Local plan scoping consultation

Re: New Local Plan Scoping Consultation (Regulation 20) –
Wilmslow Local Plan

I am writing as a resident of the Dean Row area of Wilmslow to respond to the scoping consultation. I understand this stage is not inviting individual site submissions, and my comments below are directed at the scope and approach the new plan should take, in line with paragraph 1.8 of the introduction document.

1. Spatial distribution should not default to the areas with the highest land values

Paragraph 5.24 confirms that the new plan will need to set a strategy for the distribution of development across the borough, and that the council is currently reviewing the settlement hierarchy (para 5.23), taking into account services, infrastructure, jobs and settlement form.

I would ask that this review explicitly considers the risk that development becomes concentrated in a small number of higher-value settlements such as Wilmslow, not because those locations score best against sustainability or infrastructure capacity criteria, but because higher achievable sale values there generate stronger developer margins and viability. Left unchecked, this creates a self-reinforcing pattern where allocations follow land value rather than the balanced, borough-wide distribution that national policy and the council's own settlement hierarchy approach are meant to achieve.

I would like the new plan to:
- Set out a transparent, evidence-led methodology for distributing development across the settlement hierarchy that is not skewed by developer viability assessments submitted on a site-by-site basis;
- Include viability and land value as an explicit factor considered in the sustainability appraisal, so that over-concentration in high-value areas is identified and tested as a reasonable alternative is weighed against more even distribution across the borough's settlements of similar tier.

2. The cumulative effect of development already directed at Wilmslow/Dean Row should be a starting point for the new evidence base, not ignored

Wilmslow, and the Dean Row area in particular, has already absorbed a substantial amount of housing development under the current plan period. The scoping document's baseline and spatial portrait work (Chapter 4) and sustainability appraisal (which covers landscape, cultural heritage, and social inclusiveness) should take full account of this recent delivery when assessing capacity for further growth, rather than treating each settlement as a blank slate.

I would ask the new plan to:
- Use actual, recent delivery rates by settlement (not just outstanding allocations) as part of the evidence base for the settlement hierarchy review, so that areas which have already delivered disproportionately are recognised as such;
- Retain and strengthen the strategic green gap approach (equivalent to current Policy PG5) between Wilmslow and neighbouring settlements, to prevent coalescence and protect the separate identity of settlements as continued piecemeal development pushes outward from existing boundaries;
- Require cumulative impact assessment of landscape, character and infrastructure (schools, GP capacity, road network) for settlements that have already seen significant recent growth, so that further greenfield release is tested against what the area can actually absorb, not just against a borough-wide housing number;
- Give proper weight to a brownfield-first and previously-developed-land approach before further open countryside or edge-of-settlement greenfield sites are considered around already-stretched settlements.

3. Green Belt, best and most versatile agricultural land, and biodiversity should be treated as hard constraints in the evidence base, not general site-selection preferences

Much of the remaining open land around Dean Row and similar parts of Wilmslow is Green Belt, in active agricultural use, and supports notable biodiversity, including bats, newts, barn owls and kestrels. I would ask the new plan to build the following into its scope and evidence base from the outset, so that these constraints are properly tested before any related sites are brought forward at later stages:

- Green Belt: Confirm that any review of Green Belt boundaries will only be undertaken where "exceptional circumstances" are fully and separately evidenced, in line with national policy, and only after all reasonable non-Green Belt, brownfield and previously-developed land options have been explored first. The evidence base underpinning any proposed Green Belt boundary changes should be published and subject to its own consultation, not folded into general site selection.
- Agricultural land quality: Require Agricultural Land Classification (ALC) survey data to be gathered and published as part of the evidence base, with the plan's site selection methodology giving preference to lower-grade and non-agricultural land over best and most versatile (Grades 1, 2 and 3a) agricultural land wherever reasonable alternatives exist.
- Biodiversity: Ensure the evidence base includes proper ecological survey and mapping of locally and ecologically important habitats and species corridors (including protected species such as bats and great crested newts) before Green Belt or greenfield sites are brought forward for consultation, given the separate statutory protections that apply under the Wildlife and Countryside Act and the Conservation of Habitats and Species Regulations. The plan should also confirm how the mandatory 10% biodiversity net gain requirement will be applied, and should recognise that some habitat and species impacts are irreplaceable and cannot simply be offset through net gain calculations.

4. Engagement strategy

Given the strength of local feeling in areas like Dean Row that have already experienced significant change, I would ask that the engagement strategy (Chapter 6) include clear, direct notification to residents in areas identified as having already delivered significant housing, or where Green Belt, high-grade agricultural land or notable biodiversity constraints apply, at the point options for further growth in their area are being considered, rather than relying solely on borough-wide publicity.

I would welcome confirmation that these comments have been received and will be taken into account in developing the options for the spatial strategy and settlement hierarchy.

