Bury Local Plan Consultation Final Chance

The Consultation by Bury Council on the proposed local plan closes at 5pm today so what better opportunity on a Bank Holiday than to make your views known.

You can read about what is proposed and how to submit your views here:

http://www.bury.gov.uk/index.aspx?articleid=10735

The submission I have made is follows:

This submission is made in response to the ‘Notice of Intention to prepare the Bury Local Plan and invitation to make representations on what the Local Plan should contain’ issued pursuant to Section 18 of the Town and Country Planning (Local Planning)(England) Regulations 2012.

  1. It is clear from the said Notice and in particular the following statement:

Given that the GMSF will form an integral part of Bury’s development plan, it is important to note that the approach set out in the GMSF will need to be reflected in the Bury Local Plan. In particular, the Local Plan will incorporate and reflect the levels of growth, the strategic policy approach, strategic site allocations and any revisions to the Green Belt that may evolve through the GMSF.

 

that the scope for any local determination of planning policy will be severely constrained by the decisions taken by the Greater Manchester Combined Authority (GMCA) and /or the Elected Mayor of Greater Manchester.

Consequently, I wish to place on record that I oppose the present proposed Greater Manchester Spatial Framework as set out in my submission to the consultation on that document.

  1. I believe Bury should make it clear they do not accept the premises on which the GMSF is based. The timeframe is unnecessarily long. The projected size of households is too low based on both historical records and the official projections of household size. The use of both a shorter timeframe, a more realistic projection of the size of households combined with greater housing density on existing brownfield land and future brownfields sites which can reasonably be expected to arise during the timeframe of the plan would remove the requirement for development on the existing green belt land.
  2. I believe Bury should make it clear to the GMCA that they will not approve any plan which involves the erosion of Bury’s existing protected green belt land. This position could be completely defended by the use of the official projections for population growth and household size.
  3. Subject to the above I believe that the Local Plan should require all the infrastructure to be in place before any new development is permitted. This must include roads, drainage and telecommunications (including the provision of superfast broadband). In the case of residential development it must be demonstrated that there is sufficient capacity in public services in particular GP’s and schools both primary and secondary to cope with increased demand.
  4. Given the recent problems with flooding throughout the Borough specific and additional consideration must be given to the risk of flooding not only to the proposed new properties but to the existing properties who may be adversely affected.

Petition Response

Readers may recall I presented to Parliament the petition about the Greater Manchester Spatial Framework which many local residents had signed.

I have now received the official government response which I have set out below. As one might expect it summarises what the present legal position and current policy is and encourages petitioners to continue to engage in the process which I have no doubt people will do.

The following is the petition and the official response:

​Declares that the Greater Manchester Spatial Framework should avoid large-scale residential development on the greenbelt, which is a valuable barrier to urban sprawl and is hugely valued by local people; and further declares that brownfield land should be prioritised for residential development provided that proper infrastructure is in place.

​The petitioners therefore request that the House of Commons urges the Greater Manchester Combined Authority and the Department for Communities and Local Government to make such provisions in the Greater Manchester Spatial Framework.

​And the petitioners remain, etc.—[Presented by Mr David Nuttall , Official Report, 13 December 2016; Vol. 618, c. 763 .]
[P001994]

​Observations from The Minister for Housing and Planning, (Gavin Barwell):

​Green Belts are created by local authorities, who are expected to protect them in line with policy set out in the National Planning Policy Framework. The Framework states that a Green Belt boundary can be altered only in exceptional circumstances, using the Local Plan process of public consultation followed by examination in public of the draft Plan.

​Local authorities, working with their communities, are responsible for determining the best location for the new homes needed in the area. The Framework recognises that, in exceptional circumstances, a local authority may find it necessary to review the extent of its Green Belt. In the Housing White Paper, Fixing our broken housing market, the Government reaffirmed their commitment to Green Belt protection, but also proposed a strengthening of the test of the exceptional circumstances in which Green Belt boundaries can be adjusted. This proposal is that local authorities should amend Green Belt boundaries only when they can demonstrate that they have examined fully all other reasonable options for meeting their identified development requirements, and that any impact of removing the land from Green Belt should be offset by improvements to the environmental quality or accessibility of the remaining Green Belt land.

​When any Green Belt alteration is proposed, the revised draft Plan with the supporting evidence is submitted for examination by a planning inspector. The inspector, who exercises independent judgement in the name of the Secretary of State, will consider whether the draft Plan is sound. A Plan will be found sound only if it is properly prepared, justified, effective and consistent with policy in the Framework.

