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Dear Spatial Planning Team,
My name is Poonam Millin and I live in Ashley with my husband and family. I am writing to object in the strongest possible terms to the 12 adjoining Call for Sites submissions surrounding Ashley, which together cover approximately 291.03 hectares.
I understand that a Call for Sites submission is not a planning application or planning permission. I also understand that inclusion on the Council’s site submissions map does not give the land any additional planning status and that many submitted sites will not be taken forward.
That does not reduce my concern. These submissions are enormous when considered together and have the potential to influence the Council’s future development strategy. It is therefore important that residents’ objections are recorded now, before the sites are shortlisted or assumptions are made about their suitability.
I ask that this letter is:
• recorded as my formal response to the Local Plan scoping consultation;
• retained as part of the evidence used in the land availability and site-selection process;
• linked to every HE and CFS26 reference covering the 291.03-hectare area; and
• considered before any of these sites is described as suitable, shortlisted or proposed for allocation.
1. Ashley is the wrong place for development on this scale
This is my strongest objection.
Ashley is a small rural parish. It is not a town, service centre or established growth location. It does not contain the range of employment, schools, healthcare, shops, public transport and community infrastructure required to support strategic development.
Under the current Cheshire East settlement hierarchy, growth in the “Other Settlements and Rural Areas” tier should be proportionate to the function and character of the settlement and well related to its existing built-up extent.
Ashley is also specifically listed under Policy PG 10 as an infill village. The policy defines limited infilling as development within a relatively small gap between existing buildings. A development area of 291.03 hectares would plainly not be limited infilling. It would not be a modest or proportionate extension to Ashley. It would amount to the creation of a new settlement around an existing rural village.
Ashley’s church, cricket club and public house are important parts of village life. They are not evidence that Ashley has the infrastructure needed to support thousands of additional residents. They demonstrate the identity of a small rural community, rather than the characteristics of a strategic growth centre.
The settlement hierarchy should guide the choice of development sites. It should not be amended or reinterpreted simply because a promoter has assembled a large area of land around a village.
The Council’s own scoping material says that the future settlement hierarchy will consider services, facilities, jobs, sustainable transport, retail provision and settlement form. It also states that the spatial distribution of development should consider infrastructure, landscape, ecology, heritage, flood risk, agricultural land, Green Belt and available brownfield land. These are precisely the factors that make Ashley unsuitable.
2. The land performs an important Green Belt function
Ashley lies 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 open land surrounding Ashley provides a clear physical and visual break between these areas. It prevents the Manchester conurbation from spreading further south and protects the separate identities of communities on either side of the Green Belt.
National Green Belt policy identifies five purposes, including checking unrestricted sprawl, preventing neighbouring towns from merging and safeguarding the countryside from encroachment. Green Belt boundaries should only be altered where exceptional circumstances are properly evidenced through the plan-making process.
In my view, the Ashley land makes a strong contribution to those purposes because it:
• prevents the southward expansion of the Greater Manchester built-up area;
• maintains separation between Greater Manchester and Cheshire settlements;
• protects a coherent area of open countryside;
• preserves the rural approach to Ashley, Mobberley, Rostherne and Knutsford; and
• prevents an urban corridor developing between existing settlements.
The Council must not treat the 12 submissions as unrelated pieces of land. They are adjoining sites and their combined impact would be far greater than the impact of any individual parcel. A piecemeal assessment could significantly understate the effect on openness, settlement separation and the wider Green Belt.
The land should not automatically be treated as grey belt
Grey belt is not simply any Green Belt land that a promoter wishes to develop. National policy defines it as previously developed land or other Green Belt land that does not strongly contribute to particular Green Belt purposes.
The land around Ashley is predominantly open, working countryside. Its position between the Greater Manchester conurbation and Cheshire settlements means there is a strong case that it contributes substantially to preventing sprawl and the merging of settlements.
