'Points to Consider'

The following analysis has been provided by Councillor Kenny Blair for those responding specifically to the proposed 4000 houses near High Lane, Hawk Green, Marple and Hazel Grove.

1. The GMSF strategy appears to be - "There will be a very strong emphasis on directing new development towards locations that support urban regeneration, minimise environmental impacts, reduce the need to travel, and are or can be made most accessible by public transport, cycling and walking. Development will be managed to ensure that it is both functional and architecturally inspiring and makes a positive contribution to the quality of places and the wellbeing of people securing the reuse of brownfield land, protecting open spaces within the urban area, and delivering genuinely sustainable neighbourhoods with supporting facilities and services."

The High Lane allocation does not support the strategy. It does not support urban regeneration, does not minimise environmental impacts and does not reduce the need to travel, in fact it encourages it. It also does not provide a positive contribution to the quality of places and the wellbeing or people, nor does it secure the reuse of brownfield land, protect open spaces or deliver a genuinely sustainable neighbourhood. In fact, all of the strategic allocations identify a portfolio of high quality housing sites that are outside the existing urban area, thereby going against the stated strategy. 

2. The draft GMSF, including its proposed allocations, is apparently driven by the need to deliver its proposed strategy rather than by the sites submitted under the call-for-sites exercise.However, the GMSF Vision & Strategy 2.0.3 states, "A high level of economic growth is being planned for Greater Manchester, well above baseline forecasts, taking advantage of the proposed transport investments and the numerous high quality development opportunities."  From this statement, it appears that the selection of proposed allocations has driven the vision and strategy and that the strategy has not driven the selection of the proposed allocations. This would indicate an ulterior motive on wishing to develop on the greenbelt.

3. As part of the GMSF, a Call For Sites  was launched. 800 sites were submitted in total, of which 147 are in Stockport. If these sites were delivered in a way that would achieve their maximum potential, they could yield around 325,000 units of new housing. Across Greater Manchester only 25% of the sites suggested by landowners, developers or others are within the proposed allocations; across Stockport only 11% of the suggested sites are within the proposed allocations. This would indicate that there is no need for mass development on the Green Belt as the call for sites exercise has identified sites which provide nearly 1.5 times the Objectively Assessed Need (OAN).

4. Given point 3 above and the statement in the GMSF that there is a "Lack of opportunities to provide the sites the market wants;", it appears the GMSF has given significant weight to the needs of developers rather than the needs of residents or the requirements in legislation.  

5. The GMSF states "It has been recognised within this paper that there is a need to prepare additional evidence to support the strategic allocations that we will subsequently take forward as part of the formation of a Publication version of the GMSF, and that this will of course be informed by the responses to the public consultation on the draft GMSF, IA and supporting documents. Notwithstanding this, we are of the view that the approach adopted to-date is consistent with national planning policies in the NPPF." 
The National Planning Policy Framework (NPPF) states the following - 

Para 80. Green Belt serves five purposes:

●  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. 

Para 83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. 

According to the Planning Policy Guide, unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the “very special circumstances” justifying inappropriate development on a site within the Green Belt. Council Officers keep telling us the only reason they are considering development in the Green Belt is because they cannot meet the Objectively Assessed Housing need. This does not conform with the NPPF. 

6. The green belt allocated in High Lane is high quality land that is still utilised as agricultural working land. Brownfield sites within the green belt and poorer quality green belt should be considered before allocation of this prime green belt land, but only as a last resort.

7. The GMSF states it will address air quality. By adding 4,000 new dwellings in High Lane, this will make an already bad situation worse. 

8. Sites submitted under the call for sites also included a number of (often very small) sites within the existing urban area which could well be developed under current policy and if they could then they would be added to the existing supply part of the overall figure.  The GMSF does not need to allocate them to allow them to come forward, but these should be brought forward before any consideration is given mass development on the Green belt. 

9. In the last 20 years, the population of Greater Manchester have grown by 133,000 and in Stockport by 6,000. The household projections for the next 20 years are 186,000 and 17,000. The numbers produced in the GMSF are over-zealous and take no or little account of the effects of Brexit or the Governments immigration targets. As a result, the Green Belt land should not be re-allocated until the numbers have been confirmed and all other sites are developed first. 

10. The Govt projected households from 2014-2039 show that in Stockport, it is anticipated that 8,000 will be Single Occupancy households, followed by 6,000 Households with dependant children and then 4,000 households with couples. To build 4,000 of the 6,000 households required in one area gives a skewed burden to one community of Stockport. The highest requirement is for 8,000 households with single occupancy, indicating apartments. The GMSF should be utilising all brownfield sites and building higher densities, i.e. building up, similar to Manchester City Centre and Salford. This would also bring economic benefit to Stockport by having more people visiting Stockport two centre.