Local plan scoping consultation

To whom it may concern
I am writing in response to the Cheshire East New Local Plan Scoping Consultation. I strongly object to the allocation of the adjoining Call for Sites submissions at Ashley, or to any spatial strategy which identifies Ashley for a new settlement, major urban extension or other large-scale development.
I recognise that Cheshire East must plan positively for new homes, employment and infrastructure. My objection is not to housebuilding or growth, it is to directing development towards productive Green Belt farmland in a small, poorly connected rural parish before the Council has comprehensively identified and unlocked the substantial regeneration opportunities within Cheshire East’s existing towns.
The Local Plan should use housing to solve two problems at the same time:
1. meeting the need for new homes; and
2. regenerating struggling town centres affected by retail contraction, vacant commercial space, underused upper floors, surface car parks and obsolete buildings.
Allocating large-scale housing on agricultural Green Belt may be the easier development option, but it is not necessarily the most intelligent, sustainable or beneficial option for Cheshire East.
1. Scale and cumulative impact at Ashley
Approximately 291.03 hectares of agricultural land around Ashley are understood to have been submitted through the Call for Sites process.
At an illustrative density of 30 dwellings per hectare, that land has a theoretical capacity of:
291.03 hectares × 30 dwellings per hectare = approximately 8,731 homes.
I recognise that this is an illustrative gross calculation rather than Tatton Estates’ confirmed development proposal. The actual capacity would depend upon the amount of land required for roads, schools, drainage, infrastructure and open space.
Nevertheless, the calculation demonstrates the extraordinary potential scale of the land assembled around Ashley. It is not credible to consider these parcels as isolated or unrelated sites. Taken together, they could facilitate a substantial new settlement and permanently transform the whole parish.
The Council must therefore assess the submitted parcels collectively and cumulatively, including their combined effects on Green Belt purposes, landscape, agriculture, highways, infrastructure, drainage, ecology, heritage and the identity of Ashley.
2. A town-centre and brownfield-first alternative
Cheshire East should adopt a clear “town-centre and brownfield first” spatial strategy.
The borough contains town centres where the historic amount of retail and commercial floorspace is no longer economically sustainable. This is not simply a liability: it is an opportunity to introduce new homes, healthcare, community services, employment, leisure, culture and accessible green space into existing centres.
Town-centre housing can:
• reuse vacant and obsolete buildings;
• redevelop underused shopping areas and surface car parks;
• increase footfall and local spending;
• support remaining shops, markets, cafés, pubs and services;
• create activity beyond traditional shopping hours;
• improve natural surveillance and perceptions of safety;
• support public transport and active travel;
• bring empty upper floors back into productive use;
• provide homes close to employment, health and civic services;
• reduce pressure to build on productive farmland; and
• strengthen the commercial case for investment in buildings and public realm.
This would meet housing need while also helping repair and reactivate existing places. Greenfield development at Ashley would meet housing demand only by creating a separate infrastructure requirement and potentially weakening existing centres further.
The Council should not regard the existing poor quality or weak residential market of some town centres as a reason to direct development elsewhere. That condition is part of the planning problem the Local Plan must address.
If people are presently reluctant to live in a centre because it feels unattractive, unsafe, empty or overly dependent upon failed retail, the answer should be to improve that centre—not to abandon it and consume Green Belt instead.
The Local Plan should combine housing allocations with:
• high-quality public realm;
• trees and accessible green space;
• healthcare and wellbeing provision;
• community and cultural uses;
• active ground-floor frontages;
• good walking and cycling connections;
• improvements to public transport;
• conversion or redevelopment of obsolete property;
• appropriate employment space; and
• long-term stewardship and management.
Well-designed homes are not merely an outcome of regeneration. Residents themselves provide the everyday population, spending, surveillance and civic life needed to sustain regeneration.
I have c 35 years’ experience as a property professional dealing with primarily town centres, so I clearly understand the landscape, the challenges, and I believe the solutions.
3. Crewe demonstrates the opportunity
Crewe is an immediate example of why Cheshire East should pursue this approach more comprehensively.
The Council has already acknowledged the need to move away from relying upon a struggling retail sector. It is progressing housing-led regeneration of council-owned sites in the town centre, including the undeveloped Royal Arcade land and the Chester Street and Delamere Street car parks.
The Council has indicated that these sites could provide more than 300 new homes alongside commercial space and improved public realm. It has expressly recognised that additional town-centre residents can increase footfall, strengthen the sense of community and make the centre livelier and more attractive.
The adopted planning approach for Central Crewe already supports:
• new homes at approximately 40 dwellings per hectare;
• redevelopment of underused sites;
• mixed residential, commercial, leisure and cultural uses;
• rationalisation of car parking;
• improved connections between the station and town centre; and
• residential development to support evening activity, natural surveillance and town-centre vitality.
