Local plan scoping consultation

Just ASSC Property Ltd supports the Council's proposed preparation of a Land Availability Assessment methodology to provide a transparent and consistent basis for identifying and assessing potential development sites.

As agent/promoter for land submitted through the Council's 2026 Call for Sites exercise, we have a direct interest in ensuring that the methodology provides a clear, proportionate and evidence-led assessment of site suitability, availability and to provide a deliverable outcome.

In particular, we consider that the methodology should clearly distinguish between fundamental constraints to development and matters which are capable of mitigation through appropriate design, infrastructure provision or other interventions. The presence of a potential infrastructure, access or environmental constraint should not, in itself, result in an otherwise sustainable site being filtered out where there is a realistic prospect of that constraint being satisfactorily addressed.

This is particularly relevant to larger strategic sites, where the scale of development may itself provide the ability to deliver or fund infrastructure, sustainable transport, green infrastructure and other mitigation that would not necessarily be achievable through smaller developments.

We would also encourage the Council to publish the assessment criteria, assumptions, scoring methodology and relevant weightings in sufficient detail to allow landowners and promoters to understand how conclusions have been reached.

Where initial assessments identify deficiencies or require further evidence, promoters should be given a reasonable opportunity to provide updated information, technical evidence or mitigation proposals before decisions are made about whether sites should progress for further consideration.

We therefore welcome the Council's intention to publish further details of the methodology and initial site assessments at the Plan Content and Evidence consultation stage.

Just ASSC Property Ltd supports an evidence-led spatial strategy that directs growth towards locations capable of supporting sustainable development while ensuring that sufficient land is identified to meet the borough's development needs over the plan period.

Given the scale of housing and other development likely to be required, we agree that the Council should properly assess a range of spatial options, including appropriate edge-of-settlement growth and larger strategic urban extensions. The strategy should not rely disproportionately on the capacity of existing urban areas or previously developed land where this would be insufficient to meet identified needs or result in less sustainable patterns of development.

The assessment of spatial options should recognise the role of settlements with established services, employment opportunities and transport connections, together with the potential for development itself to deliver improvements to infrastructure, sustainable transport, green infrastructure and community facilities.

Larger strategic sites can provide opportunities for comprehensive masterplanning and coordinated infrastructure delivery that may not be achievable through a more fragmented pattern of smaller development. Their contribution should therefore be assessed on its overall merits rather than site size being regarded as a disadvantage.

We support the Council's proposed consideration of factors including housing need, employment, commuting patterns, infrastructure capacity, services and facilities, environmental constraints, site availability, market attractiveness and viability. These factors should be considered collectively and transparently when determining the preferred spatial distribution of development.

Just ASSC Property Ltd supports the Council's review of the settlement hierarchy and considers that it should provide a robust, evidence-led basis for directing future growth towards the borough's most sustainable settlements.

The assessment should consider settlements comprehensively, including their population, range of services and facilities, employment opportunities, retail provision, public transport and wider sustainable transport connectivity. It should also recognise the relationship between settlements and nearby employment areas and services, rather than relying solely on facilities falling within narrowly defined settlement boundaries.

The hierarchy should distinguish between settlements that are capable of accommodating meaningful growth and smaller or less sustainable locations where significant development could result in greater reliance on private cars or require disproportionate infrastructure provision.

Importantly, settlement hierarchy and development capacity should not be treated as the same exercise. A settlement's ability to accommodate future growth will also depend upon the availability and deliverability of suitable land, environmental considerations and the potential for development to provide necessary infrastructure.

We therefore support an updated settlement hierarchy based upon transparent and current evidence, with the results used alongside the spatial distribution, infrastructure and land availability evidence when determining the most appropriate locations for future growth.

Just ASSC Property Ltd supports the Council's intention to reflect current national Green Belt policy fully in preparing the new Local Plan, including the assessment of whether Green Belt boundaries may need to change in order to meet identified development needs and the identification and assessment of grey belt land.

The borough-wide Green Belt assessment should provide a transparent, consistent and evidence-led assessment of how land performs against the relevant Green Belt purposes. In particular, the methodology used to determine whether land strongly contributes to those purposes should be clearly explained and applied consistently across the borough.

Where development needs cannot reasonably be met through other sources of land, the Council should properly consider appropriate Green Belt release through the plan-making process, having regard to national policy and the relative performance and sustainability of potential locations. Existing Green Belt designation should not, in itself, prevent otherwise suitable and deliverable sites from being objectively assessed.

The assessment should also consider sustainability and accessibility alongside Green Belt performance, including opportunities to make effective use of existing transport infrastructure and to improve sustainable transport connections through development.

We welcome the Council's intention to identify grey belt land as part of its borough-wide assessment and consider that publication of the methodology and supporting evidence will be important in enabling landowners, promoters and communities to understand how conclusions have been reached.

