Local plan scoping consultation

I am writing in response to Cheshire East Council’s Local Plan Scoping Consultation and would be grateful if this response could be formally recorded as a representation concerning the identification and assessment of potential development sites, specifically:
HE104 – Land at Styal Golf Course, Station Road, Styal, SK9 4JN
I understand that HE104 comprises approximately 57.22 hectares and has been promoted through the Call for Sites process for residential development.
I recognise the significant housing requirements facing Cheshire East and the need for the new Local Plan to identify sufficient deliverable land. However, I have serious concerns as to whether HE104 represents an appropriate, sustainable or justified location for strategic residential development.
I therefore ask the Council not to infer suitability from the site's promotion through the Call for Sites process, and instead to subject HE104 to detailed and transparent assessment against the current National Planning Policy Framework, the made Styal Neighbourhood Plan and reasonable alternative locations for growth.
1. Green Belt and the strategic separation of urban areas
HE104 comprises a very substantial area of presently open Green Belt land.
One of the most important issues is the contribution this land makes to maintaining physical and visual separation between Styal, South Manchester, Manchester Airport, Handforth/Wilmslow and surrounding developed areas.
This concern is particularly significant because the Styal Neighbourhood Plan, made in March 2025, expressly establishes a vision for Styal to remain a:
“Green Lung” between South Manchester, Manchester Airport and other nearby urban areas
providing recreation and leisure opportunities while retaining its distinctive historic and rural character.
The Neighbourhood Plan also identifies the strategic role of Styal as providing open space, leisure and recreation and seeks to maintain that function.
These are matters directly relevant to the purposes of the Green Belt.
The Council's assessment of HE104 should therefore specifically establish whether development of the site would:
• materially reduce the physical or visual separation of neighbouring built-up areas;
• contribute towards perceived or actual urban coalescence;
• extend an urbanising influence into an presently open landscape;
• undermine Styal's strategic function as a Green Belt gap and “Green Lung”; and
• fundamentally alter the open and rural character of this part of the parish.
Given the substantial size of HE104, I would also ask the Council not to assess the entire 57.22 hectares as one homogeneous Green Belt parcel.
The August 2026 NPPF requires Green Belt assessments to be sufficiently fine-grained to identify variations in the contribution made by different parts of a site and expressly provides for assessment areas to be subdivided where necessary in identifying grey belt.
That is particularly important in the case of a site of this scale.
Any conclusion that some or all of HE104 constitutes “grey belt” should therefore be supported by transparent, parcel-specific evidence demonstrating how the relevant land performs against the Green Belt purposes.
2. Loss of an established golf and recreational facility
HE104 is not simply vacant or unused open land.
It contains a long-established recreational facility.
The made Styal Neighbourhood Plan specifically records that Styal Golf Club has an 18-hole golf course, driving range and eatery and identifies it as part of the area's existing recreational and sporting provision.
Current national planning policy, including NPPF Policy HC7 – Development affecting existing recreational land and facilities, establishes that development should not result in the loss of existing sports and recreational buildings and land unless one of the relevant policy tests is satisfied.
These include an assessment clearly demonstrating that the facility is surplus to requirements, replacement by equivalent or better provision, or alternative recreational provision whose benefits clearly outweigh the loss.
I therefore ask the Council to distinguish carefully between:
an intention for the existing use to cease
and
objective evidence demonstrating that the recreational facility is surplus to requirements.
Those are materially different propositions.
If the promoter of HE104 relies upon the future closure or cessation of golf activities as evidence supporting residential development, the fact that an owner may choose to discontinue an existing recreational use should not itself establish that there is no continuing need or demand for that recreational provision.
The Council should therefore require proper evidence addressing:
• existing use and participation;
• catchment and demand;
• current and future need for golf and associated recreational facilities;
• alternative provision within the relevant catchment;
• the consequences of losing the 18-hole course and associated facilities; and
• whether replacement provision would be required.
The question should be whether the recreational facility is genuinely surplus to requirements, rather than simply whether its landowner wishes to make the land available for another purpose.
3. Potential loss of an established wedding and events business
There is also a separate and important economic consideration which should not be subsumed within the assessment of the golf course.
