Local plan scoping consultation

Comment

Representation ID: 5516

Received: 31/08/2026

Respondent: Hugh Downie

I wish to object formally to the promotion of approximately 291.03 hectares of land at Ashley, comprising 12 adjoining parcels, through the Strategic Housing and Economic Land Availability Assessment (SHELAA) and the Cheshire East Local Plan review.
The central issue is whether land of this character and strategic importance can properly be regarded as Grey Belt under the current National Planning Policy Framework.
In my view, it cannot.
This is not Green Belt which has become urbanised, fragmented or functionally detached from the countryside around it. It is a very large, substantially continuous area of open and productive countryside which still performs clear and important Green Belt functions. In particular, it restrains outward urban expansion, preserves separation between Greater Manchester and Cheshire settlements and protects the countryside around Ashley from encroachment.
Those functions arise directly from the land's location, openness and scale. They are not incidental characteristics which can simply be mitigated through development.
The Council should therefore resist any assumption that housing need, land availability or the physical ability to accommodate development is sufficient to justify treating the land as Grey Belt.
The correct question is whether this particular land continues to perform an important Green Belt role.
The evidence strongly indicates that it does.
1. The Grey Belt assessment must begin with what the land actually does
The introduction of Grey Belt policy does not mean that all undeveloped Green Belt land becomes a potential housing allocation.
Nor should the assessment begin with the number of homes which could theoretically be provided.
It should begin with the existing function of the land.
The Ashley submission comprises approximately 291 hectares of predominantly open countryside and agricultural land. The 12 parcels adjoin one another and together occupy a strategically important position between the Greater Manchester urban area and the settlements and countryside of Cheshire East.
The land remains visibly and functionally rural.
More importantly, its openness performs an identifiable planning purpose.
It helps:
• contain the outward spread of built development;
• maintain separation between different settlements and urban areas;
• protect a substantial area of Cheshire countryside from encroachment; and
• maintain a coherent Green Belt between Greater Manchester and the rural settlement pattern to the south.
These characteristics make the site fundamentally different from land which might reasonably be regarded as weak-performing Green Belt.
The Council should therefore require compelling evidence before concluding that any substantial part of this land falls within Grey Belt policy.
2. Ashley is not marginal Green Belt – it is strategically located Green Belt
Ashley should not be assessed simply as a village surrounded by fields.
Its significance is much wider.
The land forms part of the countryside separating Trafford, Hale and Altrincham from the Cheshire settlements and rural areas around Ashley, Mobberley and Knutsford.
That gives the Green Belt here an important strategic function.
Its openness maintains a clear transition between the Greater Manchester conurbation and the more dispersed rural settlement pattern of Cheshire.
Development across a substantial proportion of these 291 hectares would weaken that distinction.
The question is therefore not merely whether development would reduce the amount of countryside immediately around Ashley. It is whether releasing the land would weaken an important strategic separation between two very different settlement areas.
That consideration should carry substantial weight when determining whether the land could genuinely be described as Grey Belt.
3. The land strongly restrains urban sprawl
One of the clearest functions performed by the Ashley Green Belt is the containment of outward urban expansion.
A development approaching the scale represented by this submission would not amount to limited village growth or a modest rounding-off of an existing settlement.
It would create an extensive new area of built development within countryside presently separating Greater Manchester from rural Cheshire.
That would establish a new development front and move substantial built form further into open countryside.
The consequences would include roads, housing, lighting, drainage infrastructure, utilities and associated urban activity across land which is currently predominantly rural.
This is exactly why the scale of the submission matters.
A Green Belt release of this size would have fundamentally different spatial consequences from a small development opportunity contained by existing built form.
The land's role in containing outward growth is therefore a strong reason for concluding that it remains effective Green Belt rather than Grey Belt.
4. Settlement separation is one of Ashley's strongest Green Belt functions
The countryside around Ashley also performs an important role in keeping settlements distinct.
