Local plan scoping consultation

Re: Representation objecting to the inclusion or future allocation of Land West of A49, Whitchurch Road, Bunbury in the emerging Cheshire East Local Plan
Dear Strategic Planning Team,
I am writing as a resident of Bunbury regarding land west of the A49, Whitchurch Road, Bunbury, which I understand has been put forward via the council's site submissions process as a candidate site (see Fig 1 screen shot from council map). I understand that inclusion on the site submissions map does not itself confer any planning status, and that the call for sites is not currently open. However, I want this representation recorded against the site now, so that these concerns form part of the evidence base if and when this land, or any part of it, is considered for allocation at a future stage of plan-making.
I would also note that planning permission has already been granted on part of this land under application 25/3507/PIP. Rather than treating that as settling the matter, I would ask the council to treat it as evidence of the cumulative development pressure building on this parcel, and as a reason for particular caution before any further part of it is allocated or brought forward.
1. Conflict with the Settlement Boundary and the Bunbury Neighbourhood Plan
This land lies outside the defined Bunbury Settlement Boundary, in open countryside. The Bunbury Neighbourhood Plan (2015–2030), which forms part of the statutory Development Plan for Cheshire East, directs development to within the settlement boundary and requires the wider rural area to remain open countryside. Any future allocation of this land would conflict with Policy H1 (Settlement Boundary and Infill Development), Policy H2 (Scale of Housing Development) and Policy ENV4 (Landscape Quality, Countryside and Open Views), as well as Policy PG6 of the Cheshire East Local Plan Strategy, which defines and protects open countryside outside settlement boundaries. I would ask that the new Local Plan carry this same principle forward rather than weaken it.
This is not a marginal or ambiguous case. Two previous appeals for speculative residential development on this land have been dismissed within the last five years, primarily on the grounds of protecting the character and appearance of the open countryside and maintaining a coherent, defensible built-up edge to the village. I would ask that this appeal history be given significant weight in any future site assessment.
I would also ask the council to note that this land is not within, or affected by, any Green Belt designation, and is therefore not 'Grey Belt' land as defined in the December 2024 revisions to the National Planning Policy Framework. The Grey Belt concept, and the more permissive tests that accompany it, applies only to land within the Green Belt and has no application here. Any protection this land merits comes from the settlement boundary and countryside policies of the development plan, and from its own agricultural and environmental value as productive farmland, hay meadow and hedgerow habitat, which should be assessed on its own merits rather than conflated with the separate Grey Belt debate.
2. Cumulative Impact of Linked Site Submissions
This land should not be assessed in isolation. It forms one of several linked sites put forward by the same landowner (the Peckforton Estate) in this part of Bunbury, including land off College Lane/Vicarage Lane, land east of Wyche Road, and land off Saddlers Wells, all of which lie outside the settlement boundary. Considered together, these submissions represent a material and cumulative threat to the open countryside gap that the Neighbourhood Plan was specifically designed to protect. I would ask that any future assessment of this land consider its cumulative effect alongside these other submissions, rather than assessing each parcel as a standalone opportunity.
3. Flood Risk, Drainage and Sewerage
This land slopes to the south into a small, enclosed valley with no natural outflow. Development involving additional hard surfacing and roofing upslope, within this closed catchment, would increase both the volume and speed of surface water run-off with nowhere for that water to go. The property most immediately at risk is Pheasant Hollow, which sits directly downslope of Holly Mount at the low point of this valley. This is not a hypothetical or generalised flood risk: it is a specific, named, occupied property in the direct path of any increased run-off from this land.
The same topography raises a related concern about foul drainage. Given the fall of the land, it is not obvious that gravity drainage to the existing A49 sewer main would be achievable across the whole site, and I would ask that this be tested as part of any future site assessment rather than assumed. If package treatment plants or septic tanks were instead required, there would be a real risk of effluent discharge reaching the small ponds and wetlands that lie within the Pheasant Hollow valley, given that this is precisely the low point to which any leachate or discharge would migrate.
