Local plan scoping consultation

Dear Local Plan Team,
Please register this email as my formal representation concerning CFS26 460 – Land to the west of Whirley Road, Macclesfield and CFS26 557 – Land south of Whirley Road.
I am concerned that both sites have significant highway, Green Belt, drainage, ground condition and environmental constraints which should be fully assessed before either site is considered suitable for residential allocation.
Whirley Road and development access
Whirley Road is a particularly important issue.
I understand that during the previous Local Plan process, Cheshire East highways evidence was reported as concluding that Whirley Road was totally unsuitable for development access.
That concern is supported by what subsequently happened with the adjoining LPS18 – Land between Chelford Road and Whirley Road development. Vehicular access for that development was taken from Chelford Road, and vehicular access from Whirley Road was specifically prohibited.
This raises an obvious question for CFS26 460 and CFS26 557.
If Whirley Road was previously regarded as unsuitable for development access, and the adjoining LPS18 development was not permitted to use it for vehicular access, what credible and deliverable highway solution exists for a further 28.4 hectares of submitted housing land around Whirley Road?
This should be established at the site-selection stage rather than left to a future planning application.
Increased traffic and my direct experience
I have lived in a house on Whirley Road, with the kitchen and living room at the front of the property overlooking the road. I have therefore had the opportunity to observe traffic conditions on a regular, day-to-day basis.
From my own observations, traffic using Whirley Road has increased noticeably over time.
Whirley Road is not used solely for local access. It is also used as a through-route by drivers travelling towards Alderley Edge and the A34, and towards the A538, M56 and Manchester.
Since the previous Local Plan was prepared, substantial additional housing has been built or committed across Macclesfield, including major development in the south and south-west of the town.
The highway conditions that exist today should therefore not simply be assumed to be the same as those considered during the previous Local Plan process.
If Whirley Road was already considered seriously constrained at that time, the Council should assess whether subsequent housing growth and increased traffic have made those constraints more significant rather than less.
Parts of Whirley Road are narrow and vehicles can have difficulty passing comfortably. The wider surrounding road network also includes narrow rural roads and constrained routes towards Whirley Lane, Andertons Lane and Alderley Edge.
Increased traffic creates greater potential for conflict between vehicles and other road users, including pedestrians, cyclists, horse riders and residents accessing properties along the route.
I appreciate that my observations are personal evidence rather than formal traffic-count data. I therefore ask Cheshire East to obtain current traffic counts and undertake a contemporary highways assessment before determining whether CFS26 460 or CFS26 557 are suitable for residential allocation.
That assessment should consider not just traffic generated directly by the two sites but also the cumulative effect of existing and committed development across south-west Macclesfield and other submitted Local Plan sites.
Green Belt and the previous long-term boundary
There is also an important Green Belt issue.
The previous Local Plan specifically released LPS18 – Land between Chelford Road and Whirley Road from the Green Belt.
The adopted policy required the development to create a readily recognisable Green Belt boundary that would endure in the long term.
I therefore believe Cheshire East should explain what has materially changed since that Local Plan was adopted to justify considering further development beyond the boundary which was deliberately intended to endure in the long term.
The previous Local Plan Inspector also considered the effect of development in this area on the countryside gap between the urban edge of Macclesfield and Henbury.
Further development through CFS26 460 and CFS26 557 could extend the built-up area farther into the countryside and further reduce this separation.
I would therefore ask the Council to assess:
• whether both sites remain within the Green Belt;
• what contribution they make to Green Belt purposes;
• whether further release would result in urban sprawl or encroachment into the countryside;
• the effect on the remaining separation between Macclesfield and Henbury; and
• whether exceptional circumstances genuinely exist to justify further Green Belt release.
Peat, marshy ground and drainage
There are also known ground and drainage issues in this immediate area.
Previous planning evidence relating to the adjoining LPS18 development identified peat, marshy ground, surface-water flooding and drainage constraints.
The area known as Longmoss is particularly relevant to CFS26 557.
