To clear confusion, correct misunderstandings and combat disinformation Save Royton's Greenbelt has established a fact-checker to subject the GMCA's plans for Royton to objective and neutral scrutiny.
The purpose of this section is to understand the evidence base for the GMSF and examine the inconsistent treatment of the different boroughs in Greater Manchester along with the disproportionate plans for Royton and its neighbouring towns. We will not be dissecting national planning policy because this is something we cannot change. The Greater Manchester Combined Authority and the councils of Greater Manchester are subject to the law and must comply with national policy.
Much of the information included here formed the basis of Save Royton's Greenbelt group appeal against the GMSF. These documents are now available to download in PDF format.
Who creates the housing targets and how are they formulated?
The Greater Manchester Combined Authority creates the housing targets by applying a standardised methodology. The standard Government methodology takes projected household growth (based on projected population) and applies an affordability uplift to provide a local housing need figure (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 112).
There have been claims that the Government has set a target for Greater Manchester. This is not correct. Even though the Government has instructed the GMCA to use an outdated dataset that projects higher household growth than the most recent dataset (see Greater Manchester: Strategic Housing Market Assessment (2019), p. 35), there is no hard target. In a letter received by Councillor James Daly of Bury dated February 2019, the Secretary of State for Housing, Communities and Local Government wrote that housing numbers should be the result of a “realistic assessment … using the standard method”. The result of this analysis would then be scrutinised by an independent inspector.
This point was further reiterated in a parliamentary debate on 21st February 2019 dedicated to the framework with housing minister Kit Malthouse stating the government's targets were not “mandatory”. He offered the following clarification: “Any inspector will accept a properly evidenced and assessed variation from that target … If, for example, you have constraints like areas of outstanding natural beauty or green belt, or whatever it might be, and you can justify a lower number, then an inspector should accept that.” (Greater Manchester is not being forced to build on green belt, insists minister, Manchester Evening News). Following the debate Malthouse wrote a letter to Jim McMahon (MP for Oldham West and Royton)setting out the Government's position explaining that greenbelt boundaries can only be altered in exceptional circumstances backed up by a fully evidenced justification.
How much is the population projected to increase by?
The Government instructed the Greater Manchester Combined Authority to use the Office for National Statistics 2014-based Subnational Population Projections to determine population growth (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 112). Even though the dataset is the same one as used by the 2016 draft of the GMSF, the population growth projections are different because the 2019 draft of the GMSF considered a different date range to the 2016 draft. The 2019 draft projected a population increase of around 250,000 people over the 2018–2037 period (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 112), down from around 300,000 over 2014–2035 in the 2016 draft (Greater Manchester: Strategic Housing Market Assessment (2016), p. 180). The population of Oldham Metropolitan Borough is projected to increase by 15,800 people over the 2018–2037 period.
A comparison reveals that the projected population growth in the 2019 draft is lower across the respective ranges for every borough in Greater Manchester.
A breakdown of projected population growth over the 2014–2024 period by the Office for National Statistics shows that net natural change (i.e. births and deaths) is the biggest driver of population growth (net growth of 5.3%) with net immigration in second place (net growth of 2.6%). Internal migration within the UK runs at a deficit (i.e. more people leave Oldham to go to other parts of Britain than come to it). To access the data simply select "Oldham" from the drop-down menu or type out the name.
Sources for table and bar chart
What are household formations and why do they matter?
To establish the Local Housing Need the population growth figures are first converted into household formation projections. The reason housing need isn’t based directly on raw population figures is because different household formations can lead to different quantities (and types) of housing being required. For example, a large population dominated by young families can end up requiring less housing than a smaller population dominated by pensioners.
The DCLG 2014-based subnational household formation projections (published by the Ministry of Housing, Communities and Local Government) formed the basis of the household projections. The average household growth over the 2018–2028 period is calculated and then applied to the 2018–2037 period (Greater Manchester: Strategic Housing Market Assessment (2019), p. 36–38). The household formation projections for both drafts of the GMSF are included below.
