To whom it may concern,
Greater Manchester Spatial Framework
Draft plan consultation 2016-17
We are writing to respond to the consultation on the Greater Manchester Spatial Framework, as the three elected Councillors on Oldham Metropolitan Borough Council for the ward of Royton North. These comments are primarily related to the area we represent and serve, but also to the wider implications and proposals contained within the GMSF.
Below we have set out the issues we wish to be considered at this stage of the consultation. We write with reference to the draft version of the Greater Manchester Spatial Framework (GMSF), which is currently out for public consultation, and to place on record our objection to to two sites proposed for inclusion, namely the area known as ‘Hanging Chadder’ (28.8.10) and NG2, the land east and west of A627M (28.3.4). We also believe that the methodology and process that has brought us to this point and its justifications are deeply flawed, and that a major rethink is required to make this plan viable and make Greater Manchester the successful, vibrant, dynamic region its residents deserve.
Before discussing in detail our issues with the above named sites, we would like to point out what we believe to be serious flaws in the justification and methodology of the draft proposals.
Firstly, all of the supporting evidence and extrapolation of population growth was conducted pre-Brexit. Although reference to the potential impact of Brexit is referenced in 1.3.3, this point itself proclaims that the forecasts are based on “our assumptions”. Considering that this work was undertaken in 2015, when the prospect of a vote to leave the European Union was underestimated, it is crucial to the viability of this project that this evidence base is revisited and reassessed in the light of the changed macro-environment we now find ourselves in.
Since that vote on June 23rd, the Office for Budget Responsibility, the International Monetary Fund and the UK Chancellor have all downgraded their growth forecasts for the British economy. It is somewhat implausible that, in the face of an increasingly difficult economic outlook, a year on year increase of 2.5% in economic output is a sensible figure to continue to base the framework on. When existing industrial estates such as Stakehill Industrial Estate and the Acorn Centre in Oldham are currently operating well below full capacity, the case for massive industrial expansion becomes even more difficult to justify. This is in addition to the plethora of available units at Salmon Fields in Royton, the development agreed on the Foxdenton site and a range of sites across the north of the borough that would be more suitable for industrial expansion (we will return to this point later).
The entire modelling basis upon which this draft document has been set should, in our opinion, be re-evaluated, as with all national projections predicting a decrease in population influx following Brexit, the fundamental argument for this extent of development seems flawed. This point is further reinforced by points 1.3.1 and 1.3.2, which states that the evidence base was established in November 2014. Again, the economic outlook and all projections since point to economic growth slowing at best, and the numbers of people coming in to this country reducing due to increased controls.
Secondly, due to an ageing population and changes in societal norms, the biggest increase in demand is expected to be for single person accommodation and small families, according to research carried out by the Office for National Statistics. Whilst we acknowledge that our borough has a low council tax base and there is a need for a greater diversification in the housing offer especially in the light of planned changes to Local Government Funding, it would be remiss and short-sighted to propose the building of schemes such as those outlined in the draft GMSF and not take this into account.
Thirdly, the process that is being undertaken must be addressed. Rather than a discussion about the merits of such an over-arching strategy, the framework itself seems to be the justification in and of itself for development. Rather a case of the cart being put in front of the horse it would seem. This has only served to heighten our residents’ fears and concerns that this entire process is much further along than it is. The fact that this is just a draft document at a non-statutory consultation stage and a full statutory process has not yet started is not clear. The justification for the strategy itself is lost in the furore over accusations of land grabs of greenbelt. As part of this procedural issue, it has not been made clear who has offered the sites under consultation for consideration. It is not immediately clear to the public who is responsible for this process – something that has been fed back to us on many, many occasions over the past couple of months. The conflation of the Call For Sites stage with the Draft Consultation stage has left residents feeling detached and somewhat subverted by the process, and that it is a ‘done deal’. Drop In sessions across the borough have been held on a seemingly ad-hoc basis, with just one session held in Royton despite the overwhelming majority of the proposed development for the borough of Oldham being in our town.
The consultation process in Oldham highlights how little is understood about the need for and aims of a Strategic Framework and the drawing of lines on a series of maps has led to ‘Save the Greenbelt’ groups being set up across Gm, making it much harder to have a constructive discussion about what economic development should look like over the next 20-30 years.
This brings our submission on to another fundamental flaw in the proposed sites and process with regards to Royton. Upon the publication of the draft, the local elected members for Royton approached the head of planning to establish what was already in the Housing Land Supply in our town, as we had put together a list of around 10 sites that would remove the need for both sites mentioned in this submission to be considered for housing purposes. The majority of these sites have not been taken into consideration, and we believe that this arises from a complete disregard in the draft document of a Brownfield First policy. It is our firm conviction that there are sufficient brownfield sites in Royton and across the borough that would more than satisfy the stated growth needed in the draft.