Before either site is regarded as suitable for housing, I believe Cheshire East should establish whether peat deposits, marshy ground or hydrologically connected soils extend into CFS26 460 or CFS26 557.
This is important because development could potentially affect drainage, groundwater conditions and the existing hydrology of the area.
The Council should therefore establish:
• the extent and depth of any peat;
• existing groundwater conditions;
• current surface-water flow paths;
• whether the sites are affected by surface-water flooding;
• how development might alter drainage into surrounding land;
• whether construction would require removal or disturbance of peat; and
• whether mitigation would be practical and sustainable.
Ecology and existing habitats
The adjoining LPS18 development also required significant ecological measures, including consideration of ponds, bats, birds, hedgerows, woodland and great crested newts.
The wider Whirley Road and Longmoss area contains ponds, hedgerows, mature vegetation and connected habitat.
With several large development sites now being submitted in close proximity, these ecological impacts should be considered cumulatively, rather than assessing each individual field in isolation.
I would ask the Council to establish the ecological value of CFS26 460 and CFS26 557 and their relationship with the existing network of ponds, hedgerows and habitats in the surrounding area before deciding that either site is suitable for allocation.
Cumulative development
My concern is not simply about either site viewed independently.
CFS26 460 and CFS26 557 together account for approximately 28.4 hectares of potential residential land.
They sit in an area where substantial development has already taken place or been permitted, including LPS18.
The Council should therefore assess the cumulative impact of further development on:
• Whirley Road and the surrounding highway network;
• the A537 and routes towards the A34 and A538;
• local traffic congestion;
• road safety;
• drainage and surface-water flooding;
• schools and healthcare;
• ecological networks and habitats;
• Green Belt purposes;
• landscape character; and
• the remaining countryside separation between Macclesfield and Henbury.
Information requested
I would be grateful if the Local Plan Team could confirm:
1. Whether the previous Cheshire East highways assessment concerning the suitability of Whirley Road for development access will be reviewed when assessing CFS26 460 and CFS26 557.
2. Whether current traffic counts will be obtained before either site is considered suitable for residential allocation.
3. How vehicular access to CFS26 460 and CFS26 557 could realistically be provided given the previous restriction on vehicular access from Whirley Road for the adjoining LPS18 development.
4. Whether both sites are currently within the Green Belt and how they perform against the purposes of the Green Belt.
5. What circumstances are considered to have changed since the previous Local Plan established a Green Belt boundary intended to endure in the long term.
6. Whether the effect of development on the remaining countryside separation between Macclesfield and Henbury will be assessed.
7. Whether the presence and extent of peat, marshy ground and surface-water drainage constraints have been investigated on both sites.
8. Whether ecological surveys will consider ponds, great crested newts, bats, hedgerows, woodland and habitat connectivity.
9. Whether the cumulative impacts of CFS26 460 and CFS26 557 will be assessed together with LPS18, other existing development and other current Local Plan site submissions.
I appreciate that a submitted site is not the same as an allocated site.
However, I believe these are fundamental matters affecting whether CFS26 460 and CFS26 557 can genuinely be regarded as suitable, achievable and sustainable locations for residential development.
I therefore ask that this representation is formally recorded against CFS26 460 and CFS26 557 and taken into account before either site progresses further through the New Local Plan site-selection process.
Please could you acknowledge receipt and confirm that these concerns have been registered against both sites.
Kind regards

Richard Slater

I dug into the current evidence, and there is an important finding before we draft this.
I would not submit it as “there has been a lack of growth”. Cheshire East has now published a figure that directly contradicts that proposition: its 2026 scoping document says average annual jobs growth was 1.3% between 2010 and March 2024, against the old Local Plan's 0.7% target. (localplan.cheshireeast.gov.uk)
Population also grew: Census 2021 recorded 398,800 residents, up 28,700 or 7.7% from 2011, above the England-and-Wales rate of 6.3%. (Cheshire East Council)
So if we repeat Roland's 2016 argument as though subsequent events proved the 0.7% figure excessive, CEC can knock the submission down very easily.