The made Styal Neighbourhood Plan itself specifically identifies Styal Lodge at Styal Golf Club as a wedding and events venue.
It is therefore an established rural business recognised within the Council's own development-plan evidence.
Residential redevelopment of HE104 and the loss of the surrounding golf-course environment could have significant implications for the continued operation and viability of that business.
The Council should therefore establish, before taking HE104 forward as a potential allocation, whether redevelopment of the golf-course land would result in the closure, displacement or material impairment of Styal Lodge.
This is not simply a private commercial consideration.
The current NPPF requires development plans to support sustainable economic growth in rural areas and specifically recognises the importance of leisure, tourism and rural businesses. Policy E4 supports facilities associated with rural leisure and tourism.
The NPPF also contains an important principle under Policy P4 – Impact of development on existing activities: established businesses should not have unreasonable restrictions placed upon their operation as a consequence of subsequent development, and new development should be capable of integrating effectively with existing businesses.
Against that policy background, the Council should assess:
• whether Styal Lodge could continue operating if the surrounding golf-course use ceased;
• whether its operation relies upon land or facilities within HE104;
• whether its access, parking, servicing, utilities or other infrastructure would be affected;
• the importance of the surrounding countryside and golf-course landscape to the character and operation of the venue;
• whether residential development would give rise to conflicts between new residents and the existing events business;
• whether those conflicts could place restrictions on the existing venue;
• the employment supported by the business;
• its contribution to the rural visitor economy;
• expenditure generated for other local businesses; and
• the wider supply chain associated with weddings and events, including accommodation providers, caterers, florists, photographers, transport providers and other local suppliers.
If allocation or redevelopment of HE104 would effectively result in the loss of a viable and established rural leisure and events business, that should be expressly identified as a significant economic consequence of selecting the site.
It would be inappropriate, in my view, to assess the benefits of residential development without simultaneously assessing the economic activity, employment, tourism and established business uses which might consequently be lost.
The Council should therefore establish the likely future of Styal Lodge as part of the evidence base for HE104 rather than defer this matter until after the principle of residential development has effectively been established.
4. Scale of development and the character of Styal
At approximately 57.22 hectares, HE104 is an exceptionally substantial site in the context of Styal.
Depending upon its eventual density and net developable area, its allocation could result in a level of residential development fundamentally different in scale from the existing settlement.
This should be considered against the very recently made Styal Neighbourhood Plan.
Its vision seeks to retain Styal as an attractive rural village and its housing objective supports small-scale, limited housing where consistent with Green Belt policy and where important green spaces are protected.
I recognise that the new Cheshire East Local Plan will address strategic needs extending beyond the Neighbourhood Plan period.
Nevertheless, such a substantial departure from a spatial vision independently examined, supported at referendum and made only in March 2025 should require compelling and proportionate evidence.
The assessment should therefore consider not merely how many dwellings can theoretically be accommodated within a 57-hectare red line, but whether development at that scale is appropriate having regard to:
• Styal's settlement character;
• landscape setting;
• existing development pattern;
• Green Belt function;
• local infrastructure;
• community facilities; and
• cumulative development pressures.
5. Highways, accessibility and sustainable transport
The transport implications also require particularly careful examination.
The Styal Neighbourhood Plan itself records that:
• there has been no bus service through Styal since May 2018;
• heavy vehicular traffic is already a significant issue;
• most roads in Styal are narrow and winding;
• those roads nevertheless carry significant volumes of traffic;
• car ownership is comparatively high; and
• traffic, parking and speeding are existing concerns.
I recognise that Styal benefits from a railway station.
However, the existence of a station should not by itself establish that a strategic housing development on HE104 represents sustainable development.
The Council should establish:
• the actual walking distance from the developable portions of HE104 to the station;
• whether that route is safe, attractive and accessible throughout the year;
• rail frequency and destinations;
• capacity and reliability of rail services;
• accessibility of schools, healthcare, shops and other everyday services without a car;
• the likely modal split for future residents;
• capacity of Station Road and surrounding highways;
• junction impacts;
• cumulative traffic effects;
• safe walking and cycling connectivity;
• what highway or public-transport improvements would be required; and
• whether those improvements are realistically deliverable without themselves damaging the rural character of Styal.
