Local plan scoping consultation

Formal Representation: Objection to the SHELAA Submission for Land at Ashley — 12 Contiguous Parcels Totalling 291.03 Hectares

Dear Planning Team, Cheshire East Council

I am writing to make a formal objection to the inclusion of the proposed 291.03 hectares of land at Ashley within the Strategic Housing and Economic Land Availability Assessment (SHELAA) and to its consideration as a potential location for strategic development through the Cheshire East Local Plan review.

The submission comprises 12 adjoining and contiguous parcels extending across approximately 291.03 hectares. Considered collectively, this is a development proposal of exceptional scale in the context of Ashley. Its release would not constitute modest expansion of a rural settlement; it would represent a fundamental transformation of the countryside between Ashley, the Greater Manchester urban area and the Cheshire settlements to the south.

The land is functioning agricultural countryside within the North Cheshire Green Belt. It provides an important open buffer between the urban areas around Hale, Trafford and Altrincham and the settlements of Mobberley and Knutsford. It is, in effect, part of the remaining breathing space between Manchester and Cheshire.

For the reasons set out below, I consider that the submitted land should be assessed as unsuitable, unavailable and undeliverable for strategic development, should not be treated as Grey Belt, and should not be identified as a preferred or potential allocation in the Local Plan.

1. Green Belt protection and the strategic role of the land
The Green Belt designation around Ashley is not incidental. It serves an important strategic spatial purpose in maintaining the openness of the countryside and preventing the progressive outward expansion of the Greater Manchester conurbation.

The land forms part of a relatively narrow area of open countryside between Hale and Trafford to the north and Mobberley and Knutsford to the south. Its importance therefore extends well beyond the immediate boundaries of Ashley parish.

The land performs several of the fundamental purposes of Green Belt policy, particularly:
• checking the unrestricted sprawl of large built-up areas;
• preventing neighbouring settlements from merging;
• safeguarding the countryside from encroachment; and
• maintaining the distinction between different communities and settlement patterns.

The 291.03-hectare submission should therefore be understood as a strategic Green Belt buffer, rather than simply a collection of individual development parcels.
Development across an area of this magnitude would create a substantial new urbanised edge within open Cheshire countryside. It would push development further towards the Greater Manchester boundary and significantly narrow the remaining countryside separation between Greater Manchester and Cheshire.

The consequence would be permanent and difficult to reverse. Once this open area were developed, the strategic function of the Green Belt in this location would be materially weakened.

2. The land does not satisfy the Grey Belt test
The fact that land lies within the Green Belt does not, by itself, mean that it should be regarded as Grey Belt.

The current National Planning Policy Framework (NPPF) requires a site-specific assessment of the contribution land makes to Green Belt purposes. Grey Belt policy cannot properly be applied as a general mechanism for releasing Green Belt whenever additional housing land is required.

This submission consists overwhelmingly of open, working agricultural land. It is not a previously developed, brownfield site that has lost its relationship with the countryside. Nor is it an area that can reasonably be characterised as making only a negligible contribution to Green Belt purposes.
On the contrary, the land:
• forms a substantial area of continuous open countryside;
• contributes to preventing outward urban sprawl;
• maintains separation between distinct settlements and communities;
• provides a buffer between Greater Manchester and Cheshire;
• retains a predominantly agricultural and rural character; and
• contributes to the openness and integrity of the wider Green Belt.

The Council should therefore require compelling site-specific evidence before considering any of these parcels to be Grey Belt. In particular, the assessment should explain how an extensive area of functioning countryside, occupying a strategically important position between major urban and rural settlements, could properly be regarded as land making only a limited contribution to Green Belt purposes.

3. Preventing urban sprawl
The proposed release would facilitate the outward expansion of the Greater Manchester urban area into Cheshire countryside.

This is fundamentally different from limited infill or proportionate expansion of an established village. The scale of 291.03 hectares would create an extensive new development front and could accommodate a substantial urban presence.

The resulting pattern would be one of outward expansion from the existing urban area rather than development being directed towards established, sustainable urban locations.

This would undermine the role of the North Cheshire Green Belt as a restraint on urban sprawl and would create further pressure for development of the countryside beyond the submitted land.

The strategic purpose of this Green Belt should therefore be given substantial weight.

4. Settlement separation and the Ashley buffer
The land is particularly important because of its role in maintaining separation between settlements.
Green Belt policy is not concerned solely with whether buildings would eventually form one continuous physical line between two settlements. It also seeks to prevent the gradual erosion of the open countryside that gives settlements their separate identities.

