Local plan scoping consultation

We note that the scale of development to be planned for is not fixed and will be informed by the emerging evidence base. We will comment further once the Council publishes evidence on housing demand. However, we note that paragraphs 5.5 to 5.7 appear to focus on the production of need assessments for housing and employment and exploring ‘opportunities for regeneration’.

The 2026 NPPF makes it clear that the objectives of the policies contained within:
• Chapter 6: Delivering a sufficient supply of homes is to ‘support the delivery of a substantial increase in the supply of homes…’; and
• Chapter 7: Building a strong, effective economy is to ‘enable businesses to invest, expand and adapt in a way that reflects the opportunities, challenges and characteristics of different areas and supports long-term economic growth both locally and nationally’.

In the context of housing, we emphasise that the Standard Method figure represents a minimum requirement at 2,530 dwelling per annum. However, the PPG highlights that housing requirement may be higher than the identified housing need, and authorities should consider the merits of planning for higher growth if, for example, this would seek to reflect economic growth aspirations. This is reaffirmed under Policy HOU2: Setting requirement figures for homes within the 2026 NPPF, where part 3b states the housing requirement figure should:
‘Be higher than the overall figure identified in the local housing need assessment where appropriate and that this will include situations where a housing requirement is necessary to meet the needs of neighbouring areas or to reflect growth ambitions linked to economic development or infrastructure investment.’

In short, if the minimum housing requirement as set by the SDS or the Standard Methodology is not sufficient to meet the growth or infrastructure investment ambitions of the Council and the economic vision for the area, the housing requirement should be increased.

In the context employment and economic needs, NPPF Policy E1: Providing the conditions for long-term economic growth makes it clear that this should start with a clear economic vision and strategy, which takes a positive, proactive and realistic approach to encouraging sustainable economic growth in urban and rural areas, having regard to the UK Industrial Strategy and relevant strategic and local strategies for economic development and regeneration. It goes onto confirm that it is not just existing business needs that should be considered but also wider needs and opportunities for economic growth and investment including relevant market signals and propriety places for investment in key sectors as set out in the UK Industrial Strategy and other programmes such as Industrial Strategy Zones and AI Growth Zones.

In short, whilst it will be necessary for the Local Plan evidence base to assess past growth and land take up to explore the potential need for employment land, NPPF Policy E1 requires a more proactive and visionary approach to be adopted and clearly points to the need to positively identify opportunities for growth.

Based on the Council’s latest Annual Monitoring Report (2024/25) as set out in Table 5.1 below, Cheshire East’s jobs growth has fluctuated year on year (seemingly due to more recent changes influenced by Brexit, the pandemic and possibly the Ukraine War). Prior to this, however, jobs growth was very strong. Data shows that prior to Brexit and the pandemic, Cheshire East was successful in generating new employment, with an average of over 3,500 new jobs created year on year between 2010 to 2019 (equating to an average annual jobs growth of +1.9%).

However, the years following the pandemic have shown the local authority to be struggling to maintain employment increases, with job numbers falling from a high of 206,000 in 2019 to 201,000 in 2020. This equates to an annual average loss of jobs at -2.4%.

Over the course of the plan period, however, jobs growth has still average 1.3% per annum and this is still significantly higher than the 0.7% jobs growth the adopted plan was predicated on which led to the adopted Local Plan (and LPS inspector) concluding that an average annual housing target of 1,800 per annum. Based on this alone, this would suggest that the new Local Plan should be targeting an employment growth and investment strategy that looks to achieve at least 1.3% jobs growth per annum and in our view, it should be higher to capitalise on the locational advantages of the Borough and key sectors that align with the UK Industrial Strategy.
Table 5.1 - Employment / Jobs Growth 2010-2024
Year Cheshire East Jobs Annual Change Annual Jobs Growth Change (%)
2010 174,000 / /
2011 176,000 2,000 +1.1%
2012 178,000 2,000 +1.1%
2013 181,000 3,000 +1.7%
2014 189,000 8,000 +4.4%
2015 195,000 4,000 +2.1%
2016 199,000 4,000 +2.1%
2017 203,000 4,000 +2.0%
2018 197,000 -6,000 -3.0%
2019 206,000 9,000 +4.6%
2020 201,000 -5,000 -2.4%
2021 204,000 3,000 +1.5%
2022 204,000 0 0.0%
2023 208,000 4,000 +2.0%
2024 210,000 2,000 +1.0%

Indeed, in terms of generating additional jobs growth going forward, Cheshire East still has an excellent foundation to build upon. Cheshire East accommodates key industries and manufactures that specialise in advanced manufacturing (Bentley Motors / Siemens), Life Sciences (AstraZeneca / Recipharm), Financial Services (Barclays / Royal London) and Professional Services and an increasing level of growth in logistics and distribution.

