Local plan scoping consultation

The spatial portrait should recognise Tatton Park's strategic importance as a visitor destination receiving approximately 700,000 to 800,000 visitors in a typical year, as recorded by the Council. The Local Plan should consider how housing, visitor movement, sustainable transport, active travel, green infrastructure and the rural economy interact across the wider Tatton area.

Tatton Estate supports a landscape-led approach which protects designated assets, heritage settings, ancient woodland and high-value habitats while securing measurable nature recovery and public access. Agricultural land should be assessed according to quality, function and management rather than through a blanket assumption that all countryside performs the same role. Coordinated growth can retain field patterns, hedgerows and productive land, create connected habitats and support farming and rural enterprise.

The LPSD acknowledges that the Borough has a significant rural character with 18% of residents living in rural areas, albeit also contains a number of larger towns.

Its rural character makes Cheshire East an attractive place to live and invest. However, its rural context presents a number of challenges in securing a long-term sustainable future for Cheshire East. Of note, the long-term viability and sustainability of a number of the Borough’s rural settlements are under threat. Housing affordability, connectivity by sustainable modes of transport and poor quality or unsustainable service provision are common issues in the Borough’s rural settlements.

This context to the Borough’s rural settlements is an important consideration in the onward development of the Local Plan. The Local Plan, and where appropriate Neighbourhood Plans, provide an opportunity to respond positively to these threats and put the Borough’s villages onto a more sustainable footing.

This requires a concerted focus on the steps which the Local Plan needs to take to achieve this, including through supporting appropriate levels of growth in settlements and seeking opportunities for an enhancement in service provision. A strategy which directs almost all growth to towns risks reinforcing declining services, limited housing choice, car dependency and demographic imbalance in villages.

This concept goes beyond historic approaches of seeing rural settlements as the least sustainable locations for growth but rather towards acknowledging that they exist as existing concentrations of development, are a defining feature of the Borough’s character and need to be allowed to evolve and change to achieve a sustainable future.

This principle is supported by NPPF Policy HO6 which supports the allocation of sites for development in Local Plans ‘…which will support and enhance the vitality of rural communities and enable villages to grow and thrive, especially where this will support local services.’

A coordinated approach towards the managed growth of the Borough’s villages is needed through the Local Plan. This should involve a recognition of their inter-related nature (within defined geographies) where catchment areas for localised service provision overlap and which can inform a multi-village strategic masterplan where a coordinated growth plan, and service enhancement framework, can address some of their existing sustainability threats in the spirit of NPPF Policy HO6.

The Council should assess villages individually and as connected clusters reflecting their inter-reliance. The Tatton Villages proposition applies this principle through distinct but connected roles for Ashley, Mobberley, Rostherne and Bucklow Hill, linked to Knutsford and the Mid-Cheshire transport corridor.

The age and demographic profile of the Borough has direct implications for the Local Plan’s spatial strategy, housing mix and infrastructure policies and requirements. Of note, the Local Plan should increase the supply of smaller, accessible and adaptable homes, later-living accommodation, affordable homes and family housing in locations with access to services and public transport. This would allow older residents to move to suitable accommodation within their communities and release larger homes, while enabling younger households and local workers to remain or return.

Housing mix should be linked to measurable demographic outcomes, including the proportion of working-age residents, affordability, accessibility standards and access to healthcare and community facilities. Tatton Estate's village visions provide for a broad mix of tenures and typologies and, at Ashley, potential healthcare and school provision located within a walkable local centre.

Policy PM2 of the NPPF requires Local Plans to look beyond the specific defined plan period stating that Local Plans should reflect ‘…longer term expectations extending beyond the plan period where appropriate, including for any broad locations for growth and regeneration identified in the spatial development strategy, and any specific strategic site proposals’.

Clearly in the case of Cheshire East the Local Plan is intended to be adopted before the first SDS for the region, and so won’t benefit from being informed by the SDS, however PM2 is clear that a Local Plan should consider the period beyond the Local Plan’s stated timeframe notwithstanding.

There is a practical imperative to this. Not least, the most sustainable strategy for 55 the future growth of the Borough may be to seek to allocate one or more new settlements and major urban extensions, the full potential of which may not be realised over the 15 year plan period.

In this context, it may be appropriate for the Local Plan to allocate such sites reflective of their delivery over 25+ years including on the basis of expected delivery beyond the 15 year plan period. The alternative of limiting the allocation to what is deliverable in the plan period, with no provision for the years after, would result in such options not being capable of performing favourably, when considered against alternatives, as the numerical yield during the plan period only may indicate a scale of development which is not reflective of a sustainable proposal (i.e. too small in the context of a new settlement proposal) with the benefits as a sustainable option only becoming apparent over the long term.

This shorter-term outlook is thus likely to result in a reliance on smaller scale, piecemeal expansion of existing settlements, putting these under stress and pressure without the benefit of a strategic plan for improved service provision which planning for new settlements or large urban extensions provides.

