Andy Kelly response to the Greater Manchester Spatial Framework Consultation.

17 Jan 2017

Dear GMSF,

RE: Objection to the Greater Manchester Spatial Framework.

I am writing to formally object to the current consultation on the Greater Manchester Spatial Framework. I am a councillor in the Milnrow and Newhey Ward of Rochdale Metropolitan Borough Council. The ten Greater Manchester authorities and the Greater Manchester Combined Authority are jointly pursuing the Greater Manchester Spatial Framework (GMSF) to identify land for housing, offices and industrial use over the next twenty years. The requirement for a local plan comes from the Government.

The GMSF plan has been produced by Greater Manchester council officers and a small number of politicians. Councillors and the public, didn't get to see the plan until it was fully-formed. That's no way to make such an important decision that will affect our communities for decades or even centuries to come. We would like to see a plan built by communities. It should start with a discussion about what we want for Newhey, Milnrow and the rest of the Borough of Rochdale. Greater Manchester will soon be electing a Mayor, but the Combined Authority is too secretive. The GMSF is just one example, but it's an important one. The ten councils across Greater Manchester have a long tradition of working together effectively where they agree, and doing thing in other ways where they disagree. The councils have almost never tried to force everyone to go along a particular path against their will. I strongly support the Combined Authority, but do not believe that this work is best done at a Greater Manchester level - it is just too remote from the local communities that will be affected.

I believe that planning decisions are better done as locally as possible. I acknowledge the failure of Rochdale Metropolitan Borough Council to adopt a formal local housing plan. I am aware that this failure and reliance of the out of date Unitary Development Plan leaves our Borough vulnerable to developers. We would like to see RMBC withdraw from the GMSF and instruct Officers to begin consultations on its own Local Plan.

I intend to contribute to this consultation on the following issues:

• The loss of wildlife in the nearby woodland. The council has a duty to protect woodland and the wild life under the UK BIO Diversity Action Plan.

• The loss of a tremendous amount of Greenbelt and farm land.

• The loss of valuable, heavily used recreational spaces for the local populace of all the age groups to enjoy.

• Disruption of local footpaths and bridleways.

• Loss of the natural break from the other nearby communities, creating an ugly urban sprawl.

• The failure of the consultation to address local infrastructure issues including over capacity for local schools, hospitals, dentists and doctors, road congestion and public transport issues.

• Heavy traffic on local roads which are not suitable for the amount of housing proposed.

• More excessive housing would increase the Carbon Footprint.

The GMSF, which you published in October 2016, states that 227,200 new homes are needed in Greater Manchester by 2035. As part of this, the draft proposes the completion and extension of Kingsway Business Park to the South of the M62 motorway, and the building of 1,500 new dwellings between Newhey and Crompton. 120 of those houses are planned for green belt land in my ward alongside plans for industrial space in our village. I have consulted with hundreds of local residents on this issue and it my belief that any development on greenbelt land in Newhey and an even bigger development on land across the River Beal will have a detrimental affect on our village in what is the biggest housing building plan since the Second World War in our area. I will be using this document to set out why changing the designation of green belt land for house building is the wrong thing to do and will adversely affect our villages for decades to come.

The length of the proposed GMSF is also too long compared to plans from Councils across the country. The majority of local councils are producing 15 year local plans. The GMSF plan is a 20 year plan. This means that in Greater Manchester, the plans involve 227,200 new homes. If the GMSF was a 15 year plan like most other places in this country - you would only be consulting on plans for 170,400 houses. This would take some of the pressure off building on greenbelt in places like Newhey.

At a Full Council Meeting of RMBC on December 14, 2016 - Council Leader and Greater Manchester Combined Authority Member Richard Farnell stated that all brownfield sites would "…be filled first before one foundation is laid on Green Belt land." In your consultation, you only have a target of 70% of building on brownfield sites before building on green belt. I would like to know which statement is true? If the GMSF goes through, the result will be large-scale building on the greenbelt while numerous brownfield sites in our towns remain empty and derelict. That's largely a Government policy failure. The Government has cut funding available to develop those brownfield sites which means they are not viable. We want to see more done to use the existing brownfield sites, and to ensure that greenbelt is not developed while brownfield remains unused. Despite several requests, we still do not have a definitive list of brownfield sites available for development in Rochdale Borough nor Greater Manchester.

I also have concerns about a recent report from Shelter, the homeless charity. They found that the UK's 10 biggest housebuilders are sitting on '14 years worth of land, on which almost 1,000,000 houses could be built.' I would like to see the Greater Manchester Combined Authority work with these companies to establish how much land is being 'banked' and sat on in Greater Manchester and how releasing this land for development would lead to a reduction in housing targets. I am aware that in formulating your consultation document - despite not communicating with residents or local councillors, you did consult with developers. I would like to see you use these channels of communication and establish what land developers currently own and their plans for the next 20 years. Surely this would have been an obvious starting point for any consultation?

