Local plan scoping consultation

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.

Dear Cheshire East Council,
Hornbeam House
Crewe Business Park
Electra Way
Crewe
Cheshire
CW1 6GJ
T 0300 060 3900
PLANNING CONSULTATION: CHESHIRE EAST LOCAL PLAN SCOPING CONSULTATION
Thank you for your consultation on the above dated and received by Natural England on 21 July
2026.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
We provide the below advice on matters that we would expect to be addressed within the emerging
Local Plan. In addition, the following annexes are appended to this response:
• Annex A: Natural England’s standard advice for air quality impacts for Local Plans, which
also includes policy advice. Natural England no longer provides bespoke advice on air
quality impacts.
• Annex B: Natural England’s recommendations of sources of local plan evidence on the
natural environment.
SCOPE OF THE NEW LOCAL PLAN
Creating a vision and objectives
Natural England advises that the Plan’s vision and objectives should address impacts on and
opportunities for the natural environment and set out the environmental ambition for the plan area.
The plan should take a strategic approach to the protection and enhancement of the natural
environment, including providing a net gain for biodiversity, considering opportunities to enhance
and improve connectivity.
Planning for growth
Identifying and assessing sites
Natural England requests full consideration of the natural environment in the process of selecting
and assessing sites for allocation through the Local Plan. Development allocations should be
screened and assessed in the Strategic Environmental Assessment (SEA) and Habitats Regulations
Assessment (HRA) to determine their impact on the natural environment, including designated sites.
Any mitigation measures identified through the SEA or HRA as necessary to avoid potential impacts
on the natural environment should be embedded as requirements within site-specific policies in the Local Plan.
Green Belt
Plan policies and proposals should positively enhance land within the Green Belt. This should
include compensatory improvements to environmental quality and accessibility of remaining Green
Belt where land is removed from the Green Belt.
Green Belt land can often be degraded ‘urban fringe’ landscapes. Therefore, there will be
opportunities to ‘green’ the Green Belt and deliver environmental benefits such as landscape
enhancement, habitat creation and enhancement, and improved access to nature.
Spatial distribution
In setting an overall strategy to guide development and allocate land the Local Plan should:
• conserve and enhance the natural environment, including landscapes and green
infrastructure;
• make as much use as possible of previously developed or ‘brownfield’ land;
• allocate land with the least environmental or amenity value.
It should be recognised that some previously developed land is important for biodiversity as it can
contain open mosaic habitats (dataset), a priority habitat.
Transport and infrastructure
The Plan should recognise the role that transport networks, and their associated green
infrastructure, can play in providing valuable ecosystem services that assist in the management of,
and adaptation to, climate change e.g. carbon storage, drainage and water conservation, and
cooling urban heat islands. Natural England’s work on the Green Transport Corridors project with
Network Rail, Highways England, Wildlife Trusts and Nature Improvement Areas, builds on the
Government’s Natural Environment White Paper commitment to work with transport bodies to
enhance ecological connectivity on transport networks.
Natural environment
Designated sites
The Plan should include policies and proposals to protect and enhance biodiversity, including
designated nature conservation sites (internationally, nationally and locally designated sites of
importance for biodiversity1). Natural England advises that all relevant designated sites should be
included on the proposals map for the area so they can be clearly identified in the context of
proposed development allocations and policies for development. Designated sites should be
protected and, where possible, enhanced.
The Local Plan should be screened under Regulation 105 of the Conservation of Habitats and
Species Regulations 2017 (as amended) at an early stage so that outcomes of the assessment can
inform key decision making on strategic options and development sites. It may be necessary to
outline avoidance and/or mitigation measures at the plan level, which will usually need to be
considered as part of an Appropriate Assessment, including a clear direction for project level HRA
work to ensure no adverse effect on the integrity of internationally designated sites. It may also be
necessary for plans to provide policies for strategic or cross boundary approaches, particularly in
areas where designated sites cover more than one Local Planning Authority boundary. The direct and indirect impacts of proposed development to designated sites should be considered,
including impacts on water quality and supply to hydrologically sensitive designated sites (see
PPG). Cheshire East features a network of water sensitive meres and mosses including Rostherne
Mere and the Midlands Meres and Mosses Ramsar sites, as well as multiple standalone SSSIs, so
the importance and sensitivity of these sites should be reflected in the Local Plan.
The Plan should make explicit reference to geological conservation (including protection for
geological SSSIs and local geological sites) and the need to conserve, interpret and manage
geological sites and features in the wider environment.
