Tuesday, 17 January 2017

My letter to the Greater Manchester Spatial Framework (GMSF) consultation

16th December 2016

Dear Sir/Madam

Draft Greater Manchester Spatial Framework

I write to comment on general aspects of the draft GMSF, and in particular the proposed removal of the Green Belt status from three areas of land in my constituency of Makerfield.

General Issues about the Greater Manchester Spatial Framework:

A number of Greater Manchester Members of Parliament have raised concerns about aspects of the Framework. As advised, whilst we support the ambition of the strategic plan for jobs and growth for our city region we are concerned about the Draft Plan as published. I enclose a further copy of that letter for consideration.

In addition to the points raised in the attached letter, I am also concerned about the democratic deficit aspect of the GM Spatial Framework decision making process. If devolution is to work, then it cannot by-pass communities and their elected Councillors who must be given the opportunity to raise these matters in the Council Chamber. So far I have not been given assurances that this will be the case.

The GMSF needs to be of the highest quality and support the aspirations of both the combined authorities and the residents of all the Boroughs of Greater Manchester; a model that others can follow.

28.7.1 M6C1 Junction 25 (Wigan)

On the 15th August 2013, Mr. Kevin Ward BA, an Inspector appointed by the Secretary of State for Communities and Local Government, produced his report on the examination into the Wigan Core Strategy. The report was prepared following a number of hearings, one of which I attended to present a case against the Council’s proposal to allow industrial and logistics development on land off junction 25.

In summary, the Inspector determined that:

taking all factors into account, the benefits of the proposed broad location in terms of potential investment and job creation are not sufficient to outweigh the adverse effects in relation to the Green Belt and other matters. Exceptional circumstances to justify removal of the land in question from the Green Belt do not exist. The proposed broad location at Junction 25 of the M6 is neither justified nor consistent with national policy.

The Inspector advised that in order for the Core Strategy to be approved, this proposal would have to be removed, which is what happened. Three years ago Wigan Council conceded that its argument to remove green belt status from this area of land was not strong enough. The Council’s argument today, in relation to an even larger area of green belt at this location is no different I would argue, than it was previously.

The main issues of contention are that:

1) The Green Belt in this location separates the two settlements of Wigan and Ashton. Its removal would allow substantial development beyond the existing built up areas. This would allow sprawl of the built up area and encroachment into the countryside.
2) The site in question contributes positively to the overall appearance of the settlements and is crossed by public rights of way which provide a recreational resource for the local community.  The resource value of any maintained or rerouted rights of way, which would then no longer be in an open land situation, would be diminished, regardless of any amount of mitigating measures taken.
3) I do question if the Council requires this land to provide an adequate supply of employment land across the borough as a whole for the GMSF. In 2013 the Planning Inspector noted 200 hectares of land would be appropriate during the life of Wigan’s Core Strategy to 2026. In this respect the junction 25 proposal was not considered necessary as significant opportunities for economic growth in the borough could be met from existing sites, town centre opportunities and the proposed broad location for new development involving safeguarded land. Whilst I appreciate the extended life of the GMSF, I do wonder about the calculations that have been used to reach the levels agreed. The CPRE also queries the employment land and housing requirements identified within the framework.
4) The removal of this greenbelt would have the potential to undermine efforts to promote regeneration elsewhere in the borough and act as a disincentive to developers to assist in regeneration aspirations. Brownfield sites could be rejected in favour of this more desirable and potentially profitable green field area.
5) Whilst I can see there is some advantage in warehousing and distribution development having direct access to the motorway system, I and the former Inspector were not convinced that it was a critical factor in attracting employment. There are other sites available a little further from the motorway that would offer a reasonable prospect of attracting business. Also, removal of this greenbelt status would set a precedent and put under threat any greenbelt land close to a motorway junction.
6) Is this development proposal exceptional?  Currently, within about a two mile radius, there is the South Lancashire Industrial Estate and the Landgate Industrial Estate providing warehousing. Large scale housing and employment development has received outline permission in Bryn. There are also several other similar developments proposed in the adjoining Boroughs of Leyland and St. Helens just over the nearby constituency boundary at this point including Florida North and Haydock Point.
The Inspector previously agreed, on inspection of the Jt. 25 proposal, that the type of employment uses envisaged are typical of those found on employment sites within the borough and elsewhere and were not exceptional as to warrant removal of the Green Belt status on this site. There has been no change in the proposed use of the land since it was previously rejected.
7) The cumulative effect of the developments highlighted at 6), together with development proposed for the Bell at junction 26, also raise concerns about the impact on air quality. I note the aims of the GMSF in terms of air quality but I question how the considerable increase of HGV movements in my constituency along and around the M6 will not further compromise air quality.
8) Insufficient account is still being taken of the specific circumstances relating to junction 25 on the motorway. One of the main arguments for the Council putting this site forward is its proximity to the M6 providing easy access. However, this junction only provides direct access to the proposed development to or from the south. Vehicles travelling north on the M6 from this site would have to find a route through the already congested local areas to reach Junction 26 or travel south on the motorway to junction 24 and turn around. The idea of a two way junction 25 is no more than an aspiration and there are no proposals for such a scheme to be implemented in line with the employment plans.

Given the above, the Council’s case for inclusion of the site at Junction 25 of the M6 motorway for logistics and distribution purposes is not sufficient to outweigh the adverse effects in relation to the Green Belt and other matters and is therefore not in line with national policy.

28.7.2 M6