Local plan scoping consultation

Please find below the response to the local plan scoping consultation from Summit Planning Associates on behalf of our client English Land Ltd. Please keep us updated regarding the progress of the local plan process and further subsequent stages to submit representation and comment.

1. Introduction
The preparation of the new Cheshire East Local Plan provides an important opportunity to establish a new spatial strategy that is fully aligned with the revised National Planning Policy Framework (NPPF). In particular, the publication of the revised NPPF (Aug 2026) represents a material change in the national approach to the Green Belt, Grey Belt, sustainable patterns of development, transport connectivity and the efficient use of land. It is therefore important that the new Cheshire East Local Plan is based upon a genuine new evidence base and methodology, rather than simply carrying forward conclusions reached through previous Green Belt and site-selection exercises undertaken under a materially different national policy framework. This representation focuses particularly on the methodology that should be used to identify and assess Green Belt and Grey Belt land and to determine which locations represent the most sustainable opportunities for accommodating the Borough's development needs.
2. A comprehensive review of Green Belt and Grey Belt land should form a fundamental part of plan preparation
The new Local Plan should undertake a comprehensive and transparent assessment of Green Belt land across Cheshire East, including the identification of land which meets the current NPPF definition of Grey Belt. The NPPF defines Grey Belt by reference to whether Green Belt land strongly contributes to Green Belt purposes (a), (b) or (d), subject to the relevant exclusions. The Council's assessment methodology should therefore explicitly distinguish between;
1. the contribution that land makes to Green Belt purposes generally; and
2. whether that land meets the specific national definition of Grey Belt.
Previous assessments should not be treated as determinative where they were undertaken using different national policy, different methodologies or different assumptions about settlement form and development needs. In particular, a conclusion that land makes a contribution to the Green Belt should not of itself be treated as sufficient to exclude it from consideration as Grey Belt. The new assessment should assess purposes (a), (b) and (d) separately and should provide sufficient transparency to establish whether land strongly contributes to any of the purposes which are relevant to the current Grey Belt definition. The assessment should also have regard to the Government's Green Belt guidance, which confirms that Green Belt assessment areas may appropriately be defined at a more localised scale, particularly around existing settlements and public transport hubs or corridors. This is important because the Green Belt function of land should be assessed having regard to its actual physical and spatial characteristics rather than simply by reference to broad parcels or historic designations.

3. The new Local Plan should distinguish between Green Belt land and land which performs a strong Green Belt function
The new Local Plan should avoid treating Green Belt designation as being synonymous with unsuitability for development. The purpose of the Green Belt assessment should be to identify the land which performs the strongest strategic Green Belt functions and, conversely, land which does not make a strong contribution to the relevant purposes. This is particularly important where land;
1. is physically contained by existing development or infrastructure;
2. is closely related to an existing settlement;
3. does not perform an important role in preventing neighbouring settlements from merging;
4. does not make a strong contribution to preserving the setting or special character of a historic town;
5. can accommodate development without fundamentally undermining the purposes of the remaining Green Belt; and
6. can provide a robust and permanent new Green Belt boundary following development.
The Council should therefore identify Grey Belt land as an integral part of its spatial strategy rather than simply treating it as a development management consideration.

4. Sustainable patterns of development should inform Green Belt boundary decisions
The new NPPF places greater emphasis on the relationship between Green Belt boundary decisions and the need to promote sustainable patterns of development. The Council's Green Belt methodology should therefore consider not simply whether development could physically be accommodated, but whether directing growth to a particular location would represent a sustainable spatial strategy. This should include consideration of:
1. proximity to existing settlements;
2. access to services, facilities and employment;
3. public transport connectivity;
4. opportunities for walking and cycling;
5. existing infrastructure;
6. the relationship with existing urban form;
7. the ability to create a permanent settlement edge; and
8. the potential for development to support sustainable travel patterns.
This approach is particularly important because the NPPF now requires sustainable development considerations to inform decisions about whether Green Belt boundaries should be altered and the assessment should consequently avoid a situation where highly accessible land is retained within the Green Belt solely because it has historically been designated as such, while less sustainable locations are required to accommodate growth.

5. Public transport connectivity should be a material consideration in identifying locations for growth
The new Local Plan should give significant weight to locations which benefit from established and effective public transport connections. The NPPF's strengthened approach to development around well-connected stations demonstrates the Government's intention that existing transport infrastructure should be used more effectively to support sustainable growth. The Council should therefore ensure that its spatial strategy and site assessment methodology properly recognise the benefits of locations which are capable of supporting modal shift and reducing reliance on the private car. Assessment should include;
1. proximity to rail stations;
2. frequency and destination of rail services;
3. bus accessibility and service frequency;
4. opportunities for walking and cycling; and
5. access to major employment centres
The assessment should also recognise that transport accessibility is not simply a matter of distance from a station. The quality, directness and safety of the connection, together with the range and frequency of services, are important considerations and where locations benefit from strong connectivity to established employment and service centres, this should be reflected positively in the spatial strategy, including opportunities on Green Belt land. Where a location is within an appropriate walking distance of a well-connected station and is otherwise suitable for development, the Council should ensure that its Green Belt and spatial strategy methodologies do not artificially prevent that opportunity from being considered. The Government's policy direction is clear that the planning system should make better use of existing transport infrastructure and direct growth towards locations which provide good access to jobs and services.

6. The assessment of Grey Belt should be integrated with the assessment of settlement form
The Council should ensure that its Green Belt and site assessment methodologies properly recognise the relationship between Green Belt land and existing settlements. Particular consideration should be given to land that;
1. adjoins an established settlement;
2. is physically well-related to the settlement;
3. can be integrated into the existing settlement pattern;
4. has access to established services and facilities;
5. benefits from public transport;
6. can establish a clearly defined and permanent settlement boundary; and
7. would not result in unacceptable coalescence.
Such locations may represent significantly more sustainable opportunities for growth than isolated development locations, even where the land is currently within the Green Belt. The assessment should therefore distinguish between development which represents an unsustainable incursion into open countryside and development which constitutes a logical and well-contained extension to an existing settlement.

7. The Council should establish a transparent and consistent site assessment methodology
A land availability and site assessment methodology will be critical in determining how the new spatial strategy operates in practice. The methodology should be transparent, reproducible and capable of comparing sites on a consistent basis. As a minimum, it should assess;
Strategic factors
• relationship to the settlement hierarchy;
• Green Belt/Grey Belt status;
• contribution to Green Belt purposes;
• relationship to neighbouring settlements;
• potential for settlement coalescence;
• ability to establish a permanent boundary.
Sustainability factors
• access to services;
• access to employment;
• public transport;
• walking and cycling;
• proximity to transport hubs;
• opportunities for modal shift.
Environmental factors
• landscape;
• ecology;
• biodiversity;
• flood risk;
• heritage;
• trees and woodland;
• water resources;
• green infrastructure.
Delivery factors
• access;
• infrastructure capacity;
• abnormal costs;
• ownership;
• availability;
• deliverability;
• development timescale.
The methodology should also ensure that no single characteristic, such as Green Belt designation automatically outweighs all other considerations.

8. Development capacity should be assessed by reference to the net developable area
The new Local Plan should establish a methodology for determining the optimum sustainable development capacity of potential sites. Historic dwelling capacities should not simply be carried forward where they were based upon different assumptions or methodologies. Equally, gross site area should not be used as the sole basis for calculating capacity. The methodology should identify factors such as;
1. gross site area;
2. land required for access;
3. flood risk areas;
4. ecological constraints;
5. landscape buffers;
6. retained trees and woodland;
7. green infrastructure;
8. public open space;
9. drainage and infrastructure requirements; and
10. the resulting net developable area.
Appropriate density should then be determined having regard to the site's location and accessibility. This is particularly important for sustainable locations where the NPPF supports the efficient use of land and appropriate density, including higher densities in locations that are well served by public transport. The approach should avoid artificially suppressing the development potential of sustainable locations through historic or arbitrary assumptions about site capacity.

