Local plan scoping consultation

Subject: Formal Objection to SHELAA Land Submission: 291.03-Hectare Area, around Ashley
(12 adjoining sites totalling 291.03 hectares)
Formal Representation
I am writing to formally register my objection to the inclusion and consideration of the 291.03
hectare land submission surrounding Ashley in the Cheshire East Strategic Housing and
Economic Land Availability Assessment (SHELAA) and Local Plan review (12 adjoining sites
totalling 291.03 hectares).
This site is fundamentally unsuitable for strategic development. Below are the key planning
policy grounds demonstrating why this submission directly conflicts with national and local
planning frameworks.
1. Incompatibility with Green Belt Policy & Failure of "Grey Belt" Criteria
• "Wash-Over" Green Belt Designation: The entire parish of Ashley is designated as
"wash-over" Green Belt under Policy PG 3 (Green Belt) of the Cheshire East Local Plan
Strategy (CELPS). This status confers maximum protection to preserve the open, rural
character of settlements surrounded by sensitive countryside.
• Strategic Buffer: Ashley forms the narrowest remaining green buffer between Greater
Manchester (Trafford/Hale/Altrincham) and the towns and villages of Cheshire East
(Mobberley/Knutsford). Development here would directly breach core Green Belt
purposes defined in Paragraph 143 of the National Planning Policy Framework
(NPPF)—specifically Purpose (a) to check unrestricted urban sprawl, Purpose (b) to
prevent neighbouring towns from merging, and Purpose (c) to safeguard the countryside
from encroachment.
• Failure of "Grey Belt" Tests: Under revised national planning guidance, Green Belt
land can only be released if it qualifies as "Grey Belt" (previously developed land or land
making a negligible contribution to Green Belt purposes). Open, working farmland
across Ashley strongly fulfills Green Belt functions and is further disqualified
under NPPF Footnote 7 due to the presence of statutory environmental, heritage, and
agricultural constraints.
2. Breach of Spatial Strategy & Sustainable Settlement Hierarchy
• Incompatible Settlement Rank: Ashley is classified at the lowest tier of the settlement
hierarchy under CELPS Policy PG 2 (Settlement Hierarchy). It lacks the essential
social infrastructure, medical services, primary educational capacity, and local
employment required to support residential growth.
• Conflict with Sustainable Development: Allocating major growth in a rural location
without high-frequency public transport directly contravenes CELPS Policy SD 1
(Sustainable Development in Cheshire East), CELPS Policy SD 2, and NPPF
Chapter 2, which mandate directing development to Tier 1 Principal Towns and Tier 2
Key Service Centres.
3. Severe Highway Safety Risks & Statutory Aviation Safeguarding
• Highway Network Capacity: The rural road network serving Ashley relies on narrow
lanes, single-track bridges, and severe pinch points. The volume of vehicle movements
generated by a 291-hectare site would cause severe cumulative network congestion and
safety hazards, conflicting directly with CELPS Policy CO 1 (Sustainable Travel and
Transport), Policy CO 4, and NPPF Paragraph 115.
• Statutory Airport Safeguarding: The site sits directly beneath operational noise
contours and bird-strike hazard management zones for Manchester Airport. Introducing
high-density housing here conflicts with statutory aerodrome safeguarding protocols
and CELPS Policy SE 12 (Pollution and Land Instability) regarding public safety and
noise exposure.
4. Flood Risk, Drainage & Utility Constraints
• Surface Water & Drainage: The area lacks deep sewer networks, main grid upgrades,
and surface water drainage capacity. Allocating large-scale development would exacerbate
surface water flooding in the River Bollin catchment, violating CELPS Policy SE 13
(Flood Risk and Water Management) and NPPF Chapter 14 (Paragraphs 165–175).
• Infrastructure Deficits: Under CELPS Policy IN 1 (Infrastructure), candidate sites
must demonstrate deliverable utility connections without causing off-site environmental
harm.
5. Unacceptable Loss of Best and Most Versatile (BMV) Agricultural Land
• Food Security & Soil Quality: Soil assessments (including HS2 Phase 2b data) confirm
the site comprises Grade 2 and Subgrade 3a Best and Most Versatile (BMV) agricultural
land. The site comprises a continuous tract of Best and Most Versatile agricultural land
rather than isolated parcels, increasing its strategic importance for food production.
• Policy Conflict: National policy (NPPF Paragraph 180) and local strategy (CELPS
Policy SE 2: Efficient Use of Land) explicitly mandate that local authorities protect
high-grade agricultural land for food security and direct development to brownfield or
lower-quality land first.
6. Irreparable Harm to Landscape, Ecology & Historic Assets
• Landscape Protection: The proposal would destroy the setting of the Bollin Valley and
Parklands Local Landscape Designation (LLD) and the Rostherne/Tatton Park LLD,
violating CELPS Policy SE 4 (The Landscape).
• Ecological Degradation: Development would sever protected ecological corridors and
threaten sensitive habitats, including Cotterill Clough Nature Reserve/SSSI,
breaching CELPS Policy SE 3 (Biodiversity and Geodiversity) and NPPF
Paragraphs 180–185.
• Heritage Impact: The site encompasses the settings of 19 Grade II listed buildings
(including Ashley Hall). Under CELPS Policy SE 7 (The Historic
Environment) and NPPF Chapter 16 (Paragraphs 200–208), great weight must be
given to conserving designated heritage assets and their landscape settings.
Conclusion & Formal Request
This 291.03-hectare submission (12 adjoining sites totalling 291.03 hectares) conflicts with
almost every fundamental constraint metric used in plan-making. It breaches local spatial
strategy, fails national Green Belt policies, lacks basic infrastructure, destroys high-grade
agricultural land, and threatens protected heritage and landscape assets.
I formally request that Cheshire East Council classify these submissions as Unsuitable,
Unavailable, and Undeliverable in the SHELAA assessment and exclude them from any
future Local Plan allocations.