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The Revised Draft GMSF – politics over powerhouse?

The Revised Draft GMSF – politics over powerhouse?

Colin Robinson & Imogen Zulver 15 Jan 2019
After a two-year delay since the first draft version of the Greater Manchester Spatial Framework (GMSF) was published in October 2016, the revised draft was finally issued on Monday 7th January. This follows a mayoral manifesto pledge in 2017 for a ‘radical rewrite’ with ‘no net Green Belt losses’. This has ultimately been impossible to achieve, but nevertheless, important changes have been made to the development targets for both housing and employment land and where they will go. The revised draft was approved for consultation under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations (2012) at the Greater Manchester Combined Authority’s (GMCA’s) meeting on Friday 11th January. The consultation is now open and will close on the 18th March 2019, with final consultation earmarked for September 2019 and adoption of the plan in December 2020. The previous version of the document attracted 27,000 responses with the main concerns relating to Green Belt release for housing and employment, low density employment sites/low value warehousing and the infrastructure implications for new development. This will be the first Spatial Development Strategy (SDS) outside of London. According to the GMCA, current legislation does not allow for an SDS of the type that the GMCA requires. Whilst the revised draft continues as a Development Plan Document, the GMCA want to convert it to an SDS which would not require the unanimous approval of all of the Councils, just the GMCA, and a whole host of issues will need to be examined closely in the weeks ahead to determine whether (as an SDS) the GMSF would be (1) subject to the tests of soundness, (2) able to allocate sites for development, and (3) able to amend Green Belt boundaries. Strong views either way have so far been expressed by the development industry. The objective of the revised draft GMSF is to plan for homes, jobs, infrastructure and the environment in the ten combined authority areas of Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan. The document claims to have overcome the main concerns with the 2016 draft and sets out its plans to: Deliver a stronger emphasis on the role of brownfield land and town centres; Reduce in the net loss of Green Belt; and, Provide stronger protection of importance green spaces. The question remains, to what extent has the detail been driven by political influences and a desire to protect Green Belt at all costs? Our view is that the GMSF suppresses development rather than actually providing the appropriate level of development needed in the most suitable areas to fulfil Manchester’s role as the engine of the Northern Powerhouse. Two years ago, we raised concerns that the 2016 GMSF was pursuing conservative levels of housing, with employment growth levels well below what many other cities were achieving elsewhere in the UK. We were concerned that without a radically re-booted, pro-development GMSF, Greater Manchester would be unable to sustain the Northern Powerhouse, nor act as a healthy counterweight to London and the Greater South East. However, the latest version of the GMSF scales back the level of housing and economic development even further, making it even less likely that Greater Manchester can achieve its potential. The Plan’s main emphasis is instead on delivering new development as part of a “brownfield-first” approach through higher density developments. The 50% reduction in site allocations within the Green Belt has (rightly) grabbed many of the headlines with the overall proposed net loss of Green Belt comprising 4.1% of Greater Manchester’s total Green Belt area (-2,049 ha), compared to 8.2% previously. Housing In terms of housing, the revised draft GMSF sets a target of 200,980 new homes to be delivered in Greater Manchester 2018-2037 (or 10,578 dwellings per annum (dpa)). This annual target has reduced by 7% since the 2016 draft, which required the delivery of 227,200 new homes over a 20-year period (11,360 dpa).   Figure 1: See larger version The map at Figure 1 shows the housing targets for both the 2016 draft and the revised 2018 draft GMSF against past delivery rates [1]. Whilst it is a positive that the GMCA is planning for an increase in recent levels of housing delivery, the proposed delivery rate would still be well below the delivery rate of almost 15,000 houses achieved just before the financial crisis in 2007/08 (almost 30% lower, in fact). In terms of the methodology used in the revised draft GMSF to calculate this target, the GMCA follows the revised standard method proposed by the Government in its recent consultation on calculating ‘local housing need’, i.e. to use the 2014-based household projections with an affordability uplift. This derives a figure of around 10,500 across Greater Manchester. However, the GMCA has not distributed this need across the districts as per the standard method, but has instead redistributed the housing allocations based on policy objectives. The GMSF states that promoting higher levels of housing growth in central and northern districts will achieve a more balanced and sustainable pattern of growth, support local economies and reflect the availability of suitable sites. This is shown in Figure 2 which compares the revised draft 2019 GMSF local housing targets for each borough against the local housing need (LHN) calculated using the revised standard method. As it stands, the approach appears to be flawed.  