Policy HO4 of NPPF supports longer term strategic planning in encouraging planning for strategic scale sites which, by implication, will require the Local Plan to consider the years beyond the plan period, notwithstanding its initial focus may be over only 15 years.

Further, this longer term outlook is supported by Policy GB4 of NPPF which requires a consideration of the need to allocate safeguarded land when undertaking a Green Belt review for the purposes of minimising the need for a further Green Belt review when coming to review the Local Plan.

Again, whilst not itself directing that a plan period should extend beyond 15 years, this reinforces a need for the Local Plan to address some development requirements post-plan period and make provision for these, where appropriate, in this plan. This is important in enabling a seamless transition from the emerging Local Plan to the next iteration and ensuring, in accordance with NPPF Policy PM2, the Local Plan is grounded in longer term expectations and objectives.

The vision should commit Cheshire East to meeting identified development needs through well-designed, infrastructure-led and climate-resilient places which improve outcomes for existing and future residents. It should recognise the complementary roles of towns, villages and cross-boundary transport corridors in being able to support growth requirements in a truly sustainable manner.

Measurable outcomes should include: delivery against housing need and the five-year supply requirement; affordable, accessible and specialist housing; jobs and employment floorspace; the proportion of homes with convenient access to daily services; public transport frequency and station accessibility; walking, wheeling and cycling connectivity; delivery of education, healthcare and community facilities; publicly accessible green space; biodiversity and nature-recovery outcomes; operational and embodied carbon; flood and water resilience; heritage outcomes; infrastructure delivery against agreed triggers; and the demographic and geographic reach of engagement.

We set out above in relation to section 4 of the LPSD two central issues which the Local Plan will need to consider and which should be incorporated in the Plan’s vision and objectives, these being:

• The need to take a proactive and positive approach to address the challenges and issues faced by a number of rural settlements in Cheshire East and enable a sustainable future for these communities with a focus on address affordability challenge and service accessibility and sustainability. The vision should expressly reflect NPPF policy HO6 by supporting rural communities and enabling villages to grow and thrive where this sustains or improves local services.

• Shaping the Local Plan strategy around its future connectivity context, including NPR and other planned investment, and the influence this will have on the relationship of the northern part of the Borough with key economic areas outside of Cheshire East and housing and employment development markets and demand dynamics.

The growth strategy should pursue economic, social and environmental objectives in mutually supportive ways. Infrastructure capacity must not be treated only as a fixed constraint: the assessment should identify what improvements are required, whether development can fund or support them and how they can be phased. This is central to the NPPF's vision-led approach.

The LPSD acknowledges the significant need for housing, calculated using the standard method. However, it is critical that assembling the evidence to inform both the housing and employment land requirement that the Council fully considers how the Plan will sustain the strong economic success achieved to date. This accords with the NPPF (see above including Policies E1 and HO2(3).

The Council, where evidenced, must include consideration of a housing requirement which exceeds the minimum standard method and ensures that the proposed supply of employment land will meet the needs of all segments of the local modern economy. This aligns with the commitment articulated in the Cheshire East Plan to unlock economic prosperity. Tatton Estate's growth locations are predicated on improvement. They combine homes with rail and bus opportunities, active travel, education and healthcare provision, employment, public open space, biodiversity enhancement and community facilities. Their single ownership provides a basis for comprehensive planning and coordinated delivery rather than fragmented development.

We have set out above, in relation to Green Belt policy considered in section 3 of the LPSD, the importance of a proper and correct application of national planning policy in relation to Green Belt when identifying and appraising sites and particularly ensuring that Green Belt characteristics are not overweighted in this process relative to other sustainability criteria.

This is central to ensuring the most sustainable sites are selected for allocation, when considered in the round, and that the outcome of the site selection process is reflective of the intended spatial distribution of development, rather than this being an uncontrolled consequence.
2.70 The latter is a common outcome where a narrow objective of minimising Green Belt release at all costs and then limited such releases to sites which make the least Green Belt contribution is pursued. Such an approach would be at odds with the NPPF which is clear that priority is given to non-Green Belt sites (and within the context of Green Belt sites, to grey belt sites) only to the extent that this is compatible with achieving the most sustainable outcomes when considered in the round.

We would raise two further points in relation to the site appraisal and selection process at this stage:

1) It is important that sites are considered in the context of the development proposal which are presented and achievable in each case. Whilst a comparison of sites in their baseline (undeveloped) state is important to ascertain basic sustainable characteristics, allocation selections should be informed by what is achievable or proposed within a site which may generate different conclusions as to what represents the most sustainable allocation options.