Criteria-based policies to guide development should include application of the mitigation hierarchy2
and how the direct, indirect and cumulative impacts of development on designated sites will be
addressed.
Further information on designated sites is at Designated Sites View. Natural England’s Impact Risk
Zones (IRZs) on MAGIC maps (user guide) identify potential development impacts.
Habitats and species
Where a plan area contains irreplaceable habitats, such as ancient woodland, ancient and veteran
trees, there should be appropriate policies to ensure their protection. Natural England and the
Forestry Commission have produced standing advice on ancient woodland, ancient and veteran
trees. The Plan should also protect and enhance priority habitats and species. Details can be found
on the Joint Nature Conservation Committee website, standing advice for protected species and on
MAGIC maps.
The Cheshire and Warrington Local Nature Recovery Strategy (LNRS) also identifies a set of
priority species and species assemblages that have been identified as locally important and in need
of additional conservation effort. The LNRS sets out a suite of potential measures to address the
needs of these species, and the Local Plan should take account of these priorities and measures as
per the LNRS as a whole.
Biodiversity net gain
The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.
This should include setting a percentage target level of provision of at least 10% net gain, higher
targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain
(BNG) strategy including:
• requirements for on-site and off-site provision
• identifying priority opportunities of strategic significance using the Cheshire and Warrington
LNRS (further information below under the ‘nature recovery’ heading)
• advising on the metric to use to calculate gains, for example the most up to date version of
Defra’s Biodiversity Metric.
The Plan should also aim to achieve wider environmental gains, going beyond BNG, to include
wider natural capital benefits such as improved water and air quality and recreation. Natural
England’s Environment Benefits from Nature tool can help identify opportunities.
Hydrology
Natural England expects the Plan to consider the strategic impacts on water quality and water
resources and to address flood risk management. The Local Plan should be based on an up-to-date
evidence base on the water environment and as such the relevant River Basin Management Plans (RBMPs) should inform the development proposed in the Local Plan. RBMPs (available here)
implement the EU Water Framework Directive and outline the main issues for the water
environment and the actions needed to tackle them. Local Planning Authorities must, in exercising
their functions, have regard to these plans. It is worth noting that RBMPs are in the process of being
updated by the Environment Agency (EA), and the EA also have a wealth of more up-to-date data
available here: Water Data Explorer.
The Local Plan should contain policies which protect habitats from water related impacts, including
nutrient mitigation, and where appropriate seek enhancement. Priority for enhancements should be
focussed on internationally designated sites, SSSIs and local sites which contribute to a wider
ecological network.
Nutrient pollution is a significant problem for our freshwater habitats and estuaries, adversely
affecting water quality. Ensuring that our rivers and protected sites are clean, healthy and resilient is
critical to meeting the Government’s ground-breaking 25 Year Environment Plan which underpins
the shared ambition to leave the environment in a better state for future generations. As part of the
background information to water quality, Natural England would expect consideration of nutrient
neutrality.
New overnight development located within the nutrient neutrality catchment (as defined by Natural
England) must demonstrate how it will address the impacts of potential nutrient loading through a
HRA and include a nutrient budget calculator and mitigation strategy where necessary. The
Rostherne nutrient neutrality evidence pack is available here: Rostherne Mere Ramsar - Evidence
Pack - TIN203, and for Wybunbury Moss here: West Midland Mosses Special Area of Conservation - Evidence Pack - TIN206.
Policies should address water use, promoting the use of sustainable drainage systems (SuDS) and
water sensitive design as part of a wider green and blue infrastructure approach. Where there is
known water constraint, policies should manage available resources, such as through water
efficiency or water reuse measures.
The Local Plan should have regard to relevant Diffuse Water Pollution Plans (DWPPs) for
internationally and nationally designated sites of importance for biodiversity, including the DWPP for
Wybunbury Moss.
Peat
Based on the England Peat Status GHG and C Storage dataset, Cheshire East has over 2,250
hectares of deep peat within its boundary. It is important that this is protected from development
through planning policy. Development on peat results in the permanent loss of an irreplaceable
resource, including vast quantities of carbon stored in these soils, whether through extraction or
surface sealing. Such loss cannot be effectively mitigated. Natural England does not support the
principle of development on deep, restorable peat.
We strongly encourage that the Local Plan includes adequate protection to the authority’s peat
resources from extraction and harmful development. It should define deep, restorable peat as peat
soils of 30cm or more in depth where it occurs at or near the surface and is not overlain by a
substantial layer of made ground or other mineral material, and by explicitly stating that
development in these areas will not be permitted. It may also be beneficial to clarify that shallow
peat refers to peat soils less than 30cm in depth. These soils remain an important carbon store and
can be highly sensitive to disturbance.