Just ASSC Property Ltd supports a positive and evidence-led approach to planning for the borough's future growth, ensuring that sufficient land is identified to meet objectively assessed housing, employment and other development needs over the plan period.

The Local Plan should provide sufficient flexibility and choice in the supply of development land to support delivery throughout the plan period. This should include consideration of a balanced portfolio of sites of different scales and locations, including strategic sites where these provide sustainable opportunities for growth and can contribute significantly towards meeting identified needs.

The assessment of growth options should consider housing, employment, infrastructure and transport together rather than as separate matters. Development should be directed towards locations where existing services and infrastructure can be utilised effectively and where new development can support or deliver necessary improvements.

It is also important that the Plan's strategy remains sufficiently flexible to respond to changing housing requirements, infrastructure investment and other evidence during the plan period. A suitable contingency within the overall supply of development land can help maintain delivery where individual sites are delayed or circumstances change.

We therefore support an approach that plans positively for identified development needs while ensuring that growth is sustainable, deliverable and supported by appropriate infrastructure.

Just ASSC Property Ltd supports the Council planning positively to meet the borough's identified housing needs over the full plan period and identifying a sufficient range of deliverable housing sites to maintain supply.

The scale of housing need identified means that the Local Plan should consider sites of different sizes, including larger strategic sites where these represent sustainable and deliverable opportunities for growth. Such sites can make a meaningful contribution to housing delivery while also providing opportunities for a broad housing mix, affordable housing and supporting infrastructure.

Housing requirements should be kept under review as the Plan progresses and sufficient flexibility should be maintained to respond to updated evidence and changing housing needs.

The overall housing strategy should be closely aligned with the spatial distribution, settlement hierarchy, infrastructure and land availability evidence to ensure that identified housing needs translate into realistic and deliverable development opportunities.

Just ASSC Property Ltd supports an integrated approach to transport and infrastructure planning, with infrastructure requirements considered alongside the spatial strategy and site-selection process from an early stage.

When assessing potential development locations, the Council should distinguish between fundamental infrastructure or transport constraints and issues that are capable of being satisfactorily mitigated through investment, design or new infrastructure. Sites should not be prematurely excluded solely because improvements are required where there is a realistic and deliverable means of providing them.

The assessment should also recognise that larger strategic developments can provide opportunities to deliver or fund infrastructure improvements that may not be achievable through smaller or more fragmented development. This can include highway improvements, public transport provision, walking and cycling connections, utilities, green infrastructure and community facilities.

Accessibility should therefore be assessed using both existing provision and realistic opportunities for improving sustainable connectivity through development.

We support the preparation of the Infrastructure Issues and Context Report and subsequent Infrastructure Delivery Plan. These should clearly identify infrastructure constraints, planned investment and potential mitigation, and should be closely integrated with the assessment of spatial options and potential development sites.

Just ASSC Property Ltd supports the preparation of a comprehensive, proportionate and up-to-date evidence base to underpin the new Local Plan.

It will be important that evidence relating to housing need, spatial distribution, settlement hierarchy, Green Belt, land availability, transport and infrastructure is considered collectively rather than as a series of isolated assessments. Conclusions reached in one evidence study should be clearly reflected in other relevant parts of the plan-making process.

The evidence base should be transparent, with methodologies, assumptions, assessment criteria and relevant datasets published wherever possible. This is particularly important for evidence used to assess potential development sites and determine the spatial distribution of growth.

Evidence should also distinguish between fundamental constraints and matters capable of mitigation or resolution through development, infrastructure investment or further technical work.

Where evidence concerning individual sites is incomplete or requires further investigation, landowners and promoters should have a reasonable opportunity to provide additional or updated technical information before conclusions are reached that could exclude otherwise potentially suitable and deliverable land from further consideration.

We also support keeping the evidence base under review as the Local Plan progresses so that decisions reflect the most current available information.

Just ASSC Property Ltd supports close coordination between the emerging Cheshire and Warrington Spatial Development Strategy and the Cheshire East Local Plan.

The Local Plan should continue to progress without unnecessary delay, but should retain sufficient flexibility to respond to emerging strategic priorities identified through the Spatial Development Strategy, particularly in relation to housing growth, employment, transport and major infrastructure investment.

The emerging Spatial Development Strategy provides an opportunity to ensure that Cheshire East's future growth strategy is informed by wider strategic infrastructure, transport and economic priorities. Growth locations within Cheshire East should therefore be assessed having regard to their wider functional relationships, including access to employment, services, transport networks and planned infrastructure.

It will be important that evidence prepared for the Spatial Development Strategy and Cheshire East Local Plan is coordinated and kept under review so that potentially sustainable development opportunities are not prejudiced by assumptions made before the strategic position is sufficiently developed.

We support an integrated approach in which housing, economic growth and infrastructure investment are planned together and in which the Local Plan remains capable of responding appropriately to the emerging sub-regional strategy.