The issue faced by Greater Manchester’s local planning authorities

All Council’s across the country are required, amongst other things, to meet its objectively assessed needs, in particular in relation to housing, office and industrial and warehousing needs. This is a legislative requirement that all Council’s must have regard to and no doubt you are aware that numerous Local Plan’s across the country have been found ‘unsound’ where Council’s fail to properly address these needs properly. As such, you will be unsurprised that GMSF has had significant regard to this.

To be considered as part of the Council’s land supply that meets these needs, sites must be amongst other things be ‘suitable’, ‘available’, viable’ and ‘deliverable’ as well as having planning permission or be allocated in the Council’s Local Plan. Since many of brownfield sites have not been put forward by their owners and do not have permission for redevelopment they are not ‘available’ or ‘deliverable’. Consequently, they cannot be used as part of GM’s or the Council’s land supply.

To illustrate the shortage of ‘clean’ sites available to the Council, of the 4866 dwellings suggested by developers as part of the first part of the GM Call for sites exercise, only 47 did not result in either development in the Green Belt, on OPOL Land or resulted in a loss of employment land.

I’m afraid current evidence available to the Council indicates that there are not enough brownfield sites available to meet GM Council’s objectively assessed needs for the next 20 years. To illustrate this in an Oldham context, the Council’s draft Oldham Housing Supply as of 1st April 2016 is 7224 dwellings. The GMSF Oldham Housing Supply Target is at least 13700 dwellings plus either the 5% (685) or 20 % (2740) buffer required under Planning Legislation. As such, the Council needs to provide either 14,385 or 16,440 dwellings over the next 20 years depending if the Council delivers on its housing target . The Council’s housing land supply gap is therefore between 7161 and 9216 dwellings over the next 20 years. It is therefore clear that simply using existing ‘suitable’, ‘available’, viable’ and ‘deliverable’ brownfield sites is not going meet the Council’s housing need in the next 20 years and the extent of the gap requires significant land to be made available to meet our legislative requirement in this regard, even if we build at higher densities (which of course might not be acceptable to some communities) or build on available previously developed land.

Whilst I would agree that using brownfield land first should and will remain a priority for this Council and indeed Greater Manchester, the current information available to me means it is unfortunately unrealistic to suggest that there will be enough brownfield land to satisfy Oldham’s housing, office and industrial and warehouse needs. However, I note that some of the recent consultation responses to the GMSF have indicated that they do not accept the GMSF’s growth and land supply figures and clearly this will be need to be reviewed again, to ensure that there is a robust case supporting the development options set out in the GMSF. I also note that the recent Housing White Paper [HWP] is proposing a standardised way of calculating local need that will clarify things in this area. Therefore, like you and many others I suspect, I will be taking great interest in this part of the debate and its conclusions as it will clearly affect the development options the GMSF and Oldham propose.

Green Belt Release

Finding the right balance between delivering enough new homes and jobs and protecting the Green Belt is a challenge that Councils across the country are encountering as they prepare new Local Plans. Oldham and other Greater Manchester Councils are not the only areas struggling with this question. On the one hand there is pressure from government to ensure that enough new homes and employment floorspace is built to help address the housing crisis and support economic growth. On the other hand, there are often local residents campaigning to protect the Green Belt for understandable environmental and social reasons.

Today, there are 14 Green Belts which cover 12.4% of the countryside. This is actually a larger area than the roughly 10% of the country that is developed. Moreover, it has actually grown in the last 20 years. The modern role of the Green Belt is defined in the National Planning Policy Framework. This sets out five functions which the Green Belt is supposed to serve. These are:

• To check the unrestricted sprawl of large built-up areas;

• To prevent neighbouring towns merging into one another;

• To assist in safeguarding the countryside from encroachment;

• To preserve the setting and special character of historic towns; and

• To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

It is important to see what the Green Belt isn’t. For example, Green Belt isn’t the same as the countryside. Nor is it intended to be some sort of quality mark identifying the most attractive areas of countryside. It is largely about managing the growth of urban areas as you can see from the above.

I and others recognise that the Green Belt is still performing its role of preventing the growth of cities and towns and that it is doing that well. However, a consequence of this is that it is now a significant contributor to the housing issues the country faces. In particular, I would draw your attention to research that indicates that 35% of the price of homes in England is attributable to the constraints on development imposed by the planning system and the fact that eight of the ten most unaffordable cities in England are constrained by Green Belt.

I also note that despite early rumours and newspaper headlines, the HWP does not propose to change the Green Belt’s status. On the contrary, the HWP’s position is “to retain a high bar to ensure the Green Belt remains protected”.

The HWP proposes to amend national policy to clarify that:

• Green Belt boundaries should be amended ‘only when’ the LPA can demonstrate to have examined ‘fully’ all other reasonable options. These options include:

• brownfield sites;

• estate regeneration;

• underused and surplus public sector land among others;

• optimising density; and,

• exploring whether other authorities can help meet identified needs.

It therefore sets tests when Green Belt might be able to be released and the GMSF will clearly have to have regard to such options if it seeks to release Green Belt.

As I said earlier, finding the right balance between delivering enough new homes and jobs and protecting the Green Belt is a difficult challenge that this Council does not take lightly. There are positives and negatives on both sides of the argument and it is with this in mind that I and many others are working to find the best compromise that delivers a balance between the two.

Infrastructure

I think most people are worried about the strain on infrastructure – whether it be transport, health, education or utilities infrastructure. However, the houses proposed by the GMSF are not the root cause of such strain. Put simply, if new houses are not provided to meet GM’s need, then the result would be more people living in more overcrowded or substandard conditions or in hidden households (people sharing, living with parents etc) rather than the mixed, balanced and sustainable communities required to be provided under planning legislation. People not having access to a decent home is not something the Council could support for obvious reasons and I note that you accept that more properties are required to meet GM’s population growth.

To put this in context, the Office for National Statistics figures show 13,643 families in GM living with another family - around 1.8% of a total of 736,781. Unfortunately, Oldham is the worst area in GM according to 2011 census data, with 2.6% of families considered ‘concealed’; 1,647 from a total of 62,764. In Manchester, there are 2,814 hidden families from a total of 114,400; 2.4%. In Rochdale, 2.2% of families are ‘hidden’. A table illustrating the position is attached for information.

Furthermore, Oldham is among the areas with the highest proportion of lone parents living with other families. There are 9,800 lone parents with children; 600 of which are ‘concealed’.

Ultimately rather than houses, the countries increasing population and the increasing demands of the population are the primary cause of infrastructure strain. Consequently, arguing that new houses themselves are likely to cause infrastructure issues is incorrect since it is the increasing number of future users / people that cause these issues. Nevertheless, it does not alter your point that these issues need to be taken into account in deciding how GM goes about meeting its future needs in the GMSF and this is a point that is well made and I have regard to going forward.

I hope that the contents of this letter are self-explanatory, but please let me know if anything is not clear.

Yours sincerely

Councillor Jean Stretton