Local plan scoping consultation

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.

Whilst we note Affordable Housing delivery has been strong with an average annual delivery of 477 dwellings compared to 455 as set by the adopted Local Plan Strategy, it is important to note that the Local Plan Strategy target was based on what is now an outdated assessment of housing need and affordable housing need and particular regard needs to be had to the number of households that sit on the waiting list.

Despite strong delivery, the latest number of households on the waiting list and in need of an affordable home has nonetheless increased when compared to 2020 as shown in the uploaded figure. However, it is clear that there has been a step change since the steep increases that occurred between 2010-2013, where the waiting list stood at 12,495. The increase of 951 (from 2020 to 2025) is ~14%. Further, there has been an increase from 5,052 (2021) to 7,847 (2025) in recent years. This is an increase of 55%. It follows that there remains a very strong need to deliver more affordable housing, from a base of strong delivery. This can only be achieved through the allocation of additional land for housing and the granting of market schemes.
As of 31 March 2025, there were 7,847 households on the Cheshire East's affordable housing waiting list for rented affordable housing . This is a significant reduction compared to the peak in 2013 but still also represents a significant rise from 2021, when there were 5,052 (although we note there has been a reduction on the previous year).

Critically, the number of households on the Council's affordable housing waiting list represents only part of the need for affordable housing, as it relates only to rental accommodation. It does not take into account the need for other types of affordable housing, such as shared ownership. Applicants are asked to provide evidence of their needs and are placed in ‘Bands’ and are required to have either a local connection to the Authority as set out in the Council’s ‘Common Allocation Policy’ (see pages 13/14 and 19/20).

Noting the number of households on the Council’s housing register, we consider a critical piece of evidence for the Local Plan will be clear and accurate data on the number of households on the housing register and the number of households that confirm what their preferred/required location/settlement is. The selection of sites to be allocated within the Local Plan should pay clear regard to such evidence to best ensure these needs can be met where they are required.

In relation to settlements that are wrapped by Green Belt, it will be important to recognise that the release of Green Belt land to meet affordable housing needs in conjunction with market housing needs at the required 50% level can not only make a very positive contribution and uplift in affordable housing provision across the Borough whilst also representing an exceptional circumstances for making Green Belt boundary change around specific settlements. Indeed, NPPF Policy GB3: Altering existing Green Belt Boundaries makes it clear that exceptional circumstances include a local planning authority being unable to meet its identified need for development in full. This should reasonably include meeting the needs for affordable housing where they arise and are evident by housing waiting list data associated with each respective settlement surrounded by Green Belt whilst seeking to further boost affordable housing delivery across the Borough as a whole, particularly given the very high affordability ratios that impact on certain parts of the Borough (namely in the north of the Borough).

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 that the Council recognises Jodrell Bank Observatory (JBO)’s status as a UNESCO World Heritage Site. We consider it important that the Council clearly distinguishes between:
• the heritage significance of Jodrell Bank as a designated heritage asset, including the Grade I listed Lovell Telescope; and
• the technical and operational significance of the wider astrophysical observatory and the extensive safeguarded area surrounding the site.

The two concepts are separate and should not be married together.

We have included previous representations made to the Council in February 2022 at Appendix 3 which were issued to the Council’s Draft Jodrell Bank SPD, which has since been abandoned. This was prepared on behalf of a housing consortia, which did not include Bloor Homes but they are in agreement with its content. We consider much of the objections content is still highly relevant, particularly in light of recent Government announcements that Jodrell Bank will no longer be receiving further Government grants and funding.

UK Research and Innovation (UKRI) announced in July 2026 that it would withdraw its annual funding for JBO, which previously amounted to £2.8 million per year. UKRI stated that future investment would be directed towards projects delivering “the greatest long term impact”. Funding for e MERLIN will continue until May 2028, and the University of Manchester will continue to own and operate the Lovell Telescope. These changes indicate a diminishing operational role for JBO within the national research landscape.

The Square Kilometre Array Observatory (SKAO) headquarters is located at Jodrell Bank. The scientific data it relies upon is collected through the Square Kilometre Array (SKA) telescopes in South Africa and Australia, locations chosen specifically for their superior radio quiet environments. The headquarters receives approximately £15 million fundings annually and employs almost 200 staff, with the majority funded through international contributions from SKAO member countries. The UK is investing £327 million into SKAO between 2021 and 2030. The information is presented in the Position Statement published by UKRI which is included in the Appendix 4.

Since the appended representations were issued, construction of the SKA Observatory commenced in December 2022 (https://www.skao.int/en/news/441/ska-observatory-celebrates-start-telescope-construction-australia-and-south-africa) and it has also now reached its first construction and verification milestones, with the first 1,024 antennas now in operation and proven (https://www.skao.int/en/news/659/first-construction-milestone-australia).

This evidence demonstrates that the future of radio astronomy is increasingly centred on international facilities rather than the Jodrell Bank telescope itself.

While we recognise the Jodrell Bank site remains at the forefront of research activity, technological advances mean that the Jodrell Bank telescope itself no longer needs to be located on site for JBO to fulfil its global scientific role. This further reinforces the reduced need for an extensive safeguarding zone, which dates back to 1973 at a time when Jodrell Bank was a critical site in terms of its advanced technology. However, in light of these global developments, significantly less weight should be afforded to the current consultation zone because superior technology elsewhere and far removed from Jodrell Bank now provides the most effective and efficient data.

Whilst we note that the 1973 Directive persists and the Council are required to consult with the University of Manchester on planning applications and development proposals within the zone, we consider the above facts and the new CEC Local Plan represents a clear milestone for the Council and the Government to undertake an independent and up to date review of the genuine implication towards delivering sustainable development within this part of the Borough vs the scientific impacts at a local and global scale.

We suggest that the new Local Plan should support development proposals where it can be clearly demonstrated that there would be no unacceptable heritage impact on JBO. Bloor Homes’ land interests in Holmes Chapel and Congelton lie on the fringe of the existing settlement boundary, and there is no visual or functional relationship between these sites and JBO. In this context, development in Holmes Chapel should not be constrained by the safeguarding zone where no heritage harm can be evidenced.

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.