It would be helpful if policies and supporting text should set out clear planning application
requirements in areas where deep peat may be present. The England Peat Status Greenhouse
Gas and Carbon Storage can be used as an initial screening tool to identify potential areas of deep
peat. Natural England advises that this dataset should inform decisions on whether more detailed
ground investigations are required. You could consider including this dataset in the assets map.
Additional sources of evidence include the British Geological Survey maps portal and existing borehole data from the British Geological Survey.
We note from the map of call for sites submissions that there are a number of submitted sites on
deep peat, based on the England Peat Status GHG and C Storage dataset. Multiple of these sites
appear to be situated on areas of deep peat which are connected to internationally and nationally
designated sites. In line with our advice outlined above, Natural England does not support the
principle of development on deep, restorable peat and recommend strong consideration is given to
peat when determining which sites to take forward.
Consideration should be given not only to avoiding development on areas of deep peat, but also to
the potential impacts of development on the wider peat mass, ensuring that the location of proposed
allocations does not hinder the delivery of the objectives of the Lindow Moss Landscape Partnership
Project (The Lindow Moss Landscape Partnership - Cheshire Local Nature Partnership).
The Cheshire and Warrington LNRS identified peatland as a key priority habitat to be restored
across the county, and included specific measures related peatland restoration:
• P1.1 Where possible, peatland habitat should be restored. Where development is proposed,
it should not create harm, which cannot be mitigated.
• P1.2 Improve the condition and functioning of upland peatlands through appropriate
measures to re-wet habitats, to revegetate bare peat, to establish appropriate vegetation,
and to stabilise areas of erosion, reducing carbon emissions and creating conditions for
future peat formation, carbon sequestration and improved natural flood management.
• P1.3 Increase lowland raised bog restoration.
• P1.4 Enhance and restore blanket bog plant diversity.
• P1.5 Develop opportunities for local businesses to invest in peat restoration.
The Cheshire East Local Plan has the potential to contribute to all of these peatland-focused LNRS
measures, however measure P1.1 will be of particular relevance to the Plan. It highlights that
peatlands should be restored wherever possible and development should avoid damaging or
destroying this irreplaceable resource.
Green and blue infrastructure
Green infrastructure (GI) refers to the living network of green spaces, water and other environmental
features in both urban and rural areas. It is often used in an urban context to provide multiple
benefits including space for recreation, access to nature, flood storage and urban cooling to support
climate change mitigation, food production, wildlife habitats and health and wellbeing improvements
provided by trees, rights of way, parks, gardens, road verges, allotments, cemeteries, woodlands,
rivers and wetlands. GI is also relevant in a rural context, where it might additionally refer to the use
of farmland, woodland, wetlands or other natural features to provide services such as flood
protection, carbon storage or water purification.
Natural England advise any GI is designed and delivered in alignment with Natural England’s Green
Infrastructure Framework (GIF). The GIF was launched in January 2023 to aid local authorities and
developers in embedding GI into local planning policy and new development with a view of further
integrating the Lawton Principle of bigger, better and more connected ecological networks. The GIF
includes, but is not limited to, five key components:
• GI Principles – the why, what and how principles developed to underpin the GIF;
• GI Standards – guidance on national standards for GI quantity and quality:
S1: Green Infrastructure Strategy Standard
S2: Accessible Greenspace Standard
S3: Urban Nature Recovery Standard
S4: Urban Greening Factor (UGF) Standard
S5: Urban Tree Canopy Cover Standard;
• GI Mapping Toolkit – mapped environmental, socio-economic datasets to support the
standards and identification of priority and opportunity areas;
• GI Planning and Design Guide 2023 – a practical, evidence-based advice booklet on how to
design good quality GI;
• GI Process Journeys – a set of guides on how to apply the above components in practice
including a Process Journey for Developers and Design Teams.
The December 2025 draft NPPF makes explicit reference to Natural England’s GI standards in
policies GB8, HC1, HC3 and N1. As such, we strongly encourage Cheshire East’s Local Plan to set
standards for GI provision in line with the GIF, tailoring these as necessary to local circumstances
and evidence.