9. Environmental constraints should be assessed proportionately
The new evidence base should distinguish between constraints which represent fundamental barriers to development and those which can be addressed through appropriate design and mitigation. The presence of landscape, ecology, flood risk, trees, woodland or watercourses should not automatically result in a site being excluded where development can be appropriately located and designed. The assessment should consider whether:
1. development can be located on the least constrained parts of a site;
2. sensitive areas can be retained;
3. landscape buffers can establish a permanent boundary;
4. biodiversity can be enhanced;
5. sustainable drainage can be incorporated;
6. green infrastructure can be delivered;
7. public access can be improved; and
8. development can contribute towards wider nature recovery.
This approach will enable the Local Plan to identify locations where development can deliver environmental enhancement alongside housing and infrastructure.

10. Green Belt release should follow a genuine comparative assessment of alternatives
Where the Council identifies a need to alter Green Belt boundaries, it should undertake a transparent comparative assessment of reasonable alternatives.
This should include:
• previously developed land;
• opportunities within existing urban areas;
• opportunities for intensification;
• edge-of-settlement opportunities;
• Grey Belt land;
• other Green Belt locations; and
• opportunities in neighbouring authorities.
The assessment should not, however, operate as a rigid hierarchy in which a site is rejected simply because some brownfield capacity exists elsewhere. The NPPF requires the Council to consider the most appropriate locations for sustainable development, and Green Belt boundary decisions should be informed by the consequences of different spatial strategies for sustainable development. That is a materially different exercise from simply seeking to minimise Green Belt release.

11. Grey Belt should be considered as a positive component of the spatial strategy and should be capable of delivering wider public benefits
The identification of Grey Belt land should not be regarded simply as a consequence of Green Belt review. Where land meets the national definition of Grey Belt and is appropriately located for development, it should be considered positively as part of the Council's spatial strategy. The Government's Green Belt guidance confirms that authorities undertaking Green Belt review should identify Grey Belt land to inform the review and prioritisation of Green Belt release. The Local Plan should therefore establish a clear methodology through which Grey Belt opportunities are identified, assessed and compared alongside other sources of land supply. This will provide greater certainty for landowners, communities, developers and infrastructure providers and will allow the Council to identify the locations capable of making the greatest contribution towards meeting development needs.
Where Grey Belt land is identified as appropriate for development, the Council should also consider the wider benefits that can be secured through the development process. These may include;
1. affordable housing;
2. accessible public open space;
3. biodiversity enhancement;
4. nature recovery;
5. green infrastructure; and
6. sustainable drainage
The assessment of potential locations should therefore recognise the opportunity for appropriately located development to deliver benefits which would not otherwise be secured. The NPPF's approach to development on Green Belt land released through plan-making provides an important framework for ensuring that such development delivers substantial public benefits.

12. Recommended scope of the evidence base
Having regard to the above, the evidence base supporting the new Local Plan should include;
1. a comprehensive borough-wide Green Belt and Grey Belt assessment;
2. a transparent and reproducible site assessment methodology;
3. an updated settlement hierarchy;
4. a detailed assessment of public transport and sustainable travel accessibility;
5. identification of well-connected stations and associated development opportunities;
6. an assessment of the optimum net development capacity of potential sites;
7. updated landscape and visual evidence;
8. updated ecological and biodiversity evidence;
9. strategic flood risk evidence;
10. infrastructure capacity and infrastructure investment requirements;
11. green infrastructure and nature recovery evidence; and
12. a transparent comparative assessment of reasonable spatial strategy alternatives.
The methodologies and scoring criteria should be published sufficiently early in the plan-making process to allow stakeholders to understand and scrutinise the basis upon which locations are being assessed.

Conclusion
The new Cheshire East Local Plan should embrace the significant change in national planning policy concerning Green Belt, Grey Belt and sustainable development. The Council should undertake a comprehensive and up-to-date review of Green Belt land, identify land which meets the current definition of Grey Belt, and ensure that the assessment is based upon current evidence rather than historic conclusions. Particular weight should be given to land which is;
• physically well-related to existing settlements;
• capable of establishing a permanent and defensible boundary;
• accessible to services and employment;
• well served by public transport;
• capable of supporting sustainable travel patterns;
• capable of making efficient use of existing infrastructure; and
• able to accommodate development without fundamentally undermining the purposes of the remaining Green Belt.
The specific provisions relating to development around well-connected stations should be fully reflected in the spatial strategy and Green Belt review. More generally, the Council should recognise that good public transport connectivity is an important characteristic of sustainable locations. The assessment of Green Belt land should not therefore be based upon a presumption that Green Belt designation equates to unsuitability for development. Instead, the new Local Plan should identify where the combination of Grey Belt status, sustainable location, public transport accessibility, settlement relationship, development capacity and the ability to establish a permanent Green Belt boundary means that development would represent a more sustainable and spatially coherent solution to meeting Cheshire East's future development needs. The objective should be to identify the locations which provide the best overall planning solution, rather than simply those which result in the least release of Green Belt land. This would provide a robust and transparent basis for the subsequent identification and assessment of individual sites as the Local Plan progresses.

Please find below the response to the local plan scoping consultation from Summit Planning Associates on behalf of our client English Land Ltd. Please keep us updated regarding the progress of the local plan process and further subsequent stages to submit representation and comment.

1. Introduction
The preparation of the new Cheshire East Local Plan provides an important opportunity to establish a new spatial strategy that is fully aligned with the revised National Planning Policy Framework (NPPF). In particular, the publication of the revised NPPF (Aug 2026) represents a material change in the national approach to the Green Belt, Grey Belt, sustainable patterns of development, transport connectivity and the efficient use of land. It is therefore important that the new Cheshire East Local Plan is based upon a genuine new evidence base and methodology, rather than simply carrying forward conclusions reached through previous Green Belt and site-selection exercises undertaken under a materially different national policy framework. This representation focuses particularly on the methodology that should be used to identify and assess Green Belt and Grey Belt land and to determine which locations represent the most sustainable opportunities for accommodating the Borough's development needs.
2. A comprehensive review of Green Belt and Grey Belt land should form a fundamental part of plan preparation
The new Local Plan should undertake a comprehensive and transparent assessment of Green Belt land across Cheshire East, including the identification of land which meets the current NPPF definition of Grey Belt. The NPPF defines Grey Belt by reference to whether Green Belt land strongly contributes to Green Belt purposes (a), (b) or (d), subject to the relevant exclusions. The Council's assessment methodology should therefore explicitly distinguish between;
1. the contribution that land makes to Green Belt purposes generally; and
2. whether that land meets the specific national definition of Grey Belt.
Previous assessments should not be treated as determinative where they were undertaken using different national policy, different methodologies or different assumptions about settlement form and development needs. In particular, a conclusion that land makes a contribution to the Green Belt should not of itself be treated as sufficient to exclude it from consideration as Grey Belt. The new assessment should assess purposes (a), (b) and (d) separately and should provide sufficient transparency to establish whether land strongly contributes to any of the purposes which are relevant to the current Grey Belt definition. The assessment should also have regard to the Government's Green Belt guidance, which confirms that Green Belt assessment areas may appropriately be defined at a more localised scale, particularly around existing settlements and public transport hubs or corridors. This is important because the Green Belt function of land should be assessed having regard to its actual physical and spatial characteristics rather than simply by reference to broad parcels or historic designations.

3. The new Local Plan should distinguish between Green Belt land and land which performs a strong Green Belt function
The new Local Plan should avoid treating Green Belt designation as being synonymous with unsuitability for development. The purpose of the Green Belt assessment should be to identify the land which performs the strongest strategic Green Belt functions and, conversely, land which does not make a strong contribution to the relevant purposes. This is particularly important where land;
1. is physically contained by existing development or infrastructure;
2. is closely related to an existing settlement;
3. does not perform an important role in preventing neighbouring settlements from merging;
4. does not make a strong contribution to preserving the setting or special character of a historic town;
5. can accommodate development without fundamentally undermining the purposes of the remaining Green Belt; and
6. can provide a robust and permanent new Green Belt boundary following development.
The Council should therefore identify Grey Belt land as an integral part of its spatial strategy rather than simply treating it as a development management consideration.