This is precisely the type of development model the new Local Plan should expand.
Crewe has a railway station, bus services, existing roads, shops, a market hall, a lifestyle centre, schools, healthcare, employment and civic infrastructure. Housing there can make more efficient use of existing investment and help support services already in place.
By comparison, large-scale growth at Ashley would require the creation or major expansion of roads, schools, utilities, drainage, healthcare, public transport and community facilities. It would also generate extensive additional travel to places where those services already exist.
The Council should identify further opportunities in Crewe and undertake the same exercise across other struggling centres in Cheshire East before concluding that productive Green Belt must be released.
4. A more intelligent assessment of urban capacity
The Council’s assessment should go beyond a conventional list of obvious vacant sites. It should undertake a comprehensive urban-capacity and town-centre regeneration exercise covering:
• vacant and underused retail premises;
• obsolete shopping centres and retail blocks;
• empty upper floors;
• redundant offices and commercial buildings;
• surface car parks;
• low-density retail parks;
• publicly owned land;
• stalled development sites;
• land around railway stations and transport hubs;
• opportunities to assemble adjoining ownerships;
• sites capable of mixed-use intensification;
• buildings suitable for conversion or airspace development; and
• opportunities arising from changes in retail and office demand.
Sites should not be dismissed merely because they are more complicated than agricultural land. Fragmented ownership, remediation, demolition, viability and public-realm requirements are challenges to be addressed through planning, land assembly, partnership and investment—not reasons to select the easiest greenfield alternative.
The Council should consider using:
• development partnerships;
• development corporations or regeneration vehicles;
• compulsory purchase powers where justified;
• public-sector land assembly;
• Homes England support;
• infrastructure and regeneration funding;
• patient public and private capital;
• masterplans and design codes; and
• cross-subsidy between higher-value and lower-value uses.
Furthermore, the evolution of the Combined Authority presents a new opportunity to create a collaborative approach between borough’s to housing development, that may allow us to preserve our precious countryside. We are already struggling on many health indices be it the epidemic of mental health or obesity- less open countryside magnifies the issue. Better town centres become more desirable places to live and potentially close the viability gap with which, so many are struggling.
The purpose of a strategic Local Plan is not simply to identify land on which a volume housebuilder can build most easily. It is to shape the most sustainable and beneficial future for the whole borough.
5. Health, wellbeing and place quality
Housing and health should not be considered separately.
Town centres provide opportunities to combine new homes with primary and community healthcare, diagnostics, prevention, mental-health support, pharmacies, childcare, employment services, leisure, nutrition, social prescribing and community facilities.
Locating these services in accessible centres can:
• provide convenient access for existing and new residents;
• support early intervention and prevention;
• reduce isolation;
• generate regular footfall;
• reactivate vacant property;
• support cafés, markets and other businesses;
• create employment; and
• improve the overall appeal of the town as a place to live.
A healthy town is not created by housing alone. It requires attractive streets, green space, clean air, safe walking routes, social infrastructure and access to everyday services.
The Local Plan should therefore test potential housing locations against their ability to support healthier places and strengthen existing communities. It should favour development that regenerates places and makes efficient use of existing social infrastructure.
Building a car-dependent settlement on farmland while existing centres struggle with vacancy, poor public realm and inadequate investment would be a failure to connect housing policy with health, economic development and place regeneration.
6. Green Belt purposes
Ashley is washed over by the North Cheshire Green Belt and forms part of the narrow remaining countryside separating the Greater Manchester urban area around Hale, Hale Barns and Altrincham from the settlements and countryside around Mobberley and Knutsford.
The land performs strongly against at least three of the Green Belt purposes in paragraph 143 of the National Planning Policy Framework:
(a) checking the unrestricted sprawl of large built-up areas;
(b) preventing neighbouring towns from merging into one another; and
(c) safeguarding the countryside from encroachment.
Large-scale development would permanently erode this strategic gap, introduce substantial built form into open countryside and facilitate the southward expansion of the Greater Manchester conurbation.
The land is predominantly open, productive farmland rather than previously developed land. It should not be characterised as “grey belt” simply because it has been submitted by a landowner or is capable of accommodating development.
Paragraphs 145–148 of the NPPF require changes to Green Belt boundaries to be fully evidenced and justified. Before concluding that exceptional circumstances exist, the Council must demonstrate that it has fully examined all reasonable alternatives.
That exercise must include a genuinely comprehensive assessment of town-centre regeneration, brownfield development, underused land, vacant buildings and opportunities for higher densities in locations served by public transport.
7. Agricultural land and food production
The submitted land is not empty or valueless. It is productive agricultural land contributing to food production, rural employment, landscape character, drainage, biodiversity and the long-term resilience of the borough.
