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Real consequences? The impact of affordability on housing need in the Midlands and Northern England
In planning, the use of workplace-based affordability ratios [ARs] in the standard method for assessing local housing needs has meant that the publication of new ratios each April has garnered considerable attention. With fast house price growth and near flat wages, average house prices nationally are now 9.1 times earnings; up from 7.9 last year and higher than any historical level. Our table here provides an overview of the new local housing need [LHN] figures by local authority across England. The question of whether these new affordability ratios - and any increase in housing need they may yield - have any real impact ‘on the ground’ depends on a number of other factors, which may limit their effectiveness form a planning perspective in many areas. However, with plans needing to look over at least a 15-year horizon, even relatively small increases in housing need can create significant increases in overall plan requirements, putting authorities which are preparing new plans under pressure to find additional housing sites. This is the second of two blogs which examines the implications of the newly released AR on the standard methodology [SM2] for calculating housing need. The first examines those districts in the south of England where the substantial changes in affordability over the past year are likely to have the greatest impact from a planning perspective. It particularly focuses on those districts where the local plan is more than five years old (or soon will be), where the SM2 yields a greater housing need annually than the current plan requirement and where housing need has increased by more than 5% as a result of the new ARs. This second blog turns to the likely implications of the new AR figures on the SM2 calculations for authorities across the north of England and the Midlands, and what the new Local Housing Need [LHN] figures could mean from a plan-making perspective. Starting with the East Midlands, it is notable that all but 1 of the 36 districts have an increase in their LHN based on the latest March 2022 AR data. Collectively, there is an increase of 958 dwellings per annum [dpa] as a result of applying a revised median workplace-based affordability ratio. As can be seen in the Table below, the largest increase is for Leicester City, with its LHN increasing from 2,314 dpa to 2,464 dpa (an increase of 150 dpa, or 6%). This is particularly notable given that Leicester’s Plan is over 11 years old so it should have an immediate impact. Its AR has increased from 6.37 to 7.57 in a year (due to workplace-based earnings declining by 3%, whilst house prices increased by 15.4% - one of the highest rates of increase in the whole of the East Midlands). This is followed by West Northamptonshire, a new Unitary Authority comprising the former districts of Daventry, Northampton and South Northamptonshire, which has an increase of 135 dpa, followed by North Northamptonshire with an increase of 71 dpa. Also of interest is Melton, which has a very high proportionate increase of +14% on its 2021 LHN figure, to 231 dpa. This is entirely due to an extremely high AR of 12.27 which is the highest in northern England and the Midlands, and which represents a huge increase of 3.4 points from the 2020 position (an uplift of 38%). Reference to the Office for National Statistics [ONS’s] base calculation indicates that this leap is a combination of a 19.1% increase in median house prices over the past year to £262,000, combined with what is apparently the sharpest fall in median earnings across the whole of England (from £24,793 in 2020 to £21,358 in 2021 – a fall of 13.9%). It is also interesting to note that seven of the top ten East Midlands districts have a Local Plan over five years of age. East Midlands *Plan close to (or over) 5 years old Moving on to the West Midlands, by far the most striking figure relates to the City of Birmingham, which now has an LHN of 7,136 dpa, an increase of 313 dpa (+4%) on the 2020 AR-generated figure of 6,823 dpa. However, this somewhat masks the point that up until the 10th of January this year the figure was ‘just’ 4,829 dpa. The reason for this huge change is down to the fact that the City’s Local Plan was adopted on 10th January 2017 and hence it is only very recently over 5 years old. This time last year, the LHN was capped at 40% of the Local Plan target of 2,555 dpa, i.e. 3,577 dpa, plus the 35% urban uplift (bringing the LHN to 4,829 dpa). Now that the Local Plan is over 5 years old, that cap no longer applies. As a result, the annual household growth figure of 4,574 (2022-32) has an AR uplift of 15.7% applied, plus the 35% urban uplift taking us to 7,136 dpa. Given that the Council has long struggled to accommodate lower housing numbers in the City and has relied on the Duty to Cooperate [DtC] to redistribute much of that need elsewhere, this is likely to have profound implications for the West Midlands Metropolitan area and beyond going forward. Nine of the top ten West Midlands districts