4. Sustainable patterns of development should inform Green Belt boundary decisions
The new NPPF places greater emphasis on the relationship between Green Belt boundary decisions and the need to promote sustainable patterns of development. The Council's Green Belt methodology should therefore consider not simply whether development could physically be accommodated, but whether directing growth to a particular location would represent a sustainable spatial strategy. This should include consideration of:
1. proximity to existing settlements;
2. access to services, facilities and employment;
3. public transport connectivity;
4. opportunities for walking and cycling;
5. existing infrastructure;
6. the relationship with existing urban form;
7. the ability to create a permanent settlement edge; and
8. the potential for development to support sustainable travel patterns.
This approach is particularly important because the NPPF now requires sustainable development considerations to inform decisions about whether Green Belt boundaries should be altered and the assessment should consequently avoid a situation where highly accessible land is retained within the Green Belt solely because it has historically been designated as such, while less sustainable locations are required to accommodate growth.

5. Public transport connectivity should be a material consideration in identifying locations for growth
The new Local Plan should give significant weight to locations which benefit from established and effective public transport connections. The NPPF's strengthened approach to development around well-connected stations demonstrates the Government's intention that existing transport infrastructure should be used more effectively to support sustainable growth. The Council should therefore ensure that its spatial strategy and site assessment methodology properly recognise the benefits of locations which are capable of supporting modal shift and reducing reliance on the private car. Assessment should include;
1. proximity to rail stations;
2. frequency and destination of rail services;
3. bus accessibility and service frequency;
4. opportunities for walking and cycling; and
5. access to major employment centres
The assessment should also recognise that transport accessibility is not simply a matter of distance from a station. The quality, directness and safety of the connection, together with the range and frequency of services, are important considerations and where locations benefit from strong connectivity to established employment and service centres, this should be reflected positively in the spatial strategy, including opportunities on Green Belt land. Where a location is within an appropriate walking distance of a well-connected station and is otherwise suitable for development, the Council should ensure that its Green Belt and spatial strategy methodologies do not artificially prevent that opportunity from being considered. The Government's policy direction is clear that the planning system should make better use of existing transport infrastructure and direct growth towards locations which provide good access to jobs and services.

6. The assessment of Grey Belt should be integrated with the assessment of settlement form
The Council should ensure that its Green Belt and site assessment methodologies properly recognise the relationship between Green Belt land and existing settlements. Particular consideration should be given to land that;
1. adjoins an established settlement;
2. is physically well-related to the settlement;
3. can be integrated into the existing settlement pattern;
4. has access to established services and facilities;
5. benefits from public transport;
6. can establish a clearly defined and permanent settlement boundary; and
7. would not result in unacceptable coalescence.
Such locations may represent significantly more sustainable opportunities for growth than isolated development locations, even where the land is currently within the Green Belt. The assessment should therefore distinguish between development which represents an unsustainable incursion into open countryside and development which constitutes a logical and well-contained extension to an existing settlement.

7. The Council should establish a transparent and consistent site assessment methodology
A land availability and site assessment methodology will be critical in determining how the new spatial strategy operates in practice. The methodology should be transparent, reproducible and capable of comparing sites on a consistent basis. As a minimum, it should assess;
Strategic factors
• relationship to the settlement hierarchy;
• Green Belt/Grey Belt status;
• contribution to Green Belt purposes;
• relationship to neighbouring settlements;
• potential for settlement coalescence;
• ability to establish a permanent boundary.
Sustainability factors
• access to services;
• access to employment;
• public transport;
• walking and cycling;
• proximity to transport hubs;
• opportunities for modal shift.
Environmental factors
• landscape;
• ecology;
• biodiversity;
• flood risk;
• heritage;
• trees and woodland;
• water resources;
• green infrastructure.
Delivery factors
• access;
• infrastructure capacity;
• abnormal costs;
• ownership;
• availability;
• deliverability;
• development timescale.
The methodology should also ensure that no single characteristic, such as Green Belt designation automatically outweighs all other considerations.

8. Development capacity should be assessed by reference to the net developable area
The new Local Plan should establish a methodology for determining the optimum sustainable development capacity of potential sites. Historic dwelling capacities should not simply be carried forward where they were based upon different assumptions or methodologies. Equally, gross site area should not be used as the sole basis for calculating capacity. The methodology should identify factors such as;
1. gross site area;
2. land required for access;
3. flood risk areas;
4. ecological constraints;
5. landscape buffers;
6. retained trees and woodland;
7. green infrastructure;
8. public open space;
9. drainage and infrastructure requirements; and
10. the resulting net developable area.
Appropriate density should then be determined having regard to the site's location and accessibility. This is particularly important for sustainable locations where the NPPF supports the efficient use of land and appropriate density, including higher densities in locations that are well served by public transport. The approach should avoid artificially suppressing the development potential of sustainable locations through historic or arbitrary assumptions about site capacity.

9. Environmental constraints should be assessed proportionately
The new evidence base should distinguish between constraints which represent fundamental barriers to development and those which can be addressed through appropriate design and mitigation. The presence of landscape, ecology, flood risk, trees, woodland or watercourses should not automatically result in a site being excluded where development can be appropriately located and designed. The assessment should consider whether:
1. development can be located on the least constrained parts of a site;
2. sensitive areas can be retained;
3. landscape buffers can establish a permanent boundary;
4. biodiversity can be enhanced;
5. sustainable drainage can be incorporated;
6. green infrastructure can be delivered;
7. public access can be improved; and
8. development can contribute towards wider nature recovery.
This approach will enable the Local Plan to identify locations where development can deliver environmental enhancement alongside housing and infrastructure.

10. Green Belt release should follow a genuine comparative assessment of alternatives
Where the Council identifies a need to alter Green Belt boundaries, it should undertake a transparent comparative assessment of reasonable alternatives.
This should include:
• previously developed land;
• opportunities within existing urban areas;
• opportunities for intensification;
• edge-of-settlement opportunities;
• Grey Belt land;
• other Green Belt locations; and
• opportunities in neighbouring authorities.
The assessment should not, however, operate as a rigid hierarchy in which a site is rejected simply because some brownfield capacity exists elsewhere. The NPPF requires the Council to consider the most appropriate locations for sustainable development, and Green Belt boundary decisions should be informed by the consequences of different spatial strategies for sustainable development. That is a materially different exercise from simply seeking to minimise Green Belt release.

11. Grey Belt should be considered as a positive component of the spatial strategy and should be capable of delivering wider public benefits
The identification of Grey Belt land should not be regarded simply as a consequence of Green Belt review. Where land meets the national definition of Grey Belt and is appropriately located for development, it should be considered positively as part of the Council's spatial strategy. The Government's Green Belt guidance confirms that authorities undertaking Green Belt review should identify Grey Belt land to inform the review and prioritisation of Green Belt release. The Local Plan should therefore establish a clear methodology through which Grey Belt opportunities are identified, assessed and compared alongside other sources of land supply. This will provide greater certainty for landowners, communities, developers and infrastructure providers and will allow the Council to identify the locations capable of making the greatest contribution towards meeting development needs.
Where Grey Belt land is identified as appropriate for development, the Council should also consider the wider benefits that can be secured through the development process. These may include;
1. affordable housing;
2. accessible public open space;
3. biodiversity enhancement;
4. nature recovery;
5. green infrastructure; and
6. sustainable drainage
The assessment of potential locations should therefore recognise the opportunity for appropriately located development to deliver benefits which would not otherwise be secured. The NPPF's approach to development on Green Belt land released through plan-making provides an important framework for ensuring that such development delivers substantial public benefits.

12. Recommended scope of the evidence base
Having regard to the above, the evidence base supporting the new Local Plan should include;
1. a comprehensive borough-wide Green Belt and Grey Belt assessment;
2. a transparent and reproducible site assessment methodology;
3. an updated settlement hierarchy;
4. a detailed assessment of public transport and sustainable travel accessibility;
5. identification of well-connected stations and associated development opportunities;
6. an assessment of the optimum net development capacity of potential sites;
7. updated landscape and visual evidence;
8. updated ecological and biodiversity evidence;
9. strategic flood risk evidence;
10. infrastructure capacity and infrastructure investment requirements;
11. green infrastructure and nature recovery evidence; and
12. a transparent comparative assessment of reasonable spatial strategy alternatives.
The methodologies and scoring criteria should be published sufficiently early in the plan-making process to allow stakeholders to understand and scrutinise the basis upon which locations are being assessed.