Natural England encourages Cheshire East to include an Urban Greening Factor (UGF) standard
within local planning policy. Local authorities elsewhere in England have introduced an UGF via
policy, strategy or supplementary planning documents requiring new development proposals
to demonstrate the highest feasible levels of greening and include an UGF calculation; see UGF
Case Studies for further information. The introduction of a UGF would provide a mechanism to
increase urban biodiversity where development may be exempt from BNG requirements because of
zero scores within metric calculations. We refer you to the Urban Greening Factor User Guide and
would be happy to support in the development of a UGF.
Also, the Plan can make use of data available through Natural England’s GI Map as part of the
baseline. Natural England has launched two new mapping tools on the database to map health
inequality and environmental pressures: the Environmental Equity Index (EEI) and the Index of
Multiple Environmental Deprivation (IMED). Further details on the EEI and IMED can be found here.
Nature recovery
Natural England welcomes reference to the Cheshire and Warrington Local Nature Recovery
Strategy (LNRS) in the listed plans and strategies to help inform the local plan, and we highlight the
statutory duty of Local Planning Authorities (LPAs) to take the LNRS into account in plan-making.
LPAs are required under the Gateway 1 approach to consider vision and objectives as well as
prepare for SEA. The LNRS can be used to inform these processes and ensure LPAs take account
of biodiversity and nature recovery, including the wider social and economic benefits of those
opportunities.
The priorities for nature recovery and associated mapped and unmapped measures can provide
evidence to justify a variety of policy approaches in a local plan, including, but not limited to, open
space, natural health, GI and transport, as well as environmental policies. LNRSs contain delivery
guidance for a wide range of audiences, including designers and developers. Unmapped
measures are deliverable across the LNRS area wherever relevant to existing or proposed habitat.
Policy links occur between LNRS and BNG, particularly because, in line with the Statutory
Biodiversity Metric Guidance, the LNRS is the sole indicator of Strategic Significance uplift within the
statutory BNG metric. As such, it provides a valuable tool for informing BNG requirements for new
development, offering a 1.15 uplift in biodiversity value where proposals deliver actions mapped in
the LNRS.
Where monitoring of the emerging Local Plan is proposed it would be useful to include opportunities
to capture nature recovery achievements as a result of the Plan, using the LNRS as a baseline.
Responsible authorities leading on LNRSs are now required by Defra to monitor and report on the
delivery of nature recovery actions across their LNRS area as part of their statutory delivery role.
Aligning Local Plan monitoring with nature recovery objectives would generate valuable data and
evidence, supporting responsible authorities in meeting these reporting requirements while also
demonstrating the Plan’s contribution to wider environmental outcomes.
The priorities and measures in an LNRS (both mapped and unmapped) can steer appraisal /
assessment and policy development to ensure that opportunities for nature recovery and naturedevelopment and land use change are embedded in economic and social policies as well as
decision making.
The Local Plan should also refer to the Bollin to Mersey Nature Recovery Partnership (NRP), one of
twelve Nature Recovery Projects across England. These multi-partnership projects are designed to
fast-track nature recovery by working collaboratively to create and restore wildlife-rich habitats,
corridors and stepping-stones to help wildlife populations to move around freely. Cheshire East
Council, alongside Defra bodies and neighbouring authorities in southern Greater Manchester, sit
on the NRP ‘core partners’ group, and have been able to shape the NRP vision and priorities. The
Bollin to Mersey NRP aims to transform the natural landscape of northern Cheshire and southern
Greater Manchester, which was drained over centuries for agriculture and urban development, into
a connected network of water, wetland and woodland habitats bringing nature closer to where
people live, work and play. The Local Plan should consider the NRP and how it could contribute to
achieving this vision for the landscape.
Agricultural land and soils
The Plan should contain policies to protect Best and Most Versatile (BMV) agricultural land (Grades
1, 2, 3a). Polices should avoid the loss of BMV land. The Plan should recognise that development
has an irreversible adverse impact on the finite national stock of BMV land. Any development
proposed on BMV land should be informed by a detailed soil survey.
The Plan should have a policy for the protection of and sustainable management of soils on
development sites. This should set out mitigation measures to minimise soil disturbance and retain
as many ecosystem services as possible through careful soil management during the construction
process and appropriate soil re-use. The Plan should recognise that development (soil sealing) has
a major and usually irreversible adverse impact on soils. The impact of all types of development on
soils should be considered.
Healthy soils are not only important for agriculture, but soils with high environmental value (e.g.
wetland carbon stores such as peatland and low nutrient soils) are also important to ecological
connectivity. Development should be supported by soils surveys and management plans - see
Defra’s Code of Practice for the sustainable use of soils on construction sites.