I would ask that this land's suitability assessment specifically address the closed nature of this valley and the foul drainage question above, rather than relying on generic catchment-level modelling, and that Sustainable Drainage System (SuDS) requirements be applied rigorously given the absence of any natural outflow.
4. Unsuitable Access
Access to this land is only available from an existing track off the A49 which is, in effect, a single-track private farm track with no passing places along its length. This track is not currently suitable to serve any meaningful scale of additional dwellings: two vehicles cannot pass safely, and there is no evident scope to remedy this without significant land take and cost. I would ask that any future assessment of this land test whether the track could realistically be widened to an adoptable standard with passing bays, and whether its ownership and adoption status have been established, before this land is considered developable.

5. Highway Safety on the A49 (see images below)
Separately from site access, I have significant road safety concerns about this stretch of the A49 (Whitchurch Road) itself. It is an unusually long, straight section of road, and in practice this leads to it being used by motorcyclists travelling to and from Oulton Park circuit for overtaking at speed, despite the 30mph limit through this section. Data from the RoadRisk collision mapping service shows a cluster of recorded collisions along this stretch, including at and around the A49/Whitchurch Road junction area itself. It is also notable that incidents cluster around junctions with the A49. This development would create another dangerous intersection. Enforcement is currently limited to a single static speed camera near School Lane, which does not cover the full length of the straight. Any additional dwellings with new accesses joining this road would introduce further points of conflict onto a road with a recognised collision history. I would ask that this be treated as a significant constraint on the developability of this land, and that any future assessment consider whether measures such as average speed enforcement cameras or a reduced speed limit would need to be secured before any part of this land could be considered suitable.
6. Loss of Habitat: Wildflower Hay Meadow (see images below)
This land includes an established wildflower hay meadow, not amenity grassland or unmanaged waste ground. It supports a visibly diverse mix of grasses and wildflowers, including buttercup in significant quantity, consistent with traditional hay meadow management. This represents a habitat of recognised conservation value, and its loss would conflict with Policy BIO1 (Biodiversity) of the Bunbury Neighbourhood Plan and with the council's Biodiversity Net Gain requirements. Photographs of the meadow in flower are enclosed with this representation.
7. Loss of Hedgerows
This land is bound by mature hedgerows and trees, which contribute both to the rural character of this part of the village and to local habitat connectivity. Their loss or fragmentation to accommodate access or built development would be contrary to Policy LC1 (Built Environment) and Policy BIO1 of the Neighbourhood Plan.
8. Loss of a Protected Open View (see images below)
This land forms part of an open, uninterrupted view across countryside toward Peckforton Castle, a Grade I listed building, as seen from neighbouring properties including Holly Mount. Photographs taken from Holly Mount in May 2023, enclosed with this representation, demonstrate this view clearly. Policy ENV4 of the Bunbury Neighbourhood Plan exists specifically to protect landscape quality and open countryside views of this kind, and I would ask that any future assessment give weight to the loss of this specific, evidenced view rather than treating the landscape harm only in general terms.
9. Wider Environmental and Urban Sprawl Concerns
More broadly, I am concerned that allocating this land, taken together with the other linked Peckforton Estate submissions, would represent a form of incremental urban sprawl onto productive farmland and established countryside, contributing to the urban heat island effect through the loss of vegetated, permeable land, and placing additional pressure on local wetlands and sewerage infrastructure. I would ask that the new Local Plan's spatial strategy continue to guard against this pattern in villages such as Bunbury.
Conclusion
For the reasons set out above, I would ask that this land not be taken forward for allocation in the emerging Cheshire East Local Plan. It conflicts with the development plan as a whole, including Policies H1, H2, ENV4, LC1 and BIO1 of the Bunbury Neighbourhood Plan and Policy PG6 of the Cheshire East Local Plan Strategy, and carries specific, evidenced harms: flood and foul drainage risk to a named property and its adjoining wetlands, loss of hay meadow habitat and hedgerows, loss of a protected view to a listed building, unsuitable single-track access, and a worsening of an already recognised road safety risk on the A49.
I would be grateful if you could confirm that this representation has been recorded against the site submission for this land, so that it forms part of the evidence base for any future consultation stage at which this land, or part of it, is considered for allocation.

