Local plan scoping consultation

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.

FORMAL REPRESENTATION AND OBJECTION – HENBURY / WHIRLEY / SANDY LANE / BIRTLES ROAD, MACCLESFIELD
Please accept this email and the attached Formal Objection and Supporting Evidence Pack as my formal representation to the Cheshire East New Local Plan Scoping Consultation.
I would be grateful if you would acknowledge receipt and ensure that my representation is recorded against all relevant Call for Sites submissions affecting land around Henbury, Whirley, Sandy Lane and Birtles Road, including CFS26 590, CFS26 460 and CFS26 557 where those references correspond to the current submitted parcels, together with any overlapping or successor references covering the same land.
My objection
I wish to make my position clear from the outset.
I object to the potential allocation of these areas for substantial residential development on the evidence presently available.
I appreciate that the land shown on the Call for Sites map comprises landowner/developer submissions rather than proposed allocations or planning permissions, and that inclusion on that map confers no additional planning status.
My objection at this stage is therefore to these sites progressing towards residential allocation unless and until Cheshire East has demonstrated through comprehensive, transparent and published evidence that they are necessary, suitable, sustainable and deliverable.
I recognise that Cheshire East must plan positively for additional housing. My objection is not to properly evidenced housing need. My concern is that the concentration of submitted land around Henbury and Whirley presents an unusual combination of significant constraints which need to be understood before, rather than after, decisions are taken about residential allocation.
These include:
• the documented former Sandy Lane / Whirley Quarry landfill;
• unresolved historic waste-stream and potential industrial-waste questions;
• potential landfill gas, leachate, contaminated-groundwater and contaminant-migration pathways;
• ecology and protected species;
• Green Belt and settlement separation;
• existing infrastructure capacity;
• roads and transport;
• schools and healthcare;
• electricity, water, sewage and drainage;
• the relationship between housing and future employment;
• landscape and agricultural land;
• the setting of Grade II* Whirley Hall; and
• the cumulative effect of several potential sites being developed together.
1. Sandy Lane / Whirley Quarry former landfill
This is one of my most serious concerns.
Importantly, the existence of the landfill is not speculation.
The Environment Agency public register identifies BROCK LIMITED at Whirley Quarry, Sandy Lane, Whirley, Macclesfield, SK10 4RJ, under environmental permit KP3092CX, as an A05 landfill taking non-biodegradable wastes.
Published records also associate this with the earlier waste-management reference 53470. Even more significantly, Cheshire East's own historic housing-land evidence has previously recognised the landfill constraint in this immediate area. The Council's SHLAA assessment for Land west of Roewoods Farm, Birtles Road – site reference 3312 recorded among the physical constraints: “Located directly on landfill.”
The same assessment identified: “Consultation with Contaminated Land Officer” as part of managing the site's constraints.
I consider this highly relevant to the assessment of land now being submitted for potential residential development around Sandy Lane, Birtles Road and Whirley. This is therefore not simply a general resident concern about a former tip. Cheshire East's own previous site-assessment evidence has expressly identified landfill as a constraint affecting housing land in this immediate locality.
2. Leachate, groundwater and landfill-gas migration
The relevant question is not simply whether the boundary of a submitted housing site physically overlaps the mapped boundary of the former landfill. Historic landfill contaminants do not necessarily respect modern ownership or planning boundaries.Depending upon the geology, groundwater conditions and waste deposited, potential pathways can include:
• landfill gas;
• leachate;
• contaminated groundwater;
• contaminated soils and made ground; and
• migration through permeable geological strata.
Before adjoining land is considered suitable for residential allocation, I therefore ask Cheshire East, its Contaminated Land / Environmental Protection team and the Environment Agency, where appropriate, to establish:
• the precise historic landfill boundary;
• the depth and phases of filling;
• the original waste-management licence and subsequent permit documentation;
• the categories of waste authorised;
• what waste was actually received, insofar as historic records allow;
• historic borehole and monitoring-well information;
• soil and made-ground contamination;
• methane and carbon-dioxide monitoring;
• leachate monitoring;
• groundwater levels and groundwater quality;
• groundwater-flow direction;
• whether leachate or contaminated groundwater has ever been detected outside the recorded landfill footprint;
• whether potential migration pathways extend towards adjoining submitted land; and
• how excavation, piling, foundations, dewatering or altered drainage might change those pathways.