Landscape
The plan area is next to the Peak District National Park, and we advise that you take into account
the relevant Management Plan for the landscape. Development proposals brought forward through
the plan should avoid significant impacts on protected landscapes, including those outside the
plan’s area.
The Plan should include policies and proposals for conserving and enhancing the landscape. It
should identify, protect and enhance locally valued landscapes, informed by landscape character
assessments. Policies for development in or adjacent to rural areas and urban fringe should ensure
they reflect the character of the countryside, as well as seeking opportunities for enhancement and
improved access to nature.
The Plan should include policy wording to reduce light pollution. Lighting can be harmful to wildlife
and undermine enjoyment of the countryside or night sky, especially in intrinsically dark landscapes,
such as protected landscapes and nature reserves. Where appropriate, the Plan should identify
areas of tranquillity and include policy wording to protect them.
Health and wellbeing
Health and Health Inequalities
Spending time in green and blue spaces has been shown to encourage physical activity and promote better mental health and wellbeing. Such spaces create opportunities for recreation,
community gatherings, connecting with nature, and social interaction. For more information, see
Natural England’s Review of Nature Exposure and Human Health and Wellbeing, the Natural and
Sustainable Environments chapter of Spatial Planning for Health, and The Nature Connection
Handbook.
The Environmental Improvement Plan set a commitment that everyone should live within 15
minutes’ walk of a green or blue space. An analysis of accessible green space in England is
available through Natural England’s Mapping Database. The potential to set local standards for the
provision of open spaces can utilise Natural England’s Accessible Greenspace Standard to help
determine the size, proximity, capacity and quality of the GI needed to provide everyone with access
to a variety of quality green and blue spaces close to their home.
Active Travel
Embedding GI into walking and cycling routes can encourage the uptake of active travel, supporting
increased physical activity, improved air quality and the reduction in vehicular traffic. Creating green
corridors assists with urban cooling and increases people's opportunities to connect with nature. For
more information we refer you to page 76 of the Natural England Green Infrastructure Planning and
Design Guide and The Healthy Streets approach.
Policies should provide for better connections and address unequal access to nature to support
health and wellbeing outcomes. The design of new or improved routes should consider a range of
modes of access including walking and cycling, as well as a range of users including children and
older people, different socio-economic groups and people with disabilities. Natural England advise
that the Plan should ensure protection and enhancement of public rights of way.
Climate Change
Tree-lined streets provide shade and reduces urban heat islands, making it safer and more
comfortable for everyone to be outside, particularly groups that are vulnerable to extreme heat (like
children, older people and people with disabilities). The Local Plan could set targets to increase
urban tree canopy cover in line with Natural England’s Urban Tree Canopy Standard.
Climate Change Adaptation
The Plan should recognise that climate change mitigation and adaptation and biodiversity loss are
interlinked. Many habitats provide essential ecosystem services to allow adaptation to climate
change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining
peat as a carbon store. Policies should set out appropriate nature-based solutions for climate
mitigation and adaptation such as woodland or wetland creation.
Consideration also needs to be given to the likely impacts of climate change on protected sites,
habitats and species. See the Climate Change Adaptation Manual, Carbon Storage and
Sequestration by Habitat and National biodiversity climate change vulnerability model.
Renewable and Low Carbon Energy
Should the Local Plan identify locations and/or include a policy guiding wind, solar or other low
carbon energy generation, consideration should be given to the impact of proposals (individually
and cumulatively) on protected landscapes, nature conservation sites and soils (including areas of
shallow and deep peat).
Heritage
Heritage assets, whether tangible elements like sites and structures or intangible elements such as
stories and cultural practices, serve as valuable catalysts for social interaction within communities.
Narratives passed down through our cultural heritage provide a foundation for our sense of place and our belonging in society.
Natural and cultural heritage can open up richer access to the outdoors and nearby places of
significance, from ancient woodlands with deep histories to notable geological formations and even
urban environments shaped by vibrant cultural and industrial traditions.
Canal networks, public rights of way and disused railways are examples of historic routes.
Enhancing these heritage corridors can support their long-term preservation and support nature
recovery while strengthening their role in connecting people with nature and promoting active travel.
Local plan evidence base
Natural England would welcome reference to the Cheshire East Green Infrastructure Plan (2019 to
2030) in the list of plans and strategies to help inform the new local plan. We would encourage
Cheshire East Council to consider producing/commissioning an updated green and blue
infrastructure (GBI) strategy, particularly with the existing plan due to become outdated in a few
years.