These are matters which should inform site selection, rather than being left entirely to a future planning application after the principle of development has already been established.
6. Landscape, ecology, drainage and realistic developable capacity
A further concern is whether the headline area of 57.22 hectares gives a misleading impression of the site's true residential capacity.
The golf-course landscape contains established woodland, mature trees, hedgerows, water features and habitats which contribute collectively to landscape character, biodiversity and ecological connectivity.
A robust assessment should therefore address:
• existing habitat value;
• woodland and mature trees;
• hedgerows;
• ponds and watercourses;
• protected species;
• ecological connectivity;
• biodiversity net gain;
• sustainable drainage;
• surface-water management;
• landscape and visual effects;
• public open-space requirements;
• Green Belt mitigation;
• recreational requirements; and
• appropriate separation and landscape buffers.
Collectively, these requirements could materially reduce the amount of HE104 genuinely capable of accommodating residential development.
The Council should therefore publish both:
the gross promoted site area
and
the realistic net developable area after all constraints and necessary mitigation have been applied.
That distinction is important when HE104 is compared against alternative potential allocations.
7. The cumulative loss of existing economic, recreational and environmental value
I would particularly urge the Council not to assess the individual effects of HE104 in isolation.
Potential residential development could involve the cumulative loss or impairment of:
• a substantial area of open Green Belt;
• an established 18-hole golf course;
• associated recreational facilities;
• an established wedding and events venue;
• rural employment and visitor-economy activity;
• important landscape character;
• existing habitat;
• recreational and leisure opportunities; and
• part of the strategic green separation identified in the Styal Neighbourhood Plan.
The cumulative consequences of these losses should be weighed against the benefits of allocating HE104, rather than each issue being considered separately and discounted as capable of later mitigation.
8. Comparison with reasonable alternative sites
I appreciate that many potential housing sites within Cheshire East will have constraints.
The relevant question is therefore not simply whether individual impacts at HE104 could theoretically be mitigated.
The more important strategic question is:
Why should this particular site be selected in preference to reasonable alternatives?
Before HE104 is taken forward, I therefore ask Cheshire East to publish a transparent assessment identifying:
• the site's Green Belt contribution;
• any grey-belt conclusion and the evidence supporting it;
• effects upon strategic separation;
• realistic net residential capacity;
• loss of existing recreational provision;
• consequences for Styal Lodge and other existing businesses;
• landscape and visual effects;
• ecological constraints;
• flood risk and drainage;
• highways and sustainable-transport performance;
• access to schools and other services;
• infrastructure requirements;
• deliverability;
• timescale;
• mitigation requirements; and
• its comparative performance against reasonable alternative development sites.
Conclusion
I recognise the difficult task Cheshire East faces in planning for future housing requirements.
However, HE104 should not be regarded as suitable for strategic residential development merely because it has been promoted and may become available.
Availability is only one component of site assessment.
HE104 raises significant and interrelated questions concerning:
Green Belt function, strategic settlement separation, recreational loss, an existing rural wedding and events business, landscape character, ecology, sustainable transport, highway capacity, infrastructure and the recently made Styal Neighbourhood Plan.
I therefore ask Cheshire East Council to:
1. Record this representation specifically in relation to HE104 – Styal Golf Course.
2. Subject HE104 to a detailed, transparent and sufficiently granular Green Belt assessment before considering it for residential allocation.
3. Require objective evidence demonstrating that the golf and recreational facilities are surplus to requirements rather than treating future closure as equivalent to a lack of recreational need.
4. Assess the implications of HE104 for the continued operation and viability of Styal Lodge and the associated employment, tourism and local economic activity.
5. Undertake appropriate transport, highways, landscape, ecological, drainage and infrastructure assessment at the site-selection stage.
6. Identify a realistic net developable area and capacity rather than relying upon the gross 57.22-hectare site area.
7. Consider the cumulative effect of losing existing Green Belt, recreation, established businesses and rural landscape.
8. Demonstrate transparently why HE104 would represent a more sustainable and appropriate strategic choice than reasonable alternative sites before it is taken forward in the Local Plan.
I would be grateful if you could confirm receipt and confirm that this representation will be retained and considered as part of the Local Plan evidence and consultation record relating to HE104.