I have written to the Greater Manchester Combined Authority today with my response to the draft Greater Manchester Spatial Framework, detailing my concerns as well as those of my constituents. You can read my submission in full below.
“To whom it may concern,
I am writing to respond to the consultation on the Draft Greater Manchester Spatial Framework (GMSF). Many constituents have been in touch with me expressing their deep concerns about the draft version of the Greater Manchester Spatial Framework. I share many of these concerns.
I am aware that in August 2014, the Greater Manchester Combined Authority (GMCA) agreed to prepare a joint Development Plan Document, the GMSF, to set out the approach to housing and employment land across Greater Manchester for the next 20 years.
I support this sub-regional approach. According to the 2011 Census, approximately 36,340 people who live in Oldham commuted to other parts of Greater Manchester and beyond for work purposes. Although I welcome Oldham Partnership’s Work and Skills Strategy, whilst we would wish to enable people to live close to where they work, it is clear that with increasing connectivity, people will continue to travel for work. Planning for the jobs of the future needs to be done at a sub-regional level to ensure all parts of our communities benefit, as well as maximising the use of dwindling public resources. So it is entirely appropriate to consider both the housing and business needs of Oldham borough in the context of Greater Manchester’s.
I also support the principle of a strong Spatial Framework for Greater Manchester which shows ambition and confidence. We need to be bold and see the GMSF as a key part of developing a new industrial revolution for Greater Manchester, with Oldham, and other boroughs, transformed to a new glory, taking an unprecedented place in our region’s future, where everyone can get on, can fulfil their potential and has a home and leisure space that meets their needs at every stage of their lives.
I do not believe the draft GMSF meets these aspirations. The mix of housing to enable this is missing from the draft GMSF. In addition, whilst I recognise and support the need for business developments close to infrastructure and welcome proposals that will improve access to jobs, we must enable growth in high skilled jobs, particularly with the development of future jobs for our young people. I do not see plans for this in the draft GMSF.
In particular, I am very concerned about the proposals for development on 28% of Green Belt land across Greater Manchester and in particular 3% in Oldham. We should not forget how important green spaces are for our physical and mental health. Many of my constituents, as well people across Greater Manchester, greatly appreciate the access to green space and we need to do more, not less, to ensure all people in our sub-region have access to these spaces rather than reduce this.
I believe that we must further investigate brownfield sites before even considering encroaching on Green Belt land, which as current planning guidance says, should only be developed in ‘very exceptional circumstances’. I understand that the GMCA already has 1,000 hectares of undeveloped brownfield sites which would yield at least 55,000 new homes, nearly a quarter of the 227,200 homes the draft GMSF estimates it will need to house 300,000 more people by 2035. But this is based on out of date estimates. A new brownfield site register needs to be developed so there is confidence that all brownfield sites across Greater Manchester have been fully explored.
I am also concerned about some aspects of the methods and process used for developing the draft GMSF. Firstly, it needs to be recognised that population forecasting is not a precise science and becomes less so the longer the time period you use; a more cautious approach should be taken. Secondly, the GMCA invitation to developers to identify land for development, as well as the assumptions that have been made to justify these proposals do raise serious concerns. Many developers build by volume to maximise profit margins; as a consequence many favour large new Green Belt developments rather than brown field developments in town centres. I propose that in addition to updating the brownfield site register, the GMCA should look to address issues that prevent development on urban land such as land-banking, access, contamination, and split ownership. Thirdly, I am most concerned regarding the lack of joined up planning between the draft GMSF and the Greater Manchester for Transport’s strategy for 2040; this must be rectified in a subsequent document.
There needs to be a focus on regenerating our towns and encouraging people to live in these areas. Many town centres have felt abandoned for a long time and it’s important we focus on reviving our town centres with a mixture of commercial and housing investment. It may also be more beneficial given better access to public transport and infrastructure. These decisions will impact future generations and it’s important we don’t rush but get them right.
It is also of concern that 10 large housing developers all claimed that the authority’s objectively assessed need figure was too low, whereas the Campaign to Protect Rural England claimed it was “excessively high”. Faced with such wild variance in the estimates of population growth, it is difficult to have faith in the combined authority’s predictions.
I have had discussions with constituents and local planners about the draft GMSF. Many of my constituents have raised concerns about Green Belt development both in person and in writing and several local groups have come together to oppose the plans.
In fact, 3,000 people recently took part in a protest against the draft consultation and the impact on increased homes on Green Belt land in Shaw, Crompton and Royton, a local petition against 640 new homes on open protected land in Cowlishaw has also received over 1,200 signatures. It is very concerning that the plans in the draft GMSF are causing such distress and anger amongst my constituents. Many feel their neighbourhoods will be disproportionately affected.
In addition to the threat to the much valued green space, they have concerns that the current infrastructure would not be able to cope. Our local road network is often gridlocked, the air quality is poor and there is low confidence in much of our local public transport. It is unclear to me as to what funding, if any, will be made available to update existing transport infrastructure or to create the new transport infrastructure needed to meet the aims of the draft GMSF. The draft plan mentions no provision for new railway stations or transport infrastructure. In addition, what new health and education facilities have been factored in to such a large development in an area where these key services are under immense pressure? The GMCA needs to engage with local residents on this issue, including the Save Shaw’s Greenbelt group.
