Full text:
This responds to the scoping consultation on the scope, evidence base and spatial strategy of the new Local Plan. Section 1 is the central point. The rest is the methodology needed to give effect to it, with land at Ashley as the worked example. No site decision is sought here.
We live in Hale and walk and cycle in Ashley parish regularly. It is the nearest open countryside to our home.
1. Assess the northern Green Belt as one block, before the sites within it
Establish the separations which have to be kept, between the conurbation and Cheshire and between Knutsford, Mobberley, Ashley and the settlements along the M56 corridor. Establish the width below which each stops working, and hold to it. Apply the strategic green gap approach at paragraph 5.19 here, and map those gaps in policy.
Rationale: the submissions map shows promotions across the whole block. Ten live sites at Ashley. Along the M56, Yarwood Heath, Spodegreen Lane, Tatton Services at junctions 7 and 8, Bucklow Hill, Broomedge, Rostherne and High Legh. A very large area west of Knutsford around Tabley. Dense clusters at Mobberley, north and east of Knutsford, and at Ollerton, Marthall, Snelson and Peover Heath. Some lie north of the M56, so the motorway does not contain the pressure. Each will be assessed separately, at different times, and none of those assessments asks what remains once a proportion of them succeed. A gap can be lost without any single decision ever having decided to lose it.
Ashley matters most here because it sits at the narrowest part of the gap. It is also the point at which the erosion becomes irreversible, because a settlement of the scale promoted there would leave little worth protecting on either side of it.
The borough has to grow and Knutsford as a Key Service Centre is a reasonable place for growth. Growth at each place may well be defensible on its own. The combination is a separate question, which the methodology at paragraphs 5.8 to 5.14 leaves untested.
Access to open countryside belongs in that assessment. For Hale, Hale Barns and Altrincham the Ashley Green Belt is the nearest open land, and on our own reckoning development on the scale promoted would roughly double the walk from our home to reach it. That is the everyday value of the gap and it engages the active travel and wellbeing objectives at paragraphs 5.104 to 5.117.
2. Test grey belt claims independently
Assess grey belt status site by site against the NPPF definition and each Green Belt purpose. State expressly that promoter analysis will be tested before any of it becomes the Council's own finding. Publish the methodology of the borough-wide Green Belt assessment at paragraph 5.18 for comment before its conclusions are relied on.
Rationale: the Ashley promoter has told the Council that its own analysis "shows that the above parcels represent 'grey belt' land such that they should be prioritised for release ahead of other Green Belt locations". That is an interested party's assertion, and the assessment now under way is the document which will decide the question across the borough. Aerial imagery of the promoted land, at Ashley and at the very large block west of Knutsford alike, shows continuous working farmland with intact field boundaries, hedgerows and woodland, and no previously developed land beyond scattered farmsteads. The Knutsford block is several kilometres across and is greenfield throughout. Grey belt turns on previously developed land or land making a limited contribution to Green Belt purposes. The land as it exists answers that on its face.
3. Evidence the alternatives before any Green Belt release
Publish the capacity yielded by brownfield and underused land, by optimised densities in existing settlements and by sites outside the Green Belt, before any Green Belt release is tested. Paragraph 5.17 commits the plan to each of those steps in turn.
Rationale: the question is whether this land has to be released when brownfield, density and non-Green Belt sources have not been shown to be exhausted. That evidence should exist before the Green Belt assessment reports, so the two can be read together.
4. Assess land in common ownership cumulatively
Where one landowner promotes adjoining parcels, assess the combined release as a single strategic proposition alongside each parcel. That combined assessment should cover openness, the separation between the Greater Manchester and Cheshire settlement patterns, the integrity of the remaining Green Belt and the infrastructure the whole would require. Record common ownership and apply it consistently to deliverability and to cumulative effect. Establish whether promoted land carries conservation or heritage management undertakings given in exchange for public benefit.
Rationale: eight adjoining parcels at Ashley are promoted together for around 1,100 dwellings, a school and a shop. One at a time each looks modest. Together they are a settlement extension. Single ownership can support coordinated delivery and comprehensive infrastructure, and the promoter relies on it as evidence of coherent stewardship. It also means the parcels are one commercial proposition, so the same fact should carry weight when cumulative effect is assessed.