Conclusion
The new Cheshire East Local Plan should embrace the significant change in national planning policy concerning Green Belt, Grey Belt and sustainable development. The Council should undertake a comprehensive and up-to-date review of Green Belt land, identify land which meets the current definition of Grey Belt, and ensure that the assessment is based upon current evidence rather than historic conclusions. Particular weight should be given to land which is;
• physically well-related to existing settlements;
• capable of establishing a permanent and defensible boundary;
• accessible to services and employment;
• well served by public transport;
• capable of supporting sustainable travel patterns;
• capable of making efficient use of existing infrastructure; and
• able to accommodate development without fundamentally undermining the purposes of the remaining Green Belt.
The specific provisions relating to development around well-connected stations should be fully reflected in the spatial strategy and Green Belt review. More generally, the Council should recognise that good public transport connectivity is an important characteristic of sustainable locations. The assessment of Green Belt land should not therefore be based upon a presumption that Green Belt designation equates to unsuitability for development. Instead, the new Local Plan should identify where the combination of Grey Belt status, sustainable location, public transport accessibility, settlement relationship, development capacity and the ability to establish a permanent Green Belt boundary means that development would represent a more sustainable and spatially coherent solution to meeting Cheshire East's future development needs. The objective should be to identify the locations which provide the best overall planning solution, rather than simply those which result in the least release of Green Belt land. This would provide a robust and transparent basis for the subsequent identification and assessment of individual sites as the Local Plan progresses.

Please find below the response to the local plan scoping consultation from Summit Planning Associates on behalf of our client English Land Ltd. Please keep us updated regarding the progress of the local plan process and further subsequent stages to submit representation and comment.

1. Introduction
The preparation of the new Cheshire East Local Plan provides an important opportunity to establish a new spatial strategy that is fully aligned with the revised National Planning Policy Framework (NPPF). In particular, the publication of the revised NPPF (Aug 2026) represents a material change in the national approach to the Green Belt, Grey Belt, sustainable patterns of development, transport connectivity and the efficient use of land. It is therefore important that the new Cheshire East Local Plan is based upon a genuine new evidence base and methodology, rather than simply carrying forward conclusions reached through previous Green Belt and site-selection exercises undertaken under a materially different national policy framework. This representation focuses particularly on the methodology that should be used to identify and assess Green Belt and Grey Belt land and to determine which locations represent the most sustainable opportunities for accommodating the Borough's development needs.
2. A comprehensive review of Green Belt and Grey Belt land should form a fundamental part of plan preparation
The new Local Plan should undertake a comprehensive and transparent assessment of Green Belt land across Cheshire East, including the identification of land which meets the current NPPF definition of Grey Belt. The NPPF defines Grey Belt by reference to whether Green Belt land strongly contributes to Green Belt purposes (a), (b) or (d), subject to the relevant exclusions. The Council's assessment methodology should therefore explicitly distinguish between;
1. the contribution that land makes to Green Belt purposes generally; and
2. whether that land meets the specific national definition of Grey Belt.
Previous assessments should not be treated as determinative where they were undertaken using different national policy, different methodologies or different assumptions about settlement form and development needs. In particular, a conclusion that land makes a contribution to the Green Belt should not of itself be treated as sufficient to exclude it from consideration as Grey Belt. The new assessment should assess purposes (a), (b) and (d) separately and should provide sufficient transparency to establish whether land strongly contributes to any of the purposes which are relevant to the current Grey Belt definition. The assessment should also have regard to the Government's Green Belt guidance, which confirms that Green Belt assessment areas may appropriately be defined at a more localised scale, particularly around existing settlements and public transport hubs or corridors. This is important because the Green Belt function of land should be assessed having regard to its actual physical and spatial characteristics rather than simply by reference to broad parcels or historic designations.

3. The new Local Plan should distinguish between Green Belt land and land which performs a strong Green Belt function
The new Local Plan should avoid treating Green Belt designation as being synonymous with unsuitability for development. The purpose of the Green Belt assessment should be to identify the land which performs the strongest strategic Green Belt functions and, conversely, land which does not make a strong contribution to the relevant purposes. This is particularly important where land;
1. is physically contained by existing development or infrastructure;
2. is closely related to an existing settlement;
3. does not perform an important role in preventing neighbouring settlements from merging;
4. does not make a strong contribution to preserving the setting or special character of a historic town;
5. can accommodate development without fundamentally undermining the purposes of the remaining Green Belt; and
6. can provide a robust and permanent new Green Belt boundary following development.
The Council should therefore identify Grey Belt land as an integral part of its spatial strategy rather than simply treating it as a development management consideration.

4. Sustainable patterns of development should inform Green Belt boundary decisions
The new NPPF places greater emphasis on the relationship between Green Belt boundary decisions and the need to promote sustainable patterns of development. The Council's Green Belt methodology should therefore consider not simply whether development could physically be accommodated, but whether directing growth to a particular location would represent a sustainable spatial strategy. This should include consideration of:
1. proximity to existing settlements;
2. access to services, facilities and employment;
3. public transport connectivity;
4. opportunities for walking and cycling;
5. existing infrastructure;
6. the relationship with existing urban form;
7. the ability to create a permanent settlement edge; and
8. the potential for development to support sustainable travel patterns.
This approach is particularly important because the NPPF now requires sustainable development considerations to inform decisions about whether Green Belt boundaries should be altered and the assessment should consequently avoid a situation where highly accessible land is retained within the Green Belt solely because it has historically been designated as such, while less sustainable locations are required to accommodate growth.

5. Public transport connectivity should be a material consideration in identifying locations for growth
The new Local Plan should give significant weight to locations which benefit from established and effective public transport connections. The NPPF's strengthened approach to development around well-connected stations demonstrates the Government's intention that existing transport infrastructure should be used more effectively to support sustainable growth. The Council should therefore ensure that its spatial strategy and site assessment methodology properly recognise the benefits of locations which are capable of supporting modal shift and reducing reliance on the private car. Assessment should include;
1. proximity to rail stations;
2. frequency and destination of rail services;
3. bus accessibility and service frequency;
4. opportunities for walking and cycling; and
5. access to major employment centres
The assessment should also recognise that transport accessibility is not simply a matter of distance from a station. The quality, directness and safety of the connection, together with the range and frequency of services, are important considerations and where locations benefit from strong connectivity to established employment and service centres, this should be reflected positively in the spatial strategy, including opportunities on Green Belt land. Where a location is within an appropriate walking distance of a well-connected station and is otherwise suitable for development, the Council should ensure that its Green Belt and spatial strategy methodologies do not artificially prevent that opportunity from being considered. The Government's policy direction is clear that the planning system should make better use of existing transport infrastructure and direct growth towards locations which provide good access to jobs and services.

6. The assessment of Grey Belt should be integrated with the assessment of settlement form
The Council should ensure that its Green Belt and site assessment methodologies properly recognise the relationship between Green Belt land and existing settlements. Particular consideration should be given to land that;
1. adjoins an established settlement;
2. is physically well-related to the settlement;
3. can be integrated into the existing settlement pattern;
4. has access to established services and facilities;
5. benefits from public transport;
6. can establish a clearly defined and permanent settlement boundary; and
7. would not result in unacceptable coalescence.
Such locations may represent significantly more sustainable opportunities for growth than isolated development locations, even where the land is currently within the Green Belt. The assessment should therefore distinguish between development which represents an unsustainable incursion into open countryside and development which constitutes a logical and well-contained extension to an existing settlement.