One of the reasons the household projections in the 2019 draft are lower than those in the 2016 draft is that the duration is slightly shorter (19 years as opposed to 21), but another reason is that the 2016 draft pursued an aggressive growth strategy for household formation (Greater Manchester: Strategic Housing Market Assessment (2016), p. 185). One consequence of the different methodologies is that the total number of households across Greater Manchester is projected to be lower in 2037 than in 2035, and this also holds true in Oldham MB. This is shown in the bar chart below.
Sources for table
Greater Manchester: Strategic Housing Market Assessment (2016) (p. 185; 2035 increased formation projections)
Greater Manchester: Strategic Housing Market Assessment (2019) (p. 38; 2037 projections calculated by multiplying average household formation by a factor of 19)
Sources for bar chart
Population household and dwellings (2035 household totals)
DCLG 2014-based subnational household formation projections (2037 household totals calculated by adding projections from above table onto 2018 baseline per methodology)
What is Oldham MB's Local Housing Need?
To calculate a housing need figure the GMCA took projected household growth over the course of the plan and applied an affordability uplift (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 112). After factoring in an affordability adjustment factor, application of the methodology resulted in a total housing need of 201,000 new homes across Greater Manchester over the 2018–2037 period. This figure was formally adopted as Policy GM-H 1 (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 112). The Local Housing Need for Oldham Metropolitan Borough was calculated to be 13,604 new homes (Housing topic paper, p.8).
How do empty homes impact on Local Housing Need?
The Greater Manchester: Strategic Housing Market Assessment (2019) (pp. 150–151) highlights Oldham MB’s vacant home record. With over 3 percent (2,893) of all homes in Oldham MB vacant as of 2017, Oldham has the worst record in the whole of Greater Manchester. And with nearly 40 percent of those ongoing, Oldham also has the worst record for long-term empty homes, which stands at 1,126 dwellings as of 2017.
It is obvious from the data that Oldham and some of the other boroughs could address a sizeable chunk of local need with vacant properties. The 2016 draft of the GMSF factored this in, and although the Greater Manchester: Strategic Housing Market Assessment (2016) (pp. 186–187) doesn’t provide the actual figure, it does provide the applicable empty homes ratio, and a basic calculation reveals that bringing vacant homes back into circulation offset Oldham’s housing need by over 500 homes. It explains its rationale as follows: “The amendment means that in the areas which have more vacant dwellings there would be an expectation that some of the household need would be met by the reuse of vacant dwellings.”
The 2019 draft of the GMSF does not factor vacant homes into its Local Housing Need methodology, and no explanation is provided for this inconsistency with the 2016 draft.
How many homes in total is Oldham MB going to build?
The GMSF has set Oldham’s building target at 14,290 homes, which is 686 homes in excess of its Local Housing Need (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 113).
NB. This figure is the delivery target designed to fulfill Oldham's obligations under Policy GM-H 1 (outlined under What is Oldham MB's Local Housing Need? above) and deliver its share of the 201,000 homes in Greater Manchester. It does not include the building "buffer"; the buffer is typically 6–7% higher than the target to ensure the target is delivered, and this is added on at the land supply stage.
Have other boroughs “off-loaded” their housing quota on to Oldham MB?
That is certainly a valid interpretation of the data. Oldham has a house-building target that exceeds its Local Housing Need (along with Rochdale, Wigan, Manchester and Salford), while Bolton, Bury, Stockport, Tameside and Trafford all have house-building targets below their stated Local Housing Need. While this in itself does not suggest that some boroughs have “off-loaded” their housing needs on to other boroughs, the re-distribution of housing targets around Greater Manchester was confirmed in a parliamentary debate on 21st February 2019.
Greater Manchester has enshrined a house-building target of 201,000 as Policy GM-H 1, and the combined total of the building targets sum to 200,980, effectively 100 percent of the policy target.
So to recap what is going on here:
The Local Housing Need for each borough and city in Greater Manchester is formulated by following the prescribed Government methodology.
This results in an overall Local Housing Need of 201,000 homes for Greater Manchester.
The overall housing target for Greater Manchester is set at 201,000 homes through Policy GM-H 1.
