Local plan scoping consultation

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.

General Comment
Cheshire East need to plan positively for future housing growth. However, the Local Plan should establish clear principles for assessing developments to ensure they are sustainable, infrastructure-led, clearly meet identified needs and are supported by local communities.

Section 1: Local Plan Scoping Consultation - How to respond (1.10)
Timescale is a concern given that Parish Councils often do not meet over the summer period and many residents are away during the summer school holiday. The next programmed consultation period should take into account school holiday periods.

Section 2: New Local Plan (2.1)
Planned Development should be through the Local Plan Process. Any large strategic housing and commercial developments should only be brought forward through the Local Plan process following meaningful engagement with local communities, elected members, town and parish councils and key stakeholders. Communities should have confidence that strategic growth has been assessed transparently against reasonable alternatives and that local knowledge has informed decision-making from the outset.

Section 3: Context for the new local plan Sub heading 3.1 – 3.2 Introduction
Strategic planning policies should be based on adopted National Policies rather than draft consultation documents which may change significantly before finalised. The Local Plan may need to be revised during its production to reflect legislative changes, and if these are material the changes must be subject to consultation.

Sub heading 3.3 – 3.7 Increase in housing requirements.
Development should be in the long-term public interest rather than short term private interests or theoretical shortage of land supply. Given the shortfall in housing land supply there is pressure to release land for development where locations may not be sustainable or deliverable. CEC should issue an Interim Housing Policy Statement (IHPS) to guide developers and provide clarity during this period. This is an established route for Councils to demonstrate compliance with housing policy and outline their strategic approach (for example bringing forward safeguarded land, entering into planning performance contracts with developers and promoting town centre regeneration). There is a strategic policy void at present which is unacceptable to all parties and without an IHPS this will continue until the Local Plan is published.

Developers should demonstrate credible delivery timescales so proposed developments will deliver at least a partial solution to the shortfall. CEC has already considered that safeguarded land can help meet longer-term needs. Because of changes in the standard method for calculating the housing requirement, the “longer-term” has now arrived and CEC should make it known that it will consider favourably the principle of releasing such sites. This will help address the housing shortfall as one element in an IHPS until the new Local Plan is adopted. It will also direct developers to sites CEC has considered suitable for release rather than having to allow less than appropriate sites to be released for development on application or appeal.

Sub heading 3.11 to 3.14: Changes to Green Belt Policy
Green Belt, agricultural land and ecological assets need to be protected. Where large-scale development is proposed on greenfield land the environmental impacts must be fully assessed and demonstrably outweighed by wider public benefit. The Local Plan should reinforce a clear commitment to protecting the Green Belt, recognising that its essential characteristics of openness and permanence, as set out in the (NPPF). The Green Belt performs several important strategic purposes: checking unrestricted sprawl of large built-up areas; preventing neighbouring towns from merging; safeguarding countryside from encroachment; preserving the setting and special character of historic towns; and supporting urban regeneration by encouraging the effective use of previously developed land.

These purposes remain fundamental within Cheshire East and should form the basis of any assessment of proposed Green Belt release. The Local Plan should require that any proposal affecting Green Belt demonstrates: clearly evidenced and substantiated exceptional circumstances; that brownfield land, urban regeneration opportunities and other reasonable alternatives have been comprehensively assessed first; the impact on each of the five Green Belt purposes; the cumulative effect of Green Belt release on openness, landscape character and settlement pattern; the effect on the identity and separation of neighbouring towns and villages; and the long-term permanence and effectiveness of the Green Belt. Development should also avoid the unnecessary loss of productive agricultural land, ancient woodland and established habitats supporting biodiversity and areas vulnerable to flooding. These environmental assets contribute significantly to climate resilience, food security, landscape quality and the character of Cheshire East's rural communities. We are concerned about the statement in 3.7 “development might be approved in locations where it would not normally be allowed, such as the countryside and Green Belt, unless very strong reasons exist to refuse it” - this seems to assume a presumption to build on Green Belt. Instead, we argue that weight should be given to rejecting proposals and land submitted in the Call for Sites that would erode the physical separation between settlements or create continuous urban development. Once openness and settlement identity are lost, they cannot realistically be restored. Weight should also be given to input from Cheshire Wildlife Trust and how land has been identified in the Cheshire and Warrington Local Nature Recovery Strategy.

This aligns with the Labour Party manifesto that committed to: Preserving the Green Belt which has served England’s towns and cities well over many decades. A brownfield-first approach, prioritising previously developed land; Recognition that brownfield alone would not meet housing need; Retaining the overall purpose and general extent of the Green Belt. • Prioritising the release of lower-quality 'grey belt' land rather than high-quality Green Belt land. applying "golden rules" so that any development benefits both communities and nature. These environmental assets are irreplaceable and given, from SANT’s assessment, there is a sufficient potential housing land supply from safeguarded land, previously developed and underused land (brownfield) and greenfield land located in appropriate and sustainable locations, there is no justification to release land that strongly contributes to the original purposes of Green Belt. We ask that the Council state their position on how they will assess grey belt and how it is proposed to enforce the delivery and timing of the Golden Rules of affordable housing, infrastructure and green spaces.