It is not necessary for two towns or villages literally to meet before the Green Belt purpose of preventing coalescence becomes relevant.
The concern is the progressive erosion of the open land separating settlements.
Once major development is introduced into that space:
• the physical gap becomes narrower;
• the perception of separation is weakened;
• remaining countryside becomes more vulnerable to further pressure; and
• subsequent development can appear progressively easier to justify.
Development across the Ashley submission would therefore have consequences beyond the immediate site boundaries.
It would insert a substantial new area of urban development into countryside which presently contributes to maintaining separation between Greater Manchester and Cheshire settlements.
This is a particularly powerful reason why the land should not be characterised as Grey Belt.
5. The 12 parcels cannot sensibly be assessed as 12 unrelated sites
Taton Estates have removed some of the parcels towards the end of the consultation period. I find it hard to understand how the subject of a consultation can change during the consultation.
I have also seen the Tatton Estates covering letter for their 2026 submission to the Cheshire East ‘Call for Sites’. They say:
• That land around Ashley for 11,000 houses and 490,000 sqm of commercial floorspace is available.
• The 11,000 house and 490,000 sqm of commercial floorspace plan is “confirmed to be still available”.
• “This representation confirms that the sites are available, suitable, achievable and deliverable for the proposed uses.”
• “For the avoidance of doubt, all of the sites submitted to the 2024 CfS (Call for Sites) Exercise are still available…… to meet more of Cheshire East’s housing needs during and beyond this plan period.”
So, has this covering letter been retracted by Tatton Estates?
The document mentioned in the letter (‘Vision Document’) apparently gives more details on these proposals. Has this document, the ‘Vision Document’ been retracted?
Until confirmed that these documents (their official submissions to the 2026 Call for Sites) have been retracted I will make my comments on the whole 291.03 hectare area.
The way in which the land has been submitted must not obscure its true strategic scale.
Although divided into 12 parcels, those parcels are contiguous and collectively amount to approximately 291.03 hectares.
Their Green Belt function is therefore also interconnected.
A parcel-by-parcel assessment risks reaching conclusions which fail to recognise the consequences of releasing the land cumulatively.
The Council should ask:
What happens to the Green Belt if this connected 291-hectare area is developed?
That assessment should encompass:
• loss of openness;
• urban expansion;
• reduction in settlement separation;
• effects upon the remaining Green Belt;
• landscape change;
• ecological fragmentation;
• transport impacts;
• drainage;
• infrastructure; and
• future development pressure.
It would be artificial to conclude that adjoining parcels have no relationship with one another simply because they have separate SHELAA submission boundaries.
For Grey Belt purposes particularly, the strategic function of the land must be assessed as a whole.
6. Release would weaken the Green Belt which remained
The consequences of development would not stop at the boundary of the submitted land.
Removing any of the parcels from the Green Belt would create extensive new development edges.
Those new edges would inevitably change the relationship between the remaining Green Belt and the built-up area.
Land which currently forms part of a broad and coherent countryside gap could become:
• narrower;
• more enclosed by development;
• less effective in separating settlements; and
• increasingly vulnerable to subsequent development pressure.
The Council therefore needs to consider not merely what would be built on the submitted land, but what releasing the land would do to the effectiveness and permanence of the surrounding Green Belt.
A release cannot reasonably be regarded as an isolated adjustment with no wider spatial consequences.
7. The character of the land reinforces the conclusion that it is functioning Green Belt
The existing condition of the land is relevant.
This is predominantly open, working countryside rather than a heavily developed or urbanised landscape.
All of it remains in agricultural use.
Available evidence indicates substantial areas of Grade 2 and Subgrade 3a Best and Most Versatile agricultural land.
That agricultural function is important in its own right, but it also reinforces the Green Belt case.
The land has not lost its countryside character.
It continues to perform overlapping functions including:
• agricultural production;
• landscape value;
• ecological connectivity;
• settlement separation; and
• Green Belt containment.
