Local plan scoping consultation

Representation objecting to the inclusion of Site MB08
("Land off Ryecroft Lane", Mobberley)
1. Summary of objection
I live on Pavement Lane, directly opposite the field forming part of site MB08. I object to the
inclusion of this site in the Local Plan as a potential housing allocation, on four grounds.
1. The site lies within the 60 dB LAeq,16h daytime noise contour from Manchester
Airport. On the Council's own established position, this is at or above the Significant
Observed Adverse Effect Level (SOAEL), at which national noise policy states that
development should be avoided.
2. A planning appeal for housing less than a mile from this site was dismissed in 2016
principally because of aircraft noise at these levels. Aircraft noise in Mobberley has
increased materially since the contours relied on in that decision.
3. The construction phase of any development on this site would impose a further,
prolonged noise burden on existing residents who are already exposed to an aircraft
noise environment that is at times close to unbearable.
4. The site performs an important Green Belt function in maintaining the gap between
Mobberley and Knutsford, and its release would cause harm that has not been
justified.
I ask that site MB08 be removed from further consideration as a housing allocation.
2. Aircraft noise: the site is not a suitable location for housing
Pavement Lane and the MB08 land fall within the 60 dB LAeq,16h average summer day
noise contour published for Manchester Airport for 2025. This is shown on the airport's own
published contour mapping, and I would ask that the Council obtain and consider the current
contours directly from Manchester Airports Group as part of its evidence base for this site.
The policy consequences of that are well established:
● The Aviation Policy Framework identifies 57 dB LAeq,16h as the average daytime
level marking the approximate onset of significant community annoyance. The MB08
land is above that threshold by a clear margin.
● The World Health Organisation Guidelines for Community Noise indicate that serious
annoyance arises in outdoor living areas exposed to 55 dB(A).
● BS 8233:2014 gives a desirable upper guideline of 55 dB(A) for external amenity
space in noisier environments.
● The Noise Policy Statement for England and the Planning Practice Guidance require
decision makers to identify the Significant Observed Adverse Effect Level, above
which significant adverse effects on health and quality of life occur, and state that
such situations should be avoided.
● The National Planning Policy Framework requires that the planning system prevents
new development from being adversely affected by unacceptable levels of noise
pollution, that new development is appropriate for its location, and that decisions
avoid noise giving rise to significant adverse impacts on health and quality of life.
Cheshire East Council has itself previously taken the position, and successfully defended it
at a public inquiry, that 60 dB LAeq,16h and above equates to SOAEL in the context of
aircraft noise from Manchester Airport in Mobberley. I do not see how the Council can now
allocate for housing a site which, on its own adopted noise position, sits at or above the level
at which national policy says development should be avoided.
I would also ask the Council to consider the character of the noise, which an averaged
contour does not fully convey. Because of prevailing wind direction, the great majority of
departures from Manchester leave in a south westerly direction, over Mobberley, and
departing aircraft are considerably noisier than arriving aircraft. The result is repeated,
intrusive events throughout the day, concentrated into morning and late afternoon peaks. In
practice, conversation in gardens has to be paused. Reading, gardening, eating outdoors
and social gatherings are repeatedly interrupted. Windows have to be kept closed for much
of the time. That last point is the condition the PPG identifies as characteristic of SOAEL.
3. The 2016 appeal decision is directly relevant, and the position has
worsened since
In Appeal Ref APP/R0660/W/15/3027388 (Harman Technology Site and adjacent land, Ilford
Way, Town Lane, Mobberley), decided 4 July 2016, an Inspector dismissed an appeal for up
to 375 dwellings in Mobberley. The site was less than a mile from MB08 and under the same
flight paths.
The decision is worth setting out in some detail, because the Inspector's reasoning applies
with equal or greater force to MB08.
● The housing land was above the 60 dB(A) and 63 dB(A) contours, and the Inspector
accepted that it was reasonable to categorise the development as falling within
SOAEL (paragraph 29).
● The appellants proposed extensive external mitigation, including canopies, enclosed
garden structures, conservatory type structures, acoustic materials, building
shadowing, and a "Zone of Relative Tranquillity". The Inspector found that this
mitigation would not be likely to achieve the objective of avoiding SOAEL (paragraph
40) and that it could not be secured by conditions (paragraph 42). He noted that
nobody at the inquiry could point to any development in which similar measures had
successfully mitigated aircraft noise in outdoor space (paragraph 39).
● Although an acceptable internal noise environment was technically achievable, the
Inspector held that this "sealed box" solution "should be seen as a last resort" and
was "an additional factor weighing against permission" (paragraphs 35 and 47).
● He concluded that "an acceptable external noise environment would not be achieved.
The housing development would not be appropriate for this location" (paragraph 47),
and that the proposal conflicted with the noise policies of the Framework and the
core principle of securing a good standard of amenity for future occupants
(paragraph 48).
● In the overall balance, he found that the adverse impacts from noise significantly and
demonstrably outweighed the benefits of the scheme, including up to 375 homes and
around 56 affordable homes, at a time when the Council could not demonstrate a five
year housing land supply and the shortfall was described as substantial (paragraphs
62 and 94). He was explicit that "the adverse impacts from noise are overriding"
(paragraph 94).
That last point matters most. The Inspector reached his conclusion despite a substantial
housing land supply shortfall and despite the tilted balance in favour of sustainable
development. Housing need did not outweigh the noise objection then, and the Council
should not assume that it does now.
The noise environment has also not stood still since that decision. The Inspector relied on
the 2014 noise contours (paragraph 21). He noted in terms that noise levels had already
risen between 2012 and 2014 as airport activity recovered, and that "the number of aircraft
movements is likely to increase as MIA is operating at well below capacity", with terminal
expansion and refurbishment set to increase passenger capacity (paragraph 21). More than
a decade has now passed. Manchester Airport has since completed its Transformation
Programme, and passenger numbers and aircraft movements have grown well beyond 2014
levels. A site assessed against the current 2025 contours is therefore being assessed
against a worse noise environment than the one that caused a 375 home scheme to be
refused in this same village.
The Inspector also observed that, aside from a few dwellings on Smith Lane and isolated
properties under the flight path, the appeal proposal would have created "the most
substantial concentration of dwellings in the Mobberley area close to the take off/landing
zone for Runway 2 and the associated PNRs" (paragraph 44). Allocating MB08 would do the
same thing, on the same flight paths, in a worse noise climate.
I would ask the Council to explain, in its evidence base, what has changed since 2016 that
would justify allocating housing land in Mobberley at noise levels that an Inspector has
already found to be unacceptable.
4. Construction noise on existing residents
The points above concern the amenity of future occupiers. Existing residents deserve
consideration too.
Those of us who already live on Pavement Lane and the surrounding roads have no
mitigation available to us. Our gardens are exposed to aircraft noise which, on the days
when departures run continuously over the village, is already at the very limit of what is
tolerable. There are periods when it is not possible to hold a conversation outdoors, or to sit
outside with any comfort.
A construction programme on MB08 would add years of piling, excavation, ground
compaction, heavy plant movements, reversing alarms, deliveries and site traffic on top of
that existing aircraft noise, immediately opposite our homes. The two sources would occur
simultaneously and would not average out. Each would intrude on the quiet intervals of the
other, and there would be no respite period in the day.
At the 2016 inquiry the Inspector accepted that residual industrial noise "combined with that
from aircraft and other noise sources, such as traffic, would still be likely to add to the
annoyance factor for those residents nearest to them, particularly when using their gardens"
(paragraph 46). The same cumulative logic applies here, and construction noise is far more
intrusive than the industrial noise he was considering.
A noise environment that is already borderline would, for the duration of construction,
become unbearable. Standard construction hours conditions and a Construction
Environmental Management Plan would not address this, because they control when the
noise occurs rather than the fact that it is layered on top of an aircraft noise environment that
is already at SOAEL.
5. Green Belt and the Mobberley to Knutsford gap
I also endorse the objections made on Green Belt grounds.
The Council's own Mobberley Settlement Report (Local Plan ED37, pages 49 to 53)
identifies that the Land off Ryecroft Lane makes a major contribution to an essential Green
Belt purpose, namely preventing the merging of neighbouring settlements. The gap between
Mobberley and Knutsford at this point is less than 700 metres. Development here would
significantly and permanently reduce both the actual and the perceived separation between
the two settlements.
Green Belt was introduced to guard against this form of incremental erosion, and once
released the land cannot be recovered. The suggestion sometimes made that Green Belt
land can never be developed is not the issue. The issue is that the Council's own evidence
base identifies this land as performing one of the five Green Belt purposes to a high degree,
and no exceptional circumstances have been demonstrated that would justify overriding that.
The land is also a well used amenity for walkers and dog walkers, and land surveys and
appraisals have already been carried out around the site, including in relation to a bat
colony. Traffic on the surrounding lanes, which are narrow and in places without footways,
would be materially and adversely affected.
6. Conclusion
Site MB08 should be removed from consideration as a housing allocation.
The site sits within the 60 dB LAeq,16h daytime aircraft noise contour, at or above the level
the Council itself treats as SOAEL, where national policy directs that development should be
avoided. External noise mitigation at these levels has already been examined at a public
inquiry in this village and found to be ineffective and incapable of being secured by condition.
An Inspector has already refused a large housing scheme in Mobberley on that basis, in a
quieter noise climate than exists today, and did so even though the Council could not
demonstrate a five year housing land supply.