Local plan scoping consultation

I object that this section contains no mechanism for ensuring infrastructure is delivered before, or at the same time as, the development it is supposed to serve.

The document rightly notes that national policy requires a vision led approach to transport. A vision led approach is a requirement, not an ambition. It means locating and phasing development so that sustainable travel genuinely exists, rather than being assumed into existence.

Here is the position in Mobberley, taken from current published timetables.

Bus route 88 runs 13 journeys from Mobberley towards Knutsford on a weekday, and 12 towards Wilmslow and Altrincham. The first departure towards Knutsford is 06:52 and the last is 19:52. The last bus towards Altrincham leaves at 19:08. There is a 90 minute gap in the morning between the 08:00 and the 09:30. There is no Sunday service. The route is financially supported by Cheshire East Council and Transport for Greater Manchester, which means it depends on subsidy rather than commercial demand.

The rail service is roughly hourly from an unstaffed station with no ticket machine, situated over a mile from the historic village core.

Secondary school journeys to Knutsford Academy and GP appointments at Annandale Medical Centre in Knutsford both require travel out of the village, and neither is realistically served by an hourly bus with no evening or Sunday provision. Any additional housing here would be car dependent, and would add vehicle trips to Knutsford, Wilmslow and the Manchester Airport corridor.

I ask that the new local plan includes the following.

A minimum public transport accessibility standard that any allocated site must meet, or be made to meet through committed and funded improvement. It should be expressed in service frequency and operating hours rather than distance to the nearest stop. A stop served 13 times a day, with nothing after 19:08 and nothing on Sundays, is not meaningful public transport access.

An enforceable infrastructure phasing policy, applying to all strategic allocations and to any site released from Green Belt, which ties the occupation of dwellings to the prior or concurrent delivery of identified infrastructure. That covers school places, primary care capacity, wastewater capacity, and highway and active travel improvements. It needs to work through phasing triggers in allocation policies, secured by condition or Section 106, so that it binds rather than encourages.

A deliverability test for the Infrastructure Delivery Plan. Every item of critical infrastructure should have a named delivery body, a secured funding source and a delivery date. Anything missing one of the three should be treated as undeliverable when assessing whether a site is deliverable.

A clear statement of how infrastructure will be funded under the reformed system, given the removal of the Community Infrastructure Levy, and what replaces it. Without that, the phasing policy above cannot actually be delivered.

Recognition that rural highway issues are about safety, not capacity. In villages like Mobberley the constraint is narrow lanes without footways and junctions carrying agricultural traffic. Modelling that measures junction capacity alone will not detect any of it.

I object to the statement that the new local plan is not expected to introduce local Green Belt policies simply because Green Belt policy is set nationally. National policy sets the tests for release. It says nothing about how this particular authority should identify grey belt, how it should sequence sites, or what it should require of development on land that has been released. Those judgements are local ones. Refusing to write them down does not remove them from the process; it just removes them from public view.

My main concern is the statement that Green Belt boundaries can be altered where development around stations is proposed, as an alternative to demonstrating exceptional circumstances. I live in Mobberley. That provision applies here, and I want to set out why applying it would be unsound.

Mobberley station is unstaffed. There is no ticket office and no ticket machine, so tickets have to be bought in advance or on board. Northern run an approximately hourly service on the Mid Cheshire line between Manchester and Chester. Office of Rail and Road figures record 22,512 passenger entries and exits in 2024/25, which works out at roughly 60 movements a day. The station also lies just over a mile north of the church and the historic core of the village, in open countryside.

Development "around the station" at Mobberley therefore means releasing Green Belt a mile from the village it is nominally attached to, detached from the primary school and the shops, served by a rural halt with one train an hour. Nobody would walk to any of it. The presence of a station is being treated as a proxy for sustainability, and at Mobberley that proxy simply does not hold.

There is a second point about function. Mobberley lies south west of Manchester Airport and forms part of the Green Belt that separates the airport and the Greater Manchester conurbation from open Cheshire countryside. Its role in checking sprawl and preventing coalescence with Wilmslow, Knutsford and the airport fringe is a strong one.

I ask that the new local plan does four things.

Publish the Green Belt assessment methodology for public consultation before it is applied. The borough-wide assessment is described as already underway. If the public only sees the outputs, the framework that produced those outputs will never have been tested by anyone outside the council.
Include a local policy defining what development around stations actually means in practice, setting a minimum service frequency, minimum operating hours, and a maximum walking distance between station and settlement. Without that, any village with a rural halt is exposed on a technicality.
Assess the cumulative effect of releasing adjoining parcels. Several individually modest releases can dismantle a whole section of Green Belt while each step looks defensible on its own.
Publish the sequential evidence, showing that brownfield capacity, densification and non-Green-Belt land have genuinely been exhausted, before any Green Belt parcel is carried forward as a draft allocation. Doing it afterwards turns the sequential test into justification for a decision already taken.