7. The Council should establish a transparent and consistent site assessment methodology
A land availability and site assessment methodology will be critical in determining how the new spatial strategy operates in practice. The methodology should be transparent, reproducible and capable of comparing sites on a consistent basis. As a minimum, it should assess;
Strategic factors
• relationship to the settlement hierarchy;
• Green Belt/Grey Belt status;
• contribution to Green Belt purposes;
• relationship to neighbouring settlements;
• potential for settlement coalescence;
• ability to establish a permanent boundary.
Sustainability factors
• access to services;
• access to employment;
• public transport;
• walking and cycling;
• proximity to transport hubs;
• opportunities for modal shift.
Environmental factors
• landscape;
• ecology;
• biodiversity;
• flood risk;
• heritage;
• trees and woodland;
• water resources;
• green infrastructure.
Delivery factors
• access;
• infrastructure capacity;
• abnormal costs;
• ownership;
• availability;
• deliverability;
• development timescale.
The methodology should also ensure that no single characteristic, such as Green Belt designation automatically outweighs all other considerations.

8. Development capacity should be assessed by reference to the net developable area
The new Local Plan should establish a methodology for determining the optimum sustainable development capacity of potential sites. Historic dwelling capacities should not simply be carried forward where they were based upon different assumptions or methodologies. Equally, gross site area should not be used as the sole basis for calculating capacity. The methodology should identify factors such as;
1. gross site area;
2. land required for access;
3. flood risk areas;
4. ecological constraints;
5. landscape buffers;
6. retained trees and woodland;
7. green infrastructure;
8. public open space;
9. drainage and infrastructure requirements; and
10. the resulting net developable area.
Appropriate density should then be determined having regard to the site's location and accessibility. This is particularly important for sustainable locations where the NPPF supports the efficient use of land and appropriate density, including higher densities in locations that are well served by public transport. The approach should avoid artificially suppressing the development potential of sustainable locations through historic or arbitrary assumptions about site capacity.

9. Environmental constraints should be assessed proportionately
The new evidence base should distinguish between constraints which represent fundamental barriers to development and those which can be addressed through appropriate design and mitigation. The presence of landscape, ecology, flood risk, trees, woodland or watercourses should not automatically result in a site being excluded where development can be appropriately located and designed. The assessment should consider whether:
1. development can be located on the least constrained parts of a site;
2. sensitive areas can be retained;
3. landscape buffers can establish a permanent boundary;
4. biodiversity can be enhanced;
5. sustainable drainage can be incorporated;
6. green infrastructure can be delivered;
7. public access can be improved; and
8. development can contribute towards wider nature recovery.
This approach will enable the Local Plan to identify locations where development can deliver environmental enhancement alongside housing and infrastructure.

10. Green Belt release should follow a genuine comparative assessment of alternatives
Where the Council identifies a need to alter Green Belt boundaries, it should undertake a transparent comparative assessment of reasonable alternatives.
This should include:
• previously developed land;
• opportunities within existing urban areas;
• opportunities for intensification;
• edge-of-settlement opportunities;
• Grey Belt land;
• other Green Belt locations; and
• opportunities in neighbouring authorities.
The assessment should not, however, operate as a rigid hierarchy in which a site is rejected simply because some brownfield capacity exists elsewhere. The NPPF requires the Council to consider the most appropriate locations for sustainable development, and Green Belt boundary decisions should be informed by the consequences of different spatial strategies for sustainable development. That is a materially different exercise from simply seeking to minimise Green Belt release.

11. Grey Belt should be considered as a positive component of the spatial strategy and should be capable of delivering wider public benefits
The identification of Grey Belt land should not be regarded simply as a consequence of Green Belt review. Where land meets the national definition of Grey Belt and is appropriately located for development, it should be considered positively as part of the Council's spatial strategy. The Government's Green Belt guidance confirms that authorities undertaking Green Belt review should identify Grey Belt land to inform the review and prioritisation of Green Belt release. The Local Plan should therefore establish a clear methodology through which Grey Belt opportunities are identified, assessed and compared alongside other sources of land supply. This will provide greater certainty for landowners, communities, developers and infrastructure providers and will allow the Council to identify the locations capable of making the greatest contribution towards meeting development needs.
Where Grey Belt land is identified as appropriate for development, the Council should also consider the wider benefits that can be secured through the development process. These may include;
1. affordable housing;
2. accessible public open space;
3. biodiversity enhancement;
4. nature recovery;
5. green infrastructure; and
6. sustainable drainage
The assessment of potential locations should therefore recognise the opportunity for appropriately located development to deliver benefits which would not otherwise be secured. The NPPF's approach to development on Green Belt land released through plan-making provides an important framework for ensuring that such development delivers substantial public benefits.

12. Recommended scope of the evidence base
Having regard to the above, the evidence base supporting the new Local Plan should include;
1. a comprehensive borough-wide Green Belt and Grey Belt assessment;
2. a transparent and reproducible site assessment methodology;
3. an updated settlement hierarchy;
4. a detailed assessment of public transport and sustainable travel accessibility;
5. identification of well-connected stations and associated development opportunities;
6. an assessment of the optimum net development capacity of potential sites;
7. updated landscape and visual evidence;
8. updated ecological and biodiversity evidence;
9. strategic flood risk evidence;
10. infrastructure capacity and infrastructure investment requirements;
11. green infrastructure and nature recovery evidence; and
12. a transparent comparative assessment of reasonable spatial strategy alternatives.
The methodologies and scoring criteria should be published sufficiently early in the plan-making process to allow stakeholders to understand and scrutinise the basis upon which locations are being assessed.

Conclusion
The new Cheshire East Local Plan should embrace the significant change in national planning policy concerning Green Belt, Grey Belt and sustainable development. The Council should undertake a comprehensive and up-to-date review of Green Belt land, identify land which meets the current definition of Grey Belt, and ensure that the assessment is based upon current evidence rather than historic conclusions. Particular weight should be given to land which is;
• physically well-related to existing settlements;
• capable of establishing a permanent and defensible boundary;
• accessible to services and employment;
• well served by public transport;
• capable of supporting sustainable travel patterns;
• capable of making efficient use of existing infrastructure; and
• able to accommodate development without fundamentally undermining the purposes of the remaining Green Belt.
The specific provisions relating to development around well-connected stations should be fully reflected in the spatial strategy and Green Belt review. More generally, the Council should recognise that good public transport connectivity is an important characteristic of sustainable locations. The assessment of Green Belt land should not therefore be based upon a presumption that Green Belt designation equates to unsuitability for development. Instead, the new Local Plan should identify where the combination of Grey Belt status, sustainable location, public transport accessibility, settlement relationship, development capacity and the ability to establish a permanent Green Belt boundary means that development would represent a more sustainable and spatially coherent solution to meeting Cheshire East's future development needs. The objective should be to identify the locations which provide the best overall planning solution, rather than simply those which result in the least release of Green Belt land. This would provide a robust and transparent basis for the subsequent identification and assessment of individual sites as the Local Plan progresses.

Please find below the response to the local plan scoping consultation from Summit Planning Associates on behalf of our client English Land Ltd. Please keep us updated regarding the progress of the local plan process and further subsequent stages to submit representation and comment.

1. Introduction
The preparation of the new Cheshire East Local Plan provides an important opportunity to establish a new spatial strategy that is fully aligned with the revised National Planning Policy Framework (NPPF). In particular, the publication of the revised NPPF (Aug 2026) represents a material change in the national approach to the Green Belt, Grey Belt, sustainable patterns of development, transport connectivity and the efficient use of land. It is therefore important that the new Cheshire East Local Plan is based upon a genuine new evidence base and methodology, rather than simply carrying forward conclusions reached through previous Green Belt and site-selection exercises undertaken under a materially different national policy framework. This representation focuses particularly on the methodology that should be used to identify and assess Green Belt and Grey Belt land and to determine which locations represent the most sustainable opportunities for accommodating the Borough's development needs.
2. A comprehensive review of Green Belt and Grey Belt land should form a fundamental part of plan preparation
The new Local Plan should undertake a comprehensive and transparent assessment of Green Belt land across Cheshire East, including the identification of land which meets the current NPPF definition of Grey Belt. The NPPF defines Grey Belt by reference to whether Green Belt land strongly contributes to Green Belt purposes (a), (b) or (d), subject to the relevant exclusions. The Council's assessment methodology should therefore explicitly distinguish between;
1. the contribution that land makes to Green Belt purposes generally; and
2. whether that land meets the specific national definition of Grey Belt.
Previous assessments should not be treated as determinative where they were undertaken using different national policy, different methodologies or different assumptions about settlement form and development needs. In particular, a conclusion that land makes a contribution to the Green Belt should not of itself be treated as sufficient to exclude it from consideration as Grey Belt. The new assessment should assess purposes (a), (b) and (d) separately and should provide sufficient transparency to establish whether land strongly contributes to any of the purposes which are relevant to the current Grey Belt definition. The assessment should also have regard to the Government's Green Belt guidance, which confirms that Green Belt assessment areas may appropriately be defined at a more localised scale, particularly around existing settlements and public transport hubs or corridors. This is important because the Green Belt function of land should be assessed having regard to its actual physical and spatial characteristics rather than simply by reference to broad parcels or historic designations.

