Local plan scoping consultation

The timescale allowed for is far too short to provide meaningful input given that many residents will be on holiday during the summer school holiday and the Parish and Town Councils will not be meeting to provide their full and considered responses to the consultation. Also, the last response day is on a bank holiday - this is very unfortunate!

All large-scale strategic housing and commercial developments should only be brought forward through the local plan process, following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

The local plan should demonstrate that any proposal affecting Green Belt is based on clear evidence that land release:
1. would meet evidenced Borough-wide needs;
2. could not meet those needs outside the Green Belts;
3. utilises brownfield land and urban regeneration opportunities;
4. all other reasonable alternatives have been comprehensively assessed first;
5. would not undermine each of the five Green Belt purposes of the remaining Green Belt when considered across the plan area and adjoining plan areas;
6. that weight is given to preventing development of land which it is considered only moderately contributes, as well as strongly contributes, to the Green Belt;
7. all exceptional circumstances are evidenced and fully substantiated;
8. the cumulative impact would not harm openness, landscape character and settlement pattern;
9. would not have adverse impacts on the identity and separation of neighbouring towns;
10. avoids unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity;
11. would not prevent or delay local nature recovery as identified in the Cheshire and Warrington Local Nature Recovery Strategy;
12. avoids areas vulnerable to flooding;
13. has access to spare capacities in all forms of infrastructure including utilities, transport, health and education and where not, allocations should only be made on the basis that all developments meet or make proportionate contributions to such provision;
14. that all developments meet the Government's Golden Rules for the provision of affordable housing, infrastructure and green spaces; and
15. continues to preserve the long-term permanence and effectiveness of the Green Belt, as set out in the Government's manifesto.

In support of the local plan reinforcing a clear brownfield-first approach the following are recommended:
1. Previously developed land and the regeneration of existing urban areas should be prioritised before the release of Green Belt and productive agricultural land.
2. Regeneration of the main and market towns would make better use of existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside.
3. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment.
4. Cheshire East should approach landowners of brownfield sites to assess why they are vacant or underused and what is blocking development and consider a fund for remediation.
5. Request the Government to set up funding for treating contaminated land e.g., derelict land grant
6. Give consideration to packaging the redevelopment of several towns into one financeable programme to give it scale and make it more attractive to investors and link this to an expansion of social housing directly focused on areas of need.

Re: Para 4.7 reference should be made to the Apollo Buckingham Health Science Campus which supports education and development across all areas of healthcare.

The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after the likely adoption date. The strategy, proposals and policies need to relate to this period.

The criteria used in the initial site assessment and scoring must be published to ensure transparency regarding the decision-making process.
Cheshire East must demonstrate that its housing requirements cannot be met through previously developed and appropriate greenfield sites before identifying land for development which strongly and moderately contribute to Green Belt purposes. Where such land is considered, it should be assessed on its environmental and landscape value, infrastructure capacity, sustainability, proximity to places of employment and local social housing needs.
None of the land proposed in the Call for Sites in Adlington for some 10,000 houses would meet these needs.

A comprehensive borough-wide Green Belt Assessment is welcomed to provide an essential evidence base for informing decisions on land release. It must be completed and published at the earliest opportunity. It will provide a basis for assessing all development proposals in the Green Belt ensuring that decisions on applications will be made on a consistent strategic framework and not on a piecemeal basis leading to Green Belt erosion and before the most appropriate strategy for growth has been adopted.
Given the inability to demonstrate a 5-year housing land supply the council should prepare an Interim Housing Policy Statement setting out the policy and criteria for allowing developments, including the release of safeguarded land.
Consideration should also be given to the effect of allocations and planning permissions granted outside the borough such as within Stockport MBC area which already have the effect of allowing urban sprawl. If the local plan is considered in isolation CEC risks adding to a growing urbanisation by default which would also place pressure on the surrounding infrastructure including the highway network.
The consultation document refers to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the local plan to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station.

The adopted hierarchy forms a useful planning basis for providing a borough-wide development strategy and policies for each tier.

The evidence to inform a review of the settlement hierarchy in the new plan should be published as soon as it is available. It should consider infrastructure including all utilities as well as the provision of services and facilities, population, future places of employment and jobs, provision of housing, sustainable transport, retail and leisure provision and settlement form.

Housing growth should be distributed across the borough in locations that reflect identified housing and employment needs, make effective use of previously developed land, utilise existing infrastructure and support the regeneration of established communities. New settlements are NOT needed to meet the housing requirement.
A dispersed approach to development:
1. Would help deliver housing more quickly while supporting existing communities and utilising existing infrastructure;
2. It would be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations.
3. It could accelerate housing delivery by using sites where infrastructure and services are already available.
4. It could place social and affordable housing closer to identified needs and employment opportunities and thereby reducing commuting pressures and costs for residents.
5 It would minimise the need for relocation of population to new locations with resultant social dislocation.
6. It would support regeneration of existing towns, including Macclesfield and Crewe, rather than directing investment away from established communities.
7. It would provide investment and growth and help the regeneration of older towns with a stock of worn-out buildings and avoid new developments creating significant infrastructure issues and unsustainable environmental harm.
8. It would make better use of existing infrastructure, while allowing investment to be targeted to areas where additional capacity is required.
9. It would support existing economic and community regeneration schemes, with investment in existing areas helping to attract further private funding which in turn would generate additional local tax revenue from revitalised towns.
10. It would spread development risk, distribute development across Cheshire East to support sustainable growth and regeneration and reduce the overall risk of proposals in the borough wide plan not being delivered on time.