CPRE response to Cheshire East Council Local Plan first stage consultation

We have responded to the Cheshire East Council (CEC) issues consultation for a new (second) Local Plan. This is the first of multiple consultation stages in the Local Plan process. Once in place, the Local Plan will guide planning decisions for a long period of time. It’s important therefore for people to get involved in its development.

Our response

Here we give section-by-section notes on our response, which you can use to inform your own contribution. For the full response with a breakdown of answers to every sub-question, see CPRE Cheshire response to CEC Local Plan issues consultation.

You can read the consultation documents and add your own responses on the Cheshire East Council website.

This stage of the consultation closes on 1 July 2024.

1. Introduction

Potential plan period

We endorse CEC’s suggestion that the plan should run to 2045.

Vision and objectives

The vision aligns with our green aims. We stress that whilst the vision should be balanced across the 3 pillars of sustainability – economy, environment and society – the focus currently must be on responding to the climate emergency. We welcome the statement that this ‘will need to be reflected through every aspect of the plan and placed at forefront of planning decisions’, but question the Council’s commitment to this in view of the decision to set back its carbon neutrality target from 2035 to 2045.

2. Responding to the climate emergency

Manchester Airport should be included as a major source of harmful emissions from both aircraft and road traffic, as the runways and part of the enterprise zone and freight terminal are in Cheshire East. There should not be any further traffic-generating development at the airport and no further development on the green belt around it. Transport is the largest emitting sector of greenhouse gases, and Cheshire East Council (CEC) is currently among the worst local authorities for greenhouse gas emissions – this fact should be a wake up call.

Multiple further issues that should also be addressed include the need to tackle air pollution, stop building new roads, save peat bogs such as Danes Moss, and expand recycling facilities. CEC has failed so far to set a sufficiently sustainable path. Each time a new road is commissioned, this triggers a chain of events contributing to climate emergency, from mineral extraction to reducing land available to absorb rainfall and increasing traffic and thus the demand for more roads. CEC should instead be improving and encouraging digital connectivity to reduce need to travel, integrating transport and land use planning, and facilitating good public transport.

We note the reference in the Climate Change Emergency topic paper to the importance of preserving peatlands. We urge CEC to make the changes necessary to the new Local Plan to save what remains of Danes Moss. It was an error of judgement to allocate this land for development in the first Local Plan; that error should now be put right.

3. Healthy and safe communities

• While the consultation papers acknowledge the importance of green space for human health and wellbeing, this needs to be matched with a commitment to protecting important existing green spaces and expanding green space provision.
• To minimise effects from pollution and contamination, no further high traffic generating developments should be approved.
• To improve air quality, actions and words must match. CEC should be placing greater emphasis on air quality monitoring.
• Noise pollution should be included as an issue.

Creating areas where everyone feels safe

This section discusses safety only in terms of crime (which is not a spatial planning issue). The main spatial aspect relating to safety is the need for safe roads. This requires looking at ways to improve road safety, such as lower speed limits on rural roads, safe routes to school, and school street measures. CEC must co-ordinate work on the Local Plan and the Local Transport Plan, with highways and planning teams working in collaboration.

Reducing health inequalities

This is not a spatial planning issue. However:

• CEC could make it a requirement that new developments over a certain size must provide a health centre or the funds for one.
• The Plan must comply with protection of biodiversity and requirement of fit-for-purpose contributions from developers – because the more stable the biodiversity, the healthier the environment.
• CEC could also encourage and help communities and Parish Councils to produce resilience plans.

4. Design

We welcome central government’s introduction of a requirement for all Local Planning Authorities to produce a Design Code. We contend however that a single code is not possible for Cheshire East, because of the diversity of architectural styles across the region.

We also point out that neither Neighbourhood Plans nor Village Design Statements are mentioned – this is a big omission, as many of these contain design policies.