The Council must therefore carry out a transparent Green Belt assessment that considers:
• the contribution made by each parcel;
• the combined contribution made by all 12 sites;
• the remaining width and strength of the Green Belt gap;
• the visual experience of entering rural Cheshire;
• the risk of further development following an initial release; and
• whether any new boundary would remain clear and defensible beyond the Local Plan period.
National policy also requires authorities to examine reasonable alternatives before changing Green Belt boundaries. This includes making maximum use of suitable brownfield and underused land, considering appropriate increases in urban density and examining whether development can be accommodated in more sustainable locations.
There must be better locations elsewhere in Cheshire East, particularly brownfield sites, underused urban land, empty or obsolete buildings and sites closer to established services and public transport.
3. The housing land supply position does not make Ashley suitable
I recognise that Cheshire East is under pressure to identify more housing land. The Council’s latest published monitoring concludes that it has a 3.3-year supply of deliverable housing sites rather than the required five years.
I am not opposed to the provision of new homes. There is a clear need for genuinely affordable and social housing, as well as homes for families, older residents and people with additional needs.
My objection is to the assumption that this need should be met through strategic development in Ashley.
A housing shortfall does not mean that every site put forward by a landowner becomes sustainable. It does not remove the need to assess Green Belt harm, settlement hierarchy, transport, flooding, infrastructure, ecology, agricultural land, landscape and heritage.
For plan-making, the National Planning Policy Framework requires a sustainable pattern of development that aligns housing growth with infrastructure, improves the environment, makes effective use of urban land and addresses climate change.
It follows that housing need must influence the amount of land identified, but it cannot replace the assessment of where that housing should go.
Selecting a site with severe and overlapping constraints may also fail to address the housing shortfall if infrastructure costs, access problems, environmental mitigation or land assembly make the site slow or impossible to deliver.
4. The local road network cannot support strategic development
As someone who lives in Ashley and uses these roads every day, I know how limited the local network is.
Access depends on narrow rural lanes, restricted railway bridges, bends, junctions and physical pinch points. There are already periods of congestion towards the A538 and M56, as well as conflicts between cars, agricultural vehicles, cyclists, walkers and other road users.
Development on this scale would generate a large number of additional journeys for work, education, healthcare, shopping, leisure, deliveries, servicing and construction.
Because Ashley does not contain the facilities needed for everyday life, many of those journeys would inevitably be made by car.
The presence of a railway station should not be treated as a complete answer. The Council must examine the frequency and capacity of services, the destinations served, walking access, accessibility for disabled and older residents and whether the railway could realistically replace a significant proportion of car journeys.
As a mother, I am particularly concerned about road safety. Rural lanes without continuous pavements or safe cycling provision are not suitable routes for a large new population. Promises that people will walk or cycle cannot be accepted without safe, continuous and deliverable routes.
Before any Ashley site is shortlisted, the Council should require a cumulative transport assessment covering all 12 submissions. It should include:
• realistic household car ownership and trip rates;
• the capacity of narrow lanes, bridges and junctions;
• effects on the A538, M56 and neighbouring settlements;
• pedestrian and cycling safety;
• access for emergency and refuse vehicles;
• construction traffic and proposed haul routes;
• public transport capacity and funding;
• the timing and cost of every necessary highway improvement; and
• the residual impact after mitigation.
An unfunded proposal for a future bus service or road improvement is not proof that a site is sustainable.
5. Essential infrastructure has not been demonstrated
There is no publicly available evidence showing that Ashley has the infrastructure capacity required for development on this scale.
Before concluding that the sites are achievable, the Council should obtain firm evidence covering:
• primary and secondary school capacity;
• GP, dental and wider healthcare provision;
• wastewater treatment and sewer capacity;
• potable water supply;
• electricity network capacity and reinforcement;
• surface-water drainage;
• public transport;
• emergency services;
• waste and recycling services;
• digital connectivity; and
• community, recreation and open-space provision.
The assessment must explain what infrastructure is needed, where it would be located, how much it would cost, who would fund it and when it would be operational.
A promoter’s statement that facilities “could” be provided is not enough.