Re: Representation objecting to the inclusion or future allocation of Land West of A49, Whitchurch Road, Bunbury in the emerging Cheshire East Local Plan
Dear Strategic Planning Team,
I am writing as a resident of Bunbury regarding land west of the A49, Whitchurch Road, Bunbury, which I understand has been put forward via the council's site submissions process as a candidate site (see Fig 1 screen shot from council map). I understand that inclusion on the site submissions map does not itself confer any planning status, and that the call for sites is not currently open. However, I want this representation recorded against the site now, so that these concerns form part of the evidence base if and when this land, or any part of it, is considered for allocation at a future stage of plan-making.
I would also note that planning permission has already been granted on part of this land under application 25/3507/PIP. Rather than treating that as settling the matter, I would ask the council to treat it as evidence of the cumulative development pressure building on this parcel, and as a reason for particular caution before any further part of it is allocated or brought forward.
1. Conflict with the Settlement Boundary and the Bunbury Neighbourhood Plan
This land lies outside the defined Bunbury Settlement Boundary, in open countryside. The Bunbury Neighbourhood Plan (2015–2030), which forms part of the statutory Development Plan for Cheshire East, directs development to within the settlement boundary and requires the wider rural area to remain open countryside. Any future allocation of this land would conflict with Policy H1 (Settlement Boundary and Infill Development), Policy H2 (Scale of Housing Development) and Policy ENV4 (Landscape Quality, Countryside and Open Views), as well as Policy PG6 of the Cheshire East Local Plan Strategy, which defines and protects open countryside outside settlement boundaries. I would ask that the new Local Plan carry this same principle forward rather than weaken it.
This is not a marginal or ambiguous case. Two previous appeals for speculative residential development on this land have been dismissed within the last five years, primarily on the grounds of protecting the character and appearance of the open countryside and maintaining a coherent, defensible built-up edge to the village. I would ask that this appeal history be given significant weight in any future site assessment.
I would also ask the council to note that this land is not within, or affected by, any Green Belt designation, and is therefore not 'Grey Belt' land as defined in the December 2024 revisions to the National Planning Policy Framework. The Grey Belt concept, and the more permissive tests that accompany it, applies only to land within the Green Belt and has no application here. Any protection this land merits comes from the settlement boundary and countryside policies of the development plan, and from its own agricultural and environmental value as productive farmland, hay meadow and hedgerow habitat, which should be assessed on its own merits rather than conflated with the separate Grey Belt debate.
2. Cumulative Impact of Linked Site Submissions
This land should not be assessed in isolation. It forms one of several linked sites put forward by the same landowner (the Peckforton Estate) in this part of Bunbury, including land off College Lane/Vicarage Lane, land east of Wyche Road, and land off Saddlers Wells, all of which lie outside the settlement boundary. Considered together, these submissions represent a material and cumulative threat to the open countryside gap that the Neighbourhood Plan was specifically designed to protect. I would ask that any future assessment of this land consider its cumulative effect alongside these other submissions, rather than assessing each parcel as a standalone opportunity.
3. Flood Risk, Drainage and Sewerage
This land slopes to the south into a small, enclosed valley with no natural outflow. Development involving additional hard surfacing and roofing upslope, within this closed catchment, would increase both the volume and speed of surface water run-off with nowhere for that water to go. The property most immediately at risk is Pheasant Hollow, which sits directly downslope of Holly Mount at the low point of this valley. This is not a hypothetical or generalised flood risk: it is a specific, named, occupied property in the direct path of any increased run-off from this land.
The same topography raises a related concern about foul drainage. Given the fall of the land, it is not obvious that gravity drainage to the existing A49 sewer main would be achievable across the whole site, and I would ask that this be tested as part of any future site assessment rather than assumed. If package treatment plants or septic tanks were instead required, there would be a real risk of effluent discharge reaching the small ponds and wetlands that lie within the Pheasant Hollow valley, given that this is precisely the low point to which any leachate or discharge would migrate.
I would ask that this land's suitability assessment specifically address the closed nature of this valley and the foul drainage question above, rather than relying on generic catchment-level modelling, and that Sustainable Drainage System (SuDS) requirements be applied rigorously given the absence of any natural outflow.
