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.
Last night, I read the 896 page Site Selection document, an interesting but long read! Some good points for people to consider in their responses.
From what I read, the GSMF site selection methodology was used to identify the most sustainable locations for development that can achieve the GMSF Vision, Objectives and Spatial Strategy. The objectives that helped to form the Site Selection Criteria are –
1. Meet our housing need
2. Create neighbourhoods of choice
3. Create a thriving and productive economy in all parts of Greater Manchester
4. Maximise the potential arising from our national and international assets.
5. Reduce inequalities and improve prosperity.
6. Promote the sustainable movement of people, goods and information
7. Ensure that Greater Manchester is more resilient and carbon neutral city-region.
8. Improve the quality of our natural environment and access to green spaces.
9. Ensure access to physical and social infrastructure.
There were seven site selection criteria developed for sites in the Green belt. These were –
1. Land which has been previously developed and/ or land which is well served by public transport
2. Land that is able to take advantage of the key assets and opportunities that genuinely distinguish Greater Manchester from its competitors.
3. Land that can maximise existing economic opportunities which have significant capacity to deliver transformational change and / or boost the competitiveness and connectivity of Greater Manchester and genuinely deliver inclusive growth.
4. Land within 800m of a main town centre boundary or 800m from the other town centres centroids.
5. Land which would have a direct significant impact on delivering urban regeneration.
6. Land where transport investment (by the developer) and the creation of significant new demand (through appropriate development densities) would support the delivery of long-term viable sustainable travel options and delivers significant wider community benefits.
7. Land that would deliver significant local benefits by addressing a major local / problem issue.
As far as I can see, the GM Site 38 in High Lane, meets only one of these criteria, (see the pictures) which is Criteria 7 – Deliver significant local benefits by addressing a major local problem / issue. Criteria 7 relates to sites which have the potential to deliver signifcant local benefits by addressing a major local problem / issue. These issues were identified using local knowledge.
It relates to sites which can demonstrate direct link(s) to addressing a specific local need. To meet the criterion a site would be required to bring benefits across a wider area than the development itself and / or would bring benefits to existing communities. The type of benefits that potential sites could deliver are:
• Provide deliverable sites for housing in the north of Greater Manchester where there is an opportunity to capitalise on an existing high end market housing area and / or provide an opportunity to diversify the housing market, controbuting to the competitiveness of the north.
• Provide a specific type of housing to meet a locally identified need e.g. older persons accomodation
• Development would allow for the re-use and enhancement of an at-risk heritage asset
• Development would allow for the provision / retention of unviable community facility e.g. sports pitches
• Development would deliver signifcant highway improvements which will help to resolve existing issues in the wider area.
In my opinion, it is not clear what specific local need this addresses and from the bullet points provided above, none of them would applicable. As such, I have asked Council Officers what specific local need was identified that this allocation addressed?
In addition, again in my opinion, the proposed parcel of land would go directly against 4 of the 9 objectives of the GMSF
1. Promote the sustainable movement of people, goods and information
2. Ensure that Greater Manchester is more resilient and carbon neutral city-region.
3. Improve the quality of our natural environment and access to green spaces.
4. Ensure access to physical and social infrastructure
Finally, in their own Green Belt topic paper, they put forward their case for the re-allocation of greenbelt land due to exceptional circumstances (Page 22 - https://www.greatermanchester-ca.gov.uk/media/1739/green-belt-topic-paper-w-cover-web.pdf ). It states - The selected strategic locations and allocations in the Green Belt are well served by public transport, take advantage of key assets, maximise economic opportunities which have significant capacity to deliver transformational change, deliver inclusive growth, support town centres and have a significant impact on their regeneration, deliver long-term sustainable travel options and enable significant wider community benefits;
This is clearly not the case for Allocation 38 where it is -
1. Not well served by public transport
2. Does not take advantage of key assets
3. Will not deliver transformational change
4. Will not deliver inclusive growth
5. Does not support town centres
6. Will not deliver long-term sustainable travel options
7. Is unlikely to enable significant wider community benefits.
At last nights Marple Area Committee, one of the Agenda items was regarding the GMSF. While Cllr Blair welcomed the fact that SMBC have arranged some drop in events (see webcast below), he called for the other Councillors to back him in having an Extraordinary Marple Area Committee in High Lane and inviting Council Officers to discuss only the GMSF.
Thankfully, all Councillors supported this proposal so hopefully we can get the date sorted soon.