30 Reasons to object!
To help you – feel free to include as many of the following ideas into your objection as you wish. Please use your own words if possible. The first 8 points are in our Grapevine newsletter. Points 9 to 19 refer to objections from Sports England, the Coal Board, CPRE and United Utilities (the “Water Board”), regarding the Mottram M67 plans forwarded by the Council in 2014. Some points overlap and reinforce one another, but develop the arguments from various angles.
Update:
Four more reasons to object! Web update January 2017
Once the GMSF plans are finalized, they will be sent to the Government’s inspector. He will study all the plans and ask “What are the needs?” He will then decide whether or not to accept the plans. We can help him by demonstrating there is no need for housing on our green belts for the following reasons. Feel free to add to your objection if you’ve already sent it. You can email the planners at GMSF@agma.gov.uk [+ your name, address and postcode]
1. There is no need to “build on green belt first,” rather than on brownfield. If, by inference, the planners are making the extraordinary claim that they must build on green belt as a first resort, this must be backed up by extraordinary evidence to justify it.
2. There is no need for housing on the green belts and playing field of Mottram, Godley Green and Stalybridge, nor indeed throughout the Borough. This is because the population of Tameside has plateaued, so any demand can be met from the existing supply of brownfield sites.
3. There is no need for housing because the planners have grossly overestimated the number of houses needed! The national average for house occupancy is 2.4 per household. On this basis, only 6,000 houses would be needed, easily met by brown field sites. But Manchester planners have based their requirement for 13,400 homes on a much lower house occupancy level! For more on this, see David’s post at https://www.facebook.com/LongdendaleConservatives/posts/1808855469369909.
4. A Councillor has encouraged us to say “what WE would like” instead in the plans. However, that’s not what this consultation is about, and we have not been invited to do this. Rather, the planners have just gone ahead and told us what they want to happen. This is hardly involving the community. What is more, we did conduct a survey recently to ask how the community would like the land earmarked for the district centre to be used. Not one resident wanted another supermarket and fast food outlet there. But instead of listening to us, the Council have completely ignored our views. What comes across is that the plans are developer-driven, ie planned with developers, not the community, in mind. This is evidenced by the complete lack of infrastructure planning in place.
26 reasons to object (Posted December)
1. Planners should keep industrial sites separate from housing on numerous grounds (such as safety from chemicals, explosions and other hazards). The proposed industrial site is totally inappropriate for a residential area.
2. The development will destroy green field sites. No brown field sites whatsoever have been included in these “Mottram and Godley Green” plans! This is in spite of there being lots of brown field sites throughout Hattersley. Also the planners admit in this same GMSF document that they should be using brown sites first, as a priority!
3. The sites will exacerbate the existing excessive traffic problem, and the notion that the bypass will help is highly controversial.
4. This area already has a massive air quality problem, which is not being addressed. Planners should be thinking of ways of diverting traffic from the area, not bringing in more people to intensify the already severe difficulties.
5. Godley Green commuters will add to traffic at Motttram & the train (often already full on arriving at Hattersley from Glossop and Broadbottom in morning rush-hour).
6 .The plans are at loggerheads with the planners’ promises in their document, which we quote: “Green Belt within Greater Manchester will be retained….. preserve the setting and special character of historic towns ….…..Major improvements will be secured in air quality ……emission of air pollutants will be minimised by locating development so as to minimise the need to travel….Carefully controlling developments that would generate significant pollution such as some types of industrial activity ……..even in the event of extreme weather events, new development will not increase flood risk for adjacent landowners …….prioritising the reuse of previously developed land ….Secure high levels of amenity for residents ……. “ plus see quotes on previous pages from the (faceless) planners!
7. If the Council had responded to important objections from the Coal Board, Sport England, the Campaign for Protection of Rural England (CPRE) & over 500 community residents, they would have taken Mottram M67 off the GMSF plan, & should do so now.
8. The Godley Green plan and the Hyde Road playing fields: suddenly Tescos & the District Centre – puzzlingly on the edge of town — are now at the heart of these new developments, providing new trade for a failing store not wanted by our community. Is this the real motive behind the new development at Godley Green?
9 – 12. Sports England quote from 2014 (this is 3 objections in one):
– “This Mottram M67 strategic site includes a number of sports facilities including a gymnastics centre / sports centre and playing fields. The development of this site to provide employment land would result in the permanent loss of these facilities. – Neither the ‘weaknesses’ nor the ‘challenges’ recognise the constraints that these facilities pose to development, not do they recognise that replacement facilities would be needed.
– The sustainability appraisal is also silent in relation to the impact of the loss of the sports facilities. Paragraph 74 of the National Planning Policy Framework offers protection to these facilities and requires specific criteria to be met before they can be developed.
– Likewise, Sport England’s playing field policy would oppose development of such sites unless specific circumstances exist.”
13. Coal Board quote from 2014: “the plans fail to make any mention of the issue of land instability which has many similar characteristics and needs consideration and mitigation as required by the NPPF paragraphs 109, 120 and 121. In order to be sound the policy will need to: “Require adequate consideration of methods to reduce impacts upon and reach acceptable resolutions to issues surrounding ground instability, light, noise, water, odour and ground pollution, air quality and vibration; and Require that developments are mindful of and employ appropriate mitigation techniques to developments that occur on or near to existing areas of ground instability, contaminates, pollution and land fill sites.” At present the Plan does not indicate that it intends to address the issue of ground instability at all which is a locally distinctive issue for Tameside. We raised similar concerns at the Issues stage which have not been addressed.”
