Local plan scoping consultation

I object to any presumption that additional employment land allocation is needed. The council's own monitoring, set out in this section, argues against it.

The document records that as at 31 March 2024 there remained a supply of 375 hectares of employment land, and that just over 112 hectares had been developed since 2010. That works out at roughly 8 hectares of take up per year against a remaining supply of 375. At the observed rate, that is around 45 years of supply. The same section records jobs growth of 1.3% a year against a target of 0.7%, which indicates that employment growth in this borough is not being held back by a shortage of land.

I ask that the Economic Development Needs Assessment and Employment Land Review does three things.

First, explain the gap between a large supply and low take up, and identify how much of the 375 hectares is genuinely available and deliverable rather than notionally allocated.

Second, consider de-allocating undeliverable employment sites and reassessing them for other uses, before any new greenfield or Green Belt employment land is contemplated.

Third, test the assumed relationship between employment growth and housing need. An inflated jobs growth assumption is the most common route by which a housing requirement gets pushed above the standard method minimum, and it usually happens without anyone noticing.

No release of Green Belt for employment, including in the Manchester Airport corridor, can be justified as exceptional while a supply on this scale sits undeveloped.

I ask that the vision, objectives and measurable outcomes include the following.

An infrastructure first objective, expressed measurably. Critical infrastructure serving new development should be delivered before, or at the same time as, the development it serves. A measurable outcome could be the proportion of dwellings completed on allocated sites where the identified critical infrastructure was in place at first occupation.

A public transport accessibility outcome. The proportion of new dwellings within a defined walk time of a service meeting a stated minimum frequency and operating span.

A Green Belt outcome. The total area of Green Belt released over the plan period, reported annually. Cumulative loss otherwise disappears into a series of individual decisions and never becomes visible in aggregate.

A brownfield outcome. The proportion of completions on previously developed land, so that the plan's stated sequential approach can be monitored rather than simply asserted.

An objective on maintaining the separate identity of settlements, given the borough's distinctive pattern of towns and villages and the pressure for coalescence in the north.

Measurement is the point here. Without measurable outcomes, an infrastructure first commitment in the vision is unenforceable, and it will not survive contact with delivery pressure once the plan is adopted.

I have several comments on the engagement strategy, most of them arising directly from taking part in this consultation.

First, and most importantly. Several of the most consequential technical documents in this plan are programmed to appear as completed outputs rather than as methodologies open to consultation. That includes the land availability assessment methodology, the Green Belt assessment and the settlement hierarchy review. I ask for a commitment that for each of these, the methodology is consulted on before it is applied. Consulting only on the results is not meaningful participation, because by that stage the framework that generated the results is settled and unchallengeable.

Second. This consultation is presented as a substantial online document requiring registration and login before anyone can comment. The council's own baseline data records that 22.5% of the borough's population is aged 65 or over, against 18.7% nationally. I ask that future stages provide a clearly signposted paper response route, actively publicised in affected communities rather than merely available to those who know to ask.

Third. Where a site is submitted through the call for sites process in or adjoining a settlement, the relevant parish council and nearby residents should be notified directly when the site enters assessment. Expecting communities to monitor an online register is not adequate notice.

Fourth. Consultation periods should not run across the main summer holiday period. This one has closed on 1 September. No future stage should close with less than eight weeks' notice.

Fifth. Please confirm how the new local plan will interact with made and emerging neighbourhood plans, and give an assurance that the council will not pre-empt a neighbourhood plan in preparation by allocating sites within its area before that plan has been made.

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.