5. Natural environment

• The Plan must comply with protection of biodiversity and requirement of fit-for-purpose contributions from developers
• Not possible to comment in full yet, as still awaiting drafts of CEC’s Local Nature Recovery Strategy and biodiversity net gain supplementary planning documents.
• Need to include pictures of landscape types and designated environmental areas with lists and location diagrams so it’s possible to check whether all have been included.
• No mention of the meres, mosses and ponds for which the area is noted.
• We have lower than average tree cover, so there should be a commitment to new woodlands

6. Homes for everyone

Calculation methods

We do not endorse the standard method calculation of 1.014 homes per annum, as this is based on 2014 household projections that were subsequently shown to be wrong. Among other inadequacies, it also relies on flawed affordability assumptions which don’t yield lower prices when homes are built.

Also, this method is only advisory. CEC should instead rely on the best data available, such as that from 2021 census.

Identifying housing need is only the starting point. The Plan must also take into account constraints such as Green Belt. In Cheshire East, we need to avoid a further Green Belt review due to the fact the last review was relatively recent. Reviews should be ‘exceptional’ with boundaries set ‘having regard to their intended permanence in the long term’ – National Planning Policy Framework (NPPF) para 145.

Housing mix

New homes should be planned for the needs of the population rather than to meet developer demands, with a housing mix that recognises site-specific realities. The consultation paper itself reports that too many 4+ bedroom houses are coming forward and far too few one-bedroomed dwellings.

Ageing population

CEC must focus on meeting the housing needs of the ageing population – the 2021 census shows Cheshire East has a higher than average number of over 65s. Yet there are few options available to those wanting to downsize. The Plan should require that 15% of homes delivered are suitable for older people, and could usefully identify areas close to existing services for older people’s developments. 

Small and medium sized housing sites

• These should be delivered in partnership with local communities and town and parish councils, ideally via Neighbourhood Plans.
• Sites should avoid productive agricultural land, land prone to flooding, and any sites in specially designated areas.
• Previously developed land should be prioritised for use and sites with no public transport should be avoided.
• No further incursions into green belt.

Affordable housing

CEC must address the issue of developers failing to build the originally-agreed number of affordable homes quoting ‘viability issues’.

First homes

We do not support the adoption of additional eligibility criteria for First Homes. This is because universal policies cannot accommodate variances in particular areas, and would contradict the Council’s own Corporate Plan to ‘create a market that delivers the right type of houses in the right locations at the right price to support the needs of residents’.

Accessibility

Only 9% of housing has the four key accessibility features that many older people need (a WC at entrance level, a flush threshold to the WC, sufficiently wide doorways and circulation space, and a level access). This must be addressed.

Space standards

New homes must meet nationally-described space standards.

Gypsies, Travellers, Travelling Showpeople

The Plan needs to be informed by an up-to-date assessment of need and meet this need via existing site supply and/or suitable allocated sites and a criteria-based policy. The focus should be on brownfield sites with good access to local services.

Further housing issues

New plans will be tested against the new National Planning Policy Framework (NPPF). This document was accompanied by a ministerial statement confirming that the government’s objective is “to make the best use of previously developed land and locate more homes in our larger towns and cities where development can help to reduce the need to travel and contribute to productivity, regeneration and levelling up.”

The NPPF states “there is no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated”. Changes can only be made in exceptional circumstances, and before concluding that circumstances are exceptional, the planning authority must show they have examined fully all other options to meet the particular need.

7. Town centres and retail

CEC have identified the key issues to be addressed, and recognised realities such as the surplus of allocated retail and office space in town centres which could be used for residential purposes – so supporting the remaining businesses. We also commend the recognition that open spaces, greening and improving the public realm all play a big part in supporting town centres.

We are heartened by the recognition that neighbourhood parades of shops have big part to play in engendering successful communities where people can access day-to-day needs without needing to travel.

We advocate drawing up masterplans for each town and local centre to ensure their futures are properly planned.