The Ashley land represents a narrow but strategically important buffer between the Greater Manchester urban area and the Cheshire settlement pattern.
Removing 291.03 hectares from this buffer would significantly reduce that separation and could establish a precedent for further outward development.

The cumulative effect would be to weaken the distinction between the urban area to the north and the rural Cheshire settlements to the south.

5. The 12 parcels must be assessed as one strategic landholding
Although the submission has been divided into 12 parcels, those parcels are contiguous and adjoining. They should therefore not be assessed as twelve unrelated opportunities.

The Council should consider the consequences of releasing the entire 291.03-hectare area, including its cumulative effects on:
• Green Belt openness;
• urban sprawl;
• settlement separation;
• landscape character;
• agricultural land;
• ecological networks;
• highways and transport;
• drainage and flood risk;
• utilities and infrastructure; and
• the integrity of the remaining Green Belt.

Assessing individual parcels in isolation could substantially underestimate the consequences of the overall proposal.
The appropriate planning question is not simply whether one parcel might physically accommodate development. It is whether the connected 291.03-hectare landholding is an appropriate location for strategic development.

The evidence strongly indicates that it is not.

6. Ashley's position in the settlement hierarchy
Ashley is a small rural parish with a limited range of local services and facilities. It is not a Principal Town or Key Service Centre capable of absorbing strategic growth on the scale proposed.

A development of this magnitude would be disproportionate to Ashley's existing role and would effectively create a new urban settlement rather than providing proportionate growth for an established rural community.

Cheshire East's spatial strategy should direct substantial development towards locations where existing services, employment, public transport, community infrastructure and transport networks provide a realistic basis for sustainable growth. Strategic development should not be directed towards Ashley simply because a large area of land is available.

The settlement hierarchy must be a fundamental consideration. Growth of this scale would be much more appropriately considered in established Tier 1 and Tier 2 urban locations and other sustainable settlements capable of supporting significant additional development.

7. Transport, accessibility and road safety
The transport characteristics of Ashley present a serious obstacle to development at this scale.
Ashley is a rural location with limited public transport and a road network that is not designed to accommodate a major urban expansion.
The key concerns include:
• limited public transport provision;
• inadequate rail service capacity;
• restricted parking at Ashley railway station;
• narrow rural lanes;
• constrained railway bridges and other crossings;
• congestion affecting the A538 and M56 corridor; and
• a high degree of likely car dependency.

Ashley railway station cannot reasonably be treated as sufficient evidence that a 291.03-hectare development would be transit-oriented or sustainably accessible.
A strategic development of this scale would generate substantial additional journeys for employment, education, healthcare, shopping and other services. In the absence of adequate public transport, a significant proportion of those journeys would inevitably be undertaken by private car.
This would place additional pressure on already constrained rural roads and junctions and could create unacceptable consequences for highway safety and network capacity.

The Council should therefore assess transport sustainability on the basis of the actual capacity and characteristics of the local network, rather than relying simply on the existence of a railway station.

8. Loss of Best and Most Versatile agricultural land

A further major objection concerns the permanent loss of agricultural land.
The area contains substantial agricultural land, with available evidence indicating the presence of Best and Most Versatile (BMV) agricultural land, including Grade 2 and Subgrade 3a land.

BMV land is a finite resource. Once developed, it is effectively lost from agricultural production for the foreseeable future.
The significance of this issue is increased by the fact that the land remains actively functioning countryside. It is not previously developed land awaiting regeneration; it performs multiple roles simultaneously, including:
• food production;
• landscape character;
• ecological connectivity;
• carbon and soil functions;
• countryside separation; and
• Green Belt purposes.

The Council should therefore require a compelling justification before accepting the permanent loss of such a substantial area of productive agricultural land.
This consideration further weighs against treating the land as an obvious or low-performing Green Belt release opportunity.

9. Landscape impacts
Development on this scale would fundamentally alter the landscape character of Ashley and the surrounding Cheshire countryside.
The land contributes to the wider landscape associated with the Bollin Valley and Parklands Local Landscape Designation and the Rostherne/Tatton Park Local Landscape Designation.

The introduction of extensive housing, roads, lighting, drainage infrastructure, utilities and associated urban activity across 291.03 hectares would create a major change from the existing open agricultural landscape.