11- 18. Campaign for Protection of Rural England quote from 2014 (8 objections here, but they gave more):
– “Given the site’s ‘proximity to the M67 and lack of access by rail it is expected that development would result in an increase in traffic levels particularly given existing infrastructure capacity limitations and congestion issues in the area.’
– It would encourage long distance commuting and undermine employment opportunities for local people.
– Consequently the proposal scores negatively against Sustainability Appraisal objectives for citizens’ health,
– environmental quality, – reducing the need to travel, – strategic transport communication – and economic infrastructure.
– Use of the site would contravene Tameside saved UDP policy OL1 (Protection of the Green Belt) as no very special circumstances have been demonstrated for such inappropriate development, and OL4 (Protected Green Space) as none of the exceptions criteria would be met.”
We add:
Housing capacity on suitable brownfield land
The Campaign to Protect Rural England (CPRE) has analysed the Government’s brownfield registers pilot scheme. Employing a variety of conservative methodologies, CPRE now estimates that the available data translates to a minimum of 1.1 million homes on suitable brownfield sites across England. More ambitious methodologies put the figure much higher, towards 1.4 million. This suggests that the Government has previously severely underestimated brownfield capacity
www.cpre.org.uk
see their document on this link:
http://www.cpre.org.uk/resources/housing-and-planning/housing/item/download/4733
19. United Utilities quote from 2014: developers must demonstrate, as part of any planning application, how surface water run-off will be addressed without having any detrimental impact on existing sewer infrastructure. [LCG comment – we are not aware that this point has been addressed in the current plan, nor is it evident in the plans for Godley Green and Sidebottom Fold].
20. We simply reiterate a previous objection: according to the Localism Act proposed applications should be brought to the attention of a majority of the persons who live at, or otherwise occupy, premises in the vicinity of the land. However, most local residents were unaware of the GMSF, until a community group informed them.
21. Neither is the Plan consultation in keeping with the spirit of the Localism Act: “Planning did not give members of the public enough influence over decisions that make a big difference to their lives. Too often, power was exercised by people who were not directly affected by the decisions they were taking. This meant, understandably, that people often resented what they saw as decisions and plans being foisted on them. The result was a confrontational and adversarial system where many applications end up being fought over”. The Localism Act contains provisions to make the planning system clearer, more democratic, and more effective. However, when we scrutinise the responses to the plan of 2013-4 (which has gone forward to become the present one), the community’s objections have been ignored, rather than incorporated.
22. Walking and cycling: The plans claim “[ref GM17] There will be a particular focus on tackling air pollution in the locations where most people live. The emission of air pollutants will be minimised by: Locating and designing new development so as to minimise the need to travel and maximise the use of walking, cycling and public transport for any trips; Reducing the use of polluting vehicles” and “[ref GM19] “Promote walking and cycling, by prioritising pedestrians and cyclists, and by providing aesthetically attractive routes that connect to local facilities and to existing walking and cycling networks;” and “[ref OA26] Development of these sites would give new residents access to existing active travel and recreation opportunities based around National Cycle Route 62, the Trans-Pennine Trail and footpaths.”
However, we say:
– There is no reference to how the plan will actually maximise the use of walking and cycling. The plan appears out of touch with reality: this area remains a dangerous place to cycle, with no provision for safe cycleways in the vicinity of the proposed development near and along Hyde Road. Rather, the developments are proposed right beside a major trunk road and motorway intersection, attracting car commuting and freight, which is the exact opposite of the planners’ claim to be “Locating …development so as to minimise the need to travel and maximise the use of walking [and] cycling.”
– Cycling along Mottram Old Road to and from Gee Cross (featured on route 62 of the National Cycle Route) will be more hazardous, due to the large increase in commuter traffic from the Godley Green development there.
23. Similarly, the increased levels of commuter and freight traffic will make pedestrian negotiation of these roads yet more hazardous. Notably, there is still no provision for pedestrian access across the entire length of Hyde Road outside of the junction with Market Street. The promised bridge over Stockport Road to Tescos was quietly dropped.
24. The plans were produced before Brexit, and thus are based on pre-Brexit predictions on population-size, immigration trends, etc. These are now outmoded. Therefore a fresh post-Brexit planning framework is needed.
25. The Mottram sites are not near alternative transport such as train stations/canals. Throughout the north-west there are large sections of lockfree canals, based on the fact that these sections are natural water navigation routes. Examples include the entire length of the Bridgewater canal (Castlefields junction to Preston Brook), and the Macclesfield canal (from Marple to Macclesfield). These sections could be further developed to facilitate the most energy-conservative, fuel-efficient traffic of freight – i.e. by water. The focus of planners is only upon re-development of the Manchester Ship Canal (although this appears to be at the expense of the biodiversity and wildlife).
26. According to the plans “[ref. GM7, page 64] The green infrastructure network will be designed, managed and protected so as to help deliver the following key priorities for Greater Manchester: Enhance biodiversity, by expanding, improving and connecting habitats”
– the plans appear to do the exact opposite of this in the Mottram M67, Godley Green and Sidebottom Fold areas! Quite simply, habitats will be destroyed, connection between habitats will decrease, and wildlife migration corridors in this area, diminished with the Tesco development, will be diminished yet further. This is a significant issue between the Mottram M67 and Godley Green sites.
It is hard to envisage biodiversity being expanded when a concrete jungle is built all over the habitats.