8. Jobs, skills and economy

CEC’s ‘Jobs, Skills and Economy’ topic paper reveals that the high expectations for new job creation underlying the first Local Plan have not materialised. In fact, there has been a net decrease of 6,000 in number of jobs. This means that the huge allocations of land for employment and housing were overestimated, with only a quarter of the new land allocated for employment being taken up. There does not appear to be a survey of employment sites to show how many established ones are vacant, but it’s clear there is no need to allocate more land for employment. CEC should instead be considering re-allocating land for other purposes, particularly given the rise in home working.

Other sectors the borough should make provision for

The topic of home working has not been addressed, which is odd considering 2023 figures show 44% of UK people work from home at least some of the time. This change should be reflected in the design/layout of homes being built. Small communities – particularly rural and semi-rural ones – might benefit from having modest IT hubs. CEC shouldn’t be thinking just about how it can help large and medium sized businesses but should be thinking about small businesses, people working from home, and rural businesses.

Supporting the green economy

CPRE wants to see solar panels on the roofs of warehouses, car parks, and commercial buildings, rather than on green fields. CEC should promote this.

As CEC has (in common with other local authorities) taken over Local Enterprise Partnership responsibilities, the Council should be harnessing the possibilities of digital connectivity and supporting the creation of local enterprises, particularly those set up for community benefit.

Logistics centres

The Issues paper itself recognises that the freight and logistics sector ‘contributes to pollution and congestion’ and ‘can have a negative impact on the UK transport system and the environment’. With the vast global logistics hub near the airport, and the planned extensions to Midpoint 18 off the A54 at Middlewich plus hubs just over LA borders at Winsford Gateway and Trafford Park, there should be no more logistics centres built.

Tourism and the visitor economy

There is a need to reduce the emphasis on major tourist destinations, and draw more attention to those small attractive villages whose hospitality and retail businesses would benefit from more tourism.

We do not agree with the statement in the Issues Paper that ‘the extensive footpath, cycleway and bridleway network is a key attraction of the borough’, because those that do exist suffer from poor or non-existent maintenance. We advocate a network of quiet lanes and greenways.

9. Transport and infrastructure

• Active travel should be supported through a network of quiet lanes and greenways, plus more cycleways and cycling storage.
• Poorly maintained roads and cycle lanes are a danger to cyclists who have to divert into traffic to avoid hazards.
• We note the suggested 5 improvements to benefit walkers, wheelchair users and those with impaired mobility, and would add the wider provision of dropped kerbs.
• Lower speed limits (20mph in villages, 40mph on rural roads) would encourage more to walk and cycle and reduce accidents.
• The Plan should make a commitment to focus new developments in places where public transport already exists or can be easily provided, and there must be a requirement that developers contribute to it.
• Access to rail stations requires improvement.
• We support the re-opening of the railway station at Middlewich.
• We are concerned that recently introduced parking charges will harm smaller centres where parking was previously free.

CEC must resist calls for new roads or bypasses as these only provide short term relief, generate new and extra traffic movements, and quickly fill up and create demands for further highway capacity

Local Plan Transport Fund Allocations

National funding re-allocated from the HS2 pot will give CEC an extra £180m to spend on transport interventions over a 7-year period from 2025/26. Full guidance on how the money can be used is still to be issued. Regardless of what develops, if CEC is to meet the targets to make Cheshire East a carbon neutral borough by 2045, it must put climate change at heart of both the Local Plan and the Local Transport Plan.

Sustainable transport policies are essential, focusing on integrating land use and transport planning – as required by the NPPF – to reduce the need to travel.

Options for using the new transport funds should therefore include interventions such as introducing carbon-free bus services, improving access to stations, and improving walking and cycling facilities including safe routes to school

CEC should bear in mind that the top transport priority of the public in surveys is always the maintenance and safety of the existing road infrastructure.

We commend to CEC the CPRE Transport Policy. This advocates a sustainable transport hierarchy with digital connectivity at the top.