One final observation. Affordability is often used to argue for Green Belt release. This document records affordable housing delivery averaging 477 homes a year against a requirement of 455. The plan should not assume Green Belt release is necessary for affordable housing without evidence specific to that claim.

I object to the proposed evidence base. It is not proportionate to the scale of growth this plan will provide for, and as drafted it will not allow the plan to be found justified or effective.

The list of new evidence includes highways network modelling. There is no equivalent assessment of the social and utility infrastructure that the same growth depends on. No education or school place planning study appears. Neither does a health infrastructure capacity assessment, a water supply and wastewater treatment capacity study, an electricity network capacity assessment, a public transport accessibility study, or a landscape character assessment.

This plan will make provision for a minimum of 37,950 dwellings. It cannot sensibly be described as proportionately evidenced when road capacity alone is modelled and the capacity of every school, surgery and treatment works that has to absorb those dwellings goes unexamined.

The Infrastructure Delivery Plan is not an answer to this. An IDP sets out what infrastructure is needed and who might pay for it. It does not establish whether what already exists has any spare capacity. It is also produced late, once the spatial strategy has been settled, by which point it can only price the consequences of decisions already made.

I ask that the following are added to the evidence programme.

A school place planning and education capacity study. This should cover current and forecast surplus or deficit by planning area, the physical ability of each school site to expand, whether expansion land exists and is in the right ownership, and realistic travel to school distances and modes where local capacity has run out.

A health infrastructure capacity assessment, prepared with NHS Cheshire and Merseyside, covering GP list sizes against premises capacity, dentistry, and hospital accessibility by public transport from rural settlements.

A water supply and wastewater treatment capacity study, prepared with United Utilities, identifying headroom at each treatment works and any consented discharge limits that constrain growth.

An electricity network capacity assessment, prepared with the Distribution Network Operator.

A public transport accessibility study, assessing real service frequency, evening and weekend provision, and journey times to employment, secondary education and hospital sites.

A landscape character assessment. This is needed to assess countryside and Green Belt sites properly and does not currently appear anywhere in the programme.

Each of these should be published before or alongside the spatial distribution of development report. If they come afterwards, infrastructure capacity will be costed rather than considered.

I object to the proposed approach to the settlement hierarchy review. The criteria measure whether services are present rather than whether they have any spare capacity, and the result will be to direct growth towards settlements least able to take it.

As drafted, the review looks at provision of services and facilities, population, jobs, sustainable transport, retail provision and settlement form. On that basis a village whose primary school is nearly full, whose rail service is hourly, and which has no secondary school of its own would score the same as a village where all of those have real headroom. The hierarchy would then be cited to justify allocating growth to the first village.

Mobberley shows the problem clearly. It is currently a Local Service Centre, which on paper makes it a settlement capable of taking growth. In practice:

There is no secondary school. Secondary age children travel to Knutsford Academy, roughly four miles away in a different town. Knutsford Academy has around 1,430 pupils and is oversubscribed, receiving more first preference applications than it has places. Any scoring that credits Mobberley with secondary provision is counting a full school in another settlement, reached almost entirely by car or dedicated bus.

There is no GP surgery. Residents are registered with the Knutsford Medical Partnership at Annandale Medical Centre in Knutsford. Again, this is provision located somewhere else.

The primary school has very little room. Mobberley CofE Primary has a capacity of 210 places and 191 pupils on roll in the most recent published figures. It was expanded from 140 places in 2013 for the express purpose of becoming a one form of entry school. That leaves roughly 19 spare places spread across seven year groups, which is under three per year. It is not a school with capacity to absorb a new estate.

The rail service is a halt, not a hub. The station is unstaffed, has no ticket machine, records around 60 passenger movements a day, and sits over a mile from the historic village core. Scoring it the same as a station with a frequent service, staff and a walkable catchment would be misleading.

The bus service is thin and subsidised. Route 88 provides 13 journeys towards Knutsford on a weekday and 12 towards Wilmslow and Altrincham. The last departure towards Altrincham is at 19:08. There is a 90 minute gap between the 08:00 and 09:30 departures. There is no Sunday service at all. The route is financially supported by Cheshire East Council and Transport for Greater Manchester, so its continuation depends on subsidy decisions rather than commercial viability.

There is no village centre. Mobberley is dispersed and linear, spread over a wide area. Any settlement form scoring needs to reflect that there is no coherent core within which development could be well related to services.