That combination provides further evidence that this is not an obvious low-performing Green Belt opportunity.
8. The landscape context is inconsistent with treating the land as a simple development opportunity
The submission occupies a substantial rural landscape rather than an isolated or visually contained parcel.
The wider area is associated with the Bollin Valley and Parklands Local Landscape Designation and the Rostherne/Tatton Park Local Landscape Designation.
Development at the scale contemplated would introduce extensive housing, roads, lighting, engineering works and associated infrastructure.
The result would be a fundamental change from open countryside to an increasingly urban landscape.
Landscape considerations do not automatically determine whether land is Grey Belt.
They do, however, provide important evidence about the character, openness and sensitivity of the land being assessed.
In this instance, they reinforce rather than weaken the case for retaining Green Belt protection.
9. Ecological value further demonstrates that this is functioning countryside
The Ashley landscape also forms part of a wider ecological network.
The submitted land has relationships with surrounding habitats and ecological corridors, including Cotterill Clough Nature Reserve and SSSI.
The area also supports species identified within the evidence base, including Red-Listed birds such as:
• grey partridge;
• tree sparrow; and
• greenfinch.
Urbanisation across a large, connected landholding risks severing habitat corridors, increasing disturbance and reducing ecological connectivity across the wider countryside.
These factors should not be used as a substitute for the Green Belt assessment.
Rather, they reinforce the underlying point: the land remains part of a functioning rural landscape rather than land which has already lost its countryside role.
10. Heritage settings are closely connected with the rural character which Green Belt protects
The Ashley countryside also provides the setting for a substantial number of designated heritage assets.
The open agricultural landscape contributes to the character and setting of 19 Grade II listed buildings, including Ashley Hall.
Development would introduce built form, roads, street lighting, traffic and urban activity into landscapes which presently remain predominantly rural.
That change would inevitably alter the relationship between those heritage assets and their countryside settings.
Heritage impacts provide a separate material planning consideration, but they also demonstrate why the character of this landscape cannot reasonably be dismissed as ordinary land awaiting development.
And before any Tatton Estate land at Ashley is considered suitable for allocation, the Council should first establish the geographical extent, status and relevant provisions of the Tatton Estate Heritage Management Plan (HMP) agreed with Natural England and HMRC. Tatton Estate has itself confirmed to Parliament that 1,626 acres are identified as being of outstanding scenic, scientific and historic interest, and has specifically identified Arden House, Arden Park, North Arden Lodge and Lamb Cottage at Ashley as falling within the HMP. This is directly relevant to the assessment of the promoted sites. The Council should not consider those sites in isolation from the wider estate landscape or without first establishing the extent to which they fall within, adjoin or otherwise relate to land covered by the HMP. It should also establish whether the scale or nature of any proposed development could conflict with, prejudice or undermine the objectives, management requirements or commitments associated with the HMP. Until that relationship has been properly established, it would be premature to conclude that the promoted land is suitable for allocation.
11. Even a Grey Belt conclusion would not establish that Ashley is a sustainable location
There is an important second stage to the argument.
Even if the Council were ultimately to consider that some individual areas could fall within Grey Belt policy, that conclusion would not automatically make them suitable for strategic development.
Ashley is a small rural settlement.
It is not a Principal Town or Key Service Centre and does not presently possess the infrastructure expected of a strategic development location.
The area has:
• limited local services;
• limited public transport;
• an infrequent rail service;
• very restricted parking at Ashley station;
• limited employment opportunities;
• narrow rural roads;
• constrained bridge crossings;
• substantial drainage requirements; and
• major infrastructure needs.
The settlement hierarchy is therefore highly relevant.
The scale of development proposed would not amount to proportionate growth of Ashley. It would fundamentally change the size and function of the settlement.
That raises an obvious question:
Why should strategic growth of this magnitude be directed to a small rural settlement when more sustainable locations are available elsewhere?
12. Transport limitations make the sustainability case particularly difficult
Ashley does not benefit from the type of transport network normally associated with strategic housing growth.
