Full text:
Dear Spatial Planning Team,
I am writing as a resident of Ashley to object in the strongest possible terms to any suggestion that the 12 adjoining Call for Sites submissions surrounding the parish, covering a combined area of approximately 291.03 hectares, should be taken forward as potential strategic housing or mixed-use allocations.
I understand that a Call for Sites submission is not a planning application, a proposed allocation or an endorsement by Cheshire East Council. It is land put forward by a promoter for possible consideration. I also understand that the present scoping consultation is not formally seeking comments on individual site submissions.
However, the sheer scale and concentration of the land submitted around Ashley are directly relevant to the issues on which the Council is currently consulting: the settlement hierarchy, spatial distribution of development, Green Belt review, sustainable transport, infrastructure provision, climate change, landscape, ecology, heritage and the evidence that will be used to select or reject sites.
I therefore ask that this letter is:
• recorded as a formal response to the Local Plan scoping consultation;
• retained as evidence for the forthcoming land availability and site-selection work;
• linked to every HE and CFS26 submission reference covering the 291.03-hectare area around Ashley; and
• taken into account before any of these sites is shortlisted, described as suitable or included in a future Local Plan consultation.
1. Ashley is fundamentally unsuitable for strategic-scale growth
This is the central objection.
Under the adopted Cheshire East Local Plan, Ashley is not a Principal Town, Key Service Centre or Local Service Centre. It falls within the “Other Settlements and Rural Areas” tier. Policy PG 2 says that growth in settlements at this level should be proportionate to their function and character and well related to their existing built-up extent. The policy directs the majority of development towards larger settlements with established infrastructure, employment, facilities and public transport.
Ashley is also expressly identified under Policy PG 10 as an infill village. Infill villages lie within the open countryside and do not have full settlement boundaries. Development is ordinarily limited to relatively small gaps between existing buildings within the defined infill boundary. Development outside that boundary is not treated as limited village infilling.
A strategic development covering hundreds of hectares would be the exact opposite of limited or proportionate growth. It would not round off the village, meet a small local need or fill a gap between buildings. It would amount to the wholesale transformation of a small rural parish into a major development location.
The Council’s own scoping document says that its review of the settlement hierarchy will consider services, facilities, population, employment, sustainable transport, retail provision and settlement form. It also says that decisions about the spatial distribution of growth must take account of infrastructure, landscape, ecology, heritage, flood risk, agricultural land, Green Belt and the availability of brownfield land.
On every one of those measures, Ashley is a poor location for strategic growth.
Ashley has a church, cricket club and public house that are fundamental to village life. They are not evidence that the parish has the infrastructure or service capacity of a town. They demonstrate Ashley’s identity as a small rural community. They do not provide schools, healthcare, significant local employment, shops, frequent public transport or the wider range of services required to support a substantial new population.
The settlement hierarchy must guide site selection. It should not be rewritten or reverse-engineered to make a promoter’s preferred site appear sustainable. Nor should promises of future infrastructure be used to overlook the fact that the location is inherently remote from the services and employment needed for daily life.
The Council should therefore retain Ashley within the Other Settlements and Rural Areas tier and conclude that development on the scale contemplated by these submissions would conflict fundamentally with a sustainable settlement strategy.
2. The land performs an essential Green Belt function
Ashley occupies a highly sensitive position between the southern edge of Greater Manchester, including Hale, Hale Barns, Altrincham and Trafford, and the rural settlements of Cheshire East, including Mobberley and Knutsford.
The surrounding countryside is not an incidental strip of undeveloped land. It is the remaining physical and visual break between a major conurbation and the villages and towns of north Cheshire. Development across 291.03 hectares would materially narrow, fragment and urbanise that break.
The National Planning Policy Framework identifies the purposes of the Green Belt as including checking unrestricted urban sprawl, preventing neighbouring towns from merging and safeguarding the countryside from encroachment.
The Ashley land makes a particularly strong contribution to the first two purposes:
• It prevents the built-up area of Greater Manchester from extending southwards.