There are similar concerns from residents to the proposed development at the old Fletcher Mill site in Greenfield, Saddleworth. There have been some thoughtful alternative proposals for the site that would both boost tourism rather than the proposed 120 holiday lodges whilst also supporting small business start-ups, something which Oldham is lagging behind the rest of Greater Manchester. I would urge that these alternatives be fully explored and that the GMCA engages with both the Dovestone and Chew Valley Action Group and the Greenfield and Grasscroft Residents Association.
The north of Oldham borough is the location of a number of regionally significant “strategic” development allocations. Up to 2035, an indicative capacity of 690,000m2 of industrial and warehousing floorspace has been identified for Oldham, alongside 80,000 m2 of office space. A requirement for an additional 13,700 dwellings has also been set over this time period. This equates to 6% of the Greater Manchester total and would mean an average of 685 new homes being built every year, representing a significant increase on current house-building targets.
The town centre will continue to be recognised as the primary focus for economic, civic and cultural activity (including retail, leisure and tourism), as well as a public transport hub, with residential development being supported in this location where it complements other uses.
Housing proposals in my constituency area of Cowlishaw see a proposal for the development of 640 dwellings. In July 2016 an outline application to build 125 houses on Cowlishaw (currently designated as Other Protected Open Land in the Local Plan), was published. This did not go ahead. I am unclear why this is being pursued as part of the draft GMSF proposals when a smaller development was rejected by Oldham Council.
There is also a proposal for a major loss of Green Belt land alongside the M62 and A627M motorways for the proposed Northern Gateway of homes and business premises. The proposal to allocate land to the south of Junction 21 includes 1,500 new homes, with the majority of these (1,440) being in Oldham. Development would include the area around High Crompton are proposed. Given the recent medical research on the risks of living close to busy highways on health including the incidence of Alzheimer’s disease; recognising the importance of the precautionary principle, what health protection measures are being sought in future developments?
The Beal Valley – an area of Green Belt lying to the west of the Shaw/Rochdale Metrolink line proposes 900 new homes.
The GMSF has earmarked three areas of protected land in Shaw, Crompton and Royton all within a 2km radius. Many of my constituents feel the allocations selected are disproportionate and unfair. Shaw, Crompton and Royton will have a real hit on its recreational green spaces. Many residents are also concerned about how roads, schools and health services will cope with the additional homes proposed in the area.
In addition, as previously stated, I do feel the lack of high skills jobs infrastructure identified is a concern. We must be looking towards the jobs of the future including advanced manufacturing and digital developments.
Broadbent Moss partially falls within the St James’ ward in my constituency. The proposals for the area of Green Belt lying between Higginshaw Business Employment Area (BEA) and Heyside to the west and Broadbent and Sholver to the east, are to provide 47,040m2 of high quality employment floorspace, to complement the existing BEA, and 1,000 new homes on the land to the east of the Metrolink route between Broadbent and Sholver. Again I reiterate my points on the inappropriate development of the Green Belt.
It is also proposed that Robert Fletchers, the redundant paper mill, associated buildings and surrounding land in Greenfield sits next to Dovestone Reservoir, at the edge of the Peak District National Park, will include 100 holiday lodges, alongside 120 new homes. This will involve an amended Green Belt boundary and it is unclear that any impact on transport infrastructure has been factored in particularly given the village roads. It also concerning that whilst 220 homes are proposed, 120 will be holiday lodges – more than half of the developments proposed.
I repeat my concerns about the de-designation of Green Belt land.
Finally, whilst I accept the authorities have made attempts to engage with some local residents, I have had reports that the purpose of these events was unclear, venues not accessible and the timings not well publicised. Further the GMSF web based consultation portal is not easy to navigate and a constituent told me it took her more than three hours to find the information in relation to Oldham Borough. It is important that the public have confidence in the system and the way the consultation has been administered has not helped.
The draft GMSF proposals need to be reworked. As it stands, I do NOT support the proposals. In particular, I do not support the proposals affecting Oldham and my constituents.
I recommend the following:
- The vision for development in Greater Manchester, including Oldham borough, needs to be more ambitious, underpinned by the principles that no part of Greater Manchester is left behind, everyone can fulfil their potential and have a home for every stage of their life. To do this we need development for high skilled jobs for the future and a diverse, affordable mix of housing; this is not reflected in the current draft GMSF.
- The assumptions on population growth driving demand for housing and jobs in the future, need to be revisited.
- The Brownfield (BF) site register needs to be updated – the current BF supply has not be adequately factored in to the draft GMSF proposals.
- The presumption for Green belt development needs to change to reflect current planning guidance, that is, it should only be used in ‘very exceptional circumstances’.
- More needs to be done by the GMCA to remove obstacles for developers to commit to BF and town centre regeneration and development, including decontaminating land.
- There needs to be more joined up thinking between different parts of the public sector, for example, planning and transport, planning and education, planning and health.
- At the heart of a future GMSF must be the people we serve – these new proposals should fully and meaningfully engage with local people, including all elected representatives.
I look forward to engaging with you in the development of the next iteration of the GMSF.
Debbie Abrahams MP
Member of Parliament for Oldham East & Saddleworth”