This target is broken down to borough level so each borough and city in Greater Manchester is set their own target in such a way that the combined total is equal to the policy target.
Obviously if this target is to be met then some boroughs will need to “over-build” if others “under-build”. Clearly, the burden of supplying new homes is not evenly shared by the constituent boroughs.
Is it true Oldham is the only borough to increase its home-building target?
Yes. Oldham has seen its commitment to build 13,700 homes in the 2016 draft of the GMSF (Greater Manchester: Strategic Housing Market Assessment (2016), p. 207) rise to 14,290 in the 2019 draft (Housing topic paper, p.17–18). The latest GMSF draft provides no rationale for increasing Oldham’s target while lowering the target in every other district of Greater Manchester, despite the fact it projects lower household growth, formulates a lower housing need, and predicts that fewer homes will be required in total than the 2016 draft.
As discussed in the What are household formations? section above, the number of households is expected to increase by 12,407 over the 2018–2037 period. The Government methodology for establishing housing need upscales this figure by 10 percent to set Oldham’s Local Housing Need at 13,604 (see What is Oldham MB's Local Housing Need? above). Despite this figure being lower than the previous target, Oldham's new housing target has been increased by 590 homes to 14,290—which is 15 percent higher than the projected increase in the number of households.
Does Oldham MB have enough brownfield land to meets its housing target?
Oldham does not have enough brownfield on its books to meet its housing target, at least not for the duration of the GMSF. Given the sheer amount of derelict factories and mills and a dying high street it is a safe bet that Oldham has enough brownfield in terms of quantity to supply the GMSF, but it is what is logged that matters. Oldham has so far identified 7,585 brownfield plots (Housing topic paper, Appendix A p.20) suitable for housing. This will only supply approximately half of the 14,290 houses that Oldham intends to build. Given that there is a legal requirement to have at least five years worth of building land available, the time and financial constraints of sourcing brownfield sites and getting them “development ready” means that a “brownfield only” approach would make it impossible for the council to meet its legal obligations without Government funding.
Will Oldham MB run out of building land?
This is a long piece of analysis that dissects a complex aspect of the Spacial Framework. It also includes quite a bit of maths, which is unavoidable given the nature of the topic. An abridged and simplified version of this piece is also available on our blog.
The reason being given for releasing land from the greenbelt is that Oldham MB (and Greater Manchester at large) will run out of building land over the course of the 19-year Spacial Framework. Save Royton's Greenbelt has put this claim under forensic scrutiny and has come to the conclusion that there is no evidence to support it. In fact, we have concluded that the GMSF is engineering a building land shortage by using a mathematical conjuring trick and in reality it does not exist.
To take Oldham's case specifically, the GMSF has determined that there will be a shortage of 4,000 building plots over the course of the plan, which underpins the rationale for releasing land from the greenbelt. This number is specifically the shortfall between the number of plots Oldham needs to meet its target (15,137) and the amount of building land logged in the 2018 edition of the Strategic Housing Land Availability Assessment (11,130). The Strategic Housing Land Availability Assessment (SHLAA) is a document compiled by the council for the purpose of logging land available for building. The justification given by the Greater Manchester Spacial Framework for releasing land from the greenbelt is that there is not enough land in the SHLAA to cover the housing target. The shortfall is determined by subtracting the total in the SHLAA from the housing target figure. This amounts to 4,000 plots, roughly the amount that will be released from the greenbelt (see Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 123).
Moreover, the SHLAA also provides a trajectory for when the land will become available for building. It is structured into 5-year spans i.e. 2018–2023, 2023–2028, 2028–2033, 2033–2037 and post-2037 (this can be viewed in the table below). By plotting the SHLAA trajectory (see Housing topic paper, Appendix A, p. 1) against Oldham's building target of 450 homes per year during 2018–2023 and 860 homes for the remainder of the plan (Housing topic paper, p.17–18) we can determine exactly at which point building land will run out in Oldham.
In the graph above, we see that the projected number of builds will exceed the land supply in 2028/2029, and will run into serious trouble in the 2033/2034 period. It is clear from the graph there will be a shortfall of 4,000 building plots by 2037. The GMSF puts forward a compelling argument for their case, but there is a fundamental flaw in their approach: the SHLAA is not a fixed supply of land.