• It maintains separation between Greater Manchester settlements and the villages and towns of Cheshire East.
• It protects the perception of leaving one conurbation and entering a distinct rural area.
• It preserves a coherent tract of open countryside rather than a collection of isolated fields.
• It limits the risk of incremental development eventually producing a continuous or near-continuous urban corridor.
The fact that the land is divided into 12 submissions must not lead to it being assessed as 12 unrelated parcels. The cumulative consequence of developing them would be far greater than the apparent effect of any individual parcel. A fragmented assessment would fail to address the strategic purpose performed by the land as a whole.
The land should not be casually labelled grey belt
The revised NPPF does not make all undeveloped Green Belt land available for development. Grey belt includes previously developed land and other Green Belt land that does not strongly contribute to purposes (a), (b) or (d). Development must also avoid fundamentally undermining the remaining Green Belt and must be in a sustainable location.
The land around Ashley is predominantly open and working countryside rather than previously developed land. More importantly, its location and strategic role indicate that it makes a strong contribution to checking sprawl and preventing settlements from merging.
The Council must undertake a transparent, parcel-by-parcel and cumulative Green Belt assessment. That assessment should consider:
• the relationship between all 12 submissions;
• the present and future edges of Greater Manchester and Cheshire settlements;
• the width, openness and continuity of the remaining gap;
• the experience of travelling through and viewing the landscape;
• the risk of further development being encouraged once the first release takes place; and
• the consequences for the permanence of the Green Belt beyond the Local Plan period.
Green Belt boundaries may only be altered through the plan-making process where exceptional circumstances are fully evidenced. Before reaching that conclusion, the Council must demonstrate that it has fully considered suitable brownfield land, underused land, increased densities in sustainable urban locations and the ability of neighbouring areas to accommodate development. National policy also requires previously developed land to be considered before other Green Belt locations.
The current housing position cannot, on its own, establish that these particular sites are suitable. Housing need may justify carrying out a Green Belt review; it does not predetermine which land should be released or remove the requirement to choose sustainable locations.
3. The lack of a five-year housing supply is not a blank cheque
I recognise that Cheshire East currently reports a 3.3-year supply of deliverable housing land and that the revised standard method produces an indicative housing need of 2,530 homes per year.
I do not object to meeting genuine housing need, including the need for affordable and social housing. My objection is to meeting that need in a location that conflicts with the settlement strategy and carries an exceptional concentration of environmental, transport and infrastructure constraints.
The NPPF distinguishes between plan-making and decisions on individual planning applications. For plan-making, paragraph 11 requires a sustainable pattern of development that aligns growth with infrastructure, improves the environment, makes effective use of urban land and mitigates and adapts to climate change. It also recognises that protected areas and serious adverse impacts can justify restrictions on the amount or distribution of development.
A shortfall in housing supply does not mean that every parcel offered by a landowner becomes sustainable, achievable or appropriate. Selecting a deeply constrained site would not solve the Council’s housing position if the site then proved unable to deliver the required transport, utilities, environmental mitigation or community infrastructure.
The proper response to the housing shortfall is a robust borough-wide strategy that identifies deliverable growth in the most sustainable locations. It is not to allow the scale of the target to override the basic question of whether Ashley is the right place.
4. Transport and highway constraints make the location unsustainable
The local road network was not designed to serve strategic development.
Access through Ashley depends on narrow rural lanes, restricted railway bridges, sharp bends and physical pinch points. These routes already carry local residents, agricultural vehicles, school traffic, cyclists, walkers, airport-related journeys and traffic travelling towards the A538 and M56.
A development of this scale would generate substantial additional movements for work, education, healthcare, shopping, leisure, deliveries, servicing and construction. Because Ashley lacks the range of facilities required for everyday life, a high proportion of these journeys would be made by car.
National policy says significant development should be focused in locations that are, or can genuinely be made, sustainable by limiting the need to travel and providing a real choice of transport modes. It also requires transport effects to be considered from the earliest stages of plan-making.