But the research produces what I think is a better argument about land.
CEC's own March 2025 housing report records 27,423 homes already completed since 2010, another 12,423 remaining homes on sites with planning permission, plus 2,038 homes on allocated sites without planning permission. On CEC's own table, completions plus identified supply total 41,884 homes, before its 250-home small-sites windfall allowance. (Cheshire East Council)
The current Local Plan requirement was only a minimum 36,000 homes. (Cheshire East Council)
That does not prove the new Plan requires no new land, because the rules have changed substantially: CEC says the Government's current standard method produces a minimum new-plan housing need of 2,530 homes per year, or 37,950 over 15 years. (localplan.cheshireeast.gov.uk)
Therefore the strongest representation is: don't argue that there was no growth; demand that CEC proves how much genuinely additional land is required after deducting the enormous existing pipeline and testing what kind of growth actually occurred.
Your existing submission already identifies the key distinction between housing need, land capacity and actual delivery.
I would send this as a separate growth/land representation:
Subject: New Local Plan Scoping Consultation – Growth Evidence and the Need for Additional Housing Land
Dear Strategic Planning Team,
Please treat this email as a formal representation to the New Local Plan Scoping Consultation and provide me with a consultation reference.
I wish to raise a specific issue concerning the relationship between economic and population growth, the Government's new housing requirement, existing housing capacity and the amount of genuinely new land Cheshire East will need to allocate through the new Local Plan.
I believe this requires considerably more scrutiny before additional greenfield or Green Belt land is identified.
The previous Local Plan was built around an ambitious growth strategy
The existing Local Plan provides for a minimum of 36,000 homes between 2010 and 2030, equivalent to 1,800 homes per year.
The Council's adopted strategy explains that this was intended to support approximately 31,000 additional jobs, based upon average jobs growth of approximately 0.7% per annum.
The Council also described the underlying economic scenario as ambitious.
The housing evidence assumed net inward migration averaging approximately 2,600 people per year for twenty years — a rate the Local Plan itself said was equivalent to the highest level recorded in any single year since 1991 and considerably above the 2001-2011 average of approximately 1,700 per year.
Those assumptions were controversial at the time.
Representations made during preparation of the previous Plan specifically challenged the increase in the employment-growth assumption from approximately 0.4% to 0.7%.
Those representations referred to contemporary economic evidence concerning services, manufacturing, construction, GDP forecasts and monetary policy and questioned whether the higher growth assumption would prove sustainable.
We now have the considerable advantage of hindsight.
What actually happened?
Interestingly, Cheshire East's current New Local Plan scoping evidence states that average annual jobs growth between 2010 and March 2024 was actually:
1.3% PER ANNUM
That is considerably higher than the 0.7% annual growth assumption used in the current Local Plan.
Population also grew.
The 2021 Census recorded 398,800 Cheshire East residents, an increase of approximately 28,700 people or 7.7% since 2011.
Therefore, I am not suggesting that Cheshire East experienced no growth.
However, those headline figures actually make a proper examination of the previous strategy more important, not less.
Before setting the development strategy for another generation, Cheshire East should establish exactly what that growth consisted of and how it related to the housing assumptions used in the previous Plan.
For example:
How many additional jobs actually existed in Cheshire East in 2024 compared with 2010?
How does that numerical increase compare with the approximately 31,000 additional jobs which the Local Plan anticipated by 2030?
Which sectors generated the additional jobs?
Were they full-time or part-time?
How much of the increase reflects changes in the way employment is measured?
What happened to productivity and economic output?
How much population growth resulted from net migration?
How did actual net migration compare with the assumed 2,600 people per year?
How did household growth compare with the assumptions used to calculate housing requirements?
Simply saying that annual jobs growth averaged 1.3% does not provide that analysis.
The new Local Plan should publish a complete forecast-versus-actual audit of the previous Plan.
But there is an even bigger question: how much NEW land do we actually need?
