Local plan scoping consultation

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.

This letter has been prepared by Heatons on behalf of Tarmac Trading Limited as a
response to the Cheshire East New Local Plan Scoping Consultation. The response is intended to assist the Council in considering the scope of the new plan, particularly in relation to employment land, the effective use of previously developed land, Green Belt review and the role of existing employment locations across the borough. Accordingly, this response has been structured to respond to the relevant matters in chronological order.
Paragraphs 5.5 to 5.7: Planning for Growth
The consultation correctly identifies that the new Local Plan will need to plan positively for housing, employment, retail and other uses required to support sustainable growth across Cheshire East.
In planning for future growth, it will be important that Cheshire East provides sufficient employment land to support economic prosperity, investment and job creation alongside housing delivery. Failure to provide an adequate supply of employment land risks constraining economic growth and increasing out-commuting from the borough.
As part of this process, the Council should ensure that the evidence base and spatial strategy provide a sufficiently flexible and deliverable supply of employment land. This should include consideration of a range of site typologies, including modern strategic
sites, smaller local employment opportunities and existing employment locations capable
of being reused, intensified or modernised where appropriate.
Paragraphs 5.8 to 5.12: Identifying and Assessing Sites
Tarmac strongly encourages the Council to place significant weight upon the identification and allocation of previously developed land through the land availability assessment process. National planning policy is clear that brownfield land should be prioritised as part of a sustainable pattern of development and that underutilised sites should be brought back into effective use wherever opportunities exist.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The Council's site assessment methodology should be prepared in accordance with Policy PM9 of the National Planning Policy Framework (NPPF) (August 2026), which requires the assessment of site suitability, availability, achievability, development capacity and
delivery timescales. In applying this methodology, the Council should ensure that positive weight is afforded to sites that comprise previously developed land, benefit from existing infrastructure and access arrangements, are available within the early stages of the plan period and are capable of contributing towards identified employment needs.
Furthermore, Policy L1 of the NPPF requires development plans to identify ways of accommodating as much as possible of development needs on previously developed
land, including through the reuse and intensification of underutilised business sites. On that basis, the land availability assessment should recognise the contribution that previously developed and underutilised employment land can make to meeting future needs. Sites with an established industrial character, existing buildings or hardstanding,and available infrastructure may provide opportunities to accommodate employment growth while reducing pressure on wholly greenfield locations.
The allocation of brownfield employment sites such as this delivers a range of planning benefits. It reduces pressure on greenfield land, promotes efficient use of existing infrastructure, supports sustainable patterns of development and assists in meeting economic development objectives without requiring the significant land take associated with entirely new employment locations.
Furthermore, redevelopment would provide an opportunity to rationalise the existing site layout, modernise the built form, improve operational efficiency and deliver environmental enhancements. For example, where a site currently contains ageing industrial infrastructure and substantial areas of hardstanding, an allocation would likely lead to redevelopment that would achieve biodiversity enhancements, improved landscaping,better integration with surrounding woodland and a significantly enhanced appearance when compared with the existing condition. While the Council may assume that sites of this nature would come forward through policy compliance alone, that is unlikely to be the case for previously developed land. Allocating existing employment sites that could be expanded to create additional floorspace would provide operators with greater confidence and help unlock investment. Therefore, the value of allocating sites with an employment legacy and the capacity to provide additional floorspace should not be underestimated.
The assessment process should therefore distinguish between different forms of Green Belt land. Previously developed sites, established employment locations and heavily enclosed or visually contained sites have a different planning profile from open, undeveloped countryside. A consistent methodology for recognising these distinctions, alongside a Grey Belt assessment, would assist in identifying appropriate options for the plan.
The spatial strategy should seek to balance economic growth across the borough and should not rely solely upon large urban extensions. Existing brownfield employment sites provide valuable opportunities to support economic development in sustainable locations whilst minimising impacts upon undeveloped countryside.
A balanced spatial strategy should therefore include a clear route for assessing existing employment sites outside the principal towns and key service centres. This would help ensure that smaller-scale and local employment opportunities are not overlooked where they are well related to the highway network, have an established commercial or industrial function, and offer scope for environmental improvement.
Paragraphs 5.27 to 5.29: Development in Settlements and Countryside
Tarmac notes the Council's intention to consider the need for additional local policies regarding development both within settlements and in the countryside.
Future countryside policies should distinguish between undeveloped rural land and sites that already contain substantial built development or long-established employment uses.
This distinction is important because redevelopment or intensification of an existing employment site may raise materially different planning considerations from development on open countryside.
The Local Plan should therefore provide flexibility to enable sustainable redevelopment and expansion of existing employment sites where environmental and accessibility considerations can be appropriately addressed.