​The Framework encourages the re-use of brownfield land, if not of high environmental value. Brownfield sites differ greatly, and local authorities are best placed to assess their suitability, viability and availability. If desired locally, a local authority may consider having its own Plan policy to increase the take-up and prioritisation of brownfield sites.

​To support development of brownfield land, the Government have accelerated disposal of public sector brownfield suitable for housing, and extended permitted development to give new life to thousands of under-used buildings. We are also introducing Brownfield Registers and Permission in principle. Brownfield Registers will provide up-to-date accessible information on the brownfield sites suitable for housing in each local authority area, giving developers, communities and investors more certainty about the potential of these sites. Permission in principle will give certainty from the outset that the fundamental principles of redevelopment are acceptable. Moreover, the £3 billion Home Building Fund will provide loans for small and medium-sized building firms, custom builders and offsite construction, and help to make more land, much of it brownfield, available for new homes. An additional £1.2 billion will be available to enable starter homes to be created on brownfield land.

​I encourage the Petitioners to contribute to the preparation of Greater Manchester’s Spatial Framework for the period to 2035, and to support creation of a plan where growth can be accommodated sustainably.

Estimates Day

Following on from yesterday’s Estimates Day One today is the second day, These are essentially the days on which the House of Commons approves the top line figures for government spending. Huge figures are passed in a matter of minutes.

Yesterday, I asked my Local Government question as I was scheduled to do.

The exchange with the Housing Minister is here:

What steps is he taking to protect the green belt in Bury. [908918]

The Minister for Housing and Planning (Gavin Barwell)

Our recent housing White Paper underlines the Government’s continuing commitment to the green belt. Local councils should remove land only in exceptional circumstances, and the White Paper clarifies what that means: when they can demonstrate that they have fully examined all other reasonable options for meeting housing need.

Mr Nuttall

When a plan proposes large-scale development on the green belt, as in the case of the Greater Manchester spatial framework, will my hon. Friend assure me that he will carefully assess how realistic the various projections and assumptions are for things such as population growth and household size?

Gavin Barwell

I assure my hon. Friend that the approach that is taken will be robustly tested by a planning inspector in public, and that he will be able to give evidence. My hon. Friend is right that before councils think about releasing green-belt land, they should consider brownfield land, surplus Government land, density and how their neighbours can help to meet housing need

Housing White Paper

The long awaited White Paper on Housing is scheduled to be published today by the government. This could have major implications for us in Bury as we battle the Greater Manchester Spatial Framework ( GMSF). I am hoping the White Paper will contain proposals which will make it easier for us to contest the assumptions which Labour have made in arriving at the GMSF. In an attempt to blame the government for their own decision to propose mass development on greenbelt land Labour are claiming they have no choice because the figures on which the plan is based are given them by the government. This is only true to the extent that the Office for National Statistics produce projections for the future population which are then distributed by government departments together with housing projections. Labour have chosen to draft a plan stretching right through to the year 2034. In addition they have chosen to adjust those figures. Adjust them by increasing them hence artificially increasing the projection. Official figures show the population of Bury has grown by 4.58%. There was an estimated population of 179656 in 1997 and in 2015 this had increased by 8228.

I look forward to reading the White Paper and it will be interesting to see to what extent it assists the case we have been constructing.

 

Last day -Last chance on GMSF consultation

The public consultation on the Greater Manchester Spatial Framework ends at 11.59pm tonight so today is the last chance for local residents to let Greater Manchester Councillors know their views on the plan to build thousands of houses on Bury’s green belt.

If you have not sent in your views and you wish to do so this is the link to the Consultation Portal:

http://gmsf-consult.objective.co.uk/portal

Can I thank all those who have sent me copies of their submissions. I am gradually acknowledging them all so my apologies if you have emailed me and you have not heard back yet!

GMSF Submission

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

INTRODUCTION

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 TIMEFRAME

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

POPULATION FORECASTS

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.

INFRASTRUCTURE

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.

CONCLUSION

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.

8

Greenbelt Walk

It might be the New Year Bank Holiday but if my alarm does the business I will be up in time to do an interview in the morning on BBC Radio Manchester on the subject of the Greater Manchester Spatial Framework. Local residents protesting against the plans to allow development on Bury’s Greenbelt are planning to walk from Elton High School to Elton Reservoir starting at 11am in order to raise awareness of what is being planned. Hopefully my interview on BBC Radio Manchester will help raise awareness too!