The SHLAA is a dynamically evolving document, and as land drops off the books as it is built on other land is added as it falls into disuse. Twenty years is a long time and plenty of land will become available over this period. It is entirely possible for the SHLAA to increase in size as well as decrease. The 2012 edition of Oldham's SHLAA only logged 9,118 plots, and rather than becoming depleted over the 6-year period between 2012 and 2018 the SHLAA has increased in size to around 11,130 plots of land. Also over the 2012–2018 period, Oldham built 2,199 homes (Monitoring Report 2017/2018, p. 96). So, despite over 2,000 plots dropping off the SHLAA, Oldham's overall land availability has in fact also increased by 2,000 plots during the same period.
To illustrate what is actually occurring, it is helpful to consider what would have happened if the Spacial Framework had been initiated in 2012 using that year's edition of the SHLAA. Over a similar 20-year timeframe (2012–2033) the 2012 DCLG household predictions (published by the Ministry of Housing, Communities and Local Government) projected that 13,877 new households would be formed (the overall household projections are reproduced in the table above for convenience).
The 2012 SHLAA is broken down into four categories: plots that can be expected to deliver housing in 5 years or less, 6–10 years, 11–15 years, and finally 16+ years. The structure of the 2012 SHLAA is shown below.
By comparing the trajectory of 2012 SHLAA to the projected household increase we can see from the graph above that building land was projected to run out in the 2022/2023 period. Over a 21-year timeframe (2012–2033) the shortfall would be around 4,759 plots. The SHLAA roughly covers housing need until 2022, and then it appears to lose steam. According to the graph, by 2027 there is a shortfall of over 1,702 homes, and by the end of the 21-year period in 2033 there is a shortfall of nearly 5,000 homes. Beyond this period you can see that the gap only increases.
However, when the 2018 edition of the SHLAA was published the picture would have changed substantially. By plotting the SHLAA land trajectory against the 2012 household formation projections we see in the graph below 10,623 plots are estimated to be deliverable in the 2018–2033 period, leading to a land surplus of 918 plots over the remaining 2018–2033 period.
So what is the net effect of all of this in our 2012 Spacial Framework? Let us recap what is happening:
The government’s 2012 housing figures state that Oldham will need at least 13,877 houses over the 2012–2033 period.
The 2012 SHLAA has 9,118 building plots logged, creating a shortfall of 4,759 plots.
Over the 2012–2018 period Oldham delivers 2,199 new houses.
The updated 2018 SHLAA documents 11,130 sites and estimates a further 10,623 building plots can be delivered over the 2018–2033 period.
When these 10,623 plots are taken along with the 2,199 houses already built, that means there is now only a shortfall of 1,055 plots over the entire 21-year period, and NOT 4,759.
We see that there is originally a shortfall of 4,759 plots in the 2012 SHLAA, but this would have been reduced to just 1,055 for the 2012–2033 period once the 2018 SHLAA was published, as a result of more land becoming available.
So what exactly is going on? The shortfall in the SHLAA only occurs if you treat the SHLAA as a fixed supply that will run out, rather than a supply that is constantly replenished over a rolling 10–15 year period.
Conceptually, it is helpful to think of the SHLAA as a queue. An appropriate analogy would be doing your shopping: you go to Asda, fill your trolley and join the end of the check-out queue. There is maybe four or five people in front of you, and as they are gradually served other people join the queue behind you. All the time the queue never exceeds half a dozen people, but maybe 100 people pass through the check-out through the course of the day. However, you don’t need space for 100 people to queue. If the shop goes over to 24-hour opening then maybe 150 people will pass through the check-out over the course of the day, but the queue does not increase in size. So the size of your queue has no bearing on the number of people your shop is able to serve provided you can process your shoppers at the rate they check out. Likewise, the number of plots in the SHLAA has no bearing on the total number of houses you can build provided there is enough plots to support the necessary building rate.