3. The new Local Plan should distinguish between Green Belt land and land which performs a strong Green Belt function
The new Local Plan should avoid treating Green Belt designation as being synonymous with unsuitability for development. The purpose of the Green Belt assessment should be to identify the land which performs the strongest strategic Green Belt functions and, conversely, land which does not make a strong contribution to the relevant purposes. This is particularly important where land;
1. is physically contained by existing development or infrastructure;
2. is closely related to an existing settlement;
3. does not perform an important role in preventing neighbouring settlements from merging;
4. does not make a strong contribution to preserving the setting or special character of a historic town;
5. can accommodate development without fundamentally undermining the purposes of the remaining Green Belt; and
6. can provide a robust and permanent new Green Belt boundary following development.
The Council should therefore identify Grey Belt land as an integral part of its spatial strategy rather than simply treating it as a development management consideration.

4. Sustainable patterns of development should inform Green Belt boundary decisions
The new NPPF places greater emphasis on the relationship between Green Belt boundary decisions and the need to promote sustainable patterns of development. The Council's Green Belt methodology should therefore consider not simply whether development could physically be accommodated, but whether directing growth to a particular location would represent a sustainable spatial strategy. This should include consideration of:
1. proximity to existing settlements;
2. access to services, facilities and employment;
3. public transport connectivity;
4. opportunities for walking and cycling;
5. existing infrastructure;
6. the relationship with existing urban form;
7. the ability to create a permanent settlement edge; and
8. the potential for development to support sustainable travel patterns.
This approach is particularly important because the NPPF now requires sustainable development considerations to inform decisions about whether Green Belt boundaries should be altered and the assessment should consequently avoid a situation where highly accessible land is retained within the Green Belt solely because it has historically been designated as such, while less sustainable locations are required to accommodate growth.

5. Public transport connectivity should be a material consideration in identifying locations for growth
The new Local Plan should give significant weight to locations which benefit from established and effective public transport connections. The NPPF's strengthened approach to development around well-connected stations demonstrates the Government's intention that existing transport infrastructure should be used more effectively to support sustainable growth. The Council should therefore ensure that its spatial strategy and site assessment methodology properly recognise the benefits of locations which are capable of supporting modal shift and reducing reliance on the private car. Assessment should include;
1. proximity to rail stations;
2. frequency and destination of rail services;
3. bus accessibility and service frequency;
4. opportunities for walking and cycling; and
5. access to major employment centres
The assessment should also recognise that transport accessibility is not simply a matter of distance from a station. The quality, directness and safety of the connection, together with the range and frequency of services, are important considerations and where locations benefit from strong connectivity to established employment and service centres, this should be reflected positively in the spatial strategy, including opportunities on Green Belt land. Where a location is within an appropriate walking distance of a well-connected station and is otherwise suitable for development, the Council should ensure that its Green Belt and spatial strategy methodologies do not artificially prevent that opportunity from being considered. The Government's policy direction is clear that the planning system should make better use of existing transport infrastructure and direct growth towards locations which provide good access to jobs and services.

6. The assessment of Grey Belt should be integrated with the assessment of settlement form
The Council should ensure that its Green Belt and site assessment methodologies properly recognise the relationship between Green Belt land and existing settlements. Particular consideration should be given to land that;
1. adjoins an established settlement;
2. is physically well-related to the settlement;
3. can be integrated into the existing settlement pattern;
4. has access to established services and facilities;
5. benefits from public transport;
6. can establish a clearly defined and permanent settlement boundary; and
7. would not result in unacceptable coalescence.
Such locations may represent significantly more sustainable opportunities for growth than isolated development locations, even where the land is currently within the Green Belt. The assessment should therefore distinguish between development which represents an unsustainable incursion into open countryside and development which constitutes a logical and well-contained extension to an existing settlement.

7. The Council should establish a transparent and consistent site assessment methodology
A land availability and site assessment methodology will be critical in determining how the new spatial strategy operates in practice. The methodology should be transparent, reproducible and capable of comparing sites on a consistent basis. As a minimum, it should assess;
Strategic factors
• relationship to the settlement hierarchy;
• Green Belt/Grey Belt status;
• contribution to Green Belt purposes;
• relationship to neighbouring settlements;
• potential for settlement coalescence;
• ability to establish a permanent boundary.
Sustainability factors
• access to services;
• access to employment;
• public transport;
• walking and cycling;
• proximity to transport hubs;
• opportunities for modal shift.
Environmental factors
• landscape;
• ecology;
• biodiversity;
• flood risk;
• heritage;
• trees and woodland;
• water resources;
• green infrastructure.
Delivery factors
• access;
• infrastructure capacity;
• abnormal costs;
• ownership;
• availability;
• deliverability;
• development timescale.
The methodology should also ensure that no single characteristic, such as Green Belt designation automatically outweighs all other considerations.

8. Development capacity should be assessed by reference to the net developable area
The new Local Plan should establish a methodology for determining the optimum sustainable development capacity of potential sites. Historic dwelling capacities should not simply be carried forward where they were based upon different assumptions or methodologies. Equally, gross site area should not be used as the sole basis for calculating capacity. The methodology should identify factors such as;
1. gross site area;
2. land required for access;
3. flood risk areas;
4. ecological constraints;
5. landscape buffers;
6. retained trees and woodland;
7. green infrastructure;
8. public open space;
9. drainage and infrastructure requirements; and
10. the resulting net developable area.
Appropriate density should then be determined having regard to the site's location and accessibility. This is particularly important for sustainable locations where the NPPF supports the efficient use of land and appropriate density, including higher densities in locations that are well served by public transport. The approach should avoid artificially suppressing the development potential of sustainable locations through historic or arbitrary assumptions about site capacity.

9. Environmental constraints should be assessed proportionately
The new evidence base should distinguish between constraints which represent fundamental barriers to development and those which can be addressed through appropriate design and mitigation. The presence of landscape, ecology, flood risk, trees, woodland or watercourses should not automatically result in a site being excluded where development can be appropriately located and designed. The assessment should consider whether:
1. development can be located on the least constrained parts of a site;
2. sensitive areas can be retained;
3. landscape buffers can establish a permanent boundary;
4. biodiversity can be enhanced;
5. sustainable drainage can be incorporated;
6. green infrastructure can be delivered;
7. public access can be improved; and
8. development can contribute towards wider nature recovery.
This approach will enable the Local Plan to identify locations where development can deliver environmental enhancement alongside housing and infrastructure.

10. Green Belt release should follow a genuine comparative assessment of alternatives
Where the Council identifies a need to alter Green Belt boundaries, it should undertake a transparent comparative assessment of reasonable alternatives.
This should include:
• previously developed land;
• opportunities within existing urban areas;
• opportunities for intensification;
• edge-of-settlement opportunities;
• Grey Belt land;
• other Green Belt locations; and
• opportunities in neighbouring authorities.
The assessment should not, however, operate as a rigid hierarchy in which a site is rejected simply because some brownfield capacity exists elsewhere. The NPPF requires the Council to consider the most appropriate locations for sustainable development, and Green Belt boundary decisions should be informed by the consequences of different spatial strategies for sustainable development. That is a materially different exercise from simply seeking to minimise Green Belt release.