Sub heading 3.15: Brownfield First
The Local Plan should reinforce a clear brownfield-first approach. Previously developed land and regeneration of existing urban areas should be prioritised ahead of releasing Green Belt and productive agricultural land. Regeneration would better use existing infrastructure, increase town centre footfall, support local businesses, meet local housing needs and reduce pressure on the countryside. Government and local authorities should continue to support the redevelopment of brownfield sites by addressing viability constraints through targeted funding and infrastructure investment. The following actions should be considered: update the Brownfield Register; a targeted call for brownfield sites; assessment of blockers to brownfield development and consideration of a remediation fund. There is risk of large swathes of our market towns being underused and vacant if this is not addressed. There is an opportunity to link this to an expansion of social housing directly focused on areas of need.

Section 4: Baseline information and spatial portrait

Sub heading 4.11 – 4.16: Heritage, culture and natural environment
The Cheshire and Warrington Local Nature Recovery Strategy should be cross referenced and included within the preparation of the Local Plan.

Sub heading 4.17 – 4.19: Settlements and rural-urban composition
The Local Plan should continue to recognise the importance of Cheshire East's rural communities. Strategic development should strengthen rather than undermine the character, identity and sustainability of villages and rural settlements. Development that fundamentally changes the nature of rural communities should only be considered where there is compelling evidence that all reasonable alternatives have been exhausted, and there is a genuine local area need.

Sub heading 4.20 Demographic mix
The Local Plan should recognise the need to allocate sites for housing to facilitate ‘downsizing’ for older residents, helping to free up activity in the housing market and thus making better use of existing housing stock.

Section 5: Scope of the new Local Plan
Sub heading 5.1 Local Plan Period
The plan period needs to run from 2025 (to overlap with existing Strategy) as CEC originally proposed and run to 2045, 15 years after likely adoption date.

Sub heading 5.8 – 5.14 Identifying and assessing sites
To ensure transparency, scoring and criteria referred to within 5.11 should be published before initial site assessments. CEC should demonstrate that its housing requirements cannot be met through suitable brownfield, previously developed and appropriately located green field sites before seeking releases of land which strongly or moderately contributes to the purposes of the Green Belt. Where Green Belt land is considered, the Council should assess its contribution to Green Belt purposes, environmental and landscape value, infrastructure capacity, sustainability and proximity to existing and proposed places of employment. Housing allocations should also reflect the geographical distribution of housing need, particularly for social and affordable housing. The Call for Sites has highlighted significant land in the Green Belt, specifically in Adlington Parish where land for 10,000 houses (based on Cheshire East dph of 30) has been proposed. Whilst we understand proposed sites are being reviewed against local need and national policies, there should be clarity on the land being considered for release as soon as possible.

Subheading 5.15 – 5.18 Green Belt
The Council's commitment to preparing a comprehensive borough-wide Green Belt Assessment is welcomed and should be completed and published at the earliest opportunity because planning applications for large-scale developments affecting Green Belt land are already being promoted. Without an adopted and publicly available Green Belt Assessment, there is a risk that decisions will be made in the absence of a consistent strategic framework, leading to piecemeal erosion of the Green Belt before the Local Plan has established the most appropriate strategy for growth. The Assessment should provide a transparent and objective evaluation of Green Belt land across the borough, including: the contribution each area makes to the five purposes of the Green Belt; the degree of openness and permanence that would be affected by development; the role of land in preventing the coalescence of towns and villages; the contribution made to landscape character, biodiversity, agriculture and the wider natural environment; cumulative impacts where multiple sites are promoted; and the long-term strategic consequences of releasing individual parcels of Green Belt. The findings of this Assessment should be published before strategic Green Belt allocations are progressed. Strategic Green Belt decisions should be informed by borough-wide assessment rather than by site-specific evidence submitted in support of individual planning applications. This will ensure that decisions are consistent, transparent and in the wider public interest. CEC should also resist the incremental erosion of the Green Belt through speculative planning applications that could undermine the comprehensive plan-led approach. Given the inability to demonstrate a 5-year housing land supply CEC should prepare an Interim Housing Policy Statement. Once Green Belt land has been developed and openness lost, those strategic functions cannot realistically be restored. Consideration should also be given to the effect of areas immediately outside but neighbouring Cheshire East. This is of particular significance in the North-East of the borough where proposals have been allocated and planning permissions granted within Stockport MBC area, allowing urban sprawl. If considered in isolation, the Local Plan risks adding to urbanisation by default, placing pressure on the surrounding infrastructure including the highway network. Within 3.14 of the consultation document reference is made to “Green Belt development around well-connected railway stations”. The NPPF definition should be made explicit within the Local Plan Scoping document to avoid misunderstanding and speculative development around inappropriate stations. Not all stations meet the NPPF definition of a well-connected station. NPPF Annex B Glossary: “well-connected station”: railway stations, underground, tram and light rail stops located within a top 80 travel to work area, located partially or fully within England by Gross Value Added (GVA)72 and which, in the normal weekday timetable, are served (or have a reasonable prospect of being served as a result of upgrades and/or agreement with the rail operator) throughout the daytime by at least four trains or trams per hour overall, or at least two trains or trams per hour in any one direction.