ADDITIONAL MATTERS
Habitats Regulations Assessment
The Local Plan’s policies and site allocations should be screened in the HRA to determine whether
they will have a likely significant effect (LSE) on internationally designated sites (SACs, SPAs and
Ramsar sites). Those elements of the Plan with potential for LSEs should be taken through to an
Appropriate Assessment (AA) to determine whether there will be an adverse effect on the integrity
of the designated site when mitigation is taken into account.
Where there is LSE alone, these site allocations and/or policies need to be taken to AA alone.
Where there is no LSE alone, these sites need to be assessed in-combination with other plans or
projects, including relevant NSIPs, to establish if, together, they result in an LSE that needs to be
considered at AA. This in-combination assessment of LSE ruled out alone should come before
the AA. 
First, the AA must look at the potentially damaging aspects of each site allocation and/or policy and
the potential effects on the site features and conservation objectives and characterise the impacts in
terms of their likelihood, nature, scale, severity and duration. This assessment needs to include a
consideration of the impacts on:
• The extent and distribution of qualifying habitats and species;
• The abundance and spatial distribution of qualifying species or assemblages;
• The structure of the qualifying habitat, which should not be affected in terms of abundance
and diversity;
• The physical, chemical and biological processes that support the qualifying habitat to ensure
these are not affected.
The AA must then look at any potential mitigation measures, to determine if they can reduce the
likelihood, nature, scale, and duration of the effect to a lower level. The AA should seek mitigation
measures that are capable of implementation and will reduce the impact to the lowest level possible.
Any residual effects after applying mitigation should also be considered alone and in-combination.
Strategic Environmental Assessment
Natural England expect standalone SSSIs (those which do not overlap with internationally
designated sites) to be assessed in the SEA to determine the effects of the Plan’s policies and
allocations. It is also important to highlight that the notified features of a SSSI may differ from those of the overlapping internationally designated site, meaning the HRA may not fully cover the SSSI
assessment, and we expect this to be considered in the SEA. Further information on SSSIs and
their designation can be found on Designated Sites View.
The SEA should also consider the Plan’s impact on other biodiversity assets, including protected
landscapes, peat, priority habitats and species, irreplaceable habitats, ancient woodland and BMV
land. The SEA can also establish how the Plan will enhance the natural environment, for example
through nature restoration, implementation of nature-based solutions, improving access to
greenspace and supporting the delivery of the LNRS.
Nature Towns and Cities
We recommend Cheshire East Council consider taking part in the Nature Towns and Cities
Accreditation scheme as part of your local planning process. The scheme aligns to implementation
of the GI Framework and Standards and is designed to recognise towns and cities that put nature
and GI at the heart of their communities. The accreditation has been co-designed and tested with a
group of local authorities, with input from the voluntary sector, independent experts and government
agencies.
Achievement of accreditation demonstrates that a local authority has a strong commitment to
transforming GI to benefit people, place and nature and is working with communities and other
partners to create greener, healthier, resilient and thriving places. Applications could be for a whole
authority area or a specific town within it.
Why apply for accreditation?
• The process of accreditation is based on a framework that will help you plan how GBI can
deliver across a range of priorities in your place, supporting the process of implementing a
new GBI Strategy as part of your Local Plan process. It will support authorities in evaluating
their current GBI, supported by a self-evaluation tool and to consider links between GBI and
public health, climate resilience, community empowerment and nature recovery and pressing
issues like economic growth, active travel, and youth skills and employment.
• Strengthen your partnerships: The accreditation process supports the building of
partnerships to deliver change, creating a sense of shared direction and building capacity
across a place.
• Get external recognition for your plans to deliver urban landscape-scale change, which will
help you make the case for investment and gain support from partners and the public.
• Secure funding and investment: Accreditation will provide assurance to potential funders and
investors that your place is equipped to deliver ambitious change. This will help to attract
funding and finance from public, private and philanthropic sources.
We would be happy to support Cheshire East if you are interested in pursuing a Nature Towns and
Cities accreditation - please do get in touch if this is of interest to you. Nature Towns and Cities run
a free online monthly call where interested parties can find out more about the accreditation
scheme, please visit Accreditation support series - Nature Towns & Cities to sign up for forthcoming
sessions.
In addition to accreditation, the Nature Towns and Cities programme is supported by a free network
that you can join by entering your email address at the bottom of the website. The network has a
free to access resource library to support planning and delivery for urban nature and green spaces,
featuring case studies, articles and past webinars: Resources Library - Nature Towns & Cities and a
rolling events programme: Events - Nature Towns & Cities.