This is where Cheshire East's own latest housing figures become particularly important.
The Council's Housing Completions and Supply report, with a base date of 31 March 2025, records:
27,423 net housing completions since April 2010
It then records remaining supply of:
9,277 homes on allocated sites with planning permission
plus
3,146 homes on other sites with planning permission
plus
2,038 homes on allocated sites without planning permission.
That means the Council's own published table records:
27,423 HOMES ALREADY COMPLETED
plus
14,461 HOMES IN IDENTIFIED REMAINING SUPPLY
giving:
41,884 COMPLETED OR IDENTIFIED HOMES
before the additional small-sites windfall allowance shown in the same report.
Compare that with the existing Local Plan requirement:
36,000 HOMES.
In other words, the current Plan's housing requirement has not resulted in Cheshire East running out of identified development capacity.
CEC's own monitoring identifies completed homes plus remaining identified supply substantially exceeding that 36,000-home figure.
That should be an extremely important starting point for the new Local Plan.
The Government's new housing figure does not automatically equal new land
I recognise that the new Local Plan is being prepared under a different national planning framework.
Cheshire East's current scoping consultation states that the Government's standard method gives the borough a minimum local housing need of approximately:
2,530 HOMES PER YEAR
or:
37,950 HOMES OVER A 15-YEAR PLAN PERIOD.
I recognise that Cheshire East cannot simply disregard that national requirement.
But 37,950 homes required over a future Plan period does not automatically mean Cheshire East needs to find completely new land for 37,950 homes.
That distinction is fundamental.
Some future housing delivery will come from land which is already:
allocated;
permissioned;
under construction;
previously developed;
or otherwise capable of contributing to future supply.
Indeed, Cheshire East's own scoping document acknowledges that future provision may come from existing commitments, existing allocations and new site allocations.
Therefore the relevant question for residents is not:
“How many homes does the Government say Cheshire East needs?”
It is:
“After properly accounting for everything Cheshire East already has, how many homes genuinely require NEW land to be allocated?”
Those figures could be very different.
Cheshire East should publish a simple land requirement calculation
Before any additional Green Belt or greenfield sites are proposed, residents should be shown a straightforward calculation:
A. Total housing requirement for the new Plan period
minus
B. Existing planning permissions expected to contribute during that period
minus
C. Existing Local Plan allocations expected to contribute during that period
minus
D. Sites already under construction
minus
E. Realistic brownfield capacity
minus
F. Appropriate windfall allowance
minus
G. Other demonstrably deliverable urban capacity
equals
H. GENUINELY ADDITIONAL LAND REQUIREMENT.
It is figure H which should determine whether Cheshire East needs another substantial round of greenfield or Green Belt allocations.
Not simply the headline Government housing figure.
Do not confuse delivery problems with land shortages
There is then the question of build-out rates.
Cheshire East has substantial numbers of homes with planning permission which are not expected to be completed within five years.
A permitted home does not cease to exist merely because a developer expects to construct it in year six or seven.
The distinction must therefore be maintained between:
HOUSING NEED
LAND CAPACITY
and
HOUSING DELIVERY.
They are not interchangeable.
If sufficient land has already been allocated and permissioned but homes are being delivered more slowly than required, allocating still more land does not necessarily solve the underlying problem.
It could simply increase the quantity of development land available.
The Council should therefore demonstrate, through evidence, whether additional allocations actually increase aggregate annual housing completions.
The employment-land position deserves similar scrutiny
There is another particularly interesting figure in Cheshire East's new scoping document.
The existing Local Plan sought to provide at least 380 hectares of employment land.
CEC now reports that more than 112 hectares have been developed since 2010 — but that at 31 March 2024 there still remained a:
375-HECTARE SUPPLY OF EMPLOYMENT LAND.
At the same time, CEC says jobs growth averaged 1.3%, substantially exceeding the old Plan's 0.7% target.
That raises an important strategic question.