Sub heading 5.24 – 5.26 Spatial distribution
Development should be dispersed. CEC should not rely on a few large new settlements to meet its housing requirement. Housing growth should be distributed across the Borough in locations reflecting identified housing and employment needs, make effective use of brownfield and previously developed land, utilise existing infrastructure, and support the regeneration of established communities.

A dispersed approach to development can help deliver housing more quickly while supporting existing communities and leveraging existing infrastructure. Such development is likely to be more cost effective and socially beneficial than single point large developments in poorly connected greenfield locations. It can: accelerate housing delivery by using sites with infrastructure and services; place social and affordable housing closer to areas of identified need and employment; minimise the need for relocation of population to new locations with resultant social dislocation; support regeneration of existing towns rather than directing investment away from established communities; make better use of existing infrastructure; support earlier economic and community regeneration; and distribute development risk, reducing the overall cost and deliverability risk to the borough-wide plan. The Local Plan should prioritise housing where it is needed, where infrastructure can support it, and where social and affordable homes can be delivered quickly and the demand is present, with development distributed across Cheshire East to support sustainable growth and regeneration.

Sub heading 5.29 Development in countryside & sub heading 5.30 – 5.32 Housing
CEC should take a balanced, county-wide approach to housing delivery, ensuring development reflects local housing need, employment and infrastructure rather than concentrating growth disproportionately in particular areas. CEC housing requirement should be assessed against existing commitments, brownfield opportunities and sites identified through the call for sites. Housing growth should broadly reflect the geography of housing need and employment, helping to reduce commuting and pressure on already constrained transport networks. Development should be directed towards locations where transport, schools, healthcare, utilities and community facilities already exist, or can be expanded alongside growth. This is likely to be more sustainable and deliverable than relying on locations requiring major new infrastructure.

Sub heading 5.33 – 5.35: Affordable Housing
Social and affordable housing should be delivered where the need is greatest and as quickly as possible. Approximately 60% of Cheshire East’s social housing need is in the south, particularly around Crewe, with around 40% in the north. Housing allocations should reflect this distribution of need. CEC should prioritise sites capable of delivering social housing in the short term, rather than relying on schemes where delivery may be delayed by the need for major supporting infrastructure. Dispersing social and affordable housing across existing communities can provide better access to employment, services and transport, while making better use of existing infrastructure.

Sub heading 5.49 Housing diversification and providing for small and medium sized sites
It is important to provide a proportion of smaller sites attractive to local SME building companies.

Sub heading 5.84 – 5.90 Waste
The plan should be set out to ensure that there are sufficient accessible Refuse Sites for any new development. Locally, the closure of three sites around the Poynton/Bollington Towns means that these basic public services are not provided in these locations. Travelling to the south side of Macclesfield is not sustainable, and contrary to the current government focus on eliminating illegal dumping of waste.

Sub heading 5.91 - 5.95: Transport and infrastructure
Infrastructure must come first. The Local Plan should require infrastructure-led development rather than development-led infrastructure and needs to consider the existing shortfalls in support services. Roads, rail capacity, public transport, utilities and active travel infrastructure should be fully funded and delivered in advance of significant housing occupation. Without this approach, there is a substantial risk that large developments become heavily car dependent and place unacceptable pressure on existing infrastructure as well as being skewed towards those that can afford to drive and own a car. This principle is particularly relevant where current road and rail networks already experience congestion and capacity constraints such as rural stations with infrequent services.

Healthcare Provision
The Local Plan should require clear evidence that healthcare infrastructure can accommodate proposed growth. Where developments are of sufficient scale to require new GP surgeries, community health facilities or increased hospital capacity, these should form part of the development strategy from the outset rather than being considered after housing has been occupied.

Subheading 5.96 – 5.103 Natural environment
Resisting Green Belt land release in the open countryside will help protect valuable habitats and ensure nature corridors remain open. Biodiversity reports should be commissioned for any land considered and the findings assessed before land is considered for release.

Subheading 5.113 Climate Change
Cheshire East’s agricultural land contributes to domestic food production and long-term national food security. Its favourable agricultural conditions, including relatively high rainfall, make protecting productive farmland an important planning consideration. Agricultural land should therefore be protected from unnecessary development to safeguard future food production

Subheading 5.142 Local plan evidence base
The scoping document states that “The government requires us to make use of any standardised tools, methods and templates that it publishes to assist in evidence preparation. However, only a very basic template for site assessment and selection has been published to date.” A methodology for this needs to be set out and should be in line with guidance provided by the Ministry of Housing, Communities and Local Government and Local Government Association’s Planning Advisory Service.

Section 6: Proposed Local Plan Engagement Strategy Subheading 6.1 – 6.2
The Local Plan process may not involve sufficiently meaningful and widespread community engagement. As noted, the timing for this initial scoping consultation was unfortunate, as was the lack of any prior engagement with local councils. Successful strategic planning depends upon early, meaningful and ongoing engagement with local communities. Major developments should involve elected representatives, town and parish councils, residents and community organisations from the earliest stages of plan preparation.