Indeed, Oldham Council’s own Site Allocations Development Plan Document makes no mention of the majority of these sites and actually talks about listing some 25 hectares across Royton for protection. We believe that it is most prudent to reset discussion on this strategy, and widen it to include all aspects of growth drivers for the city region.
The sites in Royton that we believe should be considered are as follows;
We have been assured by the head of Planning and Infrastructure at Oldham Council that there is a ‘Brownfield First’ policy in Oldham, however this is contradicted by the proposed Royton North sites in this draft with both being green belt. Upon further examination of the list of sites in the current Housing Land Supply, the majority of the sites above are not included. It is our belief, and that of the overwhelming majority of Royton residents, that a much more comprehensive review of all Brownfield sites in Royton and across the borough is needed to ensure that any development on greenbelt is avoided.
Government Planning guidance was updated in October 2014 with the stated aim to enhance local authorities’ ability to “safeguard their local area against urban sprawl, and protect the green lungs around towns and cities”. National Planning Policy on building on greenbelt land is explicit – it should only be done in the most exceptional of circumstances. The case of greenbelt development has not been made, especially when there are a plethora of brownfield sites that are available for development. It is our firm belief that the exceptional circumstances do not exist.
This is further supported by the Campaign to Protect Rural England (CPRE), who have previously said: “The latest National Land Used Database shows that Greater Manchester has 2,721 hectares (of brownfield and unused land), the highest amount in the North West, which does blight areas when left in a neglected and vacant condition.”
“CPRE believes that the GMSF must focus attention on bringing back into use this wasted land resource. Land assessed as suitable for housing in Greater Manchester is 1,309 hectares and at an average build rate of 40 houses per hectare this equates to 52,360 houses. It would be perverse if brownfield land, which is generally located in more central and therefore accessible locations is not successfully reused in advance of allocating further greenfield land.”
This is particularly relevant to the proposed sites in Royton. It is somewhat bemusing to designate large swathes of the greenbelt for potential development when there is substantial brownfield land that could and should be used first, as outlined above.
With reference to our earlier point regarding the type of properties needed, brownfield sites and old mills in particular would be much more relevant. Any increase in costs could be met by further devolution of taxation, such as Stamp Duty, as called for by Jim McMahon MP. It is somewhat disjointed that a strategy such as this can be put out for consultation, when the assorted councils have neither the funds to build or the ability to support the building with the requisite infrastructure investment. Although this is not within the remit of the Greater Manchester Combined Authority currently, a campaign could and should be brought about to put pressure on the Government to devolve true power and decision making responsibility to the region, through both the GMCA and the soon to be elected Mayor. This brings us on to our next concern, namely the concentration of development in the north of the borough of Oldham, and the concerns over impact on the local infrastructure. At this stage of the process, only sites in Royton and Shaw (primarily Royton) have been forwarded for consideration. One of the overarching themes of the proposed developments is a requirement for ‘aspirational housing’. Whilst we understand the reasons for this, and wholeheartedly support the vision for Oldham, the areas proposed already have a large percentage of the higher council tax band properties within Oldham, along with Saddleworth. When taken into consideration with the projection of future demographic changes over the coming decades, densely packed infill building on precious green belt land such as Hanging Chadder is even more difficult to justify.
The Borough of Oldham and the districts of which it is comprised all have their own unique identity and characteristics. Royton, and the north of the town are renowned for the natural beauty of Tandle Hills, providing a tourist attraction that is popular across the region.. In a time of increasing pressures on budgets and health and social care, a strategy of prevention as opposed to cure is crucial in keeping an ageing population healthy. We as a society are encouraged to walk on a regular basis and maintain an active lifestyle. The scale of development proposed surrounding Tandle Hill Country Park would greatly diminish this and cause incalculable damage to the health and wellbeing of generations to come. Indeed, recent research has pointed to an increase in dementia relative to traffic volume, something that would be exponentially increased were these proposals to be realised. Not only this, but Tandle Hill Park is also a Site of Biological importance for its fungi and bird populations, according to the Oldham Council website. The proposed development could result in catastrophic damage to the environment through pollution. Much more detailed assessment would need to be undertaken in order to gauge the impact of any development, even on brownfield sites. However this brings us back to the point that the selection of proposed sites in Royton is in direct contrast to one of the stated aims of the GMSF. To quote the Executive Summary, “They (development sites) must also be designed to minimise any adverse impacts on the green belt.” Surely the most effective way of minimising impact on the greenbelt would be to minimise, if not remove, all green belt development from the Framework.