Figure 2: See larger version Figure 2 shows there are clear disparities between the LHN and the revised GMSF targets in most areas, in particular Stockport (1,078 LHN, compared to the 764 dpa GMSF target). Bolton and Tameside, two of the most deprived districts in Greater Manchester, both have reduced housing targets, despite the draft GMSF policy claiming that housing growth has been used as a tool to boost prosperity and reduce inequalities. Furthermore, the proposed distribution has no regard to the different housing market areas across Greater Manchester, and assumes that someone may be just as happy to settle in Wigan as they would be in Stockport. Moreover, the Planning Practice Guidance sets out that the standard method should be the minimum starting point for calculating LHN. The standard method has no regard to changing economic circumstances or future demographic behaviour which could have an impact on the LHN. It appears that the GMCA has used this starting point to identify their targets but have made no attempt to justify the lack of uplift, which could help to meet affordable housing needs or, critically, properly align with economic growth aspirations. The picture is even bleaker for those looking to get on the housing market any time soon. The revised draft GMSF has adopted a phased approach to delivering housing across the ten authorities. In other words, the GMCA proposes to backload delivery by lowering targets over the first 5 years and accelerate delivery in later years. The GMCA claims that there is a need to build up to a higher future delivery rate in order to obtain Government funding as well as the required masterplanning and infrastructure investments required to support development on the sites, including many of the allocations in the GMSF. Figure 3 Looking at the graph in Figure 3 we can see that this has had a particularly significant effect on Bolton, Bury, Oldham, Stockport and Trafford. Looking specifically at Bolton, the GMSF provides no housing allocations in the Borough and therefore the justification behind a phased approach here is unclear.  This suppression could assist in creating the illusion that these Greater Manchester authorities are demonstrating a five-year housing land supply, when in fact, they are knowingly underdelivering. Overall, the GMSF singularly fails to take affordability issues into account. The GMSF notes that if insufficient new homes are provided to meet increasing demand, then there is a risk that affordability levels will worsen and people will not have access to suitable accommodation that meets their needs (para 7.4). It is hard to disagree with this. However, the GMSF ignores the point by cutting the housing targets in the two districts with by far the highest affordability ratios in Greater Manchester, Stockport and Trafford, with the latter currently experiencing house prices some 8.9 times higher than earnings. By restricting housing growth in these areas and planning for more homes in more deprived areas, it risks intensifying the gap between supply and demand, contributing to continued house price increases. The revised draft GMSF also proposes a new policy (GM-H 4 Density of New Housing) which sets out minimum density requirements for new housing in Greater Manchester. These minimum density requirements are central to achieving the delivery of sites within existing brownfield sites within the urban area. However, the revised draft GMSF has little regard to site specific constraints such as flood risk, topography, ecology etc. which can reduce the net developable area of a site; nor does it have regard to the financial viability of delivering these (often complex) brownfield sites. This is another area in which the revised draft GMSF does not take into account different housing markets. The policy risks placing too much emphasis on delivering high density apartments within urban centres. It does not take into account that many families want to live in larger suburban family homes with private outdoor amenity space. England is in the middle of a housing crisis with an ever-increasing need for more family homes. The GMSF therefore needs to plan for a range of family homes in a number of locations