Available evidence indicates that land around Ashley includes areas of Grade 2 and Subgrade 3a agricultural land. These grades constitute “best and most versatile” agricultural land under the NPPF.
Paragraph 187 of the NPPF requires recognition of the economic and other benefits of best and most versatile agricultural land, soils, natural capital and ecosystem services. Where significant development of agricultural land is demonstrated to be necessary, poorer-quality land should be preferred to higher-quality land.
The Council should require a detailed and independently verified Agricultural Land Classification survey before any Ashley parcel is shortlisted.
The assessment should consider:
• agricultural quality;
• current food production;
• effects upon farm businesses;
• fragmentation of holdings;
• soil carbon;
• drainage and water management;
• biodiversity and hedgerows; and
• whether development can be accommodated on previously developed or lower-quality land.
Once productive soil is covered by roads and buildings, that resource is effectively lost permanently. Landscaping and biodiversity net gain do not recreate agricultural soil or replace food-producing capacity.
8. Cross-boundary traffic, infrastructure and community impacts
Ashley does not function as an isolated settlement. Its road, rail, employment, education, shopping and healthcare connections extend directly into Hale, Hale Barns, Altrincham, Bowdon, Manchester Airport, Wilmslow, Mobberley and Knutsford.
A development potentially comprising thousands of homes would therefore create significant effects far beyond Ashley Parish and beyond the administrative boundary of Cheshire East.
A theoretical development capacity of approximately 8,731 homes could generate many thousands of additional daily journeys. Even allowing for public transport use and homeworking, a development of this scale would place substantial additional pressure on:
• the A538 corridor;
• Ashley Road;
• Hale Road;
• the M56 and its junctions;
• routes through Hale, Hale Barns and Altrincham;
• roads towards Wilmslow, Mobberley and Knutsford;
• constrained railway bridges and rural lanes;
• Manchester Airport access routes;
• local railway services and station capacity;
• schools and healthcare facilities; and
• emergency-service response routes.
Residents already experience serious congestion at peak periods on routes towards Hale, Altrincham, Manchester Airport and the M56. The Council should not assume that this network has spare capacity or that isolated junction improvements would make a settlement of this scale sustainable.
The consequences could include:
• materially longer and less reliable journey times;
• traffic displacement onto unsuitable residential and rural roads;
• increased queuing through Hale, Hale Barns and Altrincham;
• pressure on already constrained junctions;
• additional congestion around Manchester Airport;
• conflict with pedestrians, cyclists, horse riders and agricultural vehicles;
• poorer air quality and increased emissions;
• delayed buses and reduced public-transport reliability;
• impaired access for emergency services; and
• additional pressure on schools, GP practices and other facilities outside Cheshire East.
The cumulative impact upon Trafford communities is not a secondary matter. It is fundamental to deciding whether Ashley is a sustainable location for strategic development.
Paragraphs 109, 110 and 115 of the NPPF require transport effects to be considered from the earliest stage, significant development to be focused in sustainable locations, safe access to be achieved and significant impacts upon capacity, congestion and safety to be mitigated acceptably.
The assessment must not be restricted to whether a new access can physically be constructed onto one of Ashley’s roads. It must examine how all resulting journeys would move through the wider network and where congestion, delay and displacement would occur.
9. Consultation must extend beyond Ashley
The potential impacts are sufficiently extensive that consultation limited principally to Ashley residents would be inadequate.
People living and working in Hale, Hale Barns, Altrincham, Bowdon, Mobberley, Knutsford, Wilmslow and communities along the A538 and M56 corridors could all be materially affected. Many may currently be unaware that land capable, on an illustrative calculation, of accommodating approximately 8,731 homes has been submitted immediately beyond the Trafford boundary.
Before any Ashley site is shortlisted, Cheshire East should undertake meaningful cross-boundary engagement with:
• Trafford Council;
• Greater Manchester Combined Authority;
• Transport for Greater Manchester;
• National Highways;
• Manchester Airport Group;
• Network Rail and relevant train operators;
• Cheshire East Highways;
• affected town and parish councils;
• schools, NHS bodies and emergency services; and
• residents and businesses in all communities materially affected by resulting traffic and infrastructure demand.
Public consultation should be advertised geographically according to the likely impact of development, not merely according to the boundary of the proposed site or local planning authority.
The Council should publish accessible information showing:
• the total land submitted;
• illustrative development capacities;
• likely trip generation;
• principal journey destinations;
• affected roads and junctions;
• traffic displacement scenarios;
• public-transport capacity;
• school and healthcare implications;
• proposed infrastructure interventions; and
• how those interventions would be funded and delivered.
People in neighbouring communities should be given a fair opportunity to understand and comment on the consequences before the Council forms any view on the suitability of Ashley.
10. Northern Powerhouse Rail and cumulative infrastructure uncertainty
Ashley and its surrounding countryside already face considerable uncertainty arising from Northern Powerhouse Rail and the reuse or amendment of elements of the former HS2 Phase 2b proposals.