Many of the above sectors fit neatly within the Government’s Modern Industrial Strategy for the UK, issued in November 2025 and noted under the 2026 NPPF Policy PM1. The Strategy targets eight sectors with the highest potential for productivity, exports, and job creation:
• Advanced Manufacturing
• Clean Energy Industries
• Creative Industries
• Defence
• Digital and Technologies
• Financial Services
• Life Sciences; and
• Professional and Business Services.

These sectors are expected to drive national productivity, support the net zero transition, and create 1.1 million new jobs by 2035. However, the Strategy also notes that the logistics sector is a vital contribution to the UK economy and competitiveness of the above 8 key sectors that will drive growth. Cheshire is referred to within the document in relation to Life Sciences and Chemical production in the context of boosting growth in Northern City regions and clusters. The Industrial Strategy also makes reference to improving the connectivity across the North of England, which is now being picked up through the Northern Powerhouse Rail project. It also highlights how the Government will remove blockers in the planning system to drive the economy forward and encourage growth.

The 2026 NPPF embodies the Government’s latest planning reforms but there are also wider initiatives planned by the Government in terms of tax reform and other interventions that purposefully seek to put the UK back onto a high growth agenda, as highlighted in the Industrial Strategy. In short, such reforms are targeting greater levels of jobs growth and productivity.

Ultimately, we consider the Local Plan and its evidence base must clearly set out and recognise that Cheshire East contributes strongly to the UK economy and has a record (pre-Brexit and the Pandemic) in achieving annual growth levels above 2.0% on a regular basis. Furthermore, given the importance of certain key sectors within Cheshire East, such as Advanced Manufacturing and Life Sciences, we do consider there would be merit in the Council determining if it should also apply for an Industrial Strategy Zone in further encourage growth and investment within the Borough.

Whilst we note that Green Belt boundaries can only be changed through Local Plans and exceptional circumstances must exist (except in the context of development around stations), it is clear through NPPF Policy GB2 – Assessing existing Green Belt land, that the preparation of Local Plans should still be informed by a Green/Grey Belt assessment undertaken in accordance with the process set out at Annex E of the NPPF regardless of whether exceptional circumstances exist or not.

Indeed, these assessments must identify Grey Belt land (and go as far as facilitating the identification of Grey Belt land parcels by subdividing areas into smaller assessment units where this is necessary – See Annex E1.a.iv) and inform any Green Belt boundary alterations

It is pertinent to point out that the exceptions test is only dropped in relation to land that is within a reasonable walking distance to a well-connected station. The NPPF Glossary confirms that a reasonable walking distance is around 800m / 10 minutes’ walk subject to local circumstances (i.e. topography / barriers etc) and a well connected station is one where there are (or could be with investment) 4 services an hour or 2 in one direction to a key employment TTWA throughout the day. Any land that falls outside of this definition still needs to be supported exceptional circumstances if Green Belt boundaries are to alter.

Given the Borough’s significantly increased housing requirement of 2,530 dwellings per annum as a minimum, the split housing market area within the Borough, and the importance to ensure existing key settlements can grow in a sustainable manner, it is our view that the new Local Plan will inevitably have to consider Green Belt release as part of a balanced and justified spatial strategy. The scale of need is such that relying solely on non‑Green Belt land will not provide a deliverable or sustainable pattern of growth over the plan period.