As an example, site size may have an influence on the ability to fund new infrastructure provision (including on site provision) which may change the conclusion of an assessment when considering one site over another. Alternatively, a developer’s proposition may include specific additional onsite benefits, such as new recreation facilities, which support the wider community and which again should have an influence on how a site is scored (as long as such commitments were to be incorporated into the allocation policy as a specific requirement of the development).
To this end, the site appraisal process will be required to be carried out at a level of granularity which ensures critical points of difference, such as those presented above, are able to be considered and weighted as appropriate in the appraisal process. The alternative of a more crude appraisal process which considers sites independently of such detail, may result in less sustainable development proposals being selected for allocation.

2) In a similar vein, sites should be appraised in the context of what else is being considered and potentially allocated locally. Sites can work together to, for example, fund off site infrastructure improvements, but this can only be revealed, as a form of mitigation or localised benefit, when the scenario of two or more sites coming forward together is considered.

Again, and reflective of this, the site appraisal methodology needs to have a sufficient degree of sophistication built into it to consider how outcomes, in terms of a site’s performance, may change in different scenarios.

Our comments in relation to the influence and application of Green Belt policy in the assessment of candidate sites for allocation is set out above.

Tatton Estate supports the borough-wide Green Belt assessment and the sequential approach in NPPF policy GB3. The assessment should follow Annex E, use sufficiently small assessment areas and consider physical containment, settlement form and transport corridors. It should identify grey belt without conflating Green Belt purpose with separate landscape, heritage or ecological designations.

The Council should then assess whether potential releases would promote a sustainable pattern of development, including the ability to deliver affordable housing, necessary infrastructure and accessible green space under policy GB8. Land close to existing settlements and the Mid-Cheshire Line should be evaluated alongside planned service improvements and the capacity for comprehensive development. Tatton Estate's evidence indicates that relevant parts of its promoted land may meet the grey belt definition, but the Council should reach its own conclusion through the published methodology.

Comments are provided in relation to the spatial distribution of development, at a strategic elsewhere.

That issue has a interrelationship with the question of the settlement hierarchy. A settlement hierarchy is typically a reflection of the current situation in relation to the size and status of each settlement and the service provision within it. However it is important that this is not used to prevent a proper consideration of spatial options, and site selection, which don’t directly reflect a baseline settlement hierarchy having regard to existing infrastructure and scale.

To this end, a settlement hierarchy should not become a mechanism which locks settlements into their present condition to determine future growth capacity. The methodology should consider both current sustainability and the realistic post-development position where infrastructure and services are secured through an allocation. It should assess access to services across connected groups of settlements and recognise the role of public transport and active travel improvements.

The assumption that the hierarchy is fixed and the status quo should be maintained should not be automatically carried forward for plan making purposes. In expanding on this issue we would highlight three important points:

• There is a need to consider the spatial distribution of development at a strategic level particularly in Cheshire East since, in broad terms, the northern part of the Borough has a very different economic function to the south owing to its relationship with and connectivity to Greater Manchester. This will have an influence on the question of how much growth is directed towards the north versus the south, to some degree irrespective of the size and status of existing settlements within these two locations.

• Set against this context, Policy HO4 of the NPPF requires Local Plans to consider the allocation of strategic sites, including new settlements, to meet development needs. This reflects that such sites, often based on the principle of pooling needs and meeting them in a smaller number of locations, may be the most sustainable way of planning for an area’s growth. This provides the advantage of achieving a critical mass of development in a single location where infrastructure can be properly planned and funded and where a diverse range of housing options can be provided.

Commonly strategic sites represent holistically planned new communities, albeit often representing a major expansion to a smaller existing settlement which means some road and infrastructure networks are already in place to build upon, supporting practical delivery. Clearly in such instances the development is going beyond meeting the needs of that specific settlement and would involve a level of growth which wouldn’t directly be supported through a narrow application of a settlement hierarchy as a direct indicator of a settlement’s ability to accommodate growth in a sustainable manner.
To this end, a settlement hierarchy must be seen in its context and should not be used to inform a consideration of strategic scale sites which may be assessed pursuant to Policy HO4 of the NPPF. Any settlement hierarchy which is presented in the Local Plan should be reflective of the Local Plan’s strategy, including intended development within that settlement. We would caution against its narrow use in appraising the relative sustainability of various development options for the reasons outlined.

• Finally, reflective of the points made above, it is important that the Local Plan is based on a detailed consideration of what rural settlements need to achieve a sustainable future. We set out above common threats affecting such settlements, including in relation to affordability and service accessibility and sustainability and, in this context, the principle of supporting their managed growth, on a targeted and planned basis, to address these. This may support, in some cases, a level of development which is greater than what has gone before to address these sustainability threats.

Again, in this context we therefore would caution against a narrow use of a settlement hierarchy in providing direction as to the level of development which individual settlements should be permitted to accommodate. The settlement hierarchy shouldn’t therefore be established as a limiting influence in respect of planned growth targeted at putting each settlement on a more sustainable footing through the Local Plan itself.

Please see Tatton Estate's written report as issued by email