Re: New Local Plan Scoping Consultation (Regulation 20) –
Wilmslow Local Plan

I am writing as a resident of the Dean Row area of Wilmslow to respond to the scoping consultation. I understand this stage is not inviting individual site submissions, and my comments below are directed at the scope and approach the new plan should take, in line with paragraph 1.8 of the introduction document.

1. Spatial distribution should not default to the areas with the highest land values

Paragraph 5.24 confirms that the new plan will need to set a strategy for the distribution of development across the borough, and that the council is currently reviewing the settlement hierarchy (para 5.23), taking into account services, infrastructure, jobs and settlement form.

I would ask that this review explicitly considers the risk that development becomes concentrated in a small number of higher-value settlements such as Wilmslow, not because those locations score best against sustainability or infrastructure capacity criteria, but because higher achievable sale values there generate stronger developer margins and viability. Left unchecked, this creates a self-reinforcing pattern where allocations follow land value rather than the balanced, borough-wide distribution that national policy and the council's own settlement hierarchy approach are meant to achieve.

I would like the new plan to:
- Set out a transparent, evidence-led methodology for distributing development across the settlement hierarchy that is not skewed by developer viability assessments submitted on a site-by-site basis;
- Include viability and land value as an explicit factor considered in the sustainability appraisal, so that over-concentration in high-value areas is identified and tested as a reasonable alternative is weighed against more even distribution across the borough's settlements of similar tier.

2. The cumulative effect of development already directed at Wilmslow/Dean Row should be a starting point for the new evidence base, not ignored

Wilmslow, and the Dean Row area in particular, has already absorbed a substantial amount of housing development under the current plan period. The scoping document's baseline and spatial portrait work (Chapter 4) and sustainability appraisal (which covers landscape, cultural heritage, and social inclusiveness) should take full account of this recent delivery when assessing capacity for further growth, rather than treating each settlement as a blank slate.

I would ask the new plan to:
- Use actual, recent delivery rates by settlement (not just outstanding allocations) as part of the evidence base for the settlement hierarchy review, so that areas which have already delivered disproportionately are recognised as such;
- Retain and strengthen the strategic green gap approach (equivalent to current Policy PG5) between Wilmslow and neighbouring settlements, to prevent coalescence and protect the separate identity of settlements as continued piecemeal development pushes outward from existing boundaries;
- Require cumulative impact assessment of landscape, character and infrastructure (schools, GP capacity, road network) for settlements that have already seen significant recent growth, so that further greenfield release is tested against what the area can actually absorb, not just against a borough-wide housing number;
- Give proper weight to a brownfield-first and previously-developed-land approach before further open countryside or edge-of-settlement greenfield sites are considered around already-stretched settlements.

3. Green Belt, best and most versatile agricultural land, and biodiversity should be treated as hard constraints in the evidence base, not general site-selection preferences

Much of the remaining open land around Dean Row and similar parts of Wilmslow is Green Belt, in active agricultural use, and supports notable biodiversity, including bats, newts, barn owls and kestrels. I would ask the new plan to build the following into its scope and evidence base from the outset, so that these constraints are properly tested before any related sites are brought forward at later stages:

- Green Belt: Confirm that any review of Green Belt boundaries will only be undertaken where "exceptional circumstances" are fully and separately evidenced, in line with national policy, and only after all reasonable non-Green Belt, brownfield and previously-developed land options have been explored first. The evidence base underpinning any proposed Green Belt boundary changes should be published and subject to its own consultation, not folded into general site selection.
- Agricultural land quality: Require Agricultural Land Classification (ALC) survey data to be gathered and published as part of the evidence base, with the plan's site selection methodology giving preference to lower-grade and non-agricultural land over best and most versatile (Grades 1, 2 and 3a) agricultural land wherever reasonable alternatives exist.
- Biodiversity: Ensure the evidence base includes proper ecological survey and mapping of locally and ecologically important habitats and species corridors (including protected species such as bats and great crested newts) before Green Belt or greenfield sites are brought forward for consultation, given the separate statutory protections that apply under the Wildlife and Countryside Act and the Conservation of Habitats and Species Regulations. The plan should also confirm how the mandatory 10% biodiversity net gain requirement will be applied, and should recognise that some habitat and species impacts are irreplaceable and cannot simply be offset through net gain calculations.

4. Engagement strategy

Given the strength of local feeling in areas like Dean Row that have already experienced significant change, I would ask that the engagement strategy (Chapter 6) include clear, direct notification to residents in areas identified as having already delivered significant housing, or where Green Belt, high-grade agricultural land or notable biodiversity constraints apply, at the point options for further growth in their area are being considered, rather than relying solely on borough-wide publicity.

I would welcome confirmation that these comments have been received and will be taken into account in developing the options for the spatial strategy and settlement hierarchy.