The existence of a railway station does not, by itself, establish that thousands of additional residents would have a realistic alternative to car travel. The Council must examine service frequency, capacity, accessibility, walking routes, interchange, destinations served and the practical requirements of families, older people, disabled residents and shift workers.
Before any Ashley site is shortlisted, the Council should require a strategic and cumulative transport assessment covering:
• all 12 submissions and any other planned or committed growth in the wider area;
• realistic rural household car ownership and trip rates;
• the capacity and physical limitations of railway bridges and rural lanes;
• pedestrian and cycle safety;
• access for emergency and refuse vehicles;
• construction traffic, including likely routes and duration;
• effects on the A538, M56 and neighbouring settlements;
• the capacity and deliverability of rail and bus improvements;
• the cost, funding source and delivery date for every necessary intervention; and
• the residual cumulative effect after mitigation.
Unfunded promises of a future bus service, junction improvement or active travel route should not be treated as proof that the site is sustainable. Infrastructure must be capable of being delivered when it is needed, not after congestion and safety problems have arisen.
5. Infrastructure cannot simply be promised later
There is no published evidence that Ashley has the water supply, wastewater capacity, electricity network, drainage, healthcare, education or public transport infrastructure needed to support strategic development.
The Council should obtain written evidence from the relevant infrastructure providers before concluding that any of the submissions are achievable. This should include:
• wastewater treatment and sewer capacity;
• potable water capacity;
• electricity generation and network reinforcement;
• surface-water drainage;
• primary and secondary school requirements;
• GP, dental and wider healthcare capacity;
• emergency service access and response implications;
• public transport provision;
• digital infrastructure;
• waste and recycling services; and
• the land, funding and phasing needed to deliver every necessary facility.
A promoter’s statement that infrastructure “could” be provided is not enough. The assessment should identify who would deliver it, when it would be operational, how much it would cost, whether third-party land is needed and what happens if later phases or adjoining sites do not proceed. Indeed, as a local resident of Ashley currently, I would argue that the existing local population are struggling and barely getting by on the above, before even considering the increased need of the above given a larger local need.
No Ashley parcel should be described as deliverable because it assumes that another parcel will fund or accommodate the necessary school, road, drainage system or public transport service. Where infrastructure is shared, there must be an enforceable and independently tested delivery strategy covering the whole area.
6. Flood risk and drainage require a precautionary approach
The submitted land lies within the wider River Bollin catchment and includes areas where surface-water drainage and run-off are serious concerns. Large-scale development would introduce extensive roads, roofs, drives and other impermeable surfaces into a presently rural landscape.
National policy requires plans to consider all sources of flooding, cumulative effects and future climate change. It directs development towards the lowest-risk locations and says land should not be allocated where reasonably available lower-risk sites exist.
Before any site is advanced, the Council should require:
• an updated Strategic Flood Risk Assessment;
• detailed surface-water, fluvial, groundwater and ordinary-watercourse assessment;
• catchment-level modelling rather than isolated site calculations;
• allowance for future climate conditions and more intense rainfall;
• assessment of downstream effects on the River Bollin and neighbouring land;
• mapped exceedance routes and safe access during flood events;
• evidence of wastewater and foul-drainage capacity;
• a costed and maintainable sustainable drainage strategy; and
• confirmation that drainage features do not create unacceptable airport safeguarding or bird-attraction risks.
Drainage areas, flood storage, easements and appropriate buffers must be included when calculating the genuinely developable area. They cannot be shown as incidental landscaping and then reduced later to preserve housing numbers.
7. The ecological effects could be extensive and irreversible
The Ashley landscape is an interconnected network of farmland, hedgerows, mature trees, ponds, watercourses, woodland and field margins. It includes or adjoins locally important woods and coverts such as Sunbank Wood, Hancock’s Banks, Ryecroft Covert, Lamb’s Covert, Hardy’s Covert and Jackson’s Bank.