have a Local Plan that is over five years of age although some (such as Shropshire) have an advanced emerging draft Local Plan that has already been submitted to the Secretary of State [SoS] for Examination. Regarding the lowest increase/decrease, Redditch has a revised LHN that is 4 dpa lower than before, which represents a 3% fall, followed by Solihull and Cannock Chase which also have a slightly lower figure than previous LHNs using the 2020 AR. West Midlands *Plan close to (or over) 5 years old   As for the North East region, the LHN for its 12 districts has changed little due to the 2021 AR, with only Newcastle upon Tyne seeing a change of more than 20 dpa. The City now has an LHN of 1,451 dpa compared to 1,423 dpa using the 2020 AR, an increase of 28 dpa or 2%. This is due to the 2021 AR increasing to 5.9, from 5.52 in 2020. Unlike much of the rest of the north and midlands, the impact of the LHN changes (modest though they are) may have a very limited impact across most of the region as 10 of the 12 local authorities have up-to-date Local Plans that are less than five years old. Only Middlesbrough (with a Plan that was adopted in November 2014) and South Tyneside (with a Plan last adopted in 2007) may be concerned about the likely impacts of these changes in LHN. South Tyneside Council is working towards a new draft Regulation 18 pre-publication Local Plan following public consultation in 2019 and a review of Spatial Options. Middlesbrough is further behind in its Local Plan preparation. The new LHN figures will therefore be a key consideration for both areas as a result, although the change is relatively modest (+15 dpa to 333 dpa for South Tyneside, which is close to its current 325 dpa Local Plan requirement, and +2 dpa to 262 dpa for Middlesbrough, well below its current Local Plan housing target of 410 dpa). North East *Plan close to (or over) 5 years old   Regarding the North West, some of the largest urban areas of the region (perhaps unsurprisingly) have the most substantial increases in LHN in the most recent iteration of the calculation. The cities of Liverpool and Manchester have the highest numerical increases of 123 dpa and 111 dpa respectively. Manchester City for example, sees its AR ratio increasing from 5.91 to 6.67. Liverpool’s level of AR increase is even greater, from 4.06 to 5.05. However, neither is likely to be adversely impacted by the increase in LHN in the short to medium term at least. Liverpool City Council adopted its Local Plan in January of this year with a housing target of 1,739 dpa (well below its 2,228 dpa 2022 LHN figure), whilst the Greater Manchester Combined Authority [GMCA] recently submitted its Places for Everyone [PfE] Plan to the SoS for Examination. This is a long-term plan for nine of the ten Greater Manchester districts (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Tameside, Trafford and Wigan [GM9] but not Stockport) for jobs, new homes, and sustainable growth and identified a housing target of 10,305 dpa overall of which 3,533 dpa was identified for Manchester City – below the revised 2022 LHN of 3,702 dpa. The PPG recognises that the housing need figure generated by SM2 may change as the inputs are variable and this should be taken into consideration by strategic policy-making authorities. However, LHN calculated using SM2 may be relied upon for a period of two years from the time that a plan is submitted to the Planning Inspectorate for examination[2].  This means that the GM9 districts (including Salford, Oldham, Trafford and Bury which also have some of the highest increases in the region) may argue that they do not need to revisit their housing targets despite the overall GM9 figure seeing a cumulative LHN of 10,658 dpa, up from 10,313 dpa based on the 2021 AR. One district which is likely to be significantly affected by the 2022 LHN adjustment is Stockport. Stockport Council withdrew from the Greater Manchester Spatial Framework [GMSF] in December 2020, which prevented the strategic development plan from proceeding to Regulation 19 Publication stage and instead work was undertaken to prepare PfE with the other GM9 districts. Stockport Council’s stated reason for leaving the process related to concerns around infrastructure provision, housing need and the significant proposed loss of Green Belt. In a letter to Stockport Councillors ahead of the decision, Greater Manchester mayor Andy Burnham wrote that: “the GMSF allows the 10 Greater Manchester boroughs to share out the numbers of homes that each individual borough needs to build. As a result, the GMSF allows Stockport to cut the number of planned homes by over 5,000 – 25% less than its Government target…Conversely, if Stockport was to opt out of the GMSF, it would have to find land for all these 5,000 homes”[3].    