I have today posted my response to the second draft of the GMSF Consultation, specifically in relation to Allocation 38 which sits within the ward I represent. A copy of my response can be found below which anybody can utilise in their response to the GMSF consultation.
If you are following the debate and consultation on the Greater Manchester Spatial Framework, the plan for development in Greater Manchester over the next 19 years, you will be aware of the debate between the Govt and the GM Mayor on whether they should use the 2014 Projected Numbers or the 2016 Projected Numbers.
If the 2014 number is used, GM needs to build 201,000 dwellings over the next 19 years.
If the 2016 number is used, GM needs to build 154,000 dwellings over the next 19 years.
A Govt minister seemed to indicate recently that there was some leeway on which numbers to use and the Mayor has asked for clarification. From my research on it, there is no leeway, the 2016 numbers must not be used. The response to the Govt consultation states - "We are specifying in planning guidance that using the 2016-based household projections will not be considered to be an exceptional circumstance that justifies identifying minimum need levels lower than those identified by the standard method."
So, I agree with Andy Burnham that Greater Manchester does not have the discretion over housing numbers which was suggested by the Minister. However, while it does not have the discretion over which baseline projections to use, it does have discretion over the housing numbers. The National Planning Policy Framework (NPPF) states in Article 22 -
"Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure."
and in Article 67 -
"Planning policies should identify a supply of:
a) specific, deliverable sites for years one to five of the plan period; and
b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan."
So Planning Guidance states a 15 year period, yet GM have opted for a 19 year period. Why does this matter? Under a 19 year plan, the Housing Need is calculated as 201,000 but crucially a land supply figure of 189,000, meaning GM does not have enough land to meet the demand, which ultimately needs green belt land to be released.
Under a 15 year plan, the Housing Need is calculated as 159,000 with a land supply figure of 176,000 meaning they have more land than they would need. Indeed, given the annual housing need in GM is 10,583, they have enough land to cover just short of a 17 year plan. This means no release from the green belt in this plan period.
Given all of the uncertainty surrounding which number projections to use and the potential impact of Brexit, it would make sense to limit the plan period to 15 years. When I proposed this to the Mayor, his planning team came up with some fluff that as the 10 Boroughs will be doing their local Plans, they wanted a 19 year plan to allow them to converge, but as per the Planning Guidance, the policies should identify a supply of specific, developable sites or broad locations for growth, WHERE POSSIBLE for years 11-15 of the plan.
Allocating land from the Greenbelt based on the above is a political choice rather than a necessity. Please respond to the consultation stating that given all of the uncertainty surrounding the numbers and impact of Brexit, a 19 year plan is too long and 15 years would be sufficient. Once greenbelt land has been re-designated, it is gone forever. Send a message to those making these political choices that it is NOT ACCEPTABLE!
Yesterday, myself and representatives of Save Stockport's Greenbelt, High Lane Neighbourhood Forum and High Lane Resident's Association met with the Mayor of Greater Manchester, Andy Burnham to discuss the GMSF, as I promised would happen at the public meeting I organised.
It was an interesting meeting with lots of good discussion where we presented him with a video, told him of resident's concerns in relation to Air Pollution, traffic congestion, proportionality and the housing need numbers.
In summary, he listened, he learned about High Lane and the allocation and promised it was a genuine consultation. On that basis, whatever your views on the GMSF, whether for or against, you need to respond to the consultation.