The Council should also reject any assumption that one parcel will provide infrastructure for another unless there is a complete, costed and enforceable delivery plan covering all relevant landowners and phases.
A site cannot be considered deliverable if the roads, schools, drainage systems and utilities required to serve it are dependent on uncertain future agreements.
6. Flood risk and drainage must be considered across the whole catchment
The land lies within the wider River Bollin catchment. Local residents are already aware of surface-water run-off, drainage limitations and areas where water collects following heavy rain.
Building over hundreds of hectares would introduce roads, roofs, drives and other impermeable surfaces into a landscape that currently absorbs and slows rainfall.
The consequences must be examined across the whole catchment, not through separate drainage calculations for each submitted parcel.
National policy requires plans to consider flood risk from all sources, cumulative effects and the future effects of climate change. It also says development should be directed towards land with the lowest flood risk and should not be allocated where appropriate lower-risk sites are reasonably available.
Before any allocation is considered, the Council should require:
• updated surface-water and fluvial flood modelling;
• an assessment of groundwater and ordinary watercourses;
• modelling of the cumulative effect of all 12 sites;
• appropriate climate-change allowances;
• an assessment of downstream effects on the River Bollin;
• safe access and escape routes during flood events;
• confirmation of foul sewer and wastewater capacity;
• mapped exceedance routes; and
• a fully costed, maintainable sustainable drainage strategy.
Drainage ponds, attenuation areas, flood storage, watercourse buffers and maintenance access must be included when calculating the genuinely developable area.
They should not be presented as optional landscaping or reduced later to preserve housing numbers.
7. The proposal conflicts with responsible climate planning
The climate consequences of choosing Ashley as a major growth location would be substantial.
A development that depends heavily on private cars would lock in transport emissions for decades. Construction across such a large area would also involve extensive ground disturbance, concrete, road building, utility works and the loss of soils and vegetation that currently absorb water and store carbon.
Increasingly severe heat and rainfall make it even more important to retain functioning soils, mature trees, hedgerows, woodland and natural drainage systems.
The Council should compare the full carbon and climate effects of developing Ashley with alternatives that make use of existing buildings, brownfield land, established infrastructure and locations where residents can reach work and services without relying on a car.
It would be inconsistent to declare climate and nature priorities while choosing to urbanise a large area of productive Green Belt farmland where lower-impact alternatives may exist.
8. Wildlife habitats and ecological corridors would be put at risk
The Ashley landscape is not ecologically empty simply because much of it is farmed.
It contains an interconnected network of hedgerows, mature trees, ponds, ditches, watercourses, field margins, woodland and open feeding land. These features support wildlife movement across the wider landscape and cannot be assessed in isolation.
The area includes or lies close to Cotterill Clough, an ancient clough woodland and long-established Cheshire Wildlife Trust nature reserve. Cheshire East’s ecological policy recognises that ancient woodland and other irreplaceable habitats cannot simply be recreated elsewhere.
Local evidence also identifies habitats and corridors used by bats, owls, badgers, amphibians and other protected or declining species. These records should be independently checked through properly timed surveys rather than dismissed or deferred until after allocation.
The likely effects include:
• direct habitat loss;
• fragmentation of wildlife corridors;
• damage to hedgerows and mature trees;
• changes to water flows and water quality;
• artificial lighting affecting bats and other nocturnal wildlife;
• disturbance from traffic, people and domestic animals;
• increased road mortality;
• loss of feeding and nesting areas; and
• pressure on nearby woodland and protected sites.
Pollinators, including bees, depend on connected areas of flowers, hedgerows, field margins and undisturbed habitat. Large-scale development would replace those relationships with roads, buildings, gardens and artificial lighting.
Biodiversity net gain should not be treated as permission to destroy existing habitats. Newly created habitat elsewhere cannot immediately replace mature hedgerows, ancient soils, established woodland or long-standing wildlife corridors.
The first duty should be to avoid harm by choosing a less damaging location.
