Submission to Greater Manchester Combined Authority Public Consultation
Draft Greater Manchester Spatial Framework
David Nuttall MP, Member of Parliament for Bury North
12th January 2017
I wish to make a submission to the Consultation in my capacity as the Member of Parliament for the Bury North constituency. I wish to voice both my own concerns and those of many of my constituents who have contacted me about the proposals contained within the Greater Manchester Spatial Framework (GMSF). It is not my intention to regurgitate each and every one of the many points which have been raised with me but rather to summarise the main strands of concern. I wish to put these on record particularly as they will I am sure be some people who have mentioned their concerns to me and not formally, for whatever reason, been able to make their own individual submission. Indeed there has been discussion in Bury over the lack of publicity of this matter.
It is of course sensible to have a plan setting out how land should be used in the future taking into account the need for future housing, jobs and infrastructure. However, such a plan must be sensitive to the needs of the local community. Whilst residents may have much in common, the area of Greater Manchester is essentially a collection of communities with established individual identities. The GMSF will fundamentally change areas residents live in and it will permanently remove areas of amenity they currently visit to enjoy unspoilt countryside. When considering the GMSF, it is important to remember that this will change the area permanently for all future generations.
Consequently it is important great care is taken before further progress is made. I also wish to set out some further matters which have been raised with me by my constituents I believe should be taken into consideration.
The GMSF covers a period of up to 2035. My understanding is there is no legal reason stipulating why it must cover such a long period of years. The draft Greater Manchester Combined Authority (Functions and Amendment) Order 2016 does not mention a specific timeframe that the GMSF must cover. Similarly there is nothing in the Greater London Authority Act 1999, which is the legislation from which many of the powers of the Greater Manchester area are copied from. Development plans in general are provided for in the Planning and Compulsory Purchase Act 2004 and there are no timeframe stipulations in that either.
The National Planning Policy Framework (NPPF) gives guidance on what is normally considered to be an appropriate timeframe for local plans. The NPPF suggests these plans be drawn up over an appropriate time scale, preferably a 15-year time horizon. Assuming the GMSF were to be adopted in 2018, its planned length of operation would exceed this recommendation for a local plan.
I believe the Greater Manchester Combined Authority (GMCA) should reconsider the length of time the GMSF covers
The GMSF consultation is based on a projected population growth of 294,800 by 2035, which the GMCA equates to a requirement of 227,200 net new homes. Around 12,000 of these new homes would be expected to be constructed in Bury
I doubt the accuracy of these figures and query whether they overestimate the projected population increase. I accept the inherent difficulty in making population predictions with any degree of certainty. The baseline forecast change suggests a Greater Manchester population change of 214,600 between 2014 and 2035 of up to 537,100 in the higher accelerated growth scenario. Even within Office for National Statistics (ONS) projections in recent years, there has been significant variance.
Within Bury, over the last five years there has been a change of population from 185,422 in mid-2011 to 187,884 in mid-2015 according to ONS estimates. The GMSF would seem to suggest this trend would increase far more than it has in the last five years.
Recent forecasts from the ONS have shown a variance of almost 200,000 people between the highest and lowest estimates for the year 2032 from just the 2008, 2010 and 2012 forecasts. There is too great a margin of error to use the GMSF figure as the projected population growth.
I do not believe sufficient allowance has been made for the likely fall in immigration following the referendum on the UK’s membership of the European Union and the likely ending of free movement of people. These figures were determined prior to referendum result and do not account for the developing political changes in the UK where there is an expectation that immigration will fall after the UK leaves the EU. There have been a number of new residents form Eastern Europe who have moved into the area.
I do not accept the projected figure for the number of new dwellings required. I believe these figures overestimate the numbers of houses required and I query the figure of 227,200 new households being formed by 2035 on two grounds. Firstly, the figures the GMSF use are based on an expectation of approximately 1.3 persons per dwelling. The 2011 census had a UK average of 2.3 persons per dwelling compared to 2.4 persons per dwelling in 2001. This therefore seems to assume that a lot more people will be living alone and households are getting significantly smaller, far more than the rate in the previous decade for which data is available.
The second issue with this projected number of households is the number of vacant properties in Greater Manchester.
Whilst I recognise that there has been a reduction of the number of vacant properties in Greater Manchester from a peak of 31,997 in 2008, there is still an estimated 11,873 vacant properties across the region and 907 in Bury (2015 ONS figures). There needs to be continued attention given to bringing back empty properties into use which would reduce the number of new dwellings required.
I believe the GMCA should review the projected population increase, the projected number of households needed to accommodate that increase and reconsider how much of that demand can be dealt with using existing housing stock.
PRIORITISING BROWNFIELD SITES
In addition to maximising the use of the existing housing stock, before releasing greenbelt land for development, the GMCA should comprehensively prioritise brownfield sites, regenerating our towns and stop unsightly derelict industrial areas falling into further disrepair. This is a progressive step rather than the regressive encroachment on greenbelt land.
In Bury, as of 31st March 2015, there were 399 properties with unimplemented planning permissions, a small rise from the previous year. Only 223 of these were under construction at this date, down from 350 under construction in 2013.