At the time, the GMSF housing target identified for Stockport Borough was just 793 dpa, with much of its 1,079 dpa LHN redistributed to other districts across the conurbation. It is interesting to note therefore that the latest 2022 LHN for Stockport is now 1,186 dpa, a 50% increase on the GMSF target and a 9% increase on the previous LHN figure of 1,081 dpa (based on the 2020 AR). This has been driven by a very substantial increase in Stockport’s AR, from 8.02 to 10.01 (itself a function of soaring house prices, which increased by 17% between 2020 and 2021, and falling workplace-based earnings). We await with considerable interest to see how the Council will find sufficient land to meet this higher LHN in full within its boundaries. Cheshire West and Chester, Blackpool, Preston and St Helens all see modest declines in their LHN figures under the new 2021 AR calculation, which will be of particular note to Planning Officers in those districts given that all four have Local Plans that are over 5 years old (notwithstanding the GM caveat for Wigan mentioned above).   North West *Plan close to (or over) 5 years old   Finally, for Yorkshire and The Humber, by far the largest increase in LHN (both in absolute and percentage terms) is for Leeds City, which has an increase of 153 dpa (or +4%) to 4,044 dpa. This is driven by a strong growth in its AR, from 6.34 to 7.08, although the Local Plan was only adopted in September 2019. It is still important to note that the Local Plan housing requirement of 3,247 is around 20% below the baseline starting point LHN. Sheffield is in a more difficult position given that it has a Local Plan that is over 13 years old and has an LHN that has increased by 68 dpa to 3,018 dpa, 223% higher than the current Local Plan housing requirement figure of 1,352 dpa. Most of the remaining districts in Yorkshire and the Humber’s top ten either have an adopted Plan (i.e. Doncaster) or have a Local Plan that is currently at Examination (Calderdale and York), albeit York’s new LHN is significantly higher than the requirement the Council currently believes is justified. As for those Yorkshire and the Humber districts with the lowest rate of change based on the 2021 AR, it is notable that with the exception of Barnsley, these are either predominantly rural or coastal/estuary districts, with weaker household growth tending to counteract the often very high AR issues the more affluent parts of North Yorkshire in particular face.   Yorkshire and The Humber *Plan close to (or over) 5 years old   Concluding thoughts With affordability in 2021 worsening at a faster rate than any year in the last two decades, and with it forming an integral part of the current standard method for assessing LHN, one might initially expect it to have a direct impact on many areas. However, when we look in more detail at the areas which might be affected, it is far from clear that there will be any immediate, or even long-term, consequences for those districts which have an up-to-date plan. That said, it is clear that for many local authorities that are reviewing their Local Plan in the north of England and the Midlands in particular, the generally higher figures generated by the rapidly rising AR (which counters often declining household growth over the longer term) could have significant consequences. This is particularly so when combined with other factors, such as the end of a cap to an extant Local Plan requirement (Birmingham) or the need to meet LHN in full without having the ability to redistribute unmet need across a wider HMA (Stockport). Whether this has the effect of further delays to the Plan-making system, or whether it encourages the Department for Levelling Up, Housing and Communities [DLUHC] to bring out a new SM3 that is less reliant on AR sooner rather than later, remains to be seen.   [1] ONS (2022): Ratio of house price to workplace-based earnings[2] PPG ID: 2a-008-20190220[3]  


Diminishing returns - The GMSF - A housing perspective
So, the wait is over – the Greater Manchester Spatial Framework [GMSF] Publication Draft Plan was approved by the Greater Manchester Combined Authority [GMCA] on the 30th October 2020.  Subject to approval by the 10 constituent authorities through November, the consultation on GMSF 2020 will begin on 1st December 2020 and will run for only 8 weeks, ending on 26th January 2021. There is a lot to cover on the GMSF and Lichfields is drafting a series of blogs covering particular topics. For a general summary see Brian O'Connor's GMSF in a nutshell blog. This Blog focuses on the perennially hot topic of housing. The updated GMSF has been awaited with great anticipation amongst the development community. It will set out the approach to housing land across all ten Greater Manchester [GM] authorities for the next 17 years. In recent weeks leaked documents, local newspaper headlines and e-newsletters has further dampened expectations amongst the development sector, suggesting that the GMSF was intending to go no further than the bare minimum LHN figures, further reducing the need for Green Belt release. For those that have not read in full the previous iterations, from a housing perspective, the GMSF 2020: sets out how Greater Manchester should develop up to the year 2037; identifies the amount of new housing development that will come forward across the GM 10 districts; identifies the main areas in which housing will be focused; allocates sites for housing outside of the urban