Ashley railway station provides a limited service and has restricted parking capacity.
The March 2026 parliamentary discussion concerning Cheadle station also recorded modelling which contemplated reducing services at Ashley, Plumley and Mobberley from hourly to every two hours.
That prospect is directly relevant when assessing whether Ashley represents a genuinely sustainable strategic location.
The road network is similarly constrained.
Routes into and around Ashley are predominantly rural and include important pinch points and bridge crossings over:
• the railway;
• the River Bollin; and
• Birkin Brook.
A very large development would inevitably generate substantial additional traffic through this network.
These are not minor localised issues. They go directly to whether Ashley could support development of the magnitude contemplated.
13. Highway infrastructure cannot simply be assumed to be capable of expansion
Development across 291 hectares would require substantial transport infrastructure.
The SHELAA process should not proceed on the basis that whatever roads, junction improvements or other highway works might eventually prove necessary can simply be provided.
The Council should require evidence that the required infrastructure is:
• technically achievable;
• environmentally acceptable;
• capable of obtaining the necessary approvals;
• financially viable; and
• deliverable within the required timescale.
Where strategic development depends upon major highway intervention, that dependency is relevant to both sustainability and deliverability.
14. Manchester Airport creates additional constraints
Ashley lies close to Manchester Airport and beneath operational flight paths.
That relationship introduces further considerations including:
• aircraft noise;
• aerodrome safeguarding;
• bird-strike management; and
• residential amenity.
A substantial new residential population would therefore be introduced into an area already affected by major aviation infrastructure.
Those issues provide another reason why Ashley should not simply be assumed to represent a straightforward strategic growth opportunity.
15. Flooding and drainage create additional questions over suitability and deliverability
Parts of the wider site, particularly towards the M56, already experience flooding and surface-water issues.
Development across a very large area of presently permeable countryside would introduce extensive:
• roofs;
• roads;
• parking areas;
• driveways; and
• other hard surfaces.
That would significantly alter the existing drainage regime.
The implications for the River Bollin catchment, local watercourses and downstream flood risk would require detailed assessment.
These issues should be examined at the site-selection stage rather than deferred on the assumption that engineering solutions will inevitably be available.
16. Utilities and infrastructure are not presently commensurate with development of this scale
The infrastructure serving Ashley reflects its existing function as a small rural settlement.
A strategic development approaching the scale proposed would require substantial increases in capacity across a range of services, potentially including:
• electricity;
• foul drainage;
• surface-water infrastructure;
• highways;
• schools;
• healthcare;
• public transport; and
• other community infrastructure.
There is a fundamental distinction between saying that infrastructure could theoretically be constructed and demonstrating that the required infrastructure is realistically deliverable.
That distinction is important within a SHELAA assessment.
17. Green Belt release should not begin with Ashley when more appropriate alternatives exist
The Council should also consider the proper sequence of land release.
Before contemplating the loss of strategically important Green Belt, reasonable alternatives should be thoroughly examined.
That should include:
1. suitable brownfield land;
2. previously developed sites;
3. under-used urban land;
4. opportunities for increased density in sustainable locations;
5. locations already supported by strong public transport and services; and
6. genuinely weaker-performing Green Belt sites where release would have materially less impact.
The issue is not simply whether homes can be fitted onto the Ashley land.
The issue is why this particular Green Belt should be released.
Where land makes a substantial contribution to preventing sprawl, maintaining settlement separation and protecting open countryside, there should be compelling evidence that more appropriate alternatives cannot meet the identified need.
18. Housing need does not remove the need to distinguish between stronger and weaker Green Belt
This distinction is particularly important under the current national policy framework.
Grey Belt policy would lose much of its meaning if all Green Belt capable of accommodating housing were automatically treated as suitable for release.
There must remain a meaningful distinction between:
Green Belt which continues to perform important strategic purposes
and
Green Belt whose contribution has become materially weaker.
Ashley falls clearly within the first category.