I have huge concerns about the effect on the environment. The Beal Valley is home to foxes, badgers, pheasants, lapwing, newts, weasles, roe deer etc. Losing green belt protection means concreting over fields, trees and hedges that currently provide essential wildlife corridors. The Beal Valley can ill-afford to lose such precious wildlife habitat. Biodiversity is vital, and this is about having a diversity of animals and plants as well as people. To lose this wildlife corridor and essential habitat to meet unrealistic arbitrary house building targets is not suited to the needs of our local community. To build on our green belt would deprive our villages of much of its green lung and create an urban sprawl - out of keeping with the way of life that our villages enjoy.

I have further concerns about the loss of valuable, heavily used recreational spaces for the local populace of all the age groups to enjoy. The green belt around the Beal Valley is popular for residents young and old. The disruption to our local footpaths and bridleways would affect our area hugely.

To build 120 houses in Newhey and a further 1500 houses across the River Beal in Crompton would have a detrimental affect on resident's way of life. The consultation document has much in it about house building but little about improvements to the local infrastructure and local services to pay for it. In Section 3.24 of the Greater Manchester Spatial Framework Consultation document, it says:

"Major improvements to transport infrastructure and services will be required, with a particular priority being the provision of rapid public transport services through the major new employment and housing areas, connecting residents to job opportunities."

There is no explanation of how these public transport improvements will be delivered. Newhey and Crompton currently suffer from an extremely poor public transport service. Only last year, First Buses axed the daytime 182, bus service. This affected staff, patients and visitors to the Royal Oldham Hospital. The Metrolink service servicing Newhey could not cope will such of influx of new residents. The GM Spatial Framework claims that one of the benefits of development around the Beal Valley would be an improvement to the rail network. Anyone with any local knowledge would be able to point out that the rail network does not serve the area.

The effect on local amenities that serve Newhey would also be significant. For example, Rochdale and the Royal Oldham Hospital would simply be unable to cope. They have both claimed recently that their services are at 'breaking point' In April 2011, the A&E department at Rochdale Infirmary was downgraded to a GP-led Urgent Care Centre in April and now only treats non life-threatening walk-in injuries. The maternity unit was completely scrapped. Rochdale residents now have to use either Fairfield General Hospital in Bury, the Royal Oldham Hospital, or North Manchester General Hospital A&E facilities. This has led to huge pressures at all hospital within the area covered by the Pennine Acute Trust. At no point in the consultation is there any acknowledgement of any investment nor plans for our health services. Residents in Newhey currently face a long wait just to see their GP and none of the local dentists accept NHS patients. The document does not address this problem.

The affect of our children's education is also a glaring omission. Our schools would simply be unable to cope with the expected influx of children. Again the document fails to consider this. There is no indication that the Greater Manchester Combined Authority will work with Local Education Authorities to deal with over-subscribed school places nor any discussion of additional investment in our schools.

Emergency services have seen huge cuts over the last few years. There are fewer Police Officers, Ambulance Drivers and Fire Men and Women in Rochdale and Oldham for a generation. There are no plans, according to the document to invest in our emergency services - putting pressure on already stretched services.

Local people in the area are concerned with traffic congestion (bottle necked at Kiln Lane and Jubilee Bridge) This is not acknowledged in the consultation document. Our roads will simply be unable to cope with potential developments of this size.

Newhey and huge parts of Milnrow have suffered constant flooding problems in recent years. It is my view that this will be exacerbated by further developments in the area. RMBC have still not got to grips with the problems. Adding to this, we have concerns about the effect on the overall air quality in the area due to the congestion on the M62 and the increase in the Carbon Footprint would be significant.

In conclusion, the potential development is so significant, it will change our area forever. Newhey and Crompton can simply not cope with these developments. The GMSF is a poorly written document which breaks so many planning regulations it's hard to know where to start. For example, there is no mention of affordable housing, no mention of how emergency services will be affected. No relevant thought has been given to improvements to public transport in our area. Nor, the effect on our environment etc.

It is my belief that this consultation is fundamentally flawed. The failure of your consultation to address many of the issues outlined above means that it is very difficult for local people to come up with an informed decision on plans. You have already seen senior colleagues of the majority of members of the Greater Manchester Combined Authority criticise this whole process. This includes Labour's Candidate for Greater Manchester's first elected Mayor Andy Burnham. Whilst this wouldn't be the first time that Mr Burnham has adopted a populist stance - I entirely agree with him. He has called for the controversial green belt plans to be radically rewritten, calling them 'unfair and disproportionate'.

I, stand with like hundreds of local people and oppose these potential developments in the strongest possible terms.

Yours sincerely

COUNCILLOR ANDY KELLY

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