So, to return to what is happening in 2019, we see there is a strong parallel between the two SHLAAs here: both editions of the SHLAA register enough land to support building over a 10-year period, but a 20-year period results in a shortfall of around 4,000–5,000 plots. There is an important reason for this: the SHLAA is only designed to supply land over a 10–15 year period. If you have a project that exceeds this timescale (as the GMSF does) then the SHLAA will not initially provide all the land that is required. It is very likely that the next edition of the SHLAA will push the "cliff edge" back even further, or at the very least greatly reduce the amount of land "shortage", just as the 2018 SHLAA did in the 2012 example.
The GMSF argues that the shortfall between the land required and the number of plots in the SHLAA means there is not enough building land in Oldham to service the 19-year plan, and must be supplemented by greenbelt land to supply Oldham’s building needs. Clearly this is a fundamental flaw in how the building land shortage is being calculated. The GMSF is planning a 20-year project using a register that operates on a 10–15 year timescale. It has not proven that there will be a land shortage, it has engineered one itself.
By setting a timescale that is longer than the operational timespan of the SHLAA any building project can arbitrarily create a land "shortage". For example, the 2018 SHLAA predicts a surplus in 2028, a shortage of around 800 plots in 2033, and 4,000 plots in 2037. If the GMSF had set a timescale of 25 years instead of 19 years then the land "shortage" would be about 9,000 plots. By calculating a land shortage in this manner, greenbelt protection laws can be circumvented by simply extending the timescale of the plan.
There are only two possible conclusions we can draw from all of this:
The greenbelt release fails to meet the exceptional circumstances laid down in the National Planning Policy Framework (NPPF) because the GMSF has not proven that a building land shortage exists.
That exceptional circumstances have been met because the GMSF cannot guarantee there will be enough supply in the SHLAA.
If the latter is true then this means that a loophole exists in the NPPF that can be exploited to annex building land from the greenbelt by arbitrarily setting a timescale on a plan that exceeds the current supply. Even though "exceptional circumstances" are not defined by the NPPF, normal comprehension of the English language would construe an "exceptional circumstance" to denote an unavoidable situation that is beyond the control of those at the mercy of it, not one that can be manipulated at will and not one that can be made completely avoidable by taking a more measured approach to planning and building. It is impossible to envisage that greenbelt protection laws were designed to allow for greenbelt release under such a scenario.
How many homes are going to be built on the greenbelt and where?
Approximately 4,000 new homes will be built on protected land within Oldham MB. Over 3,000 of these will be on allocations that are either in Royton or straddle Royton’s border with other districts. There are also two developments on the Rochdale border: Stakehill/Chadderton Fold which has provision for 900 houses, and Kingsway South that straddles the Shaw & Crompton border and will deliver 700 homes. The full plans for building on the greenbelt are comprehensively covered on this website.
Click here to view the full plans.
Where are the greenbelt boundaries?
All the GMSF allocations carry some kind of protection but not all carry greenbelt status. Besides greenbelt, there are also Sites of Biological Importance (SBI) and Other Protected Open Land (OPOL). Saving the greenbelt boundaries will not save the OPOL sites earmarked for development.
The allocations that are classified as greenbelt can be viewed in the interactive viewer below. The map can be controlled using the integrated drag and zoom features to zone in on the areas of interest. The striped pattern represents greenbelt earmarked for building, while the dotted pattern represents greenbelt that will be retained. Allocations that do not contain either do not have greenbelt status.
How much greenbelt will be taken?
Across Oldham MB, 352 ha (hectares) of greenbelt will be built on. Royton will lose 68 ha of greenbelt, but Shaw & Crompton is the worst hit, forfeiting 143 ha. After incorporating Saddleworth’s 10 ha of greenbelt additions (Green Belt topic paper, p. 49–51), the net loss of greenbelt will be 342 ha across Oldham. All told, Royton, Shaw & Crompton and Chadderton North (44 ha) will lose 255 ha of greenbelt between them accounting for approximately 75 percent of Oldham's greenbelt loss and over 10 percent of the Greater Manchester total.
On top of that Royton and Shaw & Crompton will also lose 59 ha of Other Protected Open Land (OPOL) taking the total net loss of protected land across Royton to 91 ha, and 401 ha across Oldham.
