Full text:
To:
Cheshire East Council
Delamere House
Delamere Street
Crewe
Cheshire CW1 2LL
Date: 3rd August 2026
Representation to Cheshire East’s new Local Plan
I welcome the opportunity to comment on the scope of Cheshire East Council's new Local Plan.
I support the principle of growth and recognise that Cheshire East needs new homes, employment opportunities and investment. However, the Local Plan represents an opportunity to consider not simply how much development is required, but where it should take place, what form it should take, and whether the infrastructure and environment are capable of supporting it.
In my view, the central objective should be to create thriving, sustainable communities rather than simply maximise the number of homes that can be accommodated.
1. Growth should be infrastructure-led and sustainable
The Local Plan correctly identifies infrastructure capacity as an important factor in determining the amount and distribution of development. I strongly support this approach.
There is already significant pressure on infrastructure and services across parts of Cheshire East, including GP and healthcare provision, school places, roads and highways, parking, bus services, rail connectivity, cycling infrastructure, broadband, sewage and drainage, community facilities, green spaces and walking routes.
The concern is not simply that individual developments may place additional pressure on one particular service. It is that the cumulative effect of successive developments can gradually exceed the capacity of the infrastructure serving a community.
The Local Plan should therefore require a robust, place-specific assessment of existing infrastructure capacity before significant additional growth is allocated. It should not be sufficient to demonstrate that an individual development makes an acceptable contribution towards infrastructure in isolation. The assessment needs to consider the cumulative impact of existing commitments, developments already underway and proposed allocations.
Infrastructure should also include green infrastructure. Parks, open spaces, walking routes, cycling routes, access to nature, wildlife corridors and other green and blue infrastructure are not optional extras. They are fundamental components of healthy and resilient communities.
The Council itself recognises that green infrastructure, health facilities and community services are part of the infrastructure required to support growth. (localplan.cheshireeast.gov.uk)
2. Development should prioritise brownfield and previously developed land
I strongly support the Council's stated intention to maximise the use of brownfield and underused land and to consider sites outside the Green Belt before considering Green Belt release.
This principle should go further and become a fundamental component of the spatial strategy.
Cheshire East should undertake a genuinely comprehensive assessment of opportunities for:
• brownfield development;
• vacant and underused land;
• redevelopment of existing developed sites;
• conversion and refurbishment of existing buildings;
• appropriate higher-density development within existing settlements;
• town-centre residential development; and
• mixed-use regeneration.
Only once these opportunities have been properly identified and assessed should pressure for development of greenfield land be considered.
This approach has several advantages. It can reduce pressure on countryside and agricultural land, make better use of existing infrastructure, support town centres and reduce the need for people to travel by car.
It can also help address the environmental impact of construction. The Council's own consultation document recognises the importance of embodied carbon and specifically identifies the reuse and refurbishment of existing buildings rather than demolition as an important consideration. (localplan.cheshireeast.gov.uk)
The Local Plan should therefore establish a clear "reuse and regenerate before demolish and build new" principle.
3. Regeneration of town centres should be a major part of the housing strategy
The changing nature of town centres presents an opportunity rather than simply a problem.
Macclesfield is a good example of a town centre facing the same structural challenges seen across the UK: changing shopping habits, online retail, changing working patterns and the resulting loss or decline of traditional retail premises.
The answer should not be to continue treating town centres primarily as retail destinations.
The new Local Plan should actively encourage mixed-use town centres, incorporating residential accommodation alongside shops, cafés, restaurants, leisure, cultural, community and employment uses.
Appropriately located residential development can bring people into town centres throughout the day and evening. A larger resident population can in turn support local businesses, leisure facilities and services, creating a positive cycle of regeneration.
The Council's own scoping document recognises that successful town centres increasingly depend on a broader mix of uses and specifically identifies residential development, community facilities and leisure as part of this diversification. (localplan.cheshireeast.gov.uk)
This should therefore be a central part of the Local Plan's strategy for accommodating growth.
4. Protect green space and create more opportunities to access nature
A growing population needs more than houses.
It needs places to walk, exercise, socialise, relax and interact with nature.
The Local Plan should therefore set ambitious and measurable standards for the provision and protection of parks, public open spaces, playing fields, walking routes, cycling routes, woodland, hedgerows, wildlife corridors and other green and blue infrastructure.
The objective should be that population growth results in more accessible green space and better opportunities for active travel, rather than a gradual reduction in the amount and quality of green space available to residents.
This is particularly important because access to green space is directly connected with health and wellbeing. The consultation document itself recognises that green spaces, recreation and community facilities are important determinants of health and that the Plan may need to establish local standards for outdoor recreation and Local Green Spaces. (localplan.cheshireeast.gov.uk)
Green space should therefore be treated as essential infrastructure and planned alongside housing, schools, healthcare and transport.
5. Protect biodiversity and take account of cumulative environmental impacts
The new Local Plan should adopt a genuinely strategic approach to biodiversity.
Development should not be assessed simply on the basis of whether an individual site can technically achieve a biodiversity net gain calculation. The wider ecological context also matters.
Particular attention should be paid to:
• wildlife corridors;
• rivers, streams, ponds and reservoirs;
• woodland and mature trees;
• hedgerows;
• protected species;
• habitats adjacent to development sites;
• the cumulative loss of habitat across a settlement; and
• the indirect effects of development on adjoining ecological systems.
A site's ecological significance cannot necessarily be understood by looking at the development footprint alone. Impacts can extend into adjoining habitats and water environments, with consequences for species and ecological connectivity.