We note that the Council is undertaking a borough wide Green Belt assessment. The latest Green Belt evidence the 2015 update to the original 2013 New Green Belt and Strategic Open Gap Study is now out of date. Since those studies were prepared, the real world context has changed:
• Numerous sites in and around settlements have come forward and been built out, altering the status and composition of Green Belt parcels.
• The new NPPF states Green Belt authorities must now prepare Green Belt Assessments and identify Grey Belt land as part of the evidence base for Local Plans.
• The NPPF now includes grey belt land — Green Belt land that makes only a limited contribution to Green Belt purposes A. B and D. The new definition of Grey Belt land no longer requires assessment of whether former footnote 7 constraints provide a strong basis for refusal. This makes identifying Grey Belt land through the Local Plan process simpler.
• The PPG’s guidance on what represents strong, moderate, weak/no contribution to Green Belt purposes A, B and D is unchanged but is now set out in Annex E of the NPPF.

A thorough and robust Green Belt assessment is necessary to establish an accurate and up to date understanding of the current status of Green Belt land across Cheshire East.

We only note that the sites controlled by Bloor Homes are not affected by this designation but agree that this is a designation that will need to be reviewed through the Local Plan.

The Council should look at the potential of each existing settlement in context of sites that are put forward and what these sites might be able to offer in terms of additional services that would support increased levels of sustainable access and growth within the settlement. For instance, this could include the ability for each site to deliver:
• New employment uses and/or allocations,
• New or enhanced provision for local education/schools,
• New shops and local community facilities,
• New indoor and outdoor sporting / recreation facilities or other forms of public open space.
• New public transport infrastructure including new walking and cycle routes, bus routes, stops and/or increased levels of service along existing routes and new train stations or increased levels of service at existing stations where feasible).

Subject to the potential for change, any settlement could potentially be elevated up the hierarchy where such improvements could be made. However, even where newly planned development and associated service could be provided would not result in a change to the settlement’s hierarchy, such change should be seen to be a positive where it would still add to the range of services in the settlement or the capacity and ongoing vitality and viability of existing services.

We agree that in the event that the Local Plan sets policies for development within Settlements it must be consistent with National Planning Policy and in particular Policy S2 of the 2026 NPPF and add local context without requiring a repetition of the NPPF policy.

We consider any policies within the Local Plan that relate to development in the Countryside should be renamed to Development outside of Settlements and be consistent with Policy S3 of the 2026 NPPF and add local context without requiring a repetition of the NPPF policy.

We note the Council may wish to continue to identify areas of special local landscape value but in doing so, this should be clearly evidenced and it made clear that such designations do not represent Protected Landscape or National Landscape designations as defined by the NPPF, where development is more greatly restricted.

We await to see the Council’s latest evidence on housing need before we comment fully on the type and mix of homes that will be required across Cheshire East. In the meantime, we note that the adopted plan contains several policies on the type and mix of homes including:
• LPS Policy SC4 – Residential Mix, which refers to new developments having to maintain, provide or contribute to a mix of housing in terms of tenure, types and sizes to create balanced communities. It goes on to lend support for Key Worker Housing, dementia friendly environments, and accommodation for the elderly, for which there is a proven need.
• SADPD Policy HOU 1 – Housing Mix, which refers to a specific mix of homes and tenures to be delivered as part of Table 8.1 within the SADPD but still sets a requirement for full and RM planning applications to be supported by an up-to-date local housing need/market assessments.
• SADPS Policy HOU 2 - Specialist Housing Provision, which lends support to specialist housing schemes and sets certain criteria for such development.
• SADPD Policy HOU 3 – Self and Custom build dwellings, which requires an unspecified proportion of self-build plots to be provided on schemes of 30 or more dwellings.
• Policy HOU 8 – Space, accessibility and wheelchair housing standards, which requires at least 30% of dwellings in major development to be M4(2) compliant and 6% to be M4 (3)(2)(a) compliant and national space standards to be met across all new proposals.

The above set of policies is one example of how the existing Local Plan is quite difficult to navigate in terms of what is required particularly from major development proposals. Indeed, on one hand support is lent to schemes that seek to deliver specialist or elderly accommodation but then there is still a policy requirement to prove the need for that scheme. This is contrary to the NPPF which clearly states that the onus is essentially on the Council. There is also potential confusion over the setting of a borough-wide housing mix and then requiring the developer to also prove the appropriate mix of homes at the detailed application stages.

