journeys. Knutsford illustrates this precisely: most of the town's primary capacity lies on the Mobberley side, while capacity on the Tabley side is limited, so parents drive their children across town twice a day, funnelling through the pinch point at Adams Hill. A town-level assessment would not even detect this. I ask that primary school capacity be assessed and provided at catchment level, that walkable school access be an explicit criterion in site selection and phasing, and that education evidence be presented spatially, mapped against proposed housing locations.

The capacity of a historic town centre is a fixed constraint. Knutsford town centre is historic and characterful and was not built for modern vehicle traffic. It is congested, parking is limited, and vehicles and pedestrians contend for the same constrained space. Street widths and historic frontages cannot be enlarged. This is a constraint of a different kind from those usually assessed: it cannot be mitigated by a contribution from an individual development, and it does not appear in a highway model of the strategic network. I ask that the capacity of historic town centres be treated as a constraint on the distribution of growth, and not solely as a matter for town centre policy, and that the evidence base include a town centre movement and public realm study.

The Cheshire and Warrington Local Nature Recovery Strategy, published in 2025 with Cheshire East Council as one of the responsible authorities, is a statutory document that local planning authorities must have regard to, and it states that they should use it to guide where and how development should take place. It records that Cheshire has lost more species than any other rural English county since 1950. Its Local Habitat Map identifies Core Local Nature Sites, Opportunity Areas for Nature Recovery, and connectivity — corridors and stepping stones between habitats.

The scoping document does not commit the new plan to translating that habitat map into its own policies map. I ask that it should. Connectivity is the element that site-by-site decision-making is least able to protect: each individual severance is small, and a network is only lost in aggregate. If connectivity is not a constraint at the plan-making stage, it becomes an argument to be had, and usually lost, one application at a time.

Three further requests follow.

The plan should include a policy protecting ecological connectivity and green corridors as such, distinct from and additional to policies protecting designated sites. For Knutsford there is a ready-made local evidence base: the Green Corridors study prepared for the Neighbourhood Plan identifies 34 corridors — 10 principal, 4 secondary, 3 aspirational and 17 urban — linking Tatton Park, The Heath, The Moor, Dog Wood, Sanctuary Moor, St John's Wood, Booths Mere, Windmill Wood, Bluebell Wood and Birkin Brook. The three aspirational corridors were identified specifically as being needed to mitigate the impacts of development. The Inspector in the recent Longridge appeal recorded that corridors of this kind around that site have been in continuous existence for hundreds of years.

The plan should be supported by strategic-level cumulative ecological assessment at town level, and the Habitats Regulations Assessment should consider growth around a town in the round rather than site by site. Around Knutsford, Rostherne Mere is a Site of Special Scientific Interest, National Nature Reserve and Ramsar site of international importance; the meres and parkland of Tatton Park lie on the town's northern edge and receive 700,000 to 800,000 visitors a year; and Booths Mere Local Wildlife Site and Birkin Brook constrain land to the east. Recreational pressure, water quality, run-off and nutrient loading from a further increment of housing are cumulative effects that only a strategic assessment can capture.

Biodiversity net gain should be delivered on site, or failing that within the same ecological network or the relevant LNRS Opportunity Area, in preference to being exported elsewhere in the borough. Net gain that is numerically satisfied miles away does nothing for the network it was meant to compensate, and over a plan period it will hollow out precisely the connectivity the LNRS exists to rebuild.

The plan should protect existing community facilities, and should require that development of any significant scale delivers community infrastructure proportionate to the population it creates — on site or within reasonable walking distance, and delivered to a timetable tied to occupation rather than left to follow at an unspecified later date.

Evidence base documents should be published as they are completed, rather than held back and released in bulk at each consultation point.

A six-week consultation window is not sufficient time for residents to absorb a large body of technical evidence and respond to it. Staged publication would cost the Council little and would materially improve the quality of the responses it receives.