4. Unsuitable Access
Access to this land is only available from an existing track off the A49 which is, in effect, a single-track private farm track with no passing places along its length. This track is not currently suitable to serve any meaningful scale of additional dwellings: two vehicles cannot pass safely, and there is no evident scope to remedy this without significant land take and cost. I would ask that any future assessment of this land test whether the track could realistically be widened to an adoptable standard with passing bays, and whether its ownership and adoption status have been established, before this land is considered developable.

5. Highway Safety on the A49 (see images below)
Separately from site access, I have significant road safety concerns about this stretch of the A49 (Whitchurch Road) itself. It is an unusually long, straight section of road, and in practice this leads to it being used by motorcyclists travelling to and from Oulton Park circuit for overtaking at speed, despite the 30mph limit through this section. Data from the RoadRisk collision mapping service shows a cluster of recorded collisions along this stretch, including at and around the A49/Whitchurch Road junction area itself. It is also notable that incidents cluster around junctions with the A49. This development would create another dangerous intersection. Enforcement is currently limited to a single static speed camera near School Lane, which does not cover the full length of the straight. Any additional dwellings with new accesses joining this road would introduce further points of conflict onto a road with a recognised collision history. I would ask that this be treated as a significant constraint on the developability of this land, and that any future assessment consider whether measures such as average speed enforcement cameras or a reduced speed limit would need to be secured before any part of this land could be considered suitable.
6. Loss of Habitat: Wildflower Hay Meadow (see images below)
This land includes an established wildflower hay meadow, not amenity grassland or unmanaged waste ground. It supports a visibly diverse mix of grasses and wildflowers, including buttercup in significant quantity, consistent with traditional hay meadow management. This represents a habitat of recognised conservation value, and its loss would conflict with Policy BIO1 (Biodiversity) of the Bunbury Neighbourhood Plan and with the council's Biodiversity Net Gain requirements. Photographs of the meadow in flower are enclosed with this representation.
7. Loss of Hedgerows
This land is bound by mature hedgerows and trees, which contribute both to the rural character of this part of the village and to local habitat connectivity. Their loss or fragmentation to accommodate access or built development would be contrary to Policy LC1 (Built Environment) and Policy BIO1 of the Neighbourhood Plan.
8. Loss of a Protected Open View (see images below)
This land forms part of an open, uninterrupted view across countryside toward Peckforton Castle, a Grade I listed building, as seen from neighbouring properties including Holly Mount. Photographs taken from Holly Mount in May 2023, enclosed with this representation, demonstrate this view clearly. Policy ENV4 of the Bunbury Neighbourhood Plan exists specifically to protect landscape quality and open countryside views of this kind, and I would ask that any future assessment give weight to the loss of this specific, evidenced view rather than treating the landscape harm only in general terms.
9. Wider Environmental and Urban Sprawl Concerns
More broadly, I am concerned that allocating this land, taken together with the other linked Peckforton Estate submissions, would represent a form of incremental urban sprawl onto productive farmland and established countryside, contributing to the urban heat island effect through the loss of vegetated, permeable land, and placing additional pressure on local wetlands and sewerage infrastructure. I would ask that the new Local Plan's spatial strategy continue to guard against this pattern in villages such as Bunbury.
Conclusion
For the reasons set out above, I would ask that this land not be taken forward for allocation in the emerging Cheshire East Local Plan. It conflicts with the development plan as a whole, including Policies H1, H2, ENV4, LC1 and BIO1 of the Bunbury Neighbourhood Plan and Policy PG6 of the Cheshire East Local Plan Strategy, and carries specific, evidenced harms: flood and foul drainage risk to a named property and its adjoining wetlands, loss of hay meadow habitat and hedgerows, loss of a protected view to a listed building, unsuitable single-track access, and a worsening of an already recognised road safety risk on the A49.
I would be grateful if you could confirm that this representation has been recorded against the site submission for this land, so that it forms part of the evidence base for any future consultation stage at which this land, or part of it, is considered for allocation.