Local plan scoping consultation

Strong objection to potential housing allocation: land to the side/rear of 272 Newcastle Road and land extending towards Stock Lane, Blakelow/Shavington
Dear Strategic Planning Team,
We are the residents of (REDACTED) Newcastle Road, Blakelow, Nantwich, and our property and garden directly adjoin the open countryside forming part of the land currently being promoted for potential development.
We wish to register our strong objection to this land being taken forward as a housing allocation or development option within the new Cheshire East Local Plan.
We understand that this is presently a Local Plan scoping consultation rather than a planning application. However, we believe it is particularly important that the Council understands the site-specific constraints of this land now, before any assumption is made that it represents a suitable or sustainable location for housing.
1. Development within the Strategic Green Gap
We consider the site's position within the Strategic Green Gap to be one of the most significant reasons why it should not be taken forward for development.
Cheshire East's own Strategic Green Gap Boundary Review identifies SGG16 as running from the Elephant public house on Newcastle Road towards the A500. Importantly, the Council describes the boundary in this location as following the rear curtilage of properties along Newcastle Road.
Our property at 266 Newcastle Road directly adjoins this open land. The rear boundary of the established Newcastle Road properties therefore represents precisely the type of clear, established and readily recognisable boundary that Cheshire East has previously used to define the edge of the Strategic Green Gap.
Development would fundamentally breach that boundary.
It would move built development substantially southwards behind the established line of Newcastle Road properties and into land whose present function is to provide openness and separation between existing settlements and development.
This is not simply an undeveloped gap awaiting housing. Its openness is the very characteristic that enables it to perform its Green Gap function.
We are also concerned that once the established rear-curtilage boundary is breached, there appears to be no equally strong or defensible boundary at which development would naturally stop. Development of this parcel could therefore create further pressure for incremental expansion towards Stock Lane and across adjoining fields.
Of particular relevance, during Cheshire East's previous Strategic Green Gap work a suggestion was made that land should be excluded from the Green Gap to make future development land available. Cheshire East described this approach as “unnecessary and unjustified” and stated that Green Gap boundary definition should not be driven by the need to provide further development sites.
We believe that principle is directly relevant here.
The subsequent promotion of land through a call-for-sites exercise should not itself provide justification for removing or weakening the protection previously afforded to it.
If Cheshire East is considering taking this land forward, we request a specific and transparent assessment explaining:
• how development would remain consistent with the purposes of the Strategic Green Gap;
• why the established rear-curtilage boundary along Newcastle Road is no longer regarded as an appropriate long-term boundary;
• what stronger and more defensible boundary would replace it;
• what effect development would have upon the openness and settlement-separation function of the Gap;
• how further incremental development towards Stock Lane would be prevented; and
• why housing requirements cannot instead be accommodated on land that does not require development within an established Strategic Green Gap.
In our view, this factor alone weighs very strongly against the selection of this particular site.
2. Protected mature oak tree directly on the development boundary
There is a very substantial mature oak tree situated directly on the boundary between our garden and the land being promoted for development.
The existing boundary fence effectively runs through the centre of the tree's trunk.
Importantly, this oak is already protected by a Tree Preservation Order.
This is therefore an existing and legally recognised arboricultural constraint, rather than simply a tree which might merit consideration at some future planning application stage.
The tree is of considerable age, size and visual prominence and makes a significant contribution to the character of our property, Newcastle Road and the adjoining countryside.
Because the tree sits directly on the boundary between our property and the promoted land, any assessment of the site's developable capacity must properly account for:
• the tree's root protection area;
• its current and future canopy;
• appropriate stand-off distances from buildings and roads;
• changes in ground levels;
• drainage infrastructure;
• lighting;
• construction operations;
• future pressure for pruning or removal from residents occupying new properties close to it; and
• its ecological and landscape value.
The protection of the tree cannot simply be dealt with by placing a garden boundary immediately alongside it.
Development needs to provide sufficient space for the tree to be retained successfully for the long term without creating conflict between the protected tree and future residents.
We therefore request that the Council's arboricultural officers specifically assess this TPO-protected oak as part of the site's evaluation and establish the appropriate undeveloped buffer before any development capacity is attributed to the site.
Given its apparent age and characteristics, we would also ask that consideration is given to whether it displays veteran-tree characteristics and requires the additional protection associated with such status.
