06 May 2021
I sit writing this blog on the eve of the Greater Manchester Mayoral election, thinking about who to vote for and having read through the election material delivered to my house, all candidates are consistent in their aspirations to ‘preserve the Green Belt of Greater Manchester’.
On this issue alone, it would appear that no candidate is willing to face up to the issues constraining housing land supply in Greater Manchester and the almost universal lack of up-to-date plans across the conurbation (including Stockport).
The lack of available housing sites (evidenced by the recent Housing Delivery Test scores, with 6 of the 10 GM districts failing the test, and the supply issues set out in the Councils’ published housing land supply positions), and the absence of up-to-date Local Plans is undermining the positive and planned growth of Greater Manchester. It represents a huge missed opportunity to help address the widely acknowledged housing crisis, securing contributions towards infrastructure provision and boosting Council finances through the receipt of New Homes Bonus payments to mention but a few benefits.
Following on from our series of blogs on the Greater Manchester Spatial Framework, which was released in October 2020 prior to the Plan being undermined by Stockport’s decision to withdraw at the 11th hour, progress on a Plan for all Greater Manchester authorities continues to be significantly delayed with no definitive timetable for its release.
Despite the lack of coverage of up to date Local Plans for the majority of Greater Manchester authorities, the drive towards getting the next iteration of the Plan prepared and released for consultation appears to be lacking and the Mayor has not been able/prepared to move it forward in his 4-year tenure to date.
Table 1 Local Plan Adoption Dates
The reason for the most recent delays could be down to the lack of appetite for releasing a contentious Plan so close to the aforementioned Local and Mayoral elections. However, the delay caused by the move to a Plan of Nine (to be known as ‘Places for Everyone’) offers the GMCA the perfect opportunity to address the obvious deficiencies in the previous iteration of the GMSF (October 2020).From a housing perspective, there are 10 key issues with the previous iteration of the Plan which need to be addressed before a sound plan can be adopted in Greater Manchester. I have summarised each of the issues below:
1) A Higher Housing Requirement – Greater Manchester needs to plan for a level of housing well above the Standard Method 2 minimum starting point to align with the growth strategies and economic development opportunities in Greater Manchester. This would improve affordability of housing across the conurbation. The last version of the GMSF was also planning to deliver less than the minimum housing requirement figure derived using the Standard Method 2 figure;
Table 2 GMSF (2020) Housing Requirement vs SM2 for each GM Authority
2) Greater Manchester is not a Single HMA – the ‘Places for Everyone’ plan needs to recognise the reality that the GM sub-region comprises of a series of overlapping Housing Market Areas, which should be reflected in any proposed redistribution of the Standard Method 2 figure (for example, Trafford’s housing need cannot be catered for by increasing delivery in Rochdale as there is a weak migratory relationship between the two);
Figure 1 Proportion of moves to Greater Manchester districts from England and Wales
Source: GMCA (2020): SHMA Update, Table 2.1
3) Housing Land Supply and Phasing Concerns - there is considerable uncertainty in relation to the deliverability of the claimed 176,665 homes over the plan period and in particular the backloading of the housing requirement will further exacerbate the immediate affordability issues being presently experienced by continued under delivery of homes to meet current needs;
Table 3 GMSF Housing Requirement 2020-2025 vs SM2
4) Diversity of Supply - a significant proportion of the claimed supply across the conurbation comprises high density apartments in the urban areas, but no analysis has been undertaken to determine that this will cater for needs particularly for family homes and affordable housing and for the changing attitudes and requirements of home working;
5) Social Infrastructure Provision - although the majority of the housing proposed in the Greater Manchester Spatial Framework (2020) is located in the existing urban areas, no provisions were in the plan to cater for the increased requirements on education contributions or open space and play provision as well as other social infrastructure requirements;
6) Worsening Affordability - nine of the ten Greater Manchester authorities have experienced worsening affordability since 2014 when preparation of the Greater Manchester Spatial Framework commenced. Stockport and Trafford are the least affordable areas, whilst Trafford's is the worst in Northern England yet neither is seeking to take positive steps to address this issue
Table 4 Greater Manchester Affordability Ratios and Redistributed Housing Needs