area; and, defines a new Green Belt boundary for Greater Manchester. The GMSF 2020 is full of fine words which set out aspirations for growth, delivery, and the role of Manchester as a city in a world stage, including meeting (just) identified needs for market and affordable housing. The questions remain as to whether this rhetoric can be matched by substance (including the evidence base that underpins it). To what extent has the detail been driven by political influences, with a desire to protect Green Belt and limit housing numbers, hamstrung the GMSF 2020? Scale of housing need Policy GM-H 1 of the GMSF 2020 sets a minimum target of 179,078 net additional dwellings over the Plan period 2020-37 at an annual average of 10,534 dpa. This is below the previous revised draft GMSF target of 200,980 new homes over a slightly longer period of 2018-2037 (or 10,578 dwellings per annum (dpa)). Even this figure was reduced by 7% from the 2016 draft, which required the delivery of 227,200 new homes over a 20-year period (11,360 dpa). The previous (lower) targets have been pursued in the knowledge that it would result in the City Region losing the £68m housing deal that was tied to the GMSF’s original target of 227,200 homes. The latest 10,534 dpa target is based on the Government’s current standard methodology [SM] for calculating local housing need [LHN], which uses the 2014-based household projections with an affordability uplift. As an initial starting point, this is correct; albeit the governments consultation on a future alternative SM need to be remembered. However, this figure represents only the starting point for identifying housing need. The GMCA does not seem to have had appropriate regard to other issues that could justify a higher figure (even if it were only to discount them). The Government is clear that the figure derived by the LHN target is intended to be a minimum; and provides Guidance that sets out the circumstances whereby a higher figure might be considered.  This is because the standard method does not attempt to predict the impact that future national or local government policies e.g. Northern Powerhouse aspirations (they are Policy Off). Nor does it account for changing economic circumstances (e.g. arising from the Covid-19 pandemic), or other factors that might impact demographic behaviour. The GMSF address this point very briefly in paragraph 1.33: “Government has been very clear that deviation from the standard methodology can only be justified in ‘exceptional circumstances’.  No exceptional circumstances have been identified to justify deviation from the standard methodology in GMSF 2020.” However, no explanation or analysis is provided by the GMCA as to why this conclusion is valid, and it does not appear to have been tested at all in the accompanying Strategic Housing Market Assessment [SHMA].  This appears to be a major omission. Section 8 of the accompanying GMSF 2020 Growth and Spatial Options Paper did assess 3 potential growth options against the GMSF Vision and the GMSF Strategic Objectives.  The higher growth option considered the delivery of 227,000 new homes compared to the 179,090 derived from the LHN calculation. However, whilst the Paper concluded that the LHN Option 2 was its preferred option, this seems to be on the basis of balancing a range of a policy considerations concerning social, environmental and economic opportunities (hence the higher growth option is criticised for “providing more land than is needed to meet GMs housing and employment needs could put more pressure on GM’s environment and could hinder activity in relation to climate change and air pollution”).  This is a different (and subsequent) exercise[1] from an exceptional circumstances test examining the deliverability of growth strategies, economic alignment or the impact of strategic infrastructure. On the face of it, if exceptional circumstances to increase the housing target above the LHN do not apply to Greater Manchester, it is difficult to see where they would apply anywhere else in Northern England. For example, as the GMSF itself states: “The strength and strategic location of Greater Manchester puts it in an ideal place to act as the primary driver for the Northern Powerhouse... …Hence it will be important to deliver relatively high levels of growth within Greater Manchester for the wider benefit of the North.” [para 2.25]   If Greater Manchester, the key driver of the Northern Powerhouse, which is essential to the Government’s north/south “Levelling Up” agenda, cannot stir itself to accelerate housing delivery and construction above the bare minimum, then where else do we turn?  In this context, aspirations for Greater Manchester to be a ‘top global city’ by the end of the plan period with similar economic indices as London and New York (para 2.19) ring hollow. Similarly, the GSMF rightly acknowledges the considerable benefits of HS2: “which will help to deliver a more integrated national economy, opening up much greater business opportunities to support UK growth… ensuring that people are well connected to the new homes and job opportunities that these investments offer” [paragraph 2.23]  This sounds an awful lot like the “strategic infrastructure improvements that are likely to drive an increase in the homes needed locally” that Government clearly indicates[2] should be one of the exceptional circumstances justifying a departure from the SM. Spatial distribution The Plan directs the bulk of housing towards what it considers to be the most sustainable areas – primarily brownfield sites within the city and town centres.  