If Cheshire East achieved employment growth considerably above the Local Plan target while retaining a very substantial supply of employment land, what does that tell us about the relationship between economic growth and the quantity of additional land that actually needs to be allocated?
The new Economic Development Needs Assessment should explicitly address this.
Growth is not the same thing as a requirement for unlimited land
The evidence therefore presents a more complicated picture than simply saying “Cheshire East is growing, therefore more land must be allocated”.
The borough has grown.
Jobs growth, according to CEC, exceeded the previous Plan assumption.
Population increased.
Thousands of homes were built.
But Cheshire East simultaneously retains substantial housing and employment land capacity.
The new Local Plan must therefore answer:
How much growth is genuinely expected?
How much housing does national policy require?
How much of that requirement can already be accommodated?
How much suitable brownfield and urban capacity exists?
How much existing permissioned and allocated capacity will carry forward?
How quickly are those existing sites actually being built?
And only after answering those questions:
HOW MUCH GENUINELY NEW LAND IS REQUIRED?
Green Belt should come at the end of that calculation, not the beginning
The consequences of getting this calculation wrong are permanent.
Once countryside is developed, it is not realistically going to return to countryside.
Once Green Belt boundaries are altered and land is developed, that change is effectively permanent.
Therefore Green Belt and greenfield land should not be treated as a reserve which automatically makes up the difference between a headline national housing requirement and recent completion rates.
Before identifying additional Green Belt land, Cheshire East should demonstrate that the requirement cannot reasonably be met through existing commitments, existing allocations, suitable brownfield capacity, urban regeneration, appropriate densities and other sustainable sources of supply.
What I am asking Cheshire East to do
I therefore ask that the evidence base for the New Local Plan includes:
1. A full forecast-versus-actual audit of the economic, employment, population, migration and housing assumptions underpinning the current Local Plan.
2. An explanation of the Council's statement that average annual jobs growth reached 1.3%, including the absolute number of jobs created and the methodology used.
3. Comparison of actual jobs growth with the approximately 31,000 additional jobs anticipated by the current Plan.
4. Comparison of assumed net migration with actual net migration.
5. A complete schedule of existing housing allocations, planning permissions, sites under construction and remaining capacity likely to contribute to the new Plan period.
6. A comprehensive assessment of realistic brownfield and urban housing capacity.
7. Transparent build-out assumptions for major existing sites.
8. A calculation showing precisely how the Government's minimum housing requirement translates into a net requirement for genuinely additional development land after existing capacity is deducted.
9. Alternative scenarios showing the effect of different reasonable build-out and brownfield assumptions upon that residual requirement.
10. No additional Green Belt release until that residual land requirement has been demonstrated.
Conclusion
The question for the new Local Plan should not simply be:
“How many homes does Cheshire East have to plan for?”
The much more important land-use question is:
“HOW MANY OF THOSE HOMES ACTUALLY REQUIRE NEW LAND?”
Cheshire East's own evidence shows substantial growth since the previous Plan was prepared.
But it also shows a substantial existing pipeline of housing and employment land.
The Council's March 2025 housing monitoring report identifies 27,423 homes already completed and a further 14,461 homes in identified remaining supply — 41,884 in total — against the current Plan's minimum requirement of 36,000. (Cheshire East Council)
Meanwhile, the new national standard-method figure is 2,530 homes per year, but CEC itself acknowledges that future provision can come from existing commitments and allocations as well as new sites. (localplan.cheshireeast.gov.uk)
Therefore, before another acre of Green Belt or greenfield land is identified for housing, the Council should publish the arithmetic demonstrating what genuinely additional land is required and why.
Growth should be accommodated.
But growth should not become an automatic justification for continually increasing the amount of land available for development without first accounting properly for the land and permissions already in the system.
Please register this as my formal representation to the New Local Plan Scoping Consultation and provide me with the consultation reference.
I would also be grateful to be notified when the Housing Needs Assessment, Economic Development Needs Assessment, Land Availability Assessment and evidence determining the residual requirement for new housing land are published.
Kind regards,
Richard Slater