11. Grey Belt should be considered as a positive component of the spatial strategy and should be capable of delivering wider public benefits
The identification of Grey Belt land should not be regarded simply as a consequence of Green Belt review. Where land meets the national definition of Grey Belt and is appropriately located for development, it should be considered positively as part of the Council's spatial strategy. The Government's Green Belt guidance confirms that authorities undertaking Green Belt review should identify Grey Belt land to inform the review and prioritisation of Green Belt release. The Local Plan should therefore establish a clear methodology through which Grey Belt opportunities are identified, assessed and compared alongside other sources of land supply. This will provide greater certainty for landowners, communities, developers and infrastructure providers and will allow the Council to identify the locations capable of making the greatest contribution towards meeting development needs.
Where Grey Belt land is identified as appropriate for development, the Council should also consider the wider benefits that can be secured through the development process. These may include;
1. affordable housing;
2. accessible public open space;
3. biodiversity enhancement;
4. nature recovery;
5. green infrastructure; and
6. sustainable drainage
The assessment of potential locations should therefore recognise the opportunity for appropriately located development to deliver benefits which would not otherwise be secured. The NPPF's approach to development on Green Belt land released through plan-making provides an important framework for ensuring that such development delivers substantial public benefits.

12. Recommended scope of the evidence base
Having regard to the above, the evidence base supporting the new Local Plan should include;
1. a comprehensive borough-wide Green Belt and Grey Belt assessment;
2. a transparent and reproducible site assessment methodology;
3. an updated settlement hierarchy;
4. a detailed assessment of public transport and sustainable travel accessibility;
5. identification of well-connected stations and associated development opportunities;
6. an assessment of the optimum net development capacity of potential sites;
7. updated landscape and visual evidence;
8. updated ecological and biodiversity evidence;
9. strategic flood risk evidence;
10. infrastructure capacity and infrastructure investment requirements;
11. green infrastructure and nature recovery evidence; and
12. a transparent comparative assessment of reasonable spatial strategy alternatives.
The methodologies and scoring criteria should be published sufficiently early in the plan-making process to allow stakeholders to understand and scrutinise the basis upon which locations are being assessed.

Conclusion
The new Cheshire East Local Plan should embrace the significant change in national planning policy concerning Green Belt, Grey Belt and sustainable development. The Council should undertake a comprehensive and up-to-date review of Green Belt land, identify land which meets the current definition of Grey Belt, and ensure that the assessment is based upon current evidence rather than historic conclusions. Particular weight should be given to land which is;
• physically well-related to existing settlements;
• capable of establishing a permanent and defensible boundary;
• accessible to services and employment;
• well served by public transport;
• capable of supporting sustainable travel patterns;
• capable of making efficient use of existing infrastructure; and
• able to accommodate development without fundamentally undermining the purposes of the remaining Green Belt.
The specific provisions relating to development around well-connected stations should be fully reflected in the spatial strategy and Green Belt review. More generally, the Council should recognise that good public transport connectivity is an important characteristic of sustainable locations. The assessment of Green Belt land should not therefore be based upon a presumption that Green Belt designation equates to unsuitability for development. Instead, the new Local Plan should identify where the combination of Grey Belt status, sustainable location, public transport accessibility, settlement relationship, development capacity and the ability to establish a permanent Green Belt boundary means that development would represent a more sustainable and spatially coherent solution to meeting Cheshire East's future development needs. The objective should be to identify the locations which provide the best overall planning solution, rather than simply those which result in the least release of Green Belt land. This would provide a robust and transparent basis for the subsequent identification and assessment of individual sites as the Local Plan progresses.

Please find below the response to the local plan scoping consultation from Summit Planning Associates on behalf of our client English Land Ltd. Please keep us updated regarding the progress of the local plan process and further subsequent stages to submit representation and comment.

1. Introduction
The preparation of the new Cheshire East Local Plan provides an important opportunity to establish a new spatial strategy that is fully aligned with the revised National Planning Policy Framework (NPPF). In particular, the publication of the revised NPPF (Aug 2026) represents a material change in the national approach to the Green Belt, Grey Belt, sustainable patterns of development, transport connectivity and the efficient use of land. It is therefore important that the new Cheshire East Local Plan is based upon a genuine new evidence base and methodology, rather than simply carrying forward conclusions reached through previous Green Belt and site-selection exercises undertaken under a materially different national policy framework. This representation focuses particularly on the methodology that should be used to identify and assess Green Belt and Grey Belt land and to determine which locations represent the most sustainable opportunities for accommodating the Borough's development needs.
2. A comprehensive review of Green Belt and Grey Belt land should form a fundamental part of plan preparation
The new Local Plan should undertake a comprehensive and transparent assessment of Green Belt land across Cheshire East, including the identification of land which meets the current NPPF definition of Grey Belt. The NPPF defines Grey Belt by reference to whether Green Belt land strongly contributes to Green Belt purposes (a), (b) or (d), subject to the relevant exclusions. The Council's assessment methodology should therefore explicitly distinguish between;
1. the contribution that land makes to Green Belt purposes generally; and
2. whether that land meets the specific national definition of Grey Belt.
Previous assessments should not be treated as determinative where they were undertaken using different national policy, different methodologies or different assumptions about settlement form and development needs. In particular, a conclusion that land makes a contribution to the Green Belt should not of itself be treated as sufficient to exclude it from consideration as Grey Belt. The new assessment should assess purposes (a), (b) and (d) separately and should provide sufficient transparency to establish whether land strongly contributes to any of the purposes which are relevant to the current Grey Belt definition. The assessment should also have regard to the Government's Green Belt guidance, which confirms that Green Belt assessment areas may appropriately be defined at a more localised scale, particularly around existing settlements and public transport hubs or corridors. This is important because the Green Belt function of land should be assessed having regard to its actual physical and spatial characteristics rather than simply by reference to broad parcels or historic designations.

3. The new Local Plan should distinguish between Green Belt land and land which performs a strong Green Belt function
The new Local Plan should avoid treating Green Belt designation as being synonymous with unsuitability for development. The purpose of the Green Belt assessment should be to identify the land which performs the strongest strategic Green Belt functions and, conversely, land which does not make a strong contribution to the relevant purposes. This is particularly important where land;
1. is physically contained by existing development or infrastructure;
2. is closely related to an existing settlement;
3. does not perform an important role in preventing neighbouring settlements from merging;
4. does not make a strong contribution to preserving the setting or special character of a historic town;
5. can accommodate development without fundamentally undermining the purposes of the remaining Green Belt; and
6. can provide a robust and permanent new Green Belt boundary following development.
The Council should therefore identify Grey Belt land as an integral part of its spatial strategy rather than simply treating it as a development management consideration.

4. Sustainable patterns of development should inform Green Belt boundary decisions
The new NPPF places greater emphasis on the relationship between Green Belt boundary decisions and the need to promote sustainable patterns of development. The Council's Green Belt methodology should therefore consider not simply whether development could physically be accommodated, but whether directing growth to a particular location would represent a sustainable spatial strategy. This should include consideration of:
1. proximity to existing settlements;
2. access to services, facilities and employment;
3. public transport connectivity;
4. opportunities for walking and cycling;
5. existing infrastructure;
6. the relationship with existing urban form;
7. the ability to create a permanent settlement edge; and
8. the potential for development to support sustainable travel patterns.
This approach is particularly important because the NPPF now requires sustainable development considerations to inform decisions about whether Green Belt boundaries should be altered and the assessment should consequently avoid a situation where highly accessible land is retained within the Green Belt solely because it has historically been designated as such, while less sustainable locations are required to accommodate growth.

5. Public transport connectivity should be a material consideration in identifying locations for growth
The new Local Plan should give significant weight to locations which benefit from established and effective public transport connections. The NPPF's strengthened approach to development around well-connected stations demonstrates the Government's intention that existing transport infrastructure should be used more effectively to support sustainable growth. The Council should therefore ensure that its spatial strategy and site assessment methodology properly recognise the benefits of locations which are capable of supporting modal shift and reducing reliance on the private car. Assessment should include;
1. proximity to rail stations;
2. frequency and destination of rail services;
3. bus accessibility and service frequency;
4. opportunities for walking and cycling; and
5. access to major employment centres
The assessment should also recognise that transport accessibility is not simply a matter of distance from a station. The quality, directness and safety of the connection, together with the range and frequency of services, are important considerations and where locations benefit from strong connectivity to established employment and service centres, this should be reflected positively in the spatial strategy, including opportunities on Green Belt land. Where a location is within an appropriate walking distance of a well-connected station and is otherwise suitable for development, the Council should ensure that its Green Belt and spatial strategy methodologies do not artificially prevent that opportunity from being considered. The Government's policy direction is clear that the planning system should make better use of existing transport infrastructure and direct growth towards locations which provide good access to jobs and services.

