Transition Wilmslow Response to the Cheshire East Sustainability Appraisal

Transition Wilmslow welcomes the opportunity to respond to the consultation on the
draft Sustainability Appraisal of the draft Wilmslow Vision. We have the following
comments:

1) In our response to the consultation on the Wilmslow Vision itself we made
clear that, although we were consulted to a degree in the stakeholder meetings,
some key aspects of the published document were not discussed in the
meetings, nor did we have sight of or endorse the specific proposals within
the Vision document. We therefore formally object to two statements in the
draft Sustainability Appraisal: para 1.5 ‘The draft Wilmslow vision has been
developed in conjunction with the stakeholder group…’ and para 2.8 ‘The
draft Wilmslow Vision has been developed by a stakeholder panel for the
town…’

2) We argued in our response to the draft Wilmslow Vision that the scale
of proposed housing development was not properly justified and that
it represented an ‘unsustainable level of growth’ , requiring as it does
development on open countryside and a major incursion into the Green Belt.
We therefore challenge the key conclusion of the Appraisal in paragraph 1.33
that the proposals in the Vision ‘can be considered to contribute towards the
achievement of sustainability’. It seems to us that the proposals for housing
development in the Green Belt run counter to the guidance on sustainability
in the National Planning Framework (see Green Belt footnote on page 5 of
Appraisal document).

3) Sustainability appraisals run the risk of being formulaic ‘box ticking’ exercises
which do little to inform critical judgement. This is exemplified here by the
assessment of the different housing development proposals (Appendix B)
where there is little or no meaningful differentiation between the options.
This is partly because where a detailed assessment has been made, as in the
Accessibility Assessments (Appendix F), this information does not find its
way into the comparative assessment (Appendix B); perhaps because in so
many instances there is a significant failure to meet the minimum standard for
accessibility.

4) A second deficiency concerns lack of appropriate survey information on which
to make an informed judgement. We highlight the following issues by way of
example in Appendix B:

• Heritage, landscapes and townscapes: The Appraisal makes bland
comments about loss of landscape character but makes no reference to the
existing Landscape Character Assessment for East Cheshire. Beyond that,
Transition Wilmslow would like to see a more detailed landscape character
assessment for Wilmslow and its surroundings which could provide a rational
basis for the Local Plan.

• Cause and effect of climate change: A local landscape assessment would
also assist in this topic area which is inadequately dealt with in the Appraisal.
This could include insights about the way development could influence
air flow between town and country with implications for human comfort,
intensification of the urban heat island and air quality (see also Pollution
section). It would also provide information on the strikingly different soil
types (sandy loam, clay and peat) which underpin Wilmslow and the proposed
development sites. Soil shrinkage will intensify with climate change and
this will differentially affect soil stability and with it land capability for
development. The contrasting permeability and run-off characteristics of the
different soils also has implications for climate resilience in the face of high
intensity rainfall and the emergent problem of surface water flooding (see also
the section on Water quality, quantity and flood risk).

• Biodiversity and geodiversity: The consultants seem to be unaware of the
very significant variation in ground conditions in the area as described above
and the fact that geodiversity is therefore a material consideration. With
regard to biodiversity, the Appraisal states that the proposed development
sites ‘are not known to contain any designated flora and fauna’; but has
anyone looked for them? An ecological survey is clearly an essential
requirement.

• Natural resources, green infrastructure and previously developed land:
All the development sites are described as Grade 3 agricultural land. Of all
the categories in the national Agricultural Land Classification scheme, Grade
3 farmland covers the greatest range of land capability but once again the
relevant site specific survey information is unavailable. The Wilmslow Open
Space Survey which informed the Wilmslow Vision is essentially a site by
site inventory. It does not recognise the critical importance of private gardens
and street trees to Wilmslow’s green infrastructure, and hence to sense of
place, quality of life and resilience to climate change; this deficiency is carried
through into the Wilmslow Vision and the Sustainability Appraisal itself.
The Wilmslow Open Space Survey recognises, but does not give proper
attention to ‘green corridors’ and ‘accessible countryside in urban fringe
areas’. Consequently these issues are identified but not well covered in either
the Wilmslow Vision or the Sustainability Appraisal. We recognise that brown
field land is in limited supply in Wilmslow. However, the very substantial
housing development that is now proposed in this part of East Cheshire will
undermine efforts at land recycling in the adjoining Boroughs of Greater
Manchester.

• Rural Economy: The effects on the rural economy are said to be positive
despite the lack of meaningful information. Four key issues under Rural
Proofing (Annex E) have not been properly addressed – loss of farmland
to development, effect on farm structure, effect on landscape character and
accessibility to the countryside.

We recognise that the draft Sustainability Appraisal of the draft Wilmslow Vision
is not a statutory requirement at this stage and has been produced to assist the local
plan process and to facilitate public engagement. However we consider that the
information deficiencies, as illustrated by the examples above, are such that it calls
into question the value of the exercise at this stage in the process. It seems like a hasty
attempt to provide a superficial legitimacy to a planning process that is receiving
vociferous criticism from the residents of the town that it seeks to serve. We would
welcome an opportunity to meet with planning staff and/or elected members to
see if there are ways in which we and other local groups can help to strengthen the
knowledge base for the Local Plan.

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