3. Badgers and established wildlife use
We have personally observed badgers using the land behind our property and have seen what we believe to be badger sett activity within/around these fields.
This is therefore not simply a theoretical ecological possibility identified through desktop records. It is based upon our own observations as adjoining residents.
We believe the presence and extent of badger activity should be investigated by an appropriately qualified ecologist before the land is considered suitable or deliverable for housing.
The survey should establish:
• the location and status of any badger setts;
• established badger paths and movement corridors;
• foraging areas;
• the relationship between badger activity and existing hedgerows, trees and field boundaries; and
• the amount of undeveloped land required for appropriate protection and mitigation.
We would be happy to provide the Council's ecological officers with further information about the locations where we have observed activity.
More widely, this land forms part of an established countryside habitat network containing mature trees, hedgerows and field boundaries. Appropriate ecological surveys should therefore consider bats, breeding and wintering birds, amphibians, invertebrates and other protected or priority species.
The ecological value and required buffers should be established before, rather than after, assumptions are made about how many houses the site could accommodate.
4. Biodiversity Net Gain should not be used to justify avoidable harm
We are concerned that established countryside could be regarded as developable on the basis that subsequent landscaping and Biodiversity Net Gain could compensate for its loss.
That would place the process in the wrong order.
Existing important habitats, protected species, mature trees and ecological corridors should first be identified and harm avoided.
The land needed for retention of the TPO tree, ecological buffers, hedgerows, badger protection, drainage infrastructure and Biodiversity Net Gain must be deducted before calculating the realistic developable area of this site.
A theoretical capacity based simply upon the site's gross acreage would therefore be misleading.
5. Open countryside and the rural character of Blakelow
The fields behind our property are clearly experienced as open countryside.
Development here would not represent infilling or consolidation of the existing built form. It would represent a substantial extension of built development behind the existing ribbon of homes along Newcastle Road.
The field pattern, hedgerows, mature trees and openness collectively provide the rural setting of this part of Blakelow.
Housing development would permanently change that character.
Landscaping around a housing estate cannot recreate openness. Even where planting eventually matures, roads, roofs, street lighting, vehicle movements and domestic activity remain urban development.
The Council should therefore carry out a site-specific Landscape and Visual Impact Assessment and settlement-separation assessment before taking this land forward.
6. Cumulative development around Shavington and Newcastle Road
Our objection is not an objection to housing development generally.
However, the Shavington and Newcastle Road area has already accommodated very substantial housing development.
The Council should therefore consider the cumulative effect of development already completed, committed or under construction before directing another major allocation to this locality.
This assessment should include:
• road and junction capacity;
• schools;
• GP and healthcare provision;
• drainage and sewer infrastructure;
• public transport;
• walking and cycling connections;
• community facilities; and
• the cumulative loss of countryside and local identity.
Further development should not simply be considered one field at a time.
The cumulative consequences of the growth already experienced in the area must form part of the strategic decision about where Cheshire East's future housing should go.
7. Highways, Newcastle Road and surrounding rural lanes
A substantial residential development behind Newcastle Road would inevitably generate significant additional vehicle movements.
We are concerned about how safe and deliverable access could realistically be achieved without placing further pressure upon Newcastle Road, Dig Lane, Stock Lane and surrounding junctions.
The assessment should address:
• the location of any proposed access;
• visibility and traffic speeds;
• additional turning movements on Newcastle Road;
• existing residential accesses;
• pedestrian safety;
• school-time congestion;
• the suitability of Dig Lane and Stock Lane;
• emergency access;
• construction traffic; and
• cumulative traffic arising from developments already built or committed around Shavington.
Dig Lane and Stock Lane should not gradually become distributor routes for successive housing developments.
Any proposed allocation should therefore demonstrate that safe access is both physically deliverable and compatible with the rural character and existing highway network.
8. Sustainability and dependence upon private cars
Proximity to existing houses along Newcastle Road does not automatically make the fields behind them a sustainable location for a major housing development.
The Council should assess actual walking and cycling routes to schools, shops, healthcare, public transport and employment rather than simply straight-line distances.
A development where everyday journeys are predominantly dependent upon private cars would be inconsistent with the aim of creating a sustainable pattern of development.
Infrastructure and sustainable transport improvements should be shown to be feasible and deliverable before the land is allocated, rather than being aspirations to be resolved later.
9. Drainage, surface water and changes to existing land
The fields currently provide a substantial permeable area.