I therefore ask that the settlement hierarchy methodology:

Scores services on spare capacity rather than existence. A school that is 91% full is not a service capable of supporting growth.
Distinguishes between services located within a settlement and services its residents must travel to another settlement to use. Counting Knutsford Academy and the Knutsford Medical Partnership as Mobberley's provision inflates Mobberley's score and hides how car dependent living here actually is.
Scores public transport on frequency, operating hours, weekend provision, and walking distance from the stop or station to the settlement served. Whether a settlement has a station at all is the wrong question.
Treats subsidised services differently from commercial ones, since a service dependent on council and TfGM funding cannot be relied on for the whole plan period.
Is published for consultation before it is applied, at the plan content and evidence stage. Classifying settlements is among the most consequential decisions in this plan, and the criteria should be tested before anyone knows what results they produce.

On the evidence above I object to Mobberley being retained as a Local Service Centre, and I object strongly to any promotion within the hierarchy. The classification is not supported by the services actually available in the village.

I object to the approach proposed here. Of everything in this consultation, it is the provision most likely to produce cumulatively significant development in villages, and the council's own arithmetic suggests it may not be deliverable as drafted.

The document sets out that meeting the draft national requirement would need roughly 3,795 dwellings on sites of one hectare or less, which is around 125 separate allocations. A further 3,795 dwellings would be needed on sites between one and 2.5 hectares, potentially another 125. That is up to 250 individual allocations across the borough. The council concedes this is likely to be challenging.

My first objection is practical. A target on that scale will inevitably be met by allocating small sites in villages, because that is where sites of that size exist in any number. Each individual allocation will appear modest. Each will sit below the threshold at which meaningful infrastructure contributions are triggered. The cumulative effect on a single village of successive small allocations is anything but modest, and nothing in the proposed scope of the plan captures it.

I therefore ask that the land availability assessment methodology records, for each settlement, the total quantum of small and medium site allocation proposed, and assesses the combined effect on school places, primary care capacity, wastewater capacity and highway safety. Cumulative impact assessment at settlement level should be a required output, not an optional one.

My second objection concerns the exception. Draft national policy allows departure from these targets where there are strong reasons why they cannot be achieved, and the council's own analysis suggests such reasons may exist here. I ask that the council evidences that position and relies on it where justified, rather than hitting an arithmetic target by allocating sites in places that fail on infrastructure and accessibility grounds.

I also want to address the reference to sites that enable villages to grow and thrive, especially where this supports local services. That should not be applied as a presumption. In Mobberley the constraint on local services is not a shortage of residents. The village has no secondary school. Its residents use Knutsford Academy, which is oversubscribed, and the Knutsford Medical Partnership principally at Annandale Medical Centre. Building more houses in Mobberley would not sustain local services, because the services in question are not in Mobberley. It would add pressure to facilities in a neighbouring town that already serve several communities.

The village primary school illustrates the same point from the other direction. Mobberley CofE Primary has 210 places and 191 pupils on roll. It was enlarged from 140 places in 2013 in order to become one form of entry. Around 19 places remain across the whole school. A few small allocations would exhaust that entirely.

I object to infrastructure capacity appearing as merely one item on a list of factors that "may" influence where development goes.

Capacity is not a preference to be balanced against market attractiveness and viability. If a wastewater treatment works has no headroom, or a school has no land to expand onto, that places a hard limit on how much development a settlement can take. It does not matter how attractive the location is to housebuilders. Listing capacity alongside a dozen other considerations makes it easy to trade away against deliverability, which is exactly what tends to happen.

I ask that the spatial distribution of development report:

Establishes an infrastructure capacity ceiling for each settlement before distributing growth, and treats that ceiling as a constraint rather than one input into a weighing exercise.
States, for every distribution option tested, what infrastructure would be required, whether it is deliverable within the plan period, and by whom.
Tests a reasonable alternative that concentrates growth in the principal towns and key service centres where infrastructure and genuine public transport already exist or could realistically be provided, and reports how that performs against dispersal and Green Belt release options.

On the larger options, I would support serious testing of a new settlement in preference to incremental village expansion. A new settlement can be planned with its own school, health provision, employment and public transport built in from the start, and funded at a scale that makes that possible. Spreading the same number of dwellings across dozens of villages in the north of the borough achieves none of that. It generates considerably more car travel and pushes the cost onto communities that get no corresponding infrastructure in return.

I support the recognition in this chapter that access to services and infrastructure is a key determinant of health. My objection is that nothing in the proposed scope carries it through into evidence or policy.

The document records that life expectancy in Cheshire East varies by more than 12 years between communities, and it acknowledges the importance of access to healthcare. Yet the evidence programme contains no health infrastructure capacity assessment, and no mechanism is proposed by which primary care capacity would shape or constrain where growth goes.

Mobberley residents are registered with the Knutsford Medical Partnership, based primarily at Annandale Medical Centre in Knutsford, around four miles away. Every additional dwelling in Mobberley adds registrations to a list serving several communities, at premises in a different settlement. Reaching those premises by public transport means an hourly subsidised bus with no Sunday service, so in practice the journey is made by car.