I am not asserting that industrial contaminants are presently leaching from the landfill into the proposed housing sites.
I am saying that, given the documented landfill and the sensitivity of residential development, this needs to be established by evidence before adjoining land is regarded as suitable for housing. The fact that contamination might theoretically be capable of remediation should not substitute for understanding the problem before allocation.
3. Historic industrial waste and Ferodo/T&N
There are also historical local questions concerning waste associated with Ferodo/T&N, including asbestos-containing friction-product material.
Again, I want to be precise. I am not asserting that Ferodo/T&N asbestos waste has been proven to have been deposited at Sandy Lane / Whirley Quarry. However, the historic landfill is documented, and the precise waste streams deposited there are directly relevant to assessing neighbouring land for residential use. I therefore ask Cheshire East and the Environment Agency to examine the original licence, licence variations, operator records, waste records and relevant archives specifically to determine whether they contain references to:
• Ferodo;
• T&N;
• asbestos-containing material;
• friction-product manufacturing waste; or
• other industrial waste.
This question should be resolved from primary evidence rather than either residents or developers being expected to speculate.
4. The landfill also has significant ecological importance
There is another important dimension to Sandy Lane Pit. Published Cheshire landscape evidence describes Sandy Lane Pit as a derelict landfill site west of Macclesfield with ponds and terrestrial habitats supporting a large number of amphibians, including great crested newts. Consequently, any assessment of the former landfill and surrounding submitted sites needs to consider contamination and ecology together. Remediation, drainage changes, road construction, lighting and development of surrounding terrestrial habitat could all potentially affect this ecological network.
5. Ecology across the wider Henbury/Whirley area
The surrounding countryside contains an interconnected network of: mature hedgerows + mature trees + woodland + ponds + grassland + pasture + scrub + field margins.
There are also regular local observations of bats, owls and badgers. Natural England's guidance identifies woodland, scrub and hedgerows as habitat where authorities should consider species including bats, breeding birds and badgers, while grassland and pasture can support bats, badgers, birds and great crested newts. The ecological question therefore cannot simply be: “Is a protected animal physically present inside this particular submitted field?”
The Council needs to understand how the whole habitat network functions.
For example:
• hedgerows and tree lines can be bat commuting routes;
• artificial lighting can disrupt otherwise retained bat corridors;
• pasture can provide owl and other bird feeding habitat;
• badgers use movement and foraging routes extending beyond their setts;
• great crested newts use terrestrial habitat as well as ponds; and
• several developments can collectively sever habitat connectivity even where individual hedges are retained.
Professional ecological surveys should therefore take place at appropriate times of year and early enough to inform site selection and realistic development capacity.
6. How much genuinely new housing land is actually required?
I also believe it is essential to distinguish the Government's headline housing requirement from the amount of genuinely additional land that needs to be allocated. Cheshire East's scoping material identifies a new standard-method minimum of approximately 2,530 dwellings per year. Over 15 years, that equates arithmetically to approximately 37,950 dwellings. However, that does not mean that land for 37,950 completely new homes must automatically be found on previously undeveloped countryside.
Before additional Green Belt or greenfield land is considered, Cheshire East should publish a transparent calculation showing: Total Local Plan housing requirement
LESS
• existing planning permissions expected to deliver during the new Plan period;
• existing allocations expected realistically to deliver;
• developments already under construction;
• suitable brownfield capacity;
• regeneration opportunities;
• under-used urban land;
• appropriate urban-density optimisation;
• a justified windfall allowance; and
• other sustainable sources of supply;
EQUALS
the residual requirement for genuinely new housing land.
That residual figure is the relevant starting point when deciding whether countryside and Green Belt land needs to be released.
7. Existing housing supply and the difference between land and delivery
Cheshire East's April 2026 Strategic Planning Update reports a deliverable five-year supply of 8,780 dwellings, equivalent to 3.3 years, against a five-year local housing need figure of 13,162 dwellings. The Council also reports that the supply has fallen from 3.8 years because more homes were built than new planning consents were granted during the reporting period. I recognise that the 3.3-year position is important.