Re: New Local Plan Scoping Consultation (Regulation 20) –
Wilmslow Local Plan

I am writing as a resident of the Dean Row area of Wilmslow to respond to the scoping consultation. I understand this stage is not inviting individual site submissions, and my comments below are directed at the scope and approach the new plan should take, in line with paragraph 1.8 of the introduction document.

1. Spatial distribution should not default to the areas with the highest land values

Paragraph 5.24 confirms that the new plan will need to set a strategy for the distribution of development across the borough, and that the council is currently reviewing the settlement hierarchy (para 5.23), taking into account services, infrastructure, jobs and settlement form.

I would ask that this review explicitly considers the risk that development becomes concentrated in a small number of higher-value settlements such as Wilmslow, not because those locations score best against sustainability or infrastructure capacity criteria, but because higher achievable sale values there generate stronger developer margins and viability. Left unchecked, this creates a self-reinforcing pattern where allocations follow land value rather than the balanced, borough-wide distribution that national policy and the council's own settlement hierarchy approach are meant to achieve.

I would like the new plan to:
- Set out a transparent, evidence-led methodology for distributing development across the settlement hierarchy that is not skewed by developer viability assessments submitted on a site-by-site basis;
- Include viability and land value as an explicit factor considered in the sustainability appraisal, so that over-concentration in high-value areas is identified and tested as a reasonable alternative is weighed against more even distribution across the borough's settlements of similar tier.

2. The cumulative effect of development already directed at Wilmslow/Dean Row should be a starting point for the new evidence base, not ignored

Wilmslow, and the Dean Row area in particular, has already absorbed a substantial amount of housing development under the current plan period. The scoping document's baseline and spatial portrait work (Chapter 4) and sustainability appraisal (which covers landscape, cultural heritage, and social inclusiveness) should take full account of this recent delivery when assessing capacity for further growth, rather than treating each settlement as a blank slate.

I would ask the new plan to:
- Use actual, recent delivery rates by settlement (not just outstanding allocations) as part of the evidence base for the settlement hierarchy review, so that areas which have already delivered disproportionately are recognised as such;
- Retain and strengthen the strategic green gap approach (equivalent to current Policy PG5) between Wilmslow and neighbouring settlements, to prevent coalescence and protect the separate identity of settlements as continued piecemeal development pushes outward from existing boundaries;
- Require cumulative impact assessment of landscape, character and infrastructure (schools, GP capacity, road network) for settlements that have already seen significant recent growth, so that further greenfield release is tested against what the area can actually absorb, not just against a borough-wide housing number;
- Give proper weight to a brownfield-first and previously-developed-land approach before further open countryside or edge-of-settlement greenfield sites are considered around already-stretched settlements.

3. Green Belt, best and most versatile agricultural land, and biodiversity should be treated as hard constraints in the evidence base, not general site-selection preferences

Much of the remaining open land around Dean Row and similar parts of Wilmslow is Green Belt, in active agricultural use, and supports notable biodiversity, including bats, newts, barn owls and kestrels. I would ask the new plan to build the following into its scope and evidence base from the outset, so that these constraints are properly tested before any related sites are brought forward at later stages:

- Green Belt: Confirm that any review of Green Belt boundaries will only be undertaken where "exceptional circumstances" are fully and separately evidenced, in line with national policy, and only after all reasonable non-Green Belt, brownfield and previously-developed land options have been explored first. The evidence base underpinning any proposed Green Belt boundary changes should be published and subject to its own consultation, not folded into general site selection.
- Agricultural land quality: Require Agricultural Land Classification (ALC) survey data to be gathered and published as part of the evidence base, with the plan's site selection methodology giving preference to lower-grade and non-agricultural land over best and most versatile (Grades 1, 2 and 3a) agricultural land wherever reasonable alternatives exist.
- Biodiversity: Ensure the evidence base includes proper ecological survey and mapping of locally and ecologically important habitats and species corridors (including protected species such as bats and great crested newts) before Green Belt or greenfield sites are brought forward for consultation, given the separate statutory protections that apply under the Wildlife and Countryside Act and the Conservation of Habitats and Species Regulations. The plan should also confirm how the mandatory 10% biodiversity net gain requirement will be applied, and should recognise that some habitat and species impacts are irreplaceable and cannot simply be offset through net gain calculations.

4. Engagement strategy

Given the strength of local feeling in areas like Dean Row that have already experienced significant change, I would ask that the engagement strategy (Chapter 6) include clear, direct notification to residents in areas identified as having already delivered significant housing, or where Green Belt, high-grade agricultural land or notable biodiversity constraints apply, at the point options for further growth in their area are being considered, rather than relying solely on borough-wide publicity.

I would welcome confirmation that these comments have been received and will be taken into account in developing the options for the spatial strategy and settlement hierarchy.