The land remains open.
Its countryside character is intact.
Its location gives it strategic importance.
Its openness separates settlements.
Its agricultural use remains active.
Its release would enable substantial outward urbanisation.
Those are precisely the characteristics which justify continued Green Belt protection.
19. The scale of release makes the Grey Belt argument particularly difficult
The sheer size of the submission should not be overlooked.
The area proposed is not a minor Green Belt adjustment.
Release at this scale would be transformative.
It could create a development area vastly larger than the existing settlement and materially alter the pattern of development between Greater Manchester and Cheshire.
The larger the release, the greater the importance of considering:
• cumulative loss of openness;
• strategic settlement separation;
• effects upon the remaining Green Belt;
• infrastructure requirements;
• landscape transformation; and
• future development pressure.
The scale of the proposal therefore strengthens the argument for a strategic rather than parcel-by-parcel Green Belt assessment.
20. The combined evidence strongly favours continued Green Belt protection
The Ashley case should ultimately be considered cumulatively.
The strongest objection is not that one isolated technical constraint makes development impossible.
It is that the land performs a clear and important strategic Green Belt function, while simultaneously presenting numerous additional reasons why large-scale development would be inappropriate.
The central Green Belt considerations are compelling:
• the land remains substantially open countryside;
• it restrains outward urban expansion;
• it safeguards the countryside from encroachment;
• it contributes materially to settlement separation;
• it maintains a strategic gap between Greater Manchester and Cheshire;
• the 12 parcels collectively form one large and coherent landholding;
• release would weaken the Green Belt remaining around it; and
• development would establish a substantial new urbanisation front.
Those considerations are reinforced by:
• Ashley's limited role within the settlement hierarchy;
• inadequate sustainable transport;
• highway constraints;
• substantial infrastructure requirements;
• aviation considerations;
• BMV agricultural land;
• landscape sensitivity;
• ecology;
• heritage;
• flooding; and
• drainage.
This is therefore not a case in which an otherwise sustainable strategic site happens to lie within Green Belt.
It is a case in which the Green Belt function of the land itself is one of the principal reasons why strategic development would be inappropriate.
Requested Action
I respectfully request that Cheshire East Council:
1. Retain the 291.03-hectare Ashley land within the Green Belt and do not identify it as Grey Belt;
2. Assess all 12 contiguous parcels cumulatively as one strategic landholding when considering Green Belt function, openness, urban sprawl, settlement separation and the effect upon the remaining Green Belt;
3. Reject any assumption that the ability to accommodate housing or the existence of housing need is sufficient to establish Grey Belt status;
4. Require clear evidence demonstrating why land which performs important Green Belt purposes could properly be regarded as Grey Belt;
5. Require reasonable brownfield, previously developed, urban and genuinely weaker-performing Green Belt alternatives to be fully examined before considering release of the Ashley land;
6. Record the land as unsuitable, unavailable and undeliverable for strategic development within the SHELAA assessment; and
7. Exclude all 12 parcels from future strategic housing allocations.
The current planning framework requires the Council to distinguish between Green Belt which genuinely performs a limited role and land whose openness remains strategically important.
Ashley falls firmly into the latter category.
Its value as Green Belt arises from precisely the characteristics which development would remove: openness, countryside character, separation between settlements and resistance to outward urban expansion.
The Tatton Estate submissions would not simply result in the loss of agricultural fields. It would alter the strategic relationship between Greater Manchester and rural Cheshire, establish a major new development front and substantially weaken the Green Belt which remained.
That is incompatible with any suggestion that this is merely weak-performing land suitable for Grey Belt treatment.
Even if Grey Belt status were argued for individual parts of the submission, the separate questions of sustainability, infrastructure, transport, agricultural value, landscape, ecology, heritage, aviation, flooding and deliverability would remain.
Taken together, the evidence provides a strong and coherent case for retaining the land within the Green Belt and excluding the entire 291.03-hectare submission from strategic development consideration.