I ask for the following.

A health infrastructure capacity assessment added to the evidence base, prepared with NHS Cheshire and Merseyside, covering GP list sizes against premises capacity, dentistry, and hospital accessibility by public transport from rural settlements. Journey time to hospital by public transport is a health equity question as much as a transport one.
A policy requiring Health Impact Assessment for major development above a defined threshold, with identified capacity shortfalls addressed through proportionate contributions.
That this evidence is prepared early enough to inform the settlement hierarchy and spatial distribution work. If it comes afterwards it will describe the consequences rather than influence the decision.

I object that this chapter, and the evidence supporting it, leaves out education altogether.

The evidence listed here consists of an Indoor Built Facilities Study, a Playing Pitch Strategy update, the Infrastructure Delivery Plan and Open Space Assessments. Schools appear nowhere, not in this chapter and not anywhere in the list of evidence the council intends to commission. The only mention of schools concerns flexible use of existing buildings, which is about reusing premises rather than providing places.

School place capacity is the most immediate infrastructure consequence of housing growth for most communities. Leaving it out of the scope entirely is a material omission.

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Mobberley CofE Primary has a capacity of 210 places and 191 pupils on roll in the most recent published figures. It was enlarged from 140 places in 2013 for the express purpose of becoming a one form of entry school. That means roughly 19 spare places spread across seven year groups, under three per year on average. The school occupies a constrained village site on Church Lane. Whether it could physically expand again, and whether land is available to do so, is not something the plan currently proposes to investigate.

Knutsford Academy has around 1,430 pupils and is oversubscribed, receiving more first preference applications than it has places. Mobberley children travel roughly four miles to reach it.

The consequence of exhausting village primary capacity is not abstract. It is either a longer car journey to a school somewhere else, or the loss of the ability to walk to school at all. Both cut directly across the plan's own active travel and health objectives.

I therefore ask that a school place planning and education capacity study is added to the evidence base. It should cover current and forecast surplus or deficit by planning area, the physical ability of each school site to expand, whether expansion land exists and is in the right ownership, realistic travel to school distances and modes where capacity is exhausted, and the lead time and funding route for any expansion required.

Separately, I ask for a policy protecting village halls, public houses, shops and places of worship in settlements where they are the sole remaining facility of their type, with a demonstrable marketing and viability test before any change of use is permitted.

I object to the suggestion that the new local plan might rely wholly on national decision making policies for development outside settlements.

National decision making policies are generic by design. They cannot address the specific landscape character and settlement pattern of north Cheshire, and in particular the narrow and shrinking separation between Mobberley, Knutsford, Wilmslow, Ashley and the Manchester Airport fringe. That separation is what gives this part of the borough its structure. Once it goes it does not come back.

I ask that the plan retains local countryside policies covering the following.

Landscape character, informed by an up to date Landscape Character Assessment. This does not appear in the proposed evidence programme and should be added.

Physical and visual separation between settlements, including within areas currently covered by Green Belt. Green Belt release would strip that protection at precisely the points where separation is already narrowest.

Village boundaries and infill boundaries, with any proposed change consulted on individually and reasoned, rather than presented as the output of a scoring exercise.

Cumulative effects. National policy assesses countryside development application by application, which means it never sees the aggregate. Mobberley is a dispersed settlement where incremental infill has a disproportionate effect on the open character of the parish.

The council should also confirm whether it intends to designate Local Green Spaces. This is mentioned in passing in the health chapter but is not otherwise programmed. If designations are intended, the process and timetable for parish councils and communities to nominate sites should be published now, because the opportunity disappears once the plan is submitted.

I object to the absence of any statement about whether the standard method figure of 2,530 dwellings a year will be treated as a minimum to be met or as a target to be exceeded.

The plan should say clearly that it will provide for the standard method requirement and will not plan for growth above it, whether through an economic uplift, an aspirational growth scenario, or unmet need arising from a neighbouring authority, unless each increment is separately evidenced, separately consulted on, and separately tested for its infrastructure and Green Belt consequences.

This matters for a straightforward reason. Every dwelling above the minimum increases the pressure for Green Belt release, and uplifts of this kind are typically introduced late in plan preparation with very little scrutiny.

The point has particular force here. Cheshire East's Green Belt in the north of the borough adjoins Greater Manchester. This authority should not absorb unmet need from adjoining authorities into its own Green Belt as a matter of course. If that is proposed, it should be a distinct, transparent decision, consulted on in its own right.

I also ask that the Housing Needs Assessment reports at a geography finer than the whole borough. Cheshire East covers 1,166 square kilometres and ranges from Crewe to deeply rural parishes. A borough wide need figure says nothing whatever about whether housing proposed in Mobberley meets a need arising in Mobberley.