Greater Manchester has at least 1000 hectares of brownfield land divided across some 439 sites which are not yet developed for housing or with planning permissions attached. If the aim of the GMSF is to provide homes for an expected increase in the population of Greater Manchester population and make best use of available land it is vital these brownfield sites are all developed first. If the protection of the green belt is removed from vast swathes of land around Bury it will simply serve as an encouragement for developers to build on these sites and the brownfield sites will never be developed. Given the choice I believe a developer will always seek to develop a greenfield site over a brownfield site.
One major concern over the proposed new developments is affordability. Many people have expressed their worry to me that by allowing development on the greenbelt there will a prevalence of high value larger family homes and more modest and more affordable homes will not be provided. Brownfield sites have great potential in this respect yet only 40% of the proposed development for Bury comes from brownfield sites. This misses an opportunity. Whilst high-rise flats would not be appropriate, more could be done to encourage increasing the density of development on brownfield sites with smaller houses or modest – 3/4 storey – apartments. These are likely to be far more affordable for first time buyers. The existing proposals appear unduly weighted towards providing an easier and potentially more lucrative option for developers to use greenbelt land. I believe there is a greater likelihood of affordable homes being built by increasing density and utilising brownfield sites than there is by encouraging developers to build new housing estates on greenbelt land.
If properly utilised, there is enough brownfield land in Greater Manchester to build at least 55,000 houses at a density of 55 homes per hectare. This would solve one quarter of the problem the GMSF says it is trying to address. If a higher density was used then of course the number would be even greater. It is not just about building houses but about building communities with amenities and making them places people want to live. This is why brownfield development will always be a better option. Communities where land is regenerated surrounded by beautiful countryside.
It is important to note that whereas the supply of greenbelt land is finite as time passes and industry and commerce change more brownfield land does become available. What might be a busy working mill in one decade can become a brownfield site ripe for redevelopment in the next. This is why I believe the GMCA should redraft the GMSF so that it focuses only on brownfield sites in Bury.
SAVING THE GREENBELT
One of the many attractions of Bury is its location close to villages, open countryside and green spaces. With increasing urban sprawl comes a loss of distinction. There is a great sense of pride in Bury and its greenbelt land is enjoyed by walkers and joggers, families and dogs all aiding physical and mental health.
The GMSF would destroy 8% of greenbelt land across Greater Manchester. 4,900 hectares of land would be irreversibly lost.
The Elton Reservoir development would see 3,460 new homes at a cost to a vast range of wildlife including 186 species of bird, 39 of whom are protected by law. From deer to bats, badgers to otters an enormous number of species would be adversely affected. Elton Reservoir contains 10 different council-designated sites of biological importance and the most concentrated and diverse group of wildlife sites in Greater Manchester.
Whilst I am reluctant to draw attention to any one objection which I have seen above any others I would urge GMSF pay particular attention to the ecological points made in the submission by David Bentley, Ecological Consultant.
As a general point, I would note that many people have raised me the 2015 Boxing Day floods which should serve as a reminder of the threat of weakening natural drainage up river from potential flood zones.
In addition to the Elton reservoir site the Walshaw development where 1,250 new homes are planned is an area incorporating a Site of Biological Importance with its biodiversity irreversibly threatened.
The danger with green-lighting greenbelt development is that it will encourage further attempts to build and does nothing to solve the problem of waste brownfield land. The countryside is one of this nation’s greatest assets and should not be wilfully disposed of when other options remain.
The planned expansion of housing across Bury would put yet more strain on the already overstretched infrastructure of the town.
Already the roads are frequently gridlocked. The area is notorious for its very poor road links arising out of the geography of the town. The route opportunities to travel North-South or East-West in the constituency are very limited.
The schools are already full and there is a lack of school places.
More homes would put more strain on the local NHS whether it is GP’s,
acute hospital provision, dentists or continuing care.
Existing drains and sewers are already frequently overloaded and there would need to be a huge programme of improvements before any housing on the scale being proposed could be safely constructed.
Providing more homes on brownfield sites close to town centres is advantageous on many levels. It puts people near local businesses and facilities. It builds communities.
The GMSF proposes a radical changes to the land use within the Bury North constituency.
The case for the GMSF covering the period right up to 2035 has not been made and is not required by law and its length of operation exceeds that recommended even for a local plan.
There is uncertainty over the projected population growth figure given the changing political landscape following the EU referendum.
The case for basing the number of new dwelling on only 1.3 people per dwelling compared to the national average of 2.3 (as per the 2011 census) has not been made and provides further evidence the projected housing need has been overstated.
I and the many other people I have spoken to in Bury and the surrounding areas are overwhelmingly of the view that the greenbelt should be protected and brownfield sites regenerated. We understand and support the need for new houses where needed but these must be constructed on existing and future brownfield sites.
The danger with giving a green light to greenbelt development is that it will encourage further development and does nothing to solve the problem of unused brownfield land. The countryside is one of this nation’s greatest assets and we should not allow it to be used for development when other options remain.
I do not believe the ecological impact on areas including Elton Reservoir has not been given enough weighting.
It is clear to everyone local that the infrastructure presently in place would be simply unable to cope with this level of development. There would need to be an enormous improvement to the infrastructure.
I believe the existing plan is not acceptable in so far as it affects Bury and the GMCA should re-consider the various aspects I have raised and remove any proposed development on the green belt.