General Objections to the GM Spatial Framework in its entirety
Email your objection to the planners at: GMSF@agma.gov.uk [include your name, address and postcode] by midnight Monday 16 January 2017. Ideally, say why you are objecting. Below are some reasons.
We are objecting to the entire GMSF in principle because it is using projected figures for the next 20 years to justify releasing swathes of land. We consider this is far too speculative, leading to the loss of greenbelt for no real reason. More specifically:
1. Lack of integration of housing and transport infrastructure developments. The Spatial Framework focusses attention on housing and industrial sites that provide employment. However, an informed response on these matters cannot be made by residents unless specific plans are tabled also regarding the transport infrastructure. What we have seen over the years is incremental development of housing and very little attention to infrastructure beyond providing access to existing roads. Consequently, communities struggle along with congested roads and railway carriages, with time-consuming delays to journeys. We have reached the stage where major infrastructure enhancement is needed to support the proposed developments, but there is nothing on the table to address these needs. A vision for transport in 2040 is not satisfactory; specific proposals that address the needs of specific housing developments are required. Consequently, the whole plan is flawed and needs to be rejected.
2. Housing projections for Greater Manchester.
The GMSF document refers to a “Population growth of 294,800, which translates into 227,200 net new homes.”
This means an occupancy level of 1.3 people per home. This is very low – much lower than the average figure now (2.35) and the projected figure for 2039 (2.21). If a more realistic occupancy level is used, the number of new homes would be significantly lower and the pressure to use green belt land would disappear.
3. Housing projections for Tameside.
The Tameside figure is 6% of the GM total. To assess Tameside’s needs, we need the Tameside population growth estimates. Tameside is estimated to be growing at 3.8% – according to the Office for National Statistics. This is made up of 3.2% natural growth; 0.1% UK migration;
and 0.5% international migration. As these figures emerged in 2014, the implications of Brexit have not been considered. If we take the figures as presented, we are effectively building in a contingency for additional population growth. The estimated population of Tameside in 2015 is 221,403 and in 2035 it is 235,885. This gives us a 20-year growth of 14,482.
Yet, the total number of additional Tameside houses is said to be 14,942. This represents a theoretical occupancy level of 0.97. It can be inferred that Tameside is being asked to build additional houses for the benefit of Greater Manchester. It means that the additional residents are likely to be commuters, aggravating the increase in congestion coming from the natural growth of Tameside’s population.
The strategic housing land availability for Tameside based on brownfield sites leads to a figure of 8,507 new houses. The Plan allows a windfall addition of 1,000 houses so that the total is 9,507. Compare this with the estimated Tameside population increase of 14,482 over the next 20 years. This gives an average occupancy level of 1.5 people, well below national averages.
The conclusion I draw is that brownfield sites can supply all Tameside’s housing needs without resorting to using any green belt land. The Spatial Plan is not only asking Tameside to supply housing for Greater Manchester, it is asking Tameside to unnecessarily sacrifice large areas of green belt land.
4. “Brownfield sites first” lacks protection. The Spatial Plan takes it for granted that brownfield sites will provide the major part of GM’s housing needs. However, there is nothing in the proposals that will make this a reality. Once the Green Belt sites have been reclassified and the Spatial Plan is approved, there is nothing to prevent developers cherry-picking the green field sites they want to develop. We need a Spatial Plan that builds in safeguards – if land is to lose its Green Belt status, it must be conditional on there being no brownfield sites left for construction work. The planners must recognise the problems here and make it explicit that Green Belt developments can only take place when there are no other alternatives. We need reassurance about protecting Green Belt land in accordance with the National Planning Policy Framework. We propose a review after 10 years – that can trigger a fresh examination of whether Green Belt land should be reclassified.
[this is an extract of David Tyler’s objection, which you are welcome to quote from or adapt].