This would not be a minor or localised visual effect. It would represent a substantial urbanisation of an area which currently provides rural openness and landscape continuity.

The landscape consequences therefore reinforce the case for retaining the land within the Green Belt.

10. Heritage assets and the historic character of Ashley and the Tatton Estate
The countryside around Ashley also contributes to the setting and significance of a substantial number of heritage assets. The open agricultural landscape provides the rural context for 19 Grade II listed buildings, including Ashley Hall.

The introduction of a large-scale urban development, together with roads, lighting, traffic and associated infrastructure, would materially change these settings.

Particular care is also required in relation to the historic Tatton Estate hedgerows, fields and landscape structure, which form part of the area's historic rural character.
Before any Tatton Estate land at Ashley is considered suitable for allocation, the Council should establish the geographical extent, status and implications of the Tatton Estate Heritage Management Plan (HMP) agreed with Natural England and HMRC.

Tatton Estate has identified land of outstanding scenic, scientific and historic interest within its management arrangements and has specifically identified Arden House, Arden Park, North Arden Lodge and Lamb Cottage at Ashley in connection with the HMP.

The Council should establish whether any promoted land falls within, adjoins or has a functional relationship with land covered by the HMP and should assess whether the scale or nature of the proposed development could conflict with, prejudice or undermine the objectives and management requirements associated with it. The heritage implications cannot properly be assessed by considering individual development parcels in isolation from the wider historic estate landscape.

11. Ecological impacts and wildlife corridors
The land also forms part of a wider ecological network within North Cheshire.
Development of 291.03 hectares would result in the loss and fragmentation of agricultural habitats, hedgerows and ecological corridors.

There are important ecological relationships with Cotterill Clough Nature Reserve and Site of Special Scientific Interest (SSSI), ancient woodland, trees subject to Tree Preservation Orders (TPOs), surrounding habitats and established wildlife corridors.

The supporting evidence also identifies protected and declining bird species, including Red-Listed species such as grey partridge, tree sparrow and greenfinch.
The effects of development should therefore be considered cumulatively, including habitat loss, fragmentation, disturbance, lighting, increased traffic, domestic activity and pressure on surrounding protected sites.

The ecological value of the land reinforces its character as functioning countryside rather than land that has become detached from the Green Belt's purposes.

12. Flood risk, drainage and infrastructure barriers
There are also significant concerns regarding the physical deliverability of development across such a large area. Parts of the wider area, particularly towards the M56, are susceptible to surface-water and flood-related issues. Development would introduce extensive areas of impermeable surface, potentially increasing runoff and placing additional pressure on drainage systems and the River Bollin catchment.

The Council should not assume that these issues can automatically be overcome through later mitigation.
A SHELAA assessment must establish whether the necessary drainage, sewerage, electricity, transport and other infrastructure can realistically be provided at the scale required.

There are also potential constraints arising from Manchester Airport, including operational noise contours and aviation safeguarding requirements. Bird-strike considerations are particularly relevant where development could alter land uses, habitats or drainage features in ways that increase aviation safety risks.
These matters create further questions about the practical deliverability and sustainability of a strategic development at Ashley.

13. Aviation and operational safety
Manchester Airport is a major piece of strategic infrastructure in close proximity to Ashley. Any major development proposal must therefore properly account for aviation safeguarding, aircraft noise and bird-strike risk.

These are not secondary matters. Development can change land management, drainage, landscaping and ecological conditions, potentially creating or increasing bird-attractant habitats.

The Council should require a robust assessment of aviation constraints before concluding that the land is suitable for allocation.
Where operational safety considerations conflict with the proposed scale or nature of development, this would constitute a further material constraint on deliverability.

14. Reasonable alternatives must be exhausted first
The release of high-performing Green Belt land should not be considered in isolation from the availability of other options.
The Council must demonstrate that reasonable alternatives for meeting identified housing and employment requirements have been properly considered before sacrificing strategically important Green Belt countryside.

This should include:
1. making full use of suitable brownfield and previously developed land;
2. optimising development in existing sustainable urban locations;
3. considering appropriate opportunities within established settlements;
4. assessing lower-performing Green Belt locations where release is genuinely necessary; and
5. considering the extent to which development needs can reasonably be accommodated through neighbouring authorities.

The relevant question is therefore not simply whether housing could physically be built at Ashley.
It is:

Why should a strategically important and high-performing area of North Cheshire Green Belt be released when more sustainable alternatives have not first been demonstrated to be exhausted?