We consider that it would be significantly more helpful if some of the above policies could be amalgamated into one policy that sets out a comprehensive set of requirements for:
• Development on Allocated sites. The policy could confirm that any site-specific policies will set out the specific expectation on the housing mix for each new site allocation. The specified mix for each site allocation should account of the existing housing within that area or settlement. This approach would rely on the Council choosing a range of new site allocations that are capable of delivering the housing mix required for a specific area. Indeed, this might involve identifying specific individual sites for elderly or student accommodation and/or a range of larger sites that can genuinely deliver a specified mix of dwellings on site. This would remove a lot of ambiguity and greater certainty over what is expected to be brought forward as part of the application process. This would aid the determination of an application and remove the requirement for the developer to then have to prove or evidence what the mix should be at the application stage and therefore considerably speed up the development management process for planning applications. That said, the overarching strategic policy should still include a provision that allows the applicant to divert from the specific site allocation policy (noting that market conditions can alter what a developer may bring forward at the time of development) and in those instances, any evidence.
• Windfall Development. This policy could set out the starting point such as set out in Table 8.1 of the SADPD on self-build standards but could also reasonably place the burden on the applicant to demonstrate how the proposal would contribute to a sustainable mix of homes within the area/settlement.
• Space Standard requirements. This could include the national space standards and the Council’s expectations on accessible homes standards to be applied to all developments. We consider the above approach is more aligned with the requirements of the NPPF and the general desire by the Government to speed up the delivery of new homes and prevent delays in the planning system. Indeed, the NPPF places a lot of onuses on the local authority to ensure an appropriate mix of homes is planned for. The following NPPF paragraphs are pertinent in this regard.

To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay. The overall aim should be to meet as much of an area’s identified housing need as possible, including with an appropriate mix of housing types for the local community.

Within this context of establishing need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. These groups should include (but are not limited to) those who require affordable housing; families with children; older people (including those who require retirement housing, housing-with-care and care homes); disabled people, people who rent their homes, families with children, looked after children, students; travellers; and people wishing to commission or build their own homes in line with NPPF Policy HO1 – Assessing the need for homes and Policy HO5 – Meeting the needs of different groups.

Our view is that the Local Plan should be identifying specific site allocations that can meet localised demands and determine if a site is to deliver solely or an element of elderly accommodation, care homes, self-build plots and a certain mix of market and affordable homes rather than seeking to get the applicant to prove what the need is at the application stage (unless it is for speculative development on sites that are not allocated in the Local Plan). Indeed, this approach is consistent with Part 1.c and d of Polic HO5. We consider such an approach will set clear standards and appropriate mixes for each site, which developers and promotors can then account for and a more accurate viability assessment of each allocation can then be carried out as part of the Local Plan process.

In terms of the mix of market homes, we also note that Part 3 of NPPF Policy H08 – Providing Affordable Homes states that a flexible approach should be taken to any development plan requirements relating to the number of bedrooms in market homes is accounted for in situations where the development proposal meets or exceeds up-to-date development plan requirements for the proportion and mix of affordable housing tenures. In short, where this is the case, the Council’s policies need to be flexible and allow the market to decide what is the best solution for the site and locality. This approach will greatly assist in a swifter delivery of homes within the area.

Moreover, to ensure the Local Plan is effective, it will still be important for the Council to continue to monitor housing delivery, and the type of new homes delivered to ensure any new policies reflect demand and needs within the various housing market areas within the Borough and surrounding the main settlements.

We note the various evidence-based reports that are listed. The Council will also need to prepare or review the following:
• Green / Grey Belt Assessment in line with Annex E of the NPPF which requires an assessment to be carried out for all of the Green Belt within the Borough. This evidence is required regardless as to whether the Council ultimately conclude as to whether exceptional circumstances exist to review the Green Belt boundaries within an area. We note that paragraph 5.18 of the Scoping Report indicates that an assessment is being carried out but it is not listed towards the end of this section.
• Updated Settlement edge review for those settlements that are not impacted by Green Belt.
• Accessibility Toolkit evidence.
• Open Space Assessments.
• Viability assessment – whilst listed this should include a full review of CIL rates within the Borough alongside the listed Infrastructure Delivery Plan.