With regards to the increase in traffic, this could have the most devastating impact. The proposals for Hanging Chadder and Thornham Fold would see somewhere in the region of 2,500 homes built. With these homes having several bedrooms, and being aimed at demographics with more disposable income, it is not unreasonable to estimate that each house will have on average 2 vehicles per household. In the immediate vicinity of Royton North alone, this will add approximately 5,000 vehicles. When a wider view is taken, this 5,000 would be in addition to thousands of extra vehicles with the new residents on developments in Cowlishaw Green and the Beal Valley development, possibly doubling this number. A growth of around 5,000 properties and as many as 10,000 people would see Royton’s populations increase in size by 50%.
This is unsustainable growth by any measure, and although the GMSF draft talks about the requisite infrastructure investment accompanying this growth and providing the schools, medical services and other facilities needed to accommodate this expansion, it is not within the remit of the GMCA to deliver these. Indeed, the trend in bus services in the north of Royton has been downward, with services to Manchester reducing at an alarming rate over the past few years. The expansion of Royton and Crompton Secondary School in the south of the town is in serious doubt due to funding issues. It is somewhat wishful thinking to add thousands more houses to this scenario without the Spatial Framework forming part of a much wider ranging and comprehensive strategy for growth in Greater Manchester.
Further concerns around the concentration of development is an environmental one. The Hanging Chadder area has long acted as a natural water table. However following a recent period of heavy rainfall surface water ran down and flooded properties along Rochdale Road and properties on Dogford Road and Fir Lane. To remove this natural barrier would lead to an increase in flooding across a large swathe of Royton. Further problems arose when the 19th century sewer system failed, leading to a sinkhole on Rochdale Road, the main road that would serve both proposed developments in Royton North. This is the latest sinkhole to appear across Greater Manchester, which results from an outdated system serving the region. It is infeasible that the volume of development being proposed could be arrived at without substantial investment in this and numerous other services which have been referenced both in this submission and elsewhere. Again, this reinforces the need for the Spatial Framework to be part of an overall strategy for modernising Greater Manchester, to ensure that the infrastructure of the region can facilitate the growth needed for the area.
Another aspect of the draft that is very disappointing is that it appears to do nothing to reverse the north/south divide within Greater Manchester with regards to types of employment and the distribution of wealth drivers. The executive summary states that all office space on a strategic level should be located within Manchester city centre, with areas like Stakehill being expanded to accommodate much greater volumes of logistical and warehousing sites. This is somewhat juxtaposed to the housing offer being proposed. Also, it completely fails to take advantage of the recent extension of the Metrolink network to Rochdale through Oldham, and also concentrates high end jobs in the centre and south of the region whilst consigning the north of the region, and Oldham in particular, to low paid jobs.
In its current format, we believe that the Greater Manchester Spatial Framework lacks the breadth and depth of vision to deliver the required change for the communities across Greater Manchester.
We believe that the inclusion of large swathes of greenbelt land is both against the wishes of local residents in Royton and beyond, but also totally unnecessary in the absence of a sufficient brownfield development strategy. The depth of feeling regarding this was seen in our ward by the excellently attended march and demonstration on January 2nd 2017, culminating in a rally at the Monument in Tandle Hill Country Park. Allied with the thousands of responses that have been received by this consultation so far, it would seem somewhat perverse that in the midst of a great devolution of power to local people that their views were not seriously taken into consideration.
We believe that there needs to be a fundamental rethink of the strategy that underpins the Greater Manchester Spatial Framework, to take a more comprehensive approach and includes areas such as transport infrastructure, the continued merger and of health and social care, additional school places and how they will be provided. Special attention must be paid to traffic congestion, and a detailed strategy developed that starts to combat the problem now.
The current draft of the GMSF contradicts the consultation of 2015, which says that the Spatial Framework should be a “plan for long term success not just short-term development”. This draft appears to place the need to build housing above all else and it would be short sighted to continue down this path without much more thought and research.
We object most vehemently to the inclusion of Hanging Chadder and the land surrounding Tandle Hill County Park, and wish to see these sites removed from the next draft of the Spatial Framework. These sites can be replaced by the ample brownfield sites in Royton and across the borough of Oldham.
We hope that the GMCA will take on board the views of not only elected representatives such as councillors and MP’s, but in particular the tens of thousands of residents from Royton and across Greater Manchester who have voiced their opinions regarding a variety of issues surrounding the Spatial Framework.
We look forward to continuing to work with residents, the Greater Manchester Combined Authority, MP’s and the individual councils to deliver the change that our residents expect and deserve.