across the combined authorities. There is also a strong, unmet demand for affordable housing across England. Policy GM-H 2 (Affordability of New Housing) sets out the GMCA’s aim to deliver at least 50,000 new affordable homes over the plan period (2018-2037) which equates to 25% of the total 200,000 homes to be delivered (2,632 annually). Greater Manchester is currently delivering an average of 1,211 affordable homes each year which is around half of the affordable housing required by the revised draft GMSF. To meet the affordable housing target, 25% of all dwellings would need to be delivered as affordable housing. This will be very challenging and, again, does not take into account viability considerations. Employment In terms of employment land, the revised draft GMSF sets out a target of 4,220,000 sqm of industrial and warehousing floorspace to be delivered in Greater Manchester over the plan period (or 222,105 sqm each year). The GMCA has trended forward past take up rates of B1c/B2 and B8 land and uplifted the resultant annual average by 25%. The revised draft GMSF claims to make provision for an industrial and warehousing supply (5,358,041 sqm) considerably higher than the overall ‘need’ to reflect the need to compete internationally for investment and provide sufficient choice and flexibility. However, compared to the 2016 draft GMSF, there has been a substantial reduction in the gap between the target and the projected supply. The total supply for Greater Manchester set out in 2016 draft GMSF exceeded the target figure by 103%[2], whereas the total supply set out in the revised 2018 draft GMSF only exceeds the target figure by 27%. It is evident that the GMCA are providing more industrial and warehousing floorspace than their ‘need’ which is positive; we agree that many of these potential allocations, particularly in the north, are suitable and deliverable however the level of supply has decreased substantially. However we think more industrial/warehousing allocations need to come forward to enhance competitiveness and flexibility in the supply. Conclusion In summary, it is a relief that the revised draft GMSF has finally been published and it is evident that the GMCA is working hard towards adopting a Plan that grapples with the issue of the Green Belt release. However in reality, more sites, both housing and industrial/warehousing, need to come forward in areas of greatest need.  The GMCA cannot afford to supress the housing delivery that is essential to sustain Greater Manchester’s economic growth. [1] 8,961 net housing completions in Greater Manchester in 2017/18.  [2] The 2016 draft GMSF made a provision of 8,126,000 sq m of industrial and warehousing supply with a target to deliver 4,000,000 sq m across the plan period.

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The only way is up?

The only way is up?

Colin Robinson 03 Jul 2018
An e-mail confirming Lichfields’ Northern Powerhouse Partner status dropped in to my inbox as I stood surveying the Manchester manor from 2o storeys up; from the delightfully named 20Stories restaurant at No1 Spinningfields. When I moved to Manchester two decades ago, only four buildings in the city topped 20 storeys and you certainly couldn’t enjoy gourmet food with a panoramic view and a raspberry martini; or enjoy living in any of them. I did once take some chips to rooftop of Portland Tower, the building where I plied my planning trade back then, but that was a glamorous as high-rise Manchester got pre-2000. Back to the future, and I stand watching the construction lifts scuttling like children’s toys up and down the façades of Renaker Build/SimpsonHaugh & Partners’ Deansgate Square Towers – the 67th floor of the tallest of four towers will top 200 metres and be the fifth tallest building in the UK – and wonder whether, for the largest city and metropolitan area in the Northern Powerhouse, the only way is indeed up? The Northern Powerhouse is characterised by cities with commonality in land use planning issues, and whilst the focus of this piece is the North West, my 20Stories view affords an outlook of the Pennines and I am acutely aware that beyond those hills the same issues are in play; and the same over t’other way too, in Liverpool. The smart money in the North West is on up, and out; across Greater Manchester. Local election results, amongst other things, have forced back – to ‘later this Summer’ - a consultation on the rewritten Greater Manchester Spatial Framework (GMSF); now the ‘baby’ of Greater Manchester Mayor Andy Burnham. The confidence and supply support from Trafford Liberal Democrats to Labour in a minority administration alliance is dependent upon a brownfield first approach to new housing, and seemingly removes from the GMSF the Flixton Station and Timperley Wedge sites put forward for Green Belt release. The two sites might have provided over 4,000 new homes and represent 6% of the residential development potential from Green Belt release sites (some 65,000 homes) across Greater Manchester. It remains to be seen how the rewritten GMSF proposes to redress the short-fall. Trafford’s reticence to embrace its housing shortage may well result in opportunities for additional sites elsewhere, across the combined authority area, but there is clearly a need for significant additional high-density, high-rise urban development and that will be driven by Manchester and Salford-focussed demand.  