However, a five-year deliverability shortfall is not necessarily the same as there being insufficient land already permitted or allocated. I therefore ask the Council to publish:
• the number of permitted but unbuilt homes;
• allocated but undeveloped homes;
• actual build-out rates;
• completion and occupation rates on major sites;
• sites excluded from the five-year deliverable supply and the reasons why;
• infrastructure constraints affecting existing sites; and
• evidence demonstrating that allocating additional land would actually increase annual completions.
The distinction between land supply and housing delivery is important.
8. Employment – where will the jobs actually be?
The housing proposals also need to be considered alongside employment. Cheshire East's own scoping evidence states that the existing Local Plan sought at least 380 hectares of employment land between 2010 and 2030 based upon average annual jobs growth of 0.7%.
The Council reports that, as at 31 March 2024:
• approximately 375 hectares of employment land remained available;
• more than 112 hectares had been developed since 2010; and
• average annual jobs growth had actually been 1.3%, substantially above the 0.7% assumption.
This demonstrates that Cheshire East has experienced employment growth. The important unanswered question for the new Plan is:
Where will the jobs associated with the next substantial period of housing and population growth actually be located?
For Macclesfield specifically, I ask the Council to therefore publish:
• forecast additional jobs;
• expected employment sectors;
• where those jobs will be located;
• employment-land requirements;
• the extent to which the existing employment-land supply can accommodate them;
• the relationship between new housing and employment locations; and
• expected commuting patterns.
If substantial housing growth around Macclesfield is not accompanied by corresponding local employment, the Plan should quantify the consequences for commuting, congestion, public transport and car dependency.
9. Infrastructure
The cumulative infrastructure implications also need to be demonstrated before major additional development is allocated.
Schools
Please provide current and forecast primary and secondary capacity, including pupils generated by housing already permitted but not yet occupied. Where new schools or expansion are required, identify:
location + capacity + cost + funding + delivery body + opening date.
Healthcare
Please assess:
• GP capacity and workforce;
• projected additional patients;
• Macclesfield Hospital capacity;
• A&E pressures;
• elective and outpatient demand; and
• funded healthcare mitigation.
Highways
Cumulative traffic modelling should include Whirley Road, Sandy Lane, Birtles Road, Wrigley Lane and relevant strategic junctions, taking account of committed development as well as potential allocations.
Public transport
The Council should demonstrate whether realistic bus, rail, walking and cycling alternatives exist or whether substantial new housing here would create additional car dependency.
Waste and recycling
The additional population needs to be reflected in refuse-collection and household-recycling capacity.
Electricity
Please establish distribution-network and substation headroom, reinforcement requirements, costs and delivery timescales, including increased demand associated with EV charging and electrified heating.
Water and wastewater
Please establish:
• potable-water headroom;
• foul-sewer capacity;
• wastewater-treatment capacity;
• reinforcement requirements;
• cost;
• funding responsibility; and
• delivery programme.
Drainage
Surface-water drainage should be considered at catchment level, including cumulative hardstanding, downstream impacts and climate-change allowances.
10. Green Belt, settlement separation and landscape
Several individual submitted fields may appear relatively modest when considered separately. Collectively, however, they could constitute a substantial extension of Macclesfield towards Henbury and Whirley.
The Council should therefore assess:
• urban sprawl;
• countryside encroachment;
• physical and visual settlement separation;
• Green Belt purposes;
• landscape character;
• important views;
• public rights of way;
• agricultural land; and
• reasonable brownfield and less environmentally constrained alternatives.
11. Whirley Hall
Whirley Hall is Grade II* listed.
The significance and setting of this highly graded heritage asset, including its relationship with the surrounding rural landscape and important views, should therefore be assessed before development capacity is assumed on surrounding land.
12. Cumulative impact
This is perhaps the central issue. The submitted sites should not be assessed as isolated parcels. The Council must undertake an area-wide assessment combining:
housing + population + jobs + commuting + traffic + schools + healthcare + public transport + waste + electricity + water + sewage + drainage + landfill + industrial waste + contaminated land + landfill gas + leachate + groundwater + bats + owls/birds + badgers + great crested newts + hedgerows + trees + ponds + Green Belt + landscape + heritage + agricultural land.
The interaction between these matters also matters.
For example:
• road access can remove hedgerows;
• artificial lighting can disrupt bat routes;
• drainage changes can affect ponds;
• excavation can alter groundwater pathways;
• development can fragment badger habitat;
• additional traffic can increase wildlife mortality; and
• several individually modest developments can collectively remove the countryside separating settlements.