Cotterill Clough is an ancient woodland and Site of Special Scientific Interest situated on a tributary of the River Bollin. Cheshire Wildlife Trust describes it as one of the county’s best examples of a clough woodland and one of its oldest nature reserves.
The potential harm is not confined to direct habitat loss. Strategic development could cause:
• fragmentation of wildlife corridors;
• changes to groundwater and surface-water flows;
• increased pollution and sediment entering watercourses;
• artificial lighting affecting bats and other nocturnal species;
• disturbance from people, traffic, noise and domestic animals;
• increased road mortality;
• loss of feeding and nesting land;
• damage to hedgerows and mature trees;
• pressure on ancient woodland and protected sites; and
• cumulative loss of habitats relied on by pollinators, birds, amphibians and mammals.
Cheshire East’s ecological network policy recognises core areas, corridors, stepping stones and restoration areas and requires development to improve habitat connectivity and resilience rather than weaken it.
The Council should require a strategic ecological assessment of the entire 291.03-hectare area before deciding that any parcel is suitable. This should include properly timed seasonal surveys, hydrological investigation, arboricultural and Tree Preservation Order surveys, assessment of ancient woodland and veteran trees, protected-species work, Natural England consultation and consideration of recreational and lighting effects.
Biodiversity net gain must not be treated as a licence to destroy established habitats or sever ecological networks. Newly created habitat elsewhere cannot simply reproduce ancient woodland, mature hedgerows, established soils or the relationships between species and the wider landscape. Avoiding harm must remain the starting point.
8. The submissions threaten highly valued landscapes
The land contributes to the setting and experience of both the Bollin Valley and Rostherne/Tatton Park Local Landscape Designations.
Cheshire East Policy ENV 3 describes these designations as among the borough’s highest-quality and most valued landscapes. It requires development to respect local distinctiveness and says adverse effects on their special qualities should be avoided. The policy also expressly requires cumulative effects to be considered.
The landscape value of Ashley does not arise from a single viewpoint or landmark. It is created by the combination of open farmland, field patterns, hedgerows, woods, lanes, historic buildings, long views, dark skies, tranquillity and the gradual transition between the Greater Manchester conurbation and rural Cheshire.
Development across this area would change the form of the parish and the relationship between Ashley, Tatton, Rostherne, Mobberley and the Bollin Valley. This could not be addressed merely by planting a belt of trees around a housing estate. New landscaping cannot recreate the openness, scale, historical field pattern or accumulated character of a centuries-old rural landscape.
A full Landscape and Visual Impact Assessment should therefore be required at site-selection stage, including winter and summer views, cumulative development scenarios, settlement coalescence, lighting effects and views from roads, public rights of way and heritage assets.
9. Heritage significance includes the open setting
Ashley is a centuries-old rural parish. Its historic interest lies not only in individual buildings but in the relationship between those buildings and the surrounding countryside.
The wider area contains numerous listed buildings and heritage assets, including Ashley Hall and the parish church, as well as historic field systems, estate boundaries, hedgerows and potential archaeological remains. Local evidence has identified 19 Grade II listed assets whose settings may be affected. The Council should verify the full list and define the zone of influence for each submission.
National policy requires great weight to be given to the conservation of designated heritage assets. Harm arising through development within an asset’s setting requires clear and convincing justification. Cheshire East Policy HER 4 similarly requires special regard to be given to preserving listed buildings, their settings and their features of interest.
The historic setting is not simply the land immediately inside a listed building’s boundary. Open fields, views, approach routes, mature trees, landscape structure and the relationship between buildings can all contribute to significance.
Before any site is shortlisted, the Council should require:
• a comprehensive heritage asset and settings audit;
• a landscape-based assessment of cumulative change;
• archaeological desk-based work;
• assessment of historic field patterns and hedgerows;
• geophysical survey and trial investigation where appropriate; and
• consultation with the Council’s conservation and archaeological advisers and Historic England where necessary.