The Government has confirmed plans for a new Liverpool–Manchester route via Warrington and Manchester Airport. Cheshire East Council has confirmed that Northern Powerhouse Rail passes through Cheshire East and that further announcements and parliamentary processes are awaited.
The Local Plan must not assess major housing development independently from this nationally significant infrastructure.
Before identifying any land at Ashley for development, the Council must establish:
• the latest potential or safeguarded rail corridors;
• associated construction compounds and access routes;
• land required for mitigation, drainage and utilities;
• noise, vibration and visual effects;
• construction traffic implications;
• ecological and landscape impacts;
• consequences for agricultural holdings;
• cumulative effects with housing development; and
• whether development would prejudice future rail options or expose new residents to unacceptable impacts.
It would be wholly inappropriate to allocate large-scale development while the location and consequences of major rail infrastructure remain unresolved.
The same community should not be expected to absorb, through separate decision-making processes, a new railway, construction activity, large-scale housing, major new roads and associated environmental loss without a single transparent assessment of their combined effects.
11. Ashley is countryside—not residual or vacant land
The manner in which Ashley is being considered risks treating its countryside as if it were unused, degraded or awaiting development.
It is none of those things.
Ashley is a living rural landscape comprising productive farmland, soils, hedgerows, woodland, watercourses, wildlife habitats, historic buildings, farms, homes, walking routes and long-established views. It provides food, employment, biodiversity, drainage, carbon storage, recreation, tranquillity and separation between settlements.
The absence of urban development is not evidence that the land is empty or underperforming. Its openness and agricultural use are precisely why it performs such an important Green Belt function.
The countryside should not be viewed simply as the space left between existing buildings. Nor should farmland be assigned a low planning value merely because its economic, environmental, health and cultural benefits do not appear in conventional development appraisals.
Ashley’s landscape is beautiful, but the case for protecting it is not based on appearance alone. It is a strategically important and productive part of the North Cheshire Green Belt.
Once this landscape is urbanised, its openness, agricultural soils, tranquillity and historic character cannot be recreated through estate landscaping, biodiversity calculations or narrow green corridors between housing parcels.
12. Additional requirements for the Local Plan
In addition to the requirements set out elsewhere in this representation, I ask Cheshire East Council to:
1. Treat all adjoining Ashley submissions as one potential strategic development for transport and infrastructure assessment.
2. Prepare a strategic cross-boundary transport model covering Cheshire East, Trafford and relevant parts of Greater Manchester.
3. Test the network effects of realistic development scenarios, including the theoretical capacity of approximately 8,731 homes, rather than assessing only individual parcels.
4. Publish baseline and future traffic information for the A538, M56 junctions and routes through Hale, Hale Barns, Altrincham, Mobberley, Wilmslow and Knutsford.
5. Assess traffic displacement onto rural lanes and residential streets, not merely principal-road capacity.
6. Demonstrate that public transport could provide a genuine alternative to private cars, with funded improvements and credible delivery timescales.
7. Consult Trafford Council, Greater Manchester Combined Authority, Transport for Greater Manchester, National Highways and all materially affected communities.
8. Integrate Northern Powerhouse Rail into the Sustainability Appraisal, transport assessment, infrastructure planning and cumulative environmental assessment.
9. Avoid allocating Ashley land until the relevant Northern Powerhouse Rail corridor and infrastructure requirements are sufficiently established.
10. Recognise Ashley’s farmland and countryside as active natural, agricultural and community infrastructure—not as vacant or residual land.
Conclusion
Ashley is in danger of being treated as if it were an expendable area of open land rather than a beautiful, productive and strategically important rural landscape.
Development on the potential scale represented by these submissions would not affect Ashley alone. Its traffic, infrastructure, environmental and public-service consequences would extend into Hale, Hale Barns, Altrincham, Bowdon, Manchester Airport, Wilmslow, Mobberley and Knutsford.
These effects would cross local-authority boundaries and must be assessed and consulted upon accordingly, with all major development assessed holistically, not within red line boundaries-that is the logic that has the public sector in turmoil already.
At the same time, Ashley faces uncertainty from Northern Powerhouse Rail and associated infrastructure. It would be irresponsible to contemplate a major new settlement without understanding the combined effects of rail construction, housing, roads, utilities, traffic and permanent landscape loss.
Cheshire East should not treat Green Belt farmland as the easiest available answer to housing need. It should first use greater imagination and strategic intelligence to regenerate its existing towns, reuse obsolete commercial land and create attractive, healthy places where new residents can support existing shops, services, public transport and community infrastructure.
The Local Plan should improve places that need investment rather than sacrifice countryside that is already performing an irreplaceable function.
Yours Sincerely
Paul Wright