7) Delivery of Affordable Housing - the GMSF sets out a ‘desire’ to deliver 50,000 affordable units over the plan period but the provision set out in the plan will not deliver anywhere near that number particularly bearing in mind that the emphasis in the Plan is to deliver the majority of growth on brownfield sites which in the past have not delivered the required rates of affordable housing;
Table 5 Affordable Housing Completions 2014/15 – 2018/19
8) An Inconsistent Evidence Base - the evidence base underpinning the GMSF (2020) is haphazard and does not follow a consistent approach. For instance, no consistent methodology is applied to the preparation of Housing Land Availability Assessments and the justification and evidence base documents to demonstrate the developability of the strategic allocations varies considerably;
9) Lack of a Comprehensive Green Belt Review and Robust Site Selection Methodology - the evidence to justify the selection of the Green Belt sites is inconsistent and retrospective. The selection of the sites should have been based on a robust and consistent site selection process which was undertaken following a strategic Green Belt review. This has not happened; and
10) Stockport - Stockport's withdrawal from the process at the 11th hour is problematic for the continuation of the GMSF. Stockport Council and the remaining 9 Greater Manchester authorities need to work cooperatively to prepare their respective plans and the remaining nine authorities preparing the Places for Everyone Plan and cannot simply 'cut Stockport adrift' as it remains an integral part of the city region.
Significant issues with the Joint Development Plan for Greater Manchester need to be positively addressed immediately or continued delays are likely with the preparation of the Plan.
There is considerable risk that the plan in its current form could be found unsound at Examination and the Greater Manchester authorities would be back to square one having wasted at least 7 years on trying to prepare a joint development plan.
The next elected Mayor of Manchester will undoubtedly have to grapple with the issue very early in their tenure. However, despite all candidates’ aspiration to protect the Green Belt, it is unlikely that a sound plan can be delivered without strategic release of some sustainable sites across the conurbation to meet identified housing needs. Although the release of Green Belt is always a contentious and emotive issue, it is imperative that the current paradox of aggregation is overcome, to positively address the immediate housing crisis in Greater Manchester.
Continued failure to plan positively will further exacerbate the housing crisis in the sub-region and will undoubtably have profound economic and social issues on Greater Manchester’s residents.
26 Oct 2020
After more false starts than the Grand National, the Greater Manchester Spatial Framework (GMSF) Publication Plan 2020 has finally been released. The GMSF 2020 will be presented to the Greater Manchester Combined Authority (GMCA’s) meeting on 30th October and will then be voted on by each of the 10 individual Greater Manchester Authorities (GM10) for approval. The GMSF has been in production since 2014 and has undergone many consultation exercises. It has received significant criticism and opposition from both the development industry and local residents.
GMSF 2020 is the most progressed version to be released. Assuming it can secure approval from all 10 Greater Manchester authorities by the end of November, a formal 8-week consultation exercise will commence on 1st December 2020 and conclude on 26th January 2021. Before the commencement of the consultation, there is likely to be some heated debates across Greater Manchester’s virtual Council Chambers. It is likely to be a turbulent few weeks in Greater Manchester politics. Indeed, Mayor Andy Burnham is urging opponents to the GMSF to ‘think long and hard’ and has added that the region ‘needed’ the GMSF to progress after five years of work.
The aim of this blog is to summarise the headline objectives and aspirations of GMSF 2020. A series of follow up blogs will be released delving deeper into the plan and the associated evidence base over the coming 5 weeks in the run up to the commencement of the consultation. These blogs will look at issues such as housing land supply and housing mix, implications for town centres, employment land, economic growth and infrastructure requirements.
At the outset it is important to point out why a sound and ambitious GMSF is required in Greater Manchester. The National Planning Policy Framework [NPPF] (§15) sets out that the planning system ‘should be genuinely plan-led’ and that ‘up-to-date plans should provide a positive vision for the future of each area’ … ‘ addressing housing needs and other economic, social and environmental priorities’. There is also a policy requirement on Local Authorities to review their plans at least once every 5 years to ensure consistency with national policy (§33).
Many of the local authorities in Greater Manchester are relying on plans which are out of date and pre-date the first iteration of the NPPF (2012). The table below sets out the year of adoption of each of the most recent plans on Greater Manchester authorities. This indicates that only 3 of the 10 authorities have plans adopted post publication of the first NPPF and only 1 is less than 5 years old since its last review.