The GMSF refers to the “Inner Area Regeneration of those parts of Manchester, Salford and Trafford surrounding the Core Growth Area.  Together with the Core Growth Area, around 40% of overall housing supply is found here.” [para 1.24, bullet 1].  In practice, this means a wholesale redistribution of housing requirements from the southern districts to Manchester, Salford and the Northern parts of the conurbation.  Regarding the latter, the GMSF aims to boost “the competitiveness of the northern districts – addressing the disparities by the provision of significant new employment opportunities and supporting infrastructure and a commitment that collectively the northern districts meet their own local housing need.” [para 1.24, bullet 3]. So what does this mean in practice?  As before, the GMCA has not distributed housing need across the districts as per the SM, but has instead redistributed the housing allocations based on policy objectives.  As summarised in Table 1.1, there are some very clear ‘winners and losers’ in the GMCA’s approach.  Stockport, Trafford and Tameside see a reduction of 740 dpa collectively, with both Tameside and Stockport seeing a reduction of around 27% based on the SM calculation. This ‘need’ is predominantly redirected towards Salford and Manchester, which increase by 675 dpa.  The redistribution to the northern districts is centred entirely around Rochdale and Wigan, with Bolton and Oldham essentially meeting their own needs.  In fact, Bury’s target is a substantial 150 dpa below its SM-derived need, a fall of a quarter.  This would seem to fly in the face of the GMCA’s goal of ensuring that higher levels of growth will be focused in northern Manchester and that they will “meet their own needs”. Table 1.1 Distribution of Housing Need Across Greater Manchester Source: GMCA (2020): GMSF Publication Draft 2020, Table 7.2 / Lichfields’ Analysis The GMSF suggests that higher levels of housing growth being focused in the central and northern districts of Greater Manchester will assist in “achieving a more balanced pattern of growth across Greater Manchester and a better distribution of skilled workers to support local economies, helping to reduce disparities.” [para 7.15] This of course assumes that people wishing to live in south Manchester would just as readily move to the Regional Centre, Wigan or Rochdale to meet their housing needs, when GMCA’s own evidence clearly demonstrates that GM is not a self-contained Housing Market Area.  Table 2.1 of the GMCA’s SHMA Update 2020 makes it abundantly clear that none of the 4 districts that are poised to see a big reduction in their housing target, have a strong relationship with the 4 Central/northern districts that will take on board their shortfall.  So, for example, 71 out of 100 house moves in Tameside took place within the same local area in the year to 2011, compared to only 3 out of every 100 moves being from Tameside to Manchester, Rochdale, Salford or Wigan.  Wigan in particular has almost no inter-relationships with the other districts and appears to be a separate housing market in itself. Table 1.2 Proportion of moves to Greater Manchester districts from England and Wales, 2011 Source: GMCA (2020): SHMA Update, Table 2.1 The effect of this will be felt by future generations with worsening affordability in the south as house prices continue to be driven up by suppressed supply. That supressed supply provides limited opportunity to provide more affordable housing. A virtuous circle creating a social and economic timebomb for future generations. Moving on to affordability specifically, this is rightly identified as a key issue: “a key challenge and priority for Greater Manchester is to ensure that new housing comes forward at a price that potential occupiers can afford.” [para 7.21] The Government is also acutely aware of the problems caused by housing affordability, and it is one of the key components of its SM for calculating housing need.  Its current proposals for a new, nationally-determined and binding housing requirement “would be focused on areas where affordability pressure is highest to stop land supply being a barrier to enough homes being built.”[3]  However, the GMSF 2020’s approach is to do precisely the opposite, redistributing housing need away from those areas with the most significant affordability problems and towards areas where housing is already comparatively affordable. As we can see from Figure 1.3, the areas that are least affordable are also the areas that the GCMA considers should have the highest cuts in their housing targets.  