Comment

Years in the making: GMSF 2020

The production and agreement of a Plan for Greater Manchester has been drawn out to say the least. As we reach a critical milestone, Nick Graham, Associate Director in our northern Planning team, highlights the main changes and points of interest in the latest version.

When I moved to the North West around six or seven years ago, one of the first things that I got involved with was the November 2014 consultation on “Initial Evidence” for a joint Plan for Greater Manchester (GM). The Greater Manchester Spatial Framework (GMSF) has been through several consultations since then, and every iteration has proposed less growth and development. This long journey culminated on Friday 23 October, which saw – after numerous delays and false starts – the release of the GMSF “Publication Plan”.

Context

Subject to endorsement by all 10 GM authorities, this is the version of the GMSF that will be submitted to Government and which the Greater Manchester Combined Authority (GMCA) and each of the authorities intend to adopt. It has been long-awaited and has taken on even greater importance given the critical role it will now play in supporting a post-pandemic economic recovery. Its publication is therefore to be welcomed.

The GMSF 2020 is due to be ‘signed off’ for consultation at a meeting of the Association of Greater Manchester Authorities (AGMA) Executive Board on 30 October and by each of the 10 authorities during November. It will then be subject to a formal Regulation 19 consultation, taking place between 1 December and 26 January 2021 (it appears that a Christmas consultation has become the norm for the GMSF!).

Much of the content of the GMSF 2020 replicates that from the 2019 version. Its content will therefore be very familiar to many. The influence of Counsel is clear in sharpening the drafting of particular policies. The Vision, spatial strategy and strategic policies of the GMSF 2020 are largely unchanged; it still focusses development in a “Core Growth Area” (the city centre, Salford Quays and Sports City), whilst aiming to boost the competitiveness of GM’s northern boroughs and sustaining competitiveness in the south of the city region.

Development strategy

Within this framework there have been some notable changes to land allocations.

The GMSF 2020 proposes the delivery of 10,534 homes per annum – in line with the minimum under the ‘standard method’ despite the clear guidance that this is only a “starting point”. This is notably below recent levels of delivery (11,525 dwellings in 2018/19). There appears to have been little to no consideration of whether a higher level of housing provision is required, for example to support economic growth ambitions, to reduce overcrowding and homelessness, or to respond to high levels of demand. The latter is despite recent data from Rightmove and Zoopla showing that postcodes in GM have seen some of the highest increases in house prices in the country in recent months.

Conversely, the GMCA has explored whether a lower requirement could be justified by the effects of the COVID-19 pandemic. However, it has concluded that there is currently “…insufficient evidence…to suggest that Greater Manchester should not be seeking to meet its overall housing need…”. It does, however, leave the door open for an early review “…outside of the statutory review timescale…” if such evidence does emerge. It also argues that the effects of the pandemic justify a phased introduction to the overall housing requirement – building from c.8,500 dwellings in the early years of the plan to 11,990 from 2030 onwards.

As we would expect in a joint Plan, there is an element of redistribution of housing needs across the conurbation, effectively – and incorrectly in our view – treating it as one single housing market area. As shown in Figure 1, the biggest uplifts in housing delivery are in Manchester and Salford and to a lesser degree in Rochdale and Wigan, whilst the ‘undersupply’ is largest in Stockport, Tameside, Trafford and Bury.

Land Allocations

The extent to which GMSF is dependent on sites in urban areas is clear. In line with its preference for brownfield land, almost 85% of housing delivery is expected to come from existing non-Green Belt sources of supply. GMSF 2020 actually asserts that in “numerical terms” it could meet its housing need without Green Belt release. However, it rightly accepts that not all urban sites will be delivered and there is therefore a need for flexibility to ensure that overall needs are met. Crucially the Plan also recognises that meeting needs is not only about the number of homes, but also about achieving “balanced and inclusive growth”. This is a welcome acknowledgement that the range and type of homes delivered are also important to the future of the GM. It is this that underpins the exceptional circumstances for Green Belt release (see below). References in the GMSF 2019 to brownfield sites being “reliant” on large amounts of public sector regeneration funding have been, unsurprisingly, toned down.

Press reports over the last few days have identified that the GMSF 2020 has reduced the amount of Green Belt release by c.60%. This is accurate if it is compared to the 2016 version, which prompted the ‘radical rewrite’. The changes compared to the 2019 GMSF are much less pronounced. Overall, GMSF 2020 proposes almost a fifth (c.19.84%) less Green Belt release than the previous version and it identifies 45 strategic development allocations (previously 51) with a cumulative yield of:

• 32,605 dwellings – almost c.4,000 homes fewer than the 2019 version (c.11.5% reduction).
• 3,129,770 sq m employment floorspace – almost c.700,000 sq m less than the 2019 version (c.18% reduction).

A number of proposed allocations have been deleted or reduced [1], and it is evident that the GMSF is increasingly reliant on the allocations being made particularly within Bury and Rochdale. A significantly greater amount of Green Belt release would be needed if not for the ‘re-distribution’ of housing needs which is enabled by GMSF. For example, if Stockport had to meet its own baseline housing needs, it would need to more than double the amount of Green Belt release to identify land for another 4,000+ homes.

Green Belt remains a very contentious aspect of GMSF. This is evident in its failure to identify any areas of safeguarded land, save for one site adjacent to Manchester Airport designated as a HS2 Growth Area, and in its proposal to add sites to the Green Belt to minimise the net loss. GMSF also proposes that Green Belt policies will be “…strictly applied…” even to those sites which it proposes for release unless applications comply with the relevant allocation policy.

A little road left to travel

Officers should be strongly commended for their work on the GMSF to date. The drafts have had to address often competing priorities and whether the right balance has been achieved will be the focus for the Examination (expected to commence around late 2021). The GMSF must first, however, secure ‘sign off’ for consultation from each of the 10 authorities. This may not be straightforward, with some opposition Members threatening to halt progress, despite the obvious benefits to their authorities of being part of the GMSF. We will be closely watching council meetings throughout November to monitor developments.

28 October 2020

[1] Key allocations from the 2019 GMSF which have been deleted or reduced in scale include, inter alia: Simister and Bowlee (yield reduced from 2,700 dwellings to 1,550 dwellings) and Whitefield (600 dwellings – deleted) in Bury; Thornham Old Road (600 dwellings – deleted) in Oldham; Trows Farm (yield reduced from 550 dwellings to 360 dwellings) in Rochdale; North of Irlam Station (yield reduced from 1,600 dwellings to 1,400 dwellings) in Salford; Carrington (yield reduced from 6,000 dwellings and 410,000 sq m to 5,000 dwellings and 350,000 sq m) in Trafford; and Land South of Pennington (160,000 sq m – deleted) in Wigan.