13. Consultation and notification
I also wish to record concern about the way this consultation has been communicated to residents living immediately around concentrations of submitted sites. I appreciate that this is a Local Plan scoping consultation rather than an individual planning application, and I am not suggesting that the usual neighbour-notification requirements for a planning application necessarily apply to this stage.
I also acknowledge that Cheshire East has publicised the consultation online. Nevertheless, I became aware of the scale of the land submitted around our community principally through other local residents.
Given the potentially profound implications of these submissions, I would have expected particularly prominent engagement with residents living immediately around the affected land. The consultation runs from 21 July until 5pm on Tuesday 1 September 2026, substantially overlapping the main summer-holiday period.
I therefore ask Cheshire East to explain:
• what targeted steps were taken to inform residents living immediately around concentrations of submitted sites;
• what engagement took place through parish/community organisations;
• how the effectiveness of that engagement was assessed;
• whether additional local engagement will now take place;
• whether an extension to the present consultation has been considered; and
• how residents immediately affected will be proactively notified when individual sites are considered for possible allocation at subsequent stages.
My specific requests
I therefore ask Cheshire East to:
1. Record this email and attached evidence pack as my formal representation and objection.
2. Cross-reference it to CFS26 590, CFS26 460 and CFS26 557 where those are confirmed as the relevant current references, and any overlapping or successor submissions covering the same land.
3. Treat the former Sandy Lane / Whirley Quarry landfill as a fundamental early site-selection constraint.
4. Obtain and examine Environment Agency permit KP3092CX, the earlier licence/permit records associated with 53470, and the available historic waste records.
5. Refer the affected sites to Cheshire East's Contaminated Land / Environmental Protection team before residential suitability is assumed.
6. Establish whether landfill gas, leachate or contaminated groundwater is present and whether migration pathways could extend into adjoining submitted land.
7. Investigate the Ferodo/T&N and asbestos-containing industrial-waste question from primary records, without assuming either that such disposal has been proven or that it did not occur.
8. Publish a transparent calculation of the residual requirement for genuinely new housing land.
9. Publish permitted-but-unbuilt and allocated-but-unbuilt housing information and explain the causes of the current five-year deliverability shortfall.
10. Publish Macclesfield-area employment forecasts, employment locations and commuting assumptions.
11. Complete cumulative infrastructure-capacity evidence before determining that substantial additional development here is sustainable.
12. Ensure protected-species and habitat-connectivity evidence informs site selection, with properly timed surveys where necessary.
13. Undertake cumulative Green Belt, settlement-separation, landscape, agricultural-land and heritage assessment, including Grade II* Whirley Hall.
14. Assess all the submitted parcels cumulatively with development already permitted or under construction, rather than as isolated fields.
15. Explain what targeted measures were taken to engage residents immediately adjoining these submitted areas and ensure proactive notification at subsequent site-selection/allocation stages.
16. Publish the evidence, scoring and reasons used to progress or reject individual sites.
Conclusion
I recognise Cheshire East's obligation to prepare a sound Local Plan and plan for additional homes.
However, the requirement to provide housing does not remove the requirement to demonstrate that the locations selected are sustainable, that reasonable alternatives have been considered and that infrastructure and environmental constraints can satisfactorily be addressed.
In the Henbury/Whirley area there is a particularly significant combination of: a documented historic landfill + unresolved historic waste streams + potential contaminant pathways + ecologically important habitat + Green Belt and settlement separation + infrastructure pressures + landscape + agricultural land + heritage.
On the evidence presently available, I object to the potential residential allocation of these sites.
I ask that they should not progress towards residential allocation unless and until Cheshire East has completed and published the evidence necessary to demonstrate that these constraints can satisfactorily be addressed and that development here is preferable to reasonable, more sustainable alternatives.
The attached evidence pack provides the supporting maps, statistics, documentary evidence and source references behind this representation.
Please acknowledge receipt and confirm:
1. that my email and attachment have been formally recorded;
2. the site references against which they have been registered;
3. that the landfill/contamination matters will be referred to the appropriate Environmental Protection / Contaminated Land officers; and
4. that I will be notified of subsequent consultation stages affecting these sites.