Given Ashley's transport limitations, settlement role, landscape sensitivity, agricultural value and infrastructure constraints, there is no compelling justification for placing this particular location at the forefront of strategic growth.

15. The cumulative planning case against allocation
The objection to the Ashley submission does not depend upon a single constraint.

The strength of the case arises from the combination of multiple, mutually reinforcing considerations.
The 291.03-hectare landholding:
• performs important Green Belt functions;
• acts as a narrow strategic buffer between Greater Manchester and Cheshire;
• helps prevent urban sprawl;
• maintains settlement separation;
• safeguards open countryside;
• is disproportionate to Ashley's position in the settlement hierarchy;
• would generate significant car-dependent travel;
• is served by constrained rural roads and limited public transport;
• would result in the loss of BMV agricultural land;
• affects important landscape designations;
• contributes to the setting of listed buildings and Ashley Hall;
• has relationships with the historic Tatton Estate landscape;
• raises ecological concerns involving protected sites, ancient woodland and wildlife corridors;
• presents flood and surface-water drainage challenges;
• raises aviation safeguarding, noise and bird-strike considerations; and
• would require substantial new infrastructure.

Taken together, these factors demonstrate that the land is not simply a potentially developable site with a Green Belt designation.
It is a strategically important area of functioning countryside whose release would have consequences for the wider spatial structure of North Cheshire and Greater Manchester.

16. Requested action
For the reasons set out above, I respectfully request that Cheshire East Council:
1. Records all 12 contiguous parcels, totalling approximately 291.03 hectares, as unsuitable, unavailable and undeliverable for strategic development within the SHELAA.
2. Assesses the 12 parcels cumulatively as a single strategic landholding, rather than allowing their subdivision to obscure the overall spatial and environmental consequences.
3. Does not identify the land as Grey Belt, given its continuing and substantial contribution to Green Belt purposes.
4. Does not identify Ashley or these parcels as a preferred location for strategic growth or as a strategic housing allocation.
5. Applies the settlement hierarchy and sustainable transport principles when considering the appropriateness of development at Ashley.
6. Requires all reasonable brownfield, previously developed, urban and lower-performing Green Belt alternatives to be properly examined before any consideration is given to releasing this high-performing Green Belt location.
7. Fully assesses the loss of Best and Most Versatile agricultural land and gives appropriate weight to the permanent loss of productive farmland.
8. Undertakes a cumulative assessment of landscape, ecological, heritage, flood-risk, transport, aviation and infrastructure impacts across the whole 291.03-hectare submission.
9. Establishes the relationship between the promoted Tatton Estate land and the Heritage Management Plan before any allocation decision is contemplated.
10. Excludes all 12 parcels from future Local Plan allocations on the basis of their combined planning, environmental, transport, agricultural, heritage, aviation, flood-risk and infrastructure constraints.

The current planning framework does not establish a general principle that Green Belt land should be released simply because additional development land is required.
The relevant issue is whether this particular land is appropriate for release when its Green Belt function, location, accessibility, environmental value, agricultural quality, heritage setting and infrastructure constraints are considered as a whole.

At Ashley, the evidence points strongly against release.

The land provides a vital North Cheshire Green Belt buffer — Manchester's remaining breathing space between the urban area around Hale, Trafford and Altrincham and the Cheshire settlements of Mobberley and Knutsford. Its open agricultural character is precisely what enables it to perform its Green Belt function.
The submission's scale makes the issue particularly serious. The proposal is not for a modest extension to a rural village but for the potential urbanisation of 291.03 hectares across 12 contiguous parcels.

Such a release would weaken the Green Belt's ability to restrain sprawl, reduce the separation between settlements, permanently remove productive agricultural land and introduce substantial additional pressure onto a rural transport network and infrastructure system that is already constrained.

Even if any part of the submission were argued to meet the Grey Belt definition, that would not resolve the separate questions of sustainable location, transport accessibility, the consequences for the remaining Green Belt, infrastructure capacity, environmental constraints and the availability of reasonable alternatives.

The combination of these factors makes the Ashley land fundamentally inappropriate for strategic development.

I therefore respectfully request that Cheshire East Council concludes that the 291.03-hectare submission is unsuitable, unavailable and undeliverable, that the land remains protected within the Green Belt, and that all 12 parcels are excluded from future Local Plan allocations.

Yours faithfully,
Ashley Cook
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