Local plan scoping consultation

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team

Subject: Peak District National Park Authority response – Cheshire East Local Plan Scoping Consultation

Dear Local Plan Team,

Please find below a response from the Peak District National Park Authority.

The Peak District National Park Authority ('the Authority', 'the National Park Authority') welcomes the opportunity to comment on the Cheshire East Local Plan Scoping Consultation.

The National Park Authority is the planning authority for the Peak District National Park. Our role is to deliver national park purposes which are:
• to conserve and enhance natural beauty, wildlife and cultural heritage
• to promote opportunities for the understanding and enjoyment of the Peak District's Special Qualities.
In pursuing these purposes, we also have a duty to foster the economic and social well-being of our local communities.

We note that part of Cheshire East's administrative area itself falls within the Peak District National Park, where the National Park Authority is the local planning authority, and that the scoping document correctly recognises this. Our comments below therefore focus on how the remainder of the Cheshire East Local Plan area, particularly land close to the shared boundary, is planned for, and the effect this may have on the setting of the National Park and on the designated areas within it.

General Comments

Specific comments in relation to sections of the scoping document are given separately below in relation to the general comments set out here.

The new Cheshire East Local Plan should demonstrate how it has regard to Section N4(4) of the National Planning Policy Framework, which states that development proposals within the setting of Protected Landscapes should be sensitively located and designed to avoid or minimise adverse impacts on the Protected Landscape.

In addition, the Local Plan and its supporting Strategic Environmental Assessment/Sustainability Appraisal should demonstrate how national park purposes have been furthered, in line with the legal duty under section 245 of the Levelling-up and Regeneration Act (LURA) 2023. Guidance confirms that this duty applies to functions carried out outside the designation boundary where the Protected Landscape is affected, including the preparation of development plans that may affect the setting of a national park. Aspects such as tranquillity, dark skies, a sense of remoteness, wildness, cultural heritage and long views from, and into, the Park may draw upon the landscape character and quality of its setting, and the duty is active rather than passive.

We note (para 4.4) that the scoping document confirms Cheshire East borders the Peak District National Park to the east, and that the boundary follows administrative rather than landscape lines in places. We would welcome this being carried through consistently into the evidence base and policies as the plan progresses, rather than being treated as a peripheral matter.

Housing requirement and growth pressure

We note the very significant increase in Cheshire East's housing requirement discussed at paragraphs 3.3–3.7 of the scoping document, from 1,800 homes per year under the current Local Plan Strategy to 2,530 homes per year under the revised standard method; a 41% increase. Given the borough's Local Service Centres and infill villages closest to the National Park boundary (including Bollington, Rainow, Prestbury, Disley, Gawsworth, Higher Poynton and Sutton Lane Ends), we are concerned about the cumulative effect of a significantly increased housing requirement on the setting of the National Park, particularly where the settlement hierarchy review (paras 5.20–5.23) and land availability assessment (paras 5.8–5.12) may identify additional or larger allocations in these locations. We have viewed the sites submitted through the council's call for sites map and would ask that proximity to, and potential visual/landscape effect upon, the National Park boundary and its setting be included as an explicit criterion within both the settlement hierarchy review and the site selection/land availability assessment methodology, alongside the factors already listed at paragraph 5.25. We would welcome sight of the finalised land availability assessment methodology and initial site assessments once published, so that this can be reviewed in relation to the setting and purposes of the National Park.

Habitats Regulations Assessment and population effects on protected areas

We note that a Habitats Regulations Assessment is listed only as forthcoming evidence (para 5.145), with no further detail yet available on its scope. Our own mapping identifies substantial areas of the Peak District Moors (South Pennine Moors Phase 1) Special Protection Area and South Pennine Moors Special Area of Conservation directly adjoining the shared boundary, together with a number of priority habitats and Sites of Special Scientific Interest (and their associated Impact Risk Zones) within the fringe itself. Given the scale of housing growth now being planned for, we would ask that the HRA:
• explicitly scopes recreational disturbance to the Peak District Moors (South Pennine Moors Phase 1) SPA and South Pennine Moors SAC using a Zone of Influence of at least 24.4km, reflecting the 75th percentile distance identified in Natural England-commissioned visitor survey evidence for this SPA/SAC specifically (Caals, Liley and Rush, Recreation Use of the South Pennine Moors and Implications for Strategic Housing Growth).
• also screens, on a precautionary basis, the Peak District Dales SAC, notwithstanding that its nearest point lies some 8km from the Cheshire East boundary on the far side of Buxton; and
• has regard to the SSSI Impact Risk Zones and priority habitats identified within the fringe area, which engage Natural England's standing consultation requirements for certain development types independently of the SPA/SAC's own zone of influence.
Where likely significant effects cannot be ruled out, we would ask that appropriate mitigation (which may include a Recreational Impact Mitigation Strategy, developer contributions, or green infrastructure enhancement, following the approach taken by other authorities sharing this SPA/SAC) is explored jointly with this Authority and Natural England before allocations are finalised. We would welcome the opportunity to be consulted directly on the HRA scope at an early stage, and to discuss and agree any mitigation strategy that may be necessary.