9. The landscape harm would be extensive
Ashley forms part of a wider rural landscape connected to the Bollin Valley and the Rostherne and Tatton Park area.
Cheshire East Policy ENV 3 identifies the Bollin Valley and Rostherne/Tatton Park as Local Landscape Designations and describes such areas as among the borough’s highest-quality and most valued landscapes. The policy also requires cumulative effects to be considered.
The value of this landscape comes from the combination of:
• open farmland;
• historic field patterns;
• mature hedgerows and trees;
• woodland and coverts;
• rural lanes;
• long views;
• historic buildings;
• tranquillity and dark skies; and
• the gradual transition from Greater Manchester into rural Cheshire.
Development across 291.03 hectares would permanently alter that experience.
A belt of newly planted trees around a housing development would not restore the openness, historic field patterns or sense of separation that had been lost. Landscaping can soften buildings, but it cannot recreate a centuries-old rural landscape.
The Council should therefore require a full cumulative Landscape and Visual Impact Assessment before any site is shortlisted. It should include winter and summer views, effects from public rights of way and roads, artificial lighting, settlement coalescence and the combined impact of all 12 sites.
10. Ashley’s heritage includes its rural setting
Ashley is a historic rural parish. Its significance does not lie only in individual listed buildings. It also comes from the relationship between its buildings, farms, lanes, field boundaries, trees and open countryside.
Historic England records Grade II listed assets in Ashley, including Ashley Hall Farm and the Church of St Elizabeth. Cheshire East policy requires special regard to be given to preserving listed buildings, their settings and their features of architectural or historic interest.
Local evidence identifies a wider group of listed buildings and historic assets that could be affected by development across the submitted area. The Council should verify the complete schedule and assess the setting of every relevant asset.
The setting of a listed building is not limited to its garden or immediate boundary. Open views, approach routes, surrounding fields, estate planting and the relationship between buildings can all contribute to its significance.
National policy requires great weight to be given to the conservation of designated heritage assets and requires clear and convincing justification for harm caused through development within their settings.
Before any site is considered suitable, the Council should require:
• a comprehensive heritage and settings assessment;
• archaeological desk-based research;
• assessment of historic field patterns and hedgerows;
• geophysical survey where appropriate;
• consideration of cumulative landscape change; and
• consultation with the Council’s conservation and archaeological advisers.
These matters must be considered before allocation. They should not be left until a planning application, when the principle of development may already have been established.
11. The loss of productive agricultural land would be unacceptable
The soil information available to residents, including evidence gathered in connection with HS2, indicates that substantial parts of the submitted area may comprise Grade 2 and Subgrade 3a agricultural land.
Both classifications fall within the definition of Best and Most Versatile agricultural land. Cheshire East Policy RUR 5 says that development should avoid the loss of this land and allows the Council to require detailed field assessments.
Before any site is shortlisted, each parcel should be subject to an independent, detailed Agricultural Land Classification survey.
The Council should not rely solely on broad national maps or information supplied without field testing.
The importance of the land goes beyond its current agricultural output. It contributes to:
• food production;
• the rural economy;
• water infiltration and flood management;
• soil carbon;
• landscape character;
• wildlife habitat; and
• the long-term resilience of local food systems.
National policy recognises the economic and wider benefits of Best and Most Versatile land and states that, where significant development of agricultural land is necessary, poorer-quality land should be preferred.
The cumulative loss of hundreds of hectares of connected agricultural land would be very different from the development of a small or isolated field. Once this land is covered by buildings and roads, its agricultural and soil functions cannot realistically be restored.
12. Manchester Airport adds further constraints
Ashley’s proximity to Manchester Airport creates additional noise, safety and safeguarding issues that must be considered before any land is shortlisted.
Cheshire East Policy GEN 5 states that development which would adversely affect the operational integrity or safety of a safeguarded aerodrome will not be permitted. The policy requires consideration of official safeguarding maps and consultation with the relevant safeguarding authority where necessary.