Given the age of many of the Greater Manchester plans, it is imperative to get a robust and ambitious plan in place as soon as possible to ensure the right amount and type of development in the right locations across Greater Manchester. GMSF 2020 sets out some heady aspirations and wants to transform Greater Manchester into ‘a top global city (§2.17) by the end of the plan period. Coupled with that, the GMSF recognises that ‘the strength and strategic location of Greater Manchester puts it in an ideal place to act as the primary driver for the Northern Powerhouse’ and ‘it will be important to deliver relatively high levels of growth within Greater Manchester for the wider benefit of the North’.
The GMSF has set out ambitious aspirations and objectives but do the policies on housing and economic growth align with them?
In terms of employment growth, the Plan seeks to maintain a very high level of economic diversity across Greater Manchester and facilitate the development of high value clusters in prime sectors such as advanced manufacturing, digital and cyber, health innovation and logistics. The GMSF also makes provisions for the development of:
2,500,000 sq.m of new office floorspace over the period to 2020-2037 focused on the City Centre, the Quays, Manchester Airport Enterprise Zone and Town Centres (an increase from the 2018 iteration of the plan from 2,460,000 over a longer plan period (2018-2037)
At least 4,100,000 sq.m of industrial and warehousing floorspace offering a range of opportunities across Greater Manchester and significantly increasing the supply of high-quality sites across the norther parts of Greater Manchester (a slight decrease overall from the 2018 iteration of the plan from 4,220,ooo although the plan period was 2 years longer (2018-2037)
In terms of housing growth, the GMSF seeks to deliver a minimum of 179,078 net additional dwellings over the period 2020-2037, an annual average of 10,534. It also proposes:
The annual housing requirement will be phased and will increase over the duration of the plan period, with 12,000 units being delivered per annum post 2030.
At least 50,000 additional affordable homes across Greater Manchester, with at least 30,000 being social or affordable rent.
58% of the supply will comprise apartments with the remaining 42% comprising houses.
All new dwellings must comply with national space standards and be built to Part M4(2) of the Building Regulations.
That the minimum net residential density will be 35 dwelling per hectare which will increase depending on the site’s proximity to services and sustainable modes of transport.
The plan recognises that the northern areas of Greater Manchester have had relatively low levels of growth over recent years and significant intervention will be required to rebalance the economy. The GMSF seeks to direct growth to the north of the conurbation including the provision of a good supply of high-quality development sites and major transport improvements. Investment in the key town centres of the north is also seen as playing a vital part in achieving this aspiration.
The Greater Manchester Green Belt has remained relatively intact since its designation in 1984 and its continued protection has facilitated that redevelopment of many brownfield sites across the conurbation. However, GMSF 2020 recognises that there is an insufficient supply of housing and employment land to meet the identified needs. As such, the plan seeks to allocate 1,939ha of Green Belt land for development. This represents just 3.25% of the total Green Belt in Greater Manchester and 45% of Greater Manchester will continue to remain as Green Belt. Since the 2016 version of the GMSF, the amount of Green Belt land proposed for development has decreased by 60%.
The Plan is also focused on the delivery of sustainable development and protecting the valuable Green and Blue infrastructure in Greater Manchester. It also aims to deliver a carbon neutral Greater Manchester no later than 2038 with a dramatic reduction in greenhouse gas emissions. To achieve this, it is expected that new development will: be net zero carbon from 2038; will incorporate electric vehicle charging point to future proof development; will prioritise connection to a renewable energy/heating/cooling network; and achieve energy demand reductions for residential development.
The viability evidence which underpins the GMSF is yet to be released. It will be very interesting to see how the plans ambitions for at least 25% of the total housing requirement to comprise affordable housing (particularly on brownfield high density sites) coupled with the ambitious sustainability, energy efficiency measures; and, the significant infrastructure requirements across the north of the conurbation have been factored in and accounted for.
As set out at the beginning, the purpose of this blog is to provide an overview of the key headlines from the GMSF and our follow up blogs will delve deeper into the Plan itself, the associated evidence base (yet to be released) and discuss the possible implications for development across Greater Manchester.