Re: New Local Plan Scoping Consultation (Regulation 20) –
Wilmslow Local Plan

I am writing as a resident of the Dean Row area of Wilmslow to respond to the scoping consultation. I understand this stage is not inviting individual site submissions, and my comments below are directed at the scope and approach the new plan should take, in line with paragraph 1.8 of the introduction document.

1. Spatial distribution should not default to the areas with the highest land values

Paragraph 5.24 confirms that the new plan will need to set a strategy for the distribution of development across the borough, and that the council is currently reviewing the settlement hierarchy (para 5.23), taking into account services, infrastructure, jobs and settlement form.

I would ask that this review explicitly considers the risk that development becomes concentrated in a small number of higher-value settlements such as Wilmslow, not because those locations score best against sustainability or infrastructure capacity criteria, but because higher achievable sale values there generate stronger developer margins and viability. Left unchecked, this creates a self-reinforcing pattern where allocations follow land value rather than the balanced, borough-wide distribution that national policy and the council's own settlement hierarchy approach are meant to achieve.

I would like the new plan to:
- Set out a transparent, evidence-led methodology for distributing development across the settlement hierarchy that is not skewed by developer viability assessments submitted on a site-by-site basis;
- Include viability and land value as an explicit factor considered in the sustainability appraisal, so that over-concentration in high-value areas is identified and tested as a reasonable alternative is weighed against more even distribution across the borough's settlements of similar tier.

2. The cumulative effect of development already directed at Wilmslow/Dean Row should be a starting point for the new evidence base, not ignored

Wilmslow, and the Dean Row area in particular, has already absorbed a substantial amount of housing development under the current plan period. The scoping document's baseline and spatial portrait work (Chapter 4) and sustainability appraisal (which covers landscape, cultural heritage, and social inclusiveness) should take full account of this recent delivery when assessing capacity for further growth, rather than treating each settlement as a blank slate.

I would ask the new plan to:
- Use actual, recent delivery rates by settlement (not just outstanding allocations) as part of the evidence base for the settlement hierarchy review, so that areas which have already delivered disproportionately are recognised as such;
- Retain and strengthen the strategic green gap approach (equivalent to current Policy PG5) between Wilmslow and neighbouring settlements, to prevent coalescence and protect the separate identity of settlements as continued piecemeal development pushes outward from existing boundaries;
- Require cumulative impact assessment of landscape, character and infrastructure (schools, GP capacity, road network) for settlements that have already seen significant recent growth, so that further greenfield release is tested against what the area can actually absorb, not just against a borough-wide housing number;
- Give proper weight to a brownfield-first and previously-developed-land approach before further open countryside or edge-of-settlement greenfield sites are considered around already-stretched settlements.

3. Green Belt, best and most versatile agricultural land, and biodiversity should be treated as hard constraints in the evidence base, not general site-selection preferences

Much of the remaining open land around Dean Row and similar parts of Wilmslow is Green Belt, in active agricultural use, and supports notable biodiversity, including bats, newts, barn owls and kestrels. I would ask the new plan to build the following into its scope and evidence base from the outset, so that these constraints are properly tested before any related sites are brought forward at later stages:

- Green Belt: Confirm that any review of Green Belt boundaries will only be undertaken where "exceptional circumstances" are fully and separately evidenced, in line with national policy, and only after all reasonable non-Green Belt, brownfield and previously-developed land options have been explored first. The evidence base underpinning any proposed Green Belt boundary changes should be published and subject to its own consultation, not folded into general site selection.
- Agricultural land quality: Require Agricultural Land Classification (ALC) survey data to be gathered and published as part of the evidence base, with the plan's site selection methodology giving preference to lower-grade and non-agricultural land over best and most versatile (Grades 1, 2 and 3a) agricultural land wherever reasonable alternatives exist.
- Biodiversity: Ensure the evidence base includes proper ecological survey and mapping of locally and ecologically important habitats and species corridors (including protected species such as bats and great crested newts) before Green Belt or greenfield sites are brought forward for consultation, given the separate statutory protections that apply under the Wildlife and Countryside Act and the Conservation of Habitats and Species Regulations. The plan should also confirm how the mandatory 10% biodiversity net gain requirement will be applied, and should recognise that some habitat and species impacts are irreplaceable and cannot simply be offset through net gain calculations.

4. Engagement strategy

Given the strength of local feeling in areas like Dean Row that have already experienced significant change, I would ask that the engagement strategy (Chapter 6) include clear, direct notification to residents in areas identified as having already delivered significant housing, or where Green Belt, high-grade agricultural land or notable biodiversity constraints apply, at the point options for further growth in their area are being considered, rather than relying solely on borough-wide publicity.

I would welcome confirmation that these comments have been received and will be taken into account in developing the options for the spatial strategy and settlement hierarchy.