Potential matters include:
• aircraft noise;
• building heights;
• lighting;
• radar and communications interference;
• construction equipment;
• bird-strike risk; and
• drainage or wetland features that may attract birds.
The Council has also confirmed that Manchester Airport’s latest published noise contours are now to be applied in decision-making because aircraft movements in 2025 exceeded the equivalent 2019 figure.
Every submitted parcel should be assessed against the current contours and safeguarding maps. Manchester Airport should be consulted formally before any conclusion is reached on suitability.
Noise mitigation should not be reduced to a requirement for residents to keep windows closed. The Council must consider noise, ventilation, overheating and quality of life together, particularly during warmer summers.
13. The proposal would overwhelm Ashley’s identity
My husband and I bought our home in Ashley five years ago because we wanted to live in a genuinely rural community. We chose the parish for its open countryside, tranquillity, wildlife and distinct village character.
This is not simply about protecting a private view or resisting all change.
The church, cricket club and pub are at the heart of Ashley. Together with the historic buildings, farms, lanes and fields, they give the parish an identity that has developed over centuries.
Development across 291.03 hectares would not complement that identity. It would overwhelm it.
Ashley would no longer be a small rural parish surrounded by open countryside. It would become an existing village enclosed by a large new urban development.
Local people have also lived through years of uncertainty and controversy connected with major infrastructure proposals, including the additional Manchester Airport runway and HS2. I accept that these earlier proposals are not, by themselves, planning reasons to reject the current submissions.
They are, however, important context. The community has already experienced prolonged uncertainty, disruption and concern about the loss of its landscape and way of life. Residents should not now be left for years with another enormous speculative proposal hanging over them.
The Council should provide clear information, meaningful opportunities to comment and early decisions on sites that are plainly inconsistent with a sustainable settlement strategy.
Formal requests
I formally request that Cheshire East Council:
1. Records this letter as a formal Local Plan scoping representation.
2. Links it to every HE and CFS26 submission covering the 291.03-hectare area around Ashley.
3. Publishes the full list of relevant site references, boundaries, proposed uses and non-confidential supporting documents.
4. Assesses the 12 sites individually and cumulatively, including a scenario in which all or most of the land is developed.
5. Retains Ashley’s position as an infill village within the Other Settlements and Rural Areas tier unless compelling independent evidence supports a different conclusion.
6. Does not change the settlement hierarchy or Ashley’s status simply to make the promoted land appear more sustainable.
7. Screens the sites out as unsuitable at the earliest evidence-led stage and does not shortlist or propose them for allocation.
8. Publishes a transparent Green Belt and grey belt assessment addressing sprawl, settlement separation, openness, cumulative effects and the long-term strength of any proposed boundary.
9. Demonstrates that suitable brownfield, underused urban land, higher-density urban opportunities and less constrained locations have been fully examined first.
10. Requires cumulative transport, infrastructure, flood-risk and drainage assessments before reaching any conclusion on suitability or achievability.
11. Requires strategic ecological, landscape, heritage, archaeological and Agricultural Land Classification evidence before site selection.
12. Obtains formal responses from Manchester Airport, highways authorities, utility providers, education and healthcare bodies, the Environment Agency, Natural England and other relevant organisations.
13. Publishes the assessment scores, evidence and reasons if any Ashley site survives the initial screening process.
14. Notifies me directly of every future consultation or decision involving these sites.
Conclusion
The need for housing does not make every promoted site suitable.
Ashley is an infill village in the Green Belt and open countryside. It does not have the settlement function, transport network, services or infrastructure required for strategic growth.
The submitted land also has a concentration of serious constraints involving Green Belt purposes, transport, drainage, flooding, agricultural quality, ecology, landscape, heritage and airport operations.
These are not minor matters that can be dealt with through routine mitigation after the site has been allocated. They go to the central question of whether Ashley is a sustainable location for development on this scale.
It is not.
I therefore ask Cheshire East Council to find these submissions 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 provide further evidence and representations at every subsequent stage of the Local Plan process.
Yours faithfully,
Poonam Millin,