10. Historic environment

It’s not possible to respond to general questions about heritage matters, as we are still awaiting the new central government National Development Management Policies. These will incorporate a suite of heritage policies.

Jodrell Bank

It’s not clear why the Jodrell Bank Observatory Supplementary Planning Document was not finalised and adopted following consultation between December 2021 and Feb 2022.

Now that the site is a designated World Heritage Site, there should be no further inappropriate development in the ‘buffer zone’ around it.

11. Towns and villages

Settlement hierarchy

Villages identified as ‘Local service centres’ should not all be placed into a single classification. This is because they vary so much in size and features and in their ability to absorb expansion.

Distribution of development

A point should be added relating to the need to identify where land can be re-allocated for different purposes, for example in failing retail areas and areas currently allocated for employment use but no longer required.

How to supporting the re-use of previously developed and urban land while making sure sufficient development comes forward

• Ensure that the brownfield register is fully up-to-date.
• Co-ordinate infrastructure to bring forward more brownfield sites.
• Encourage higher densities where appropriate to the character of the area.
• Promote proactive use of masterplans, compulsory purchase, and other planning tools.

Right matters identified?

We are glad to see that landscape impact, green belt and air quality are listed as important issues to take into account in selecting development sites for the Local Plan. We also note the reference to ‘accessibility of the site to important services and facilities’ – this is often a key issue that is not fully resolved when new developments are proposed. Appropriate educational and medical facilities are paramount.

Supporting community facilities

To support existing and proposed community facilities, the Plan could state that new development should be sited in locations that are either well-served with facilities or can be made to be.

Other issues

We call for CEC to carry forward the Village Design Statements that existed when the first Local Plan was created (a previous call that CEC rejected). Most of these statements could still apply, with suitable updating.

12. Rural matters

• CEC needs to introduce a policy to protect farmed countryside from potentially damaging developments and other uses which deplete natural assets and the long term benefits they provide. This includes not just ‘best and most versatile’ land, but also grade 3B agricultural land. Some carefully-designed affordable housing in places served by public transport (or which could easily be so) is appropriate.
• CEC could consider establishing a local partnership of farmers, landowners, NGOs and experts to develop a vision and plan which addresses the challenges and opportunities.
• There are no exceptional circumstances that would justify making further alterations to Green Belt. CEC maintained during the previous Local Plan process that it would not need to allocate more green belt for development than it already had for the coming plan period.
• We recommend CPRE’s Green Belt report – The state of the Green Belt 2023 – a vision for the 21st century.
• CEC should respect the Green Gap designation more in future – it has not proved a robust mechanism for protecting undeveloped areas in the past.
• In general, CEC should give greater consideration to the needs of rural residents across all its policies.

13. Minerals

• We recommend a holistic approach to minerals and waste policies. Both topic areas should take account of the wider sub-regional picture, to encourage practices such as the recycling of aggregates from demolition sites.
• There should be a policy proposition stating that it is necessary to achieve the more prudent use of natural resources through re-use, recycling and the use of alternative materials wherever possible.
• The number of heavy lorry movements relating to quarries should be addressed.

14. Waste

All household waste sites should be safeguarded. The decision to mothball or close 3 household recycling centres is a backwards step.

15. Any issues not covered that should be

The following issues are not covered, but are required by the NPPF:

Leisure, telecommunications, security, water supply, wastewater, flood risk, community facilities including health, education and cultural infrastructure and conservation and enhancement of the natural environment including green infrastructure.

It is also a moot point as to whether landscape is adequately dealt with.

We hope that the financial pressures assailing CEC do not prevent it producing a sound and resilient second Local Plan.

Next steps

Read the full CPRE Cheshire response to the CEC Local Plan issues consultation.

Read the CEC Local Plan consultation document and have your say

More information

CPRE Report: The state of the Green Belt 2023 – a vision for the 21st century.

National Planning Policy Framework (NPPF)

CPRE Transport Policy