Housing, roads, driveways and associated infrastructure would fundamentally alter surface-water behaviour.
This is particularly important for established properties such as ours which sit immediately around the edge of the site.
Before considering allocation, the Council should require evidence concerning:
• existing surface-water flow routes;
• field drainage;
• groundwater;
• foul and surface-water sewer capacity;
• proposed discharge points;
• changes to existing ground levels;
• climate-change allowances;
• sustainable drainage requirements; and
• cumulative effects of existing development.
Existing homes must not become the receptors for overflow or exceedance flows from a newly developed site.
Drainage feasibility should be demonstrated before the principle of development is established.
10. Effect upon existing homes
We fully understand that the planning system does not protect an individual's private right to a particular view.
Our objection is therefore not simply that we would lose our outlook across the field.
Our concern is the wider planning consequence of replacing open countryside immediately behind established homes with a substantial residential development.
Depending upon its layout this could result in:
• overlooking and loss of privacy;
• overbearing development;
• artificial lighting;
• vehicle headlights;
• noise;
• traffic;
• changes to ground levels;
• drainage impacts;
• construction disturbance;
• pressure upon existing trees and hedgerows; and
• roads, public open spaces or drainage infrastructure being positioned directly behind existing gardens.
Appropriate landscape and ecological buffers and appropriate separation from existing properties will further reduce the realistic developable area of the land.
11. Previous development does not justify crossing the next boundary
We are concerned about a pattern in which previous development is itself subsequently used to justify the next outward extension.
The purpose of a Local Plan is to make strategic choices about where growth should occur, rather than allowing the settlement boundary to expand incrementally according to whichever adjoining land is promoted by landowners.
The rear boundary of Newcastle Road presently provides a clear dividing line between established residential properties and open countryside.
Removing that boundary would make the next development proposal progressively harder to resist.
The Council should therefore identify where the permanent long-term edge of development is intended to be and demonstrate why moving that boundary is strategically necessary.
12. The site should be compared with less harmful alternatives
A call-for-sites submission demonstrates that land has been promoted. It does not itself demonstrate that the land is suitable, sustainable or necessary for development.
Before considering this site, the Council should compare it transparently with reasonable alternatives including:
• previously developed and underused land;
• locations within existing settlement boundaries;
• sites with stronger sustainable transport connections;
• locations with existing infrastructure capacity; and
• land where development would cause less landscape and ecological harm.
The fact that this land has been made available should not itself determine whether it is allocated.
Requested action
For all of these reasons, we respectfully request that Cheshire East Council:
1. does not take the land to the rear of Newcastle Road and towards Stock Lane forward as a housing allocation or preferred development site;
2. retains the land as open countryside and within the Strategic Green Gap;
3. gives substantial weight to the established rear-curtilage boundary along Newcastle Road identified in Cheshire East's own Strategic Green Gap evidence;
4. assesses how development could possibly be reconciled with the purposes of the Strategic Green Gap before the land progresses any further;
5. records and assesses the existing TPO-protected mature oak immediately on the boundary of 266 Newcastle Road and the promoted land;
6. establishes an appropriate undeveloped buffer and root protection area around that tree before calculating site capacity;
7. investigates the badger activity and possible setts reported by adjoining residents through appropriate ecological survey;
8. establishes ecological corridors, protected habitats and biodiversity constraints before calculating site capacity;
9. undertakes an appropriate landscape and settlement-separation assessment;
10. assesses highways, sustainable transport, drainage and sewer capacity before determining that the land is suitable;
11. considers the cumulative effect of the very substantial development already accommodated around Shavington;
12. compares the site transparently against brownfield, underused and better-connected alternatives;
13. records this representation against the assessment of the relevant call-for-sites parcel(s); and
14. directly notifies adjoining residents of subsequent consultation stages concerning this land.
We would be happy for Cheshire East's planning, ecological or arboricultural officers to contact us should they wish to inspect the TPO-protected oak from our property or require further information concerning the badger activity we have observed.
This objection is not an objection to Cheshire East meeting genuinely evidenced housing needs.
It is an objection to this particular site, where development would breach a clearly established countryside and Strategic Green Gap boundary, would affect land containing significant ecological and arboricultural constraints, and would compound the substantial development that has already taken place around Shavington.
We believe there is a strong strategic planning case for retaining this land as open countryside and excluding it from future housing allocation.
Yours faithfully,
Amanda and John Grinnell