5. Publish the true extent of what is promoted
Publish each site, its area, the promoter and, where boundaries sit inside one another, the net area under assessment. Aggregating nested boundaries would overstate the land promoted. Assessing only the smallest of them would understate it. Publish the material submitted in support. Where a promoter states a dwelling capacity, verify the developable area behind it.
Rationale: the map shows twelve sites at Ashley. Two north of the M56 are withdrawn. Ten are live, all mixed-use development and regeneration. Eight match the parcels in the letter of 31 March 2026, totalling 40.50 hectares on that letter's own figures. The other two, the Ashley Garden Village SW and SE quadrants, are much larger and appear to envelope the eight, mirroring the letter's wider tier of a further 2,000 dwellings. The promoter has publicly described the live proposal as approximately 1,070 homes. The map and that description do not agree. Separately, 1,100 dwellings on 40.50 hectares, before a school, a shop and green infrastructure, implies a density well above the existing settlement. The map gives boundaries and sizes, which is welcome. It identifies no promoter and carries no supporting documents, so residents can see where the sites are and cannot see what is argued about them.
6. Draw boundaries that will endure
Record land withdrawn from a call for sites, with the date and the stated reason, and carry that record into the Green Belt boundary review. Where a proposed boundary depends on an infrastructure scheme, record that scheme's consenting status and whether its alignment is fixed. Do not draw a Green Belt boundary to the alignment of an unconsented scheme.
Rationale: the promoter proposes the M56 to the north and the Northern Powerhouse Rail route to the south as the boundaries containing the settlement. NPR has £1.1 billion for planning and design and a programme funding cap, with delivery in the 2030s, no confirmed consenting route and no fixed alignment here. A boundary drawn to that alignment moves when the alignment moves, which is the opposite of the permanence the policy requires. The same letter records land north of the M56 with "the potential to expand the settlement to around 11,000 dwellings", confirmed as still available and withdrawn in August 2026. Boundaries should hold against its resubmission.
7. Publish what a settlement must offer before it takes strategic growth
Set out the tests a settlement must pass, covering services, employment, health and education capacity, committed public transport frequency, station and parking capacity and highway capacity. Paragraph 5.16 allows boundary change where development around stations is proposed, so publish criteria for that route based on the service a station actually provides.
Rationale: Ashley is a small village washed over by the Green Belt. Its station sits on the Mid-Cheshire line and NPR services would not call there, so that scheme brings a rail corridor through the promoted land without improving the village's own service. A station exception turning on the existence of a platform, without regard to the service calling at it, would open Green Belt release at every rural halt in the borough.
8. Transport evidence built on committed schemes
The transport evidence base should separate committed and funded schemes from aspirational ones. It should not attribute accessibility benefits to schemes that have no funded delivery route and it should take account of service reductions that are in prospect.
Rationale: the Ashley promotion relies on Northern Powerhouse Rail and on "potential tram/train links between Altrincham, Hale and Manchester Airport via Ashley". Current rail links here are appalling. Set against that, the realistic prospect at Ashley station is a reduction from an hourly to a two-hourly service if the funded Cheadle station proceeds, and it's that bad with only a 2-hourly service on Sundays now. An evidence base that credits the aspiration while passing over the potential reduction in services would not be sound.
9. Assess the capacity of the roads, bridges and station serving a site
Assess the physical capacity of the local network serving any candidate site, covering lane widths, railway and river bridge crossings, single-lane pinch points, junction capacity on the strategic network and station access and parking. Where capacity is exceeded, identify and cost the works required before a site is treated as deliverable.
Rationale: every approach to Ashley is a narrow rural lane. The village is reached across constrained bridges over the railway, the River Bollin and Birkin Brook, and traffic from development here would load onto the A538 and the M56 junctions, which are already congested at peak. Ashley station has very limited parking, so rail use by new residents would depend largely on walking and cycling from within the development itself. These are physical limits on what the location can absorb and they should be established before a site is scored. Treating them as resolvable later assumes the answer.
10. Establish constraints before shortlisting
Gather an up-to-date agricultural land classification survey, Manchester Airport public safety zones, noise contours and bird-strike safeguarding, heritage asset settings and ecological designations before the filter at paragraph 5.11 runs.
Rationale: at Ashley the available evidence indicates Grade 2 and Subgrade 3a Best and Most Versatile land, three Local Landscape Designations, Cotterill Clough SSSI and the settings of 19 Grade II listed buildings. Handling these as mitigation after selection comes too late to affect the outcome.