Local plan scoping consultation

Comment

Representation ID: 6172

Received: 01/09/2026

Respondent: Avison Young

Paragraph 3.5 states that “Cheshire East’s housing need has now increased to 2,530 homes per year”.
This text goes on to acknowledge that this represents a 41% increase compared to the current
Local Plan housing requirements.

The Councils most recent Housing Monitoring Update (base date 31st March 2025), published in
April 2026, reports a 3.3 year supply of housing. It is therefore clear that Cheshire East Council are
going to need to identify additional suitable, available and deliverable housing sites across the
Borough as part of the emerging Local Plan, in order to boost their supply and demonstrate a
robust five year supply of housing. This will require the identification of a broad range of sites
including small and medium sites, alongside larger strategic sites, to ensure that a suitable mix of
house types, sizes and tenures are provided to meet identified housing need and deliver an
appropriate level of affordable housing to help create balanced and sustainable communities.
Elderloch support this approach to meeting the Borough’s housing needs and ensuring that the
emerging Local Plan is positive, appropriate, effective and consistent with national policy, which
are the four fundamental requirements of a ‘sound’ Development Plan, in accordance with
National Planning Policy Framework (NPPF) Policy PM15.
Cheshire East Council will be aware that an overreliance on large strategic sites can present
significant challenges for maintaining a consistent supply of deliverable housing sites. This has
been recently demonstrated with Strategic Site allocation LPS33: North Cheshire Growth Village,
Handforth East, which was allocated in the adopted 2017 Local Plan Strategy to deliver 1,500
homes during the plan period until 2030. However, there have been significant delays, owed to
coordinating complicated planning applications, securing funding and delivering necessary
infrastructure, and development on site has only commenced this year which is significantly
slower than originally projected.
In the context of the prolonged delays to delivery at strategic sites, together with the significant
increases in the housing targets, it is clear that Cheshire East Council is going to have to positively
plan for growth and identify a range of additional sites to accommodate future development
needs. A balanced strategy that incorporates both larger strategic sites and appropriately scaled,
deliverable edge-of-settlement Green Belt sites, like Deandale Equestrian Centre, which is a highly
sustainable and logical option for Green Belt release, will provide greater flexibility, resilience and
certainty in meeting future housing needs.

Comment

Representation ID: 6173

Received: 01/09/2026

Respondent: Avison Young

Paragraph 5.5 – 5.7 of the Local Plan Scoping document acknowledge that sufficient land needs to
be identified, including identifying future housing land informed by evidence on housing need.
Elderloch support the planning for growth approach to help significantly boost economic
opportunities and diversify housing provision.

Comment

Representation ID: 6174

Received: 01/09/2026

Respondent: Avison Young

Paragraph 5.11 briefly outlines the methodology for identifying future development sites; the
approach for which is generally welcomed. Clearly this exercise will need to be transparent and
evidence led. As part of the land availability assessment methodology, Elderloch believe the
following criteria should be included:
• Whether the site is sustainably located;

• Potential site constraints;
• The relationship to the existing settlement boundaries;
• Whether the land is considered previously developed; and
• Any conclusions from the latest borough wide Green Belt assessment which must be
completed in accordance with the latest national policy guidance.
• The availability of the site and realistic prospects/ timescales for delivery;
• The current surrounding development context, including whether identified constraints
can reasonably be addressed through scheme design and mitigation.
Elderloch reserves the right to comment further on the site selection methodology at the next
stage of the Local Plan consultation.

Comment

Representation ID: 6175

Received: 01/09/2026

Respondent: Avison Young

In terms of reviewing the Green Belt boundaries, Elderloch agree that as set out in paragraph 5.16
and in accordance with national policy, amendments should only be sought in exceptional
circumstances. Given the significant increase in housing need and the Council’s current housing
land supply position, it is clear the Council will need to robustly test whether its development
needs can be met without altering Green Belt boundaries. Where those needs cannot be met
without the release of Green Belt land, exceptional circumstances would exist to justify Green Belt
boundary changes in accordance with national policy.
While the Council should continue to prioritise urban and brownfield sites in line with national
policy, the limited development capacity within the Borough’s existing settlements and urban
areas means that additional land will be required to meet future housing demand. As a result, the
release of carefully selected Green Belt sites in sustainable locations should be considered as part
of the Local Plan process to avoid a significant undersupply of housing land, as no better
alternative sites exist.
Smaller Green Belt sites on the edge of settlements, such as Deandale Equestrian Centre, can
provide a particularly effective solution. Small to medium sized sites are more often than not less
reliant on major infrastructure investment and therefore can be delivered more quickly, thus
making an important contribution to maintaining the Borough’s five year housing land supply. As
such, the allocation of small and medium size sites should form an important component of the
Council’s Local Plan spatial strategy, and should make up a significant proportion of the housing
land ultimately earmarked for future residential development under the emerging Plan.
To support this approach, the Council should undertake a comprehensive Green Belt review to
identify whether further Green Belt sites could be released without causing significant harm to the
purposes of the Green Belt. This would not only help to meet objectively assessed housing needs
but also allow the allocation of the most suitable and sustainable sites.
Elderloch therefore supports the Council’s approach to review and, where appropriate, amend
Green Belt boundaries to ensure the Local Plan can meet the Borough’s housing and development
requirements.