So, the 4 bars in the Figure below highlighted red (Bury, Stockport, Tameside and Trafford), which have GMSF targets below the SM identified need, are also the 4 districts that have the highest median affordability ratio (workplace-based). Indeed, Trafford’s median affordability ratio is as high as 9.58, which is the highest of any district in the whole of northern England (comprising 72 districts).  Observers may struggle to reconcile this with the rather complacent comment in paragraph 7.21 of the GMSF 2020 that: “Overall, Greater Manchester is a relatively affordable place to live on average compared to some other parts of the UK, particularly London and the South.” Figure 1.3 Comparison of Affordability Ratios and proposed GMSF Housing Targets Source: Lichfields / ONS.  Green bar denotes a GMSF housing target that is above the SM need; a red bar denotes a GMSF target below the SM need; and a grey bar denotes that the two targets are broadly in alignment. The type of homes to be provided A key part of the overall strategy is to maximise the amount of development on brownfield sites in the most accessible locations and minimise the loss of greenfield and Green Belt land as far as possible.  In this regard, the GMSF 2020 states that “in order to deliver the necessary densities, an increasing proportion of new dwellings will be in the form of apartments and town houses, continuing recent trends” [para 7.30].  The GMSF 2020 goes on to say that “there is scope to increase the number of families living in apartments, especially if higher density neighbourhoods can be made more inclusive for all age groups.” [para 7.31] As a result, Table 7.3 of the GMSF 2020 identifies that 58% of all the residential land supply to 2037 comprises apartments.  This is a huge amount and fails to address the significant need for family housing in GM.  Whilst the delivery of apartments and the efficient use of space for housing are clearly important considerations, the current pandemic has thrown into sharp relief people’s basic desire for access to private outdoor areas, preferably a garden, and, increasingly, to live in a property that is going to give them the additional space that would allow them to work from home on a regular basis. Furthermore, the Council’s own evidence suggests that high density schemes tend to be less viable and struggle to provide the supporting infrastructure (including affordable housing) necessary for sustainable communities.  As set out in the GMCA’s GM Strategic Viability Report: “in the city centres the higher density schemes, generally come forward with PRS and have little or no affordable housing due to viability concerns.” [page 52] There is a lack of any explanation as to how education, health and recreation infrastructure could be provided in the City Centre to support such high-density apartment developments that will presumably have to accommodate large numbers of children. Supply Table 7.1 sets out that in numerical terms, the existing supply of potential housing sites identified in the districts' strategic housing land availability assessments [SHLAAs], small sites and empty properties is adequate to meet the overall identified need, and that the additional 24,472 GMSF 2020 Green Belt allocations would result in an overall supply of 208,925.  This is 16.7% higher than the SM target over the 17 year plan period. Whilst any flexibility in supply is welcome, there is considerable uncertainty over whether the 176,665 homes identified in these SHLAAs, plus another 7,788 of windfall allowances, will really come forward as planned.  For example, from an initial review of the accompanying Housing Land supply tables, it appears that at least 64,000 units included in the Table (40% of the total) do not have any extant planning permission in place, nor are they allocated in an adopted Plan.  It therefore seems ambitious to assume that all of these will come forward over the plan period. The GMCA also seem to be suggesting that many of these sites are not viable at present, and will be difficult to deliver without substantial public sector intervention – “Many of these sites therefore face challenges which will need assistance to kick-start their delivery” [para 7.17]. The GMSF also argues that GM needs to identify a phasing trajectory which it considers is realistic and which will result in housing being delivered as planned over the life of the plan.  This is due to the uncertainties over Covid-19, but also because “a significant proportion of the land supply in the early years of the plan is made up from sites within the urban area, the majority of which are on previously developed land.  Many of these sites therefore face challenges which will need assistance to kick-start their delivery” [para 7.17]. The upshot of this is that the annual average delivery is reduced from 10,534 dpa to just 8,498 dpa in the first 5 years of the plan to 2025, with the shortfall being met at the back end of the plan period.  As a result, and according to Table 7.2, this means that Tameside’s annual target for the first 5 years, which has already been arbitrarily reduced from 651 dpa to 475 dpa, actually falls to just 281 dpa between 2020-2025 – a 57% drop on its actual needs.  