These matters should be investigated before allocation. They should not be deferred to a future planning application after the principle of development has effectively been established.
10. The loss of Best and Most Versatile agricultural land would be substantial
The agricultural and soil information relied on by local residents, including material produced in connection with HS2, appears to identify extensive areas of Grade 2 and Subgrade 3a land. These grades fall within the definition of Best and Most Versatile agricultural land.
The Council should commission or require a detailed Agricultural Land Classification survey for every parcel before any site is shortlisted. Broad strategic maps are not sufficient for a decision involving such a large and continuous tract of farmland.
Cheshire East Policy RUR 5 says proposals should avoid the loss of Best and Most Versatile land. Where loss is proposed, the Council may require detailed field assessments, and the benefits must clearly outweigh the economic and other consequences.
The NPPF also recognises the wider benefits of high-quality agricultural land, soils, trees and woodland. Where significant development of agricultural land is shown to be necessary, poorer-quality land should be preferred.
This land contributes not only to food production but also to soil carbon, water infiltration, flood attenuation, landscape character and the rural economy. Once covered by roads and buildings, these functions cannot realistically be restored.
The cumulative loss of a large, coherent area of productive land is materially different from the loss of a small or isolated field. The assessment must consider the strategic agricultural value of the whole tract.
11. Climate change strengthens the case for a more sustainable location
The climate objection is not an abstract one.
Strategic development in Ashley would be likely to:
• create long-term car-dependent travel patterns;
• increase transport and construction emissions;
• seal productive soils;
• reduce natural water storage;
• place additional pressure on trees, hedgerows and habitats;
• increase artificial lighting;
• expose more people to aircraft and road noise; and
• require substantial new infrastructure to serve a previously rural location.
Paragraph 11 of the NPPF requires plans to align growth and infrastructure, make effective use of urban land, improve the environment and mitigate and adapt to climate change.
Before considering major Green Belt release, the Council must publish a credible urban capacity and alternatives assessment. This should cover:
• suitable brownfield land;
• underused commercial and public-sector land;
• appropriate town-centre and transport-corridor development;
• higher densities in genuinely sustainable locations;
• stalled or unimplemented permissions;
• empty or underused buildings capable of conversion;
• regeneration opportunities; and
• alternative greenfield sites with fewer environmental and infrastructure constraints.
I am not suggesting that every empty building or brownfield parcel can accommodate housing. I am asking the Council to demonstrate, transparently, that it has investigated and compared all reasonable alternatives before contemplating the permanent loss of this part of the Green Belt.
That comparison should be published through the Sustainability Appraisal and Strategic Environmental Assessment, with clear scoring and reasons rather than conclusions reached after a preferred location has already been selected.
12. Manchester Airport creates additional safeguarding and noise constraints
Given Ashley’s proximity to Manchester Airport, every submitted parcel must be checked against the current official aerodrome safeguarding maps and the latest airport noise contours.
Cheshire East Policy GEN 5 prevents development that would adversely affect the operational integrity or safety of a safeguarded aerodrome. Its supporting text confirms that Manchester Airport’s assessment may need to address obstacles, bird attraction, lighting, radar and communications interference, and construction hazards.
This is particularly relevant where flood mitigation or sustainable drainage could involve ponds, wetlands or other features potentially attractive to birds.
The Council also confirmed in April 2026 that the latest published Manchester Airport noise contours now apply. Policy ENV 13 says that new homes would not normally be permitted above the Significant Observed Adverse Effect Level and that affected sites require a noise impact assessment. It also requires noise, ventilation, indoor air quality and overheating to be considered together.
No parcel should be described as suitable until Manchester Airport has been formally consulted and any noise or safeguarding constraint has been mapped. Reliance on closed windows and mechanical ventilation would also need particularly careful examination in the context of increasingly hot summers.
13. The cumulative effect on Ashley’s identity must be recognised
My wife and I bought our home in Ashley five years ago specifically because of its rural setting, green space and distinctive village character.