Moreover, in the context that Green Belt release is likely to be necessary, Elderloch supports the
policy direction at paragraph 5.17 which notes that densities will be optimised in the correct
locations. This is clearly consistent with national policy which seeks to ensure efficient use of land.
However, it is noted that this policy should also allow for sufficient flexibility to enable
developments to reflect the layout and character of surrounding areas.
Paragraph 5.18 notes that a borough wide Green Belt assessment will be undertaken to identify
grey belt land and inform future decisions on potential Green Belt release. Elderloch supports the
review, providing it is done at an appropriately granular scale where each site can be considered
thoroughly on its own merits, and in a manner that fully reflects the latest national policy guidance
in relation to Green Belt/ Grey Belt land.
For example, if the Green Belt Review only considers strategic scale development parcels
comprising large swathes of land under numerous different ownerships, this could contain a range
of sites which each contribute to the Green Belt purposes differently. The assessment should
therefore be capable of considering sites or sub-parcels on their own merits where appropriate,
including having regard to changes in settlement form and surrounding development since earlier
Green Belt studies were undertaken. This is particularly important where historic assessments
have considered broad strategic parcels which may contain individual areas that perform
differently against the individual purposes of the Green Belt.
The assessment should also properly identify previously developed land within the Green Belt and
ensure that historic strategic parcel conclusions are not treated as final, where the current site
specific context has changed. This will ensure the evidence is sufficiently robust to inform any
subsequent decisions on Green Belt boundary changes and site selection.
As such, Elderloch maintain that the Green Belt assessment must be undertaken in a more
granular manner, so that the conclusions of the study are robust and directly inform any proposals
to alter the Green Belt boundaries to accommodate future development needs.

Comment

Representation ID: 6176

Received: 01/09/2026

Respondent: Avison Young

Paragraph 5.20 outlines the four tier settlement hierarchy and strategy for development, noting
Handforth as a ‘key service centre’. Elderloch support this identification for Handforth and agree
that growth should be directed to sustainable key service centres like Handforth as they provide
a range of key services and amenities to support future population growth.

Comment

Representation ID: 6177

Received: 01/09/2026

Respondent: Avison Young

Paragraphs 5.24–5.26 recognise that the new Local Plan will need to establish an appropriate
spatial distribution of development and that, given the scale of growth likely to be required, this
may include opportunities for sustainable edge-of-settlement growth. Elderloch supports this
approach.
The distribution of growth should be informed by a balanced assessment of sustainability, housing
need, accessibility to services and employment, infrastructure capacity, land availability, market
attractiveness and deliverability, rather than applying an overly rigid distribution based solely on
settlement size or historic patterns of growth.
In this context, sustainable Key Service Centres such as Handforth should continue to play an
appropriate role in accommodating future housing growth, including through suitable and
deliverable edge-of-settlement sites where necessary.

Comment

Representation ID: 6178

Received: 01/09/2026

Respondent: Avison Young

Paragraph 5.29 of the scoping document addresses the overall approach to development outside
of settlements. It is our position that no further policies are needed in this respect as national
policies are already prescriptive and as such, the Local Plan should avoid additional local policy
tests which are not consistent with national policies, and to avoid any duplication or cutting across
the NPPF.

Comment

Representation ID: 6179

Received: 01/09/2026

Respondent: Avison Young

Paragraph 5.35 of the Scoping document states that the new Local Plan “will need to establish
affordable housing requirements, including the overall number of homes to be provided and the tenure
mix, informed by evidence on housing needs and development viability”.
Elderloch fully supports the principle of improving affordability across Cheshire East and agree
that a Housing Needs Assessment will be required to inform the Local Plan, and ensure any future
policies in this regard are appropriate.
It is noted that there is currently no up to date evidence on affordable housing need in Cheshire
East, so undertaking this work will, in turn, enable the policy to be informed and assist with the
strategic policy direction. That being said, again, it will be important for any forthcoming policy to
allow for flexibility and site specific circumstance such as viability to be taken into account.

Comment

Representation ID: 6180

Received: 01/09/2026

Respondent: Avison Young

Finally, paragraph 6.52 acknowledges that further call for sites exercises will be undertaken
throughout the plan making process. Elderloch support this approach and welcome further
opportunities to engage with the emerging Local Plan. We would also advocate for, and request,
the opportunity for developers and landowners to be able to comment on the Council’s findings/
conclusions from its site assessment work, including a meaningful opportunity to review published
site assessments, correct any factual inaccuracies and provide updated evidence where necessary
before conclusions become embedded at later stages of the Local Plan.