Lichfields knows that market well, leading the planning process on several 30+ storey towers. There is plenty here about Lichfields’ housing and expertise and insight. One certainty is that Andy Burnham will want the GMSF and a housing strategy for Greater Manchester sorted well in advance of the next Mayoral election in 2020. Back at a 20th storey terrace lunch table – I was at 20Stories as a client celebration on completion of an important regeneration project – I dropped into the conversation the spatial framework; not the Burnham ‘baby’ but the City of Manchester Plan of 1945. Those who know me will recognise that I am a bastion of topical conversation. Chapter 12 Housing Standards starts with quote from once Bishop of Manchester William Temple ‘We need more space, above all more space for and in the homes of people…’; nothing changes. The 1945 Plan includes page-upon-page of guidance on appropriate residential densities, standards for internal living and principles for outdoor amenity space. I read it recently, and I bring to this into the discussion.  Stick with me my lunch guests did.   The 1945 Plan’s relevance to modern day society and policy aspirations, through its references to ensuring that the delivery of residential development is ‘…compatible with a sense of well-being’, achieves a ‘softening…of stark lines’ and contributes to ‘enlivening…arid monotony’ is palpable. It goes on to say that ‘…means must be found to bring back living greenery into our inner residential districts’. Whilst the Manchester Plan was seeking a move away from bare, drab too-closely-built Victorian streets the reference to well-being is as applicable now as it was then. Millennials (born early 80s to mid-90s), often dubbed Generation Rent, are occupying a significant proportion of new-build city apartments across UK towns and cities; Manchester and Salford are no exception. In the past, Baby Boomers who moved ‘out’ to new-build peripheral housing estates often cited isolation and loneliness given an absence of ‘community’ and facilities; a sense of being a long way out from their traditional inner-city residential areas. As we increasingly embrace building up as well as out, and land availability constraints will demand this, land use planning needs to be increasingly minded of those living a long way up. Residential tower blocks have always carried the risk of social isolation, all too often a social failing of our elderly citizens. Such discussions about loneliness typically focus on the elderly, but a recent Study by the Office for National Statistics found that young people (aged 16-24) identified with a feeling being lonely more often than is the case with any other adult age group. If Millennials and those who follow (so called Generation Z) are to populate and make communities out of our high-rise cities then the Northern Powerhouse needs to reflect on the foresight of 1945 to ‘…bring back living greenery into our inner residential districts’. It is not the greenery per se that might guard against that threat of loneliness, rather the opportunity carried by open space for social interaction. Moreover, making something of that potential is down to those potential users; the Fortnite versus real world conundrum. Don’t think either that I’m questioning high-rise, high-quality being delivered in our new vertical cities; that is top drawer. It’s the spaces in between that is of fundamental importance to creating liveable and sustainable environments. Perhaps Yazz –known well by my Generation X cohort – was prophesising about 21st century living when she sang– But if we should be evicted, Huh, from our homes, We'll just move somewhere else, And still carry on – in the 1988 hit The Only Way is Up.   Generation Rent might be residentially peripatetic and upwardly bound, but that footloose sense captured by Yazz will only meet with success if our urban environments delivery a sense of well-being and belonging. Ultimately the Northern Powerhouse, and its success, is all about, and dependent upon, the people of the North. That is, utilising their economic might to drive forward the new Northern agenda. We can only do this if land use planning creates the right foundations for society, and looking after the social well-being of Northern Powerhouse citizens is paramount as our cities grow up as well as grow out.

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