This is not an objection based simply on a private view or a wish to prevent all change. My experience as a resident confirms the qualities recognised by the planning policies: openness, tranquillity, dark skies, historic character, agricultural land, a close relationship with the countryside and a small but active community.
Ashley’s church, cricket club and public house are not interchangeable facilities that can be moved or replicated within a new housing estate. Together with the historic buildings, farms, lanes and surrounding fields, they form the social and physical identity of the parish.
Development across 291.03 hectares would not amount to a modest extension of Ashley. It would overwhelm the existing settlement and, in practical terms, erase its identity as a small rural parish.
Residents have also spent decades living with uncertainty and disruption associated with major infrastructure proposals, including the additional Manchester Airport runway and HS2. Those previous controversies are not, by themselves, a planning reason to reject these submissions. They are, however, relevant to cumulative community wellbeing, confidence in public bodies and the importance of early, open and meaningful engagement.
Local people should not be left for years with a vast speculative proposal hanging over the parish while the promoter’s evidence, infrastructure assumptions and intentions remain unclear.
Formal requests
I formally request that Cheshire East Council:
1. Records this letter as a scoping representation and links it to all 12 HE and CFS26 submissions covering the 291.03-hectare area.
2. Publishes the full list of site references, boundaries, proposed uses and non-confidential supporting information so residents can understand precisely what has been submitted.
3. Assesses the 12 submissions both individually and cumulatively, including a scenario in which all or a substantial proportion of the land is developed.
4. Screens the submissions out as unsuitable at the earliest evidence-led stage and does not shortlist or propose them for allocation.
5. Does not alter Ashley’s place in the settlement hierarchy to accommodate a pre-existing site promotion, unless an independent review provides compelling evidence that Ashley has the services, infrastructure, transport accessibility and settlement function required for strategic growth.
6. Publishes a transparent Green Belt assessment examining purposes (a), (b) and (d), the remaining strategic gap, the combined effect of the submissions and the long-term permanence of any revised boundary.
7. Demonstrates that all reasonable brownfield, urban, density and alternative-location options have been fully examined before considering the release of Green Belt land around Ashley.
8. Requires strategic transport and infrastructure evidence before site selection, including costed, funded and phased proposals supported by the relevant service providers.
9. Completes catchment-level flood, drainage and wastewater assessments, including cumulative effects and future climate-change allowances.
10. Requires strategic ecological, landscape, heritage and archaeological assessments, rather than deferring these issues until after allocation.
11. Requires detailed field-based Agricultural Land Classification surveys and gives full weight to the cumulative loss of Grade 2 and Subgrade 3a land.
12. Obtains a formal safeguarding and noise response from Manchester Airport for every affected parcel.
13. Does not describe the land as available or achievable without independently verified evidence of landowner control, infrastructure delivery, access, viability, phasing and the absence of overriding legal or physical constraints.
14. Publishes clear reasons and assessment scores if any Ashley submission survives the initial screening process.
15. Notifies me directly of every future consultation involving these sites, including the plan content and evidence stage and the proposed Local Plan consultation.
Conclusion
The need for additional housing does not make every promoted site suitable.
Ashley is a small Green Belt infill village within the open countryside. It lacks the settlement function, service provision, transport choices and infrastructure required for development on this scale. The submitted land also performs a significant Green Belt role and is subject to a concentration of agricultural, ecological, landscape, heritage, flood, transport and airport-related constraints.
Taken together, these are not minor matters capable of being resolved through routine mitigation. They go to the principle of whether Ashley is a sustainable strategic growth location. It is not.
I therefore ask Cheshire East Council to assess these submissions rigorously, record them as unsuitable for strategic development and exclude them from any shortlist or future Local Plan allocation.
Please acknowledge receipt, provide a representation reference and confirm that this letter has been linked to every relevant HE and CFS26 site submission.
I reserve the right to submit further technical evidence and representations at each subsequent stage of the Local Plan process.
Yours faithfully,
Duncan Millin