The Local Plan should therefore require cumulative ecological impacts to be considered at settlement and strategic levels, not simply application by application.
The Council already identifies reversing biodiversity decline, protecting trees and hedgerows, enhancing green infrastructure and supporting nature recovery as important issues. These ambitions should be translated into strong and measurable policies. (localplan.cheshireeast.gov.uk)
6. Climate change should influence where development takes place, not just how buildings are constructed
Climate resilience should not be treated primarily as a matter of installing better technology in individual buildings.
The location of development is itself a major climate and sustainability decision.
Development in locations that require residents to drive for work, education, healthcare, shopping and leisure can create long-term transport emissions and car dependency which cannot easily be designed out afterwards.
The Local Plan should therefore prioritise locations where residents can realistically access services and employment by walking, cycling and public transport.
At the same time, development should be designed to manage flooding, surface water, overheating, biodiversity loss and other climate risks.
I particularly welcome the consultation's recognition of embodied carbon and the importance of reuse and refurbishment of existing buildings. This should be reflected in the eventual policies and not remain simply an aspiration. (localplan.cheshireeast.gov.uk)
7. Heritage should be regarded as an asset, not an obstacle to development
Cheshire East's historic buildings, townscapes and landscapes are an important part of what makes the borough distinctive.
The Local Plan should support the adaptive reuse and continued occupation of historic buildings, rather than allowing buildings to fall into disrepair before being replaced by new development.
Heritage-led regeneration can also form part of the solution to the challenges facing town centres.
Development should be expected to respond to local character and heritage rather than imposing generic housing designs that could be located anywhere in the country.
I welcome the Council's proposal to consider heritage sensitivity, adaptive reuse and heritage-led regeneration as part of the new Local Plan. (localplan.cheshireeast.gov.uk)
8. Cumulative impacts need to be properly addressed
One of the most important issues for the new Local Plan should be the cumulative impact of development.
A development can appear acceptable when considered in isolation but become unsustainable when considered alongside numerous other developments in the same settlement.
This applies to traffic, parking, schools, healthcare, drainage, sewage, public transport, biodiversity, landscape, green space and community facilities.
The Local Plan therefore needs a methodology for assessing cumulative development pressure at settlement level, rather than relying primarily on individual planning applications to identify and mitigate problems.
This is particularly important in smaller settlements. A settlement cannot necessarily absorb development at the same rate as a larger urban area simply because there is technically developable land available.
The capacity of a settlement's infrastructure, services, environment and community should be a determining factor.
9. Planning conditions and developer commitments must actually be enforced
The effectiveness of the Local Plan ultimately depends on implementation.
There is little value in requiring trees to be retained, ecological measures to be followed, pollution controls to be implemented or construction management plans to be complied with if these commitments are not subsequently enforced.
I have personally observed examples on new development sites where trees identified on approved plans for retention, have nevertheless been felled; where required protective fencing has not been erected in accordance with a Construction Management Plan; and where construction-site flood water has been pumped towards a river via a route passing over the roots of a protected tree. This behaviour has persisted despite the site manager and CEC Planning Enforcement being made aware.
Whether individual incidents result from deliberate non-compliance, poor supervision or inadequate enforcement, they demonstrate a wider point: planning policy must be accompanied by effective monitoring and enforcement mechanisms.
The new Local Plan should therefore include measurable outcomes not only for what development is approved, but for what is actually delivered and maintained.
Where developers commit to infrastructure, landscaping, biodiversity measures, tree protection, drainage or environmental mitigation, there should be clear responsibility, timescales, monitoring and consequences for non-compliance.
10. The Local Plan needs measurable outcomes that reflect the quality of places created
I welcome the proposal for the new Local Plan to contain measurable outcomes.
However, those measures should extend beyond conventional planning metrics such as the number of homes permitted or completed.
The Council should measure whether development is actually creating better places.
Potential indicators could include:
• infrastructure capacity relative to population growth;
• GP and healthcare capacity;
• school capacity;
• sewage and drainage capacity;
• access to parks and green space;
• walking and cycling accessibility;
• public transport accessibility;
• biodiversity and habitat connectivity;
• tree and hedgerow retention;
• town-centre vacancy and footfall;
• reuse of brownfield land and existing buildings;
• embodied carbon;
• delivery of affordable housing;
• community facility provision; and
• compliance with planning conditions and environmental commitments.
This would give the Plan a much stronger focus on outcomes rather than simply development delivery.
Conclusion
I support the preparation of a new Local Plan and I support appropriate growth in Cheshire East.
However, I believe the Plan should establish a clear hierarchy for accommodating that growth:
First, reuse and regenerate existing buildings and previously developed land.
Second, make better use of existing settlements, including appropriate town-centre and mixed-use development.
Third, ensure that development is located where existing infrastructure can support it, or where the necessary infrastructure can be delivered before or alongside the development.
Only then should pressure for further greenfield development be considered.
Growth should enhance communities rather than simply expand them.
The more important question is:
What level and form of growth can be accommodated while maintaining — and ultimately improving — the infrastructure, green spaces, biodiversity, heritage, character, health and quality of life that make established communities successful places to live?
I would encourage Cheshire East Council to make this principle central to the new Local Plan.
The Council has an opportunity to produce a plan that does more than accommodate housing numbers. It can create a framework for well-connected, environmentally resilient, economically vibrant and genuinely sustainable communities. That should be the ambition for Cheshire East through to 2045.
I would be grateful if you would keep me informed about any future progress/developments.
Regards,
Tom Mather