The widely publicised claim that “half of the greenbelt has been saved” while may be true at metropolitan level, is not true in relation to Oldham MB. Oldham loses 342 ha in the 2019 draft compared to 434 ha in the 2016 draft—a saving of just 21 percent (Green Belt topic paper, p. 31).
The tables below catalogue how much protected land each district and ward will lose. These are only estimates of greenbelt loss obtained using the MappingGM measuring tool (see the Where are the exact boundaries of the greenbelt? section directly above), so it would be prudent to allow a 10 percent error margin.
Loss of protected land (greenbelt and OPOL) in hectares across the wards of Oldham MB
What will be the distribution of housing across Oldham MB’s greenbelt?
The physical scale of land mass isn’t the only important factor in analyzing the greenbelt allocations. The distribution of plot allocations is also an important consideration due to the impact on local infrastructure. There are three principle ways to consider the allocations: locality, proximity, and population density. Each of these will be addressed in turn.
First, however, we should highlight an anomaly with the evidence base: the Greater Manchester Spacial Framework DOES NOT INCLUDE either the allocation at Chadderton Folds or at Kingsway South (Shaw & Crompton) in its evidence base for Oldham. This is a serious problem and is discussed in detail in the next section. Because these allocations straddle the Rochdale border it is not possible for us to determine how many builds will be on the Oldham side, so they are omitted from the analysis here. This is not an oversight by us, but a consequence of the flawed evidence base.
All the plot counts and the locality data can be obtained from Greater Manchester’s Plan for Homes, Jobs and the Environment (pp. 242–272) and the concept plans for Beal Valley, Broadbent Moss and Cowlishaw, both of which are housed on this website under “Plans”.
First up, by referring to the Greater Manchester’s Plan for Homes, Jobs and the Environment and the concept plans for Beal Valley, Broadbent Moss and Cowlishaw it is possible to determine precisely how many housing units are allocated to each ward. By considering the locality of the allocations, we see that Royton’s allocations account for about one third of all the allocation plots in the borough. In fact, we see that just five wards (Royton North and South, Shaw and Crompton, and St. James’) account for over 80 percent of all the allocation plots.
Distribution of allocation plots across the wards of Oldham MB
Royton’s approximate 33% doesn’t tell the full story. Many of the allocations lie on the Royton border (such as Beal Valley, Broadbent Moss and Cowlishaw) which will invariably have an impact on Royton’s infrastructure. In fact, by considering those allocations that transgress Royton’s border along with those allocations within Royton we see they account for 3,250 of the 4,050 plots—80 percent of all of Oldham MB’s greenbelt plots.
NB. It should be noted that the total number of plots listed here is slightly different to the ward-by-ward number listed above because the concept plan for Beal Valley has 170 more plots than the GMSF allocation.
Finally, in considering the distribution of the plot allocations, population must also be taken into account. In the final table and graph of this section the proportion of allocation plots per district is compared with the district household numbers as they stood at the 2011 census (p. 7). The distribution of plots is highly disproprotionate when you take into account the existing household numbers, with Royton accounting for 35 percent of the total share of the plots but only 10 percent of all households across Oldham MB. This would increase Royton’s population by approximately 16 percent over a relatively short period. It is extremely doubtful Royton could absorb such an expansion without a proportionate up-scaling in infrastructure and public services.
Is the GMSF building more greenbelt homes than they say they are?
This would certainly appear to be the case. The way the GMSF is supposed to work is to evidence test Local Housing Need and set a target based on that. Apart from the numerous questionable methods that have been invoked to get us to this point, you still end up with a hard target. The collective targets amount to 200,980 home builds (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 113), and the GMCA set a policy target of 201,000 builds. After setting these targets the land must be supplied for them which has resulted in the most controversial aspect of the GMSF: the release of greenbelt land. Greenbelt plots have been allocated to top up the existing building land, in order to supply the targets. The table below demonstrates that in most cases the total land supply is approximately 6–7 percent above the overall target, once the greenbelt allocations are taken into account (Greater Manchester’s Plan for Homes, Jobs and the Environment, p. 123). It is standard practice to provide a small buffer so there is nothing unusual at this stage.