Similarly, Trafford, which has an SM need of 1,369 dpa reduced to a GMSF annual target of 1,091 dpa, would only have to deliver 591 dpa for the first 5 years – a fall of 778 dpa on its actual need in the most unaffordable location in northern England.  This will undoubtedly leave many households having to move elsewhere to meet their housing needs. Affordable housing delivery The viability point also has serious repercussions for the delivery of affordable housing in GM.  The GMSF recognizes that “Greater Manchester is facing a housing crisis...The increase in rough sleeping over recent years has been the most visible manifestation of this, but lying behind it is a much more extensive problem of many people being unable to access suitable housing at an affordable price and with certainty of tenure.  Over 99,000 people are on the local authority housing waiting lists in Greater Manchester. A lack of appropriate housing options prevents some people from forming their own households, particularly younger adults, whilst those who can may have to cope with substandard or expensive accommodation.” [para 7.2] This is an important point, and one that has doubtless led to the ‘aspiration’ to “deliver at least 50,000 additional affordable homes across Greater Manchester up to 2037, with at least 30,000 being for social rent or affordable rent”. [Policy GM-H-2] However, to deliver 50,000 affordable homes out of a target of 179,090, this means that around 28% of all dwellings delivered will need to be for some form of social housing. The GMCA’s GMSF Strategic Viability Report Stage 1 (September 2020) makes sobering reading in this regard.  It states that: “When affordable housing is introduced to the typologies tested (up to 20% as a mix of affordable rent and shared ownership) most typologies were found to be viable within VA1 -VA3.  However, typologies tested in VA4 and VA5, cannot afford to deliver any affordable housing using the current assumptions.” So even in the higher value areas of southern GM, affordable housing was only tested at 20% of overall delivery.  In the weaker housing market areas, which cover large swathes of northern GM, much of Manchester City and almost all of Tameside, no affordable housing is viable at all.  Given that many of these areas are expected to accommodate the bulk of the GSMF’s housing sites, this conclusion cannot be reconciled with an ambition for 50,000 affordable homes – it appears fundamentally undeliverable based on the housing strategy at present. The fact that apparently 144,221 dwellings will come forward on often complex previously developed land (Table 7.1) further weakens the GCMA’s viability argument. Conclusion Whilst we welcome the arrival of the latest draft of the GMSF following a substantial hiatus, there is much to be concerned about regarding its practical deliverability.  Some components of the overall strategy, of seeking to improve affordability, making best use of brownfield land and providing greater flexibility in the housing land supply, are to be welcomed. Whilst we are of course living in unprecedented times with considerable uncertainty regarding the strength of the economy, how it will impact on the housing market in the short and long term, and how (and when) the development industry will fully recover.  However, it has to be said that the strategy followed, of redirecting development to selected northern districts and particularly the Regional Centre in high density apartment blocks appears a very risky one that does not seem to align well with existing needs and an increased shift towards home-working in the outer suburbs. The GMCA appear willing to forego GM’s leadership role at the heartbeat of the Northern Powerhouse just as they were prepared to lose the £68 million housing deal by targeting a lower housing target and less contentious levels of Green Belt release.  As a result, we are faced with a situation that the least affordable parts of Greater Manchester will see levels of housing provision that are significantly below their actual need.  Furthermore, that need will be pushed back to the later years of the plan, after 2030.  Housing supply is shifted to the Regional Centre, Wigan and Rochdale, which have very limited relationships with Trafford, Stockport and Tameside.  Family housing will be replaced with high density apartment blocks, often in some of the least viable parts of the conurbation, and much of it for PRS.  This means that affordable housing targets cannot be met, nor community infrastructure delivered.  It is difficult to see how this can be reconciled with the ambition expressed in the document for Greater Manchester to become a ‘global city’ on a par with London and New York. [1] The exercise set out in the Growth and Spatial Options Paper forms a subsequent stage in the analysis after the exceptional circumstances test has been undertaken, as set out in the PPG (2a-010-20190220): “This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan).”[2] MHCLG: Planning Practice Guidance, Reference ID: 2a-010-20190220[3]MHCLG (August 2020): White Paper – Planning for the Future, paragraph 1.20