6. The assessment of Grey Belt should be integrated with the assessment of settlement form
The Council should ensure that its Green Belt and site assessment methodologies properly recognise the relationship between Green Belt land and existing settlements. Particular consideration should be given to land that;
1. adjoins an established settlement;
2. is physically well-related to the settlement;
3. can be integrated into the existing settlement pattern;
4. has access to established services and facilities;
5. benefits from public transport;
6. can establish a clearly defined and permanent settlement boundary; and
7. would not result in unacceptable coalescence.
Such locations may represent significantly more sustainable opportunities for growth than isolated development locations, even where the land is currently within the Green Belt. The assessment should therefore distinguish between development which represents an unsustainable incursion into open countryside and development which constitutes a logical and well-contained extension to an existing settlement.

7. The Council should establish a transparent and consistent site assessment methodology
A land availability and site assessment methodology will be critical in determining how the new spatial strategy operates in practice. The methodology should be transparent, reproducible and capable of comparing sites on a consistent basis. As a minimum, it should assess;
Strategic factors
• relationship to the settlement hierarchy;
• Green Belt/Grey Belt status;
• contribution to Green Belt purposes;
• relationship to neighbouring settlements;
• potential for settlement coalescence;
• ability to establish a permanent boundary.
Sustainability factors
• access to services;
• access to employment;
• public transport;
• walking and cycling;
• proximity to transport hubs;
• opportunities for modal shift.
Environmental factors
• landscape;
• ecology;
• biodiversity;
• flood risk;
• heritage;
• trees and woodland;
• water resources;
• green infrastructure.
Delivery factors
• access;
• infrastructure capacity;
• abnormal costs;
• ownership;
• availability;
• deliverability;
• development timescale.
The methodology should also ensure that no single characteristic, such as Green Belt designation automatically outweighs all other considerations.

8. Development capacity should be assessed by reference to the net developable area
The new Local Plan should establish a methodology for determining the optimum sustainable development capacity of potential sites. Historic dwelling capacities should not simply be carried forward where they were based upon different assumptions or methodologies. Equally, gross site area should not be used as the sole basis for calculating capacity. The methodology should identify factors such as;
1. gross site area;
2. land required for access;
3. flood risk areas;
4. ecological constraints;
5. landscape buffers;
6. retained trees and woodland;
7. green infrastructure;
8. public open space;
9. drainage and infrastructure requirements; and
10. the resulting net developable area.
Appropriate density should then be determined having regard to the site's location and accessibility. This is particularly important for sustainable locations where the NPPF supports the efficient use of land and appropriate density, including higher densities in locations that are well served by public transport. The approach should avoid artificially suppressing the development potential of sustainable locations through historic or arbitrary assumptions about site capacity.

9. Environmental constraints should be assessed proportionately
The new evidence base should distinguish between constraints which represent fundamental barriers to development and those which can be addressed through appropriate design and mitigation. The presence of landscape, ecology, flood risk, trees, woodland or watercourses should not automatically result in a site being excluded where development can be appropriately located and designed. The assessment should consider whether:
1. development can be located on the least constrained parts of a site;
2. sensitive areas can be retained;
3. landscape buffers can establish a permanent boundary;
4. biodiversity can be enhanced;
5. sustainable drainage can be incorporated;
6. green infrastructure can be delivered;
7. public access can be improved; and
8. development can contribute towards wider nature recovery.
This approach will enable the Local Plan to identify locations where development can deliver environmental enhancement alongside housing and infrastructure.

10. Green Belt release should follow a genuine comparative assessment of alternatives
Where the Council identifies a need to alter Green Belt boundaries, it should undertake a transparent comparative assessment of reasonable alternatives.
This should include:
• previously developed land;
• opportunities within existing urban areas;
• opportunities for intensification;
• edge-of-settlement opportunities;
• Grey Belt land;
• other Green Belt locations; and
• opportunities in neighbouring authorities.
The assessment should not, however, operate as a rigid hierarchy in which a site is rejected simply because some brownfield capacity exists elsewhere. The NPPF requires the Council to consider the most appropriate locations for sustainable development, and Green Belt boundary decisions should be informed by the consequences of different spatial strategies for sustainable development. That is a materially different exercise from simply seeking to minimise Green Belt release.

11. Grey Belt should be considered as a positive component of the spatial strategy and should be capable of delivering wider public benefits
The identification of Grey Belt land should not be regarded simply as a consequence of Green Belt review. Where land meets the national definition of Grey Belt and is appropriately located for development, it should be considered positively as part of the Council's spatial strategy. The Government's Green Belt guidance confirms that authorities undertaking Green Belt review should identify Grey Belt land to inform the review and prioritisation of Green Belt release. The Local Plan should therefore establish a clear methodology through which Grey Belt opportunities are identified, assessed and compared alongside other sources of land supply. This will provide greater certainty for landowners, communities, developers and infrastructure providers and will allow the Council to identify the locations capable of making the greatest contribution towards meeting development needs.
Where Grey Belt land is identified as appropriate for development, the Council should also consider the wider benefits that can be secured through the development process. These may include;
1. affordable housing;
2. accessible public open space;
3. biodiversity enhancement;
4. nature recovery;
5. green infrastructure; and
6. sustainable drainage
The assessment of potential locations should therefore recognise the opportunity for appropriately located development to deliver benefits which would not otherwise be secured. The NPPF's approach to development on Green Belt land released through plan-making provides an important framework for ensuring that such development delivers substantial public benefits.

12. Recommended scope of the evidence base
Having regard to the above, the evidence base supporting the new Local Plan should include;
1. a comprehensive borough-wide Green Belt and Grey Belt assessment;
2. a transparent and reproducible site assessment methodology;
3. an updated settlement hierarchy;
4. a detailed assessment of public transport and sustainable travel accessibility;
5. identification of well-connected stations and associated development opportunities;
6. an assessment of the optimum net development capacity of potential sites;
7. updated landscape and visual evidence;
8. updated ecological and biodiversity evidence;
9. strategic flood risk evidence;
10. infrastructure capacity and infrastructure investment requirements;
11. green infrastructure and nature recovery evidence; and
12. a transparent comparative assessment of reasonable spatial strategy alternatives.
The methodologies and scoring criteria should be published sufficiently early in the plan-making process to allow stakeholders to understand and scrutinise the basis upon which locations are being assessed.

Conclusion
The new Cheshire East Local Plan should embrace the significant change in national planning policy concerning Green Belt, Grey Belt and sustainable development. The Council should undertake a comprehensive and up-to-date review of Green Belt land, identify land which meets the current definition of Grey Belt, and ensure that the assessment is based upon current evidence rather than historic conclusions. Particular weight should be given to land which is;
• physically well-related to existing settlements;
• capable of establishing a permanent and defensible boundary;
• accessible to services and employment;
• well served by public transport;
• capable of supporting sustainable travel patterns;
• capable of making efficient use of existing infrastructure; and
• able to accommodate development without fundamentally undermining the purposes of the remaining Green Belt.
The specific provisions relating to development around well-connected stations should be fully reflected in the spatial strategy and Green Belt review. More generally, the Council should recognise that good public transport connectivity is an important characteristic of sustainable locations. The assessment of Green Belt land should not therefore be based upon a presumption that Green Belt designation equates to unsuitability for development. Instead, the new Local Plan should identify where the combination of Grey Belt status, sustainable location, public transport accessibility, settlement relationship, development capacity and the ability to establish a permanent Green Belt boundary means that development would represent a more sustainable and spatially coherent solution to meeting Cheshire East's future development needs. The objective should be to identify the locations which provide the best overall planning solution, rather than simply those which result in the least release of Green Belt land. This would provide a robust and transparent basis for the subsequent identification and assessment of individual sites as the Local Plan progresses.