Breakdown of land supply across Greater Manchester including the greenbelt allocations
Now, here is the problematic part: these greenbelt allocations don’t account for all the greenbelt releases. There are several cross-border developments that have houses scheduled that do not seem to service the target of either area. Two examples of this that affect Oldham MB are the Stakehill/Chadderton Fold (allocation 2) and Kingsway South (allocation 3) developments. Between them they will supply a further 1,600 homes that do not serve Oldham’s 14,000 home-building target. Could they service Rochdale’s target? This is difficult to assess, because Rochdale has two cross-border developments with Bury (allocation 1.1 at Heywood/Pilsworth and allocation 1.2 at Simister and Bowley), so it is not possible to isolate the development in Rochdale. However, since Bury has no further cross-border developments then it is feasible to consider the collective total of Oldham, Rochdale and Bury. The results are interesting to say the least. As you can see from the above table, the combined number of evidenced greenbelt allocations for Bury, Oldham and Rochdale collectively sum to 12,989. This is broadly consistent with the Greater Manchester’s Plan for Homes, Jobs and the Environment – Overview document which puts the total number of allocations for Bury, Oldham and Rochdale at 13,100. By referring to Greater Manchester’s Plan for Homes, Jobs and the Environment (p. 195–289) it is possible to factor in the boundary plots that have been omitted from the above table.
As you can see, the total number of allocations for Bury, Oldham and Rochdale comes to 16,985, substantially more than the 12,989 allocations in the evidenced table (or the 13,100 in the overview document). That is almost 4,000 allocation plots more!
This is a complicated argument so to sum up the main points:
The cumulative Local Housing Need for Bury, Oldham & Rochdale is assessed at 34,922 homes.
The cumulative house-build target is 35,920 (in line with policy GM-H 1)
The land made available for building these houses is 38,072 plots, including 12,989 recorded greenbelt allocations.
The boundary developments (allocations 1.1, 1.2, 2 and 3) release enough undocumented extra greenbelt to build another 4,000 houses over the stated target for Bury, Oldham and Rochdale.
The GMSF certainly gives the appearance of underhand tactics here. No matter how flawed the housing targets are as they stand, the greenbelt allocations in the first table are evidenced to service them. But here we have 4,000 extra builds that are not evidenced, and not included in any cumulative total within the Greater Manchester Spacial Framework. The only way to get these figures is to read through a 400 page document and add them up yourself!
The Mayor of Greater Manchester and the GMCA have a serious question to answer on this point. After pledging to save the greenbelt, and castigating the Government for imposing an outdated population dataset on them, why have they slipped in an extra 4,000 greenbelt home builds above the policy target and kept them "off the books"?
What are the main points to take away from this page?
The Local Housing Need as produced by the Government mandated methodology stands at 13,604 houses for Oldham MB.
Oldham MB has added on an extra non-mandatory 700 houses above and beyond what it needs to supply, taking its target to 14,290.
The increased target is almost certainly due to Oldham MB picking up the slack for under-supplying boroughs so Greater Manchester can meet its policy target.
Oldham MB does not have enough brownfield land documented to meet its housing target over the duration of 2018–2037 plan.
On the other hand, even by its own figures Oldham does have at least ten years of building land left and there is no evidence that a building land shortage will occur, as more will become available.
The GMSF wants to build 4,000 houses on the greenbelt in Oldham MB, and about 3,000 of those will be in or around Royton.
The greenbelt builds will increase Royton's population by about 16 percent, and that does not even include the population increase that will come from non-greenbelt development.
After Shaw and Crompton, Royton will lose the most greenbelt in Oldham MB.
The GMSF will also be releasing greenbelt land at Chadderton Fold and Kingsway South to supply a further 1,600 unevidenced houses, which will be in addition to the aforementioned 4,000 greenbelt homes. In a nutshell, the GMSF documentation states that 13,000 homes will be built on the greenbelt in Bury, Oldham and Rochdale, but when you add up the allocations the total comes to 17,000.