Paragraphs 5.65 to 5.69: Employment and Economy
Policy E1 of the NPPF requires development plans to establish a positive economic strategy, allocate sites to meet identified employment needs and facilitate the expansion and modernisation of businesses. The Council's evidence base should therefore identify not only new employment opportunities but also existing employment sites capable of regeneration, intensification and modernisation. National policy also recognises the importance of supporting economic growth within rural areas. Policy E1 applies equally to sustainable economic growth in both urban and rural locations, while Policy E4
specifically supports the sustainable growth of businesses in rural areas and directs decision-makers towards opportunities that utilise previously developed land and sites physically well related to existing development.
The employment and economy section should therefore ensure that the new Local Plan is informed by a robust understanding of the quantity, quality, location and deliverability of employment land required over the plan period. This should include consideration of both strategic employment provision and smaller or specialist sites that support local supply chains, rural businesses and existing employment clusters.
The Council should place particular emphasis on the role that previously developed and underutilised employment sites can play in meeting future employment requirements. The redevelopment of brownfield land represents one of the most sustainable forms of economic growth, enabling employment needs to be accommodated whilst minimising pressure on greenfield land and reducing the need for wholly new employment locations.
Such an approach aligns with national planning policy objectives relating to the effective use of land, regeneration and sustainable development.
Within that assessment, previously developed employment sites should be treated as an important component of the potential land supply. Some such sites may contain older buildings, hardstanding or legacy industrial infrastructure, yet still offer opportunities for modernisation, environmental enhancement and more efficient use of land. Their role should be considered alongside, rather than after, wholly new employment allocations.
Redeveloping sites that are well positioned to contribute towards future economic needs,benefit from direct access to the A-road network and have strong connectivity to key towns such as Macclesfield and Congleton, as well as to the wider strategic road network,
should be prioritised. Redevelopment of such sites would provide the opportunity to modernise and intensify the use of underutilised brownfield land, delivering new employment floorspace, supporting business investment and creating jobs in a highly sustainable location.
The Council should also recognise that employment needs are not limited to large urban
or strategic locations. Existing employment sites in rural or edge-of-settlement locations can perform a complementary role by supporting local jobs, reducing the need for longer commuting trips and allowing established uses to adapt to changing business requirements. Where such sites are accessible, deliverable and capable of accommodating environmental improvements, they should be assessed positively
through the plan-making process.
Paragraphs 5.91 to 5.95: Transport and Infrastructure
Policy TR1 of the NPPF requires development plans to locate growth where it can make effective use of existing transport infrastructure and support sustainable movement patterns. Similarly, Policy TR3 requires development to utilise existing transport infrastructure and optimise the amount of development that can be accommodated in accessible locations.
Tarmac Trading Limited therefore supports the Council's intention to ensure that future development is supported by appropriate transport and infrastructure provision. An effective transport network is essential to supporting sustainable economic growth, maintaining business competitiveness and ensuring that development is delivered in suitable and accessible locations.
The emerging Local Plan should recognise the significant benefits associated with directing development towards sites that already benefit from established infrastructure and access arrangements. Redevelopment of such sites reduces the need for extensive new infrastructure provision, limits the environmental impacts associated with greenfield development and enables growth to be delivered more efficiently and sustainably.
The transport and infrastructure evidence should give appropriate weight to sites that can make use of established access arrangements and existing infrastructure. This can reduce delivery risk, avoid unnecessary infrastructure duplication and support the efficient reuse of land already associated with employment or industrial activity.
A plan-led approach should therefore assess the ability of existing employment sites to operate safely and efficiently, including access, servicing, traffic generation, connectivity to labour markets and opportunities for mitigation or improvement. Sites that perform well against these criteria may provide a sustainable and deliverable source of future employment land.
As such, by implementing the approach set out in the consultation, it is clear that the redevelopment of underutilised brownfield employment sites served by existing highway infrastructure represents one of the most efficient forms of development available to the Council. This approach aligns not only with NPPF Policies TR1 and TR3 but also with Policy L1, which seeks to maximise the contribution that previously developed land can make towards meeting development needs.
Conclusion
In conclusion, Tarmac Trading Limited supports the preparation of a new Local Plan which positively plans for sustainable growth, economic investment and the effective use of land across Cheshire East. The new Local Plan should be underpinned by a robust and flexible evidence base which recognises the contribution that existing employment locations,previously developed land and underutilised brownfield sites can make towards meeting future employment needs.
Particular weight should be given to sites which benefit from an established employment
or industrial character, existing infrastructure and access arrangements, and the ability to deliver modernised floorspace alongside environmental enhancements. Such sites can support business investment, job creation and local economic resilience while reducing pressure on wholly greenfield locations.
The Council should therefore ensure that its site assessment, Green Belt and Grey Belt review, settlement hierarchy, spatial distribution and employment evidence base all provide a clear and positive route for considering the redevelopment, intensification and modernisation of existing employment sites where they are suitable, available, achievable and deliverable.
Tarmac respectfully requests that these matters are taken into account as the new Local Plan progresses, and that appropriate policy wording and site assessment criteria are developed to support the effective reuse of brownfield employment land, sustainable rural economic growth and the delivery of a balanced employment land supply over the plan period.