Renewable and low carbon energy

We note the general commitment to supporting renewable and low-carbon energy generation, including on-site and standalone solar and wind schemes, at paragraphs 5.113–5.117, and that a Climate Change and Renewable Energy Study is proposed as part of the evidence base (paras 5.103, 5.145). We would ask that this study explicitly includes a landscape sensitivity and capacity assessment for solar and wind development, having particular regard to cumulative impact and to the effect of such development on the setting of the National Park; including tranquillity, dark skies and long views into and out of the Park, in accordance with the LURA duty referred to above. We would ask that any future renewable and low carbon energy policy arising from this evidence base includes locational or criteria-based wording that refers specifically to the setting and Special Qualities of the National Park, rather than a general policy of support alone.

We would also highlight that the current adopted Local Plan Strategy already includes Policy SE 15 'Peak District National Park Fringe', which seeks to ensure that development within the Park Fringe does not have an adverse impact upon National Park purposes and valued characteristics. We would ask that an equivalent, and ideally strengthened, policy approach is retained in the new Local Plan, and that this is not treated as content that will simply be superseded by National Development Management Policies, since the Park Fringe designation and its associated evidence (the Local Landscape Designation Document) are locally specific to the Cheshire East/Peak District boundary and unlikely to be replicated at a national level.

Waste Management

The management of waste falls within the scope of the new Local Plan. Paragraphs 5.84 to 5.90 of the scoping consultation address waste issues. It is noted Cheshire East commissioned a Waste Needs Assessment (WNA) in 2023 to inform the new Local Plan, which found that there is sufficient existing capacity within the Borough to manage recycling and composting, inert recovery and hazardous waste up to 2041. The main issue identified by the WNA was a future shortfall in residual waste management capacity, particularly for local authority collected waste and commercial and industrial waste that cannot be recycled. The WNA indicates that remaining capacity elsewhere in the Northwest may be sufficient to accommodate future needs, and that further discussions with neighbouring authorities will be required as the plan progresses.

It is assumed the WNA accounts for waste arising within the part of the Borough which lies within the National Park boundary, since there is no mention of excluding it. This approach is welcomed, and dovetails with the broad approach the National Park Authority is pursuing in the Local Plan Review process because of the sparsely populated nature of the handful of Cheshire East parishes within the National Park boundary, and the fact that there are no major waste arisings which come from non-household sources. The provision of large-scale waste facilities is considered inappropriate within the Peak District due to the designation as a National Park; large scale facilities are incompatible with National Park purposes because of potential adverse environmental impacts and because they may require the importation of waste. Agreement is being sought from Cheshire East (along with the other neighbouring authorities) for continued commitment to maintain existing waste management capacity to cater for the needs of their residents within the National Park throughout the plan period.

It is noted an updated WNA will be prepared to extend forecasts to at least 2045 and reassess future capacity requirements. The National Park Authority assumes the update WNA will also account for waste arisings from the part of the Borough which lies within the National Park.

One of the listed wider strategies which will help to inform the new Local Plan is the Cheshire East Municipal Waste Strategy to 2030. There is no mention of part of the Borough lying within the National Park boundary, and therefore it is again assumed to deal with all waste arising from the Borough including from within the handful of parishes within the National Park boundary.

Cross-boundary matters

We would welcome clarification and, where appropriate, early engagement on the following cross-boundary matters identified through the scoping document:
• The Cheshire and Warrington Spatial Development Strategy (para 3.17–3.18). We would ask to understand whether and how the National Park Authority will be engaged as this is prepared, given that Cheshire East's Local Plan must be in general conformity with it.
• Green Belt (para 4.15). The Green Belt in Cheshire East forms part of that surrounding Greater Manchester and the Potteries; we would ask to be informed of any Green Belt or grey belt findings emerging from the borough-wide Green Belt assessment in locations that could affect the setting of the National Park, once this evidence is published.
• Waste capacity (para 5.87). We note ongoing discussions with neighbouring authorities regarding residual waste and ‘other recovery’ capacity shortfalls, and would ask for confirmation that this does not anticipate any role for land within or adjoining the National Park.
• Settlement hierarchy and spatial distribution (paras 5.20–5.26). We would ask to be directly consulted on any options for the distribution of development that could affect settlements close to the shared boundary.
Detailed comments on evidence base

Para 5.145 (New evidence). We would ask that the Climate Change and Renewable Energy Study, the Habitats Regulations Assessment, and the Settlement Hierarchy Review scopes are shared with the Authority prior to finalisation, given their direct relevance to the matters raised above.

We would welcome the opportunity to discuss any of the above in more detail and to be included as a consultee on the relevant evidence base documents as they are prepared, ahead of the next ('plan content and evidence') consultation stage.

Consultation and engagement

We note that the Council's approach to engagement is described as ‘digital first but not digital-only’ and that the Statement of Community Involvement confirms a statutory requirement to make documents available for inspection ‘at our principal office and at such other places within our area as we consider appropriate’ (para 5.2). It is not clear from the published material where, other than the Council's principal office in Crewe, such documents or paper copies of consultation materials might be made available. We would ask that particular consideration is given to the accessibility of the consultation process for residents of rural areas and settlements close to the National Park boundary, some of whom may not have reliable digital access or confidence engaging digitally, and for whom travel to Crewe may be disproportionately difficult, (a resident of Rainow, for example, faces around an hour's journey by private car, or up to two hours by public transport). We would welcome confirmation that paper copies of consultation documents will be made available at local libraries or other appropriate locations closer to these communities, to help ensure fair and effective engagement with the plan across the whole plan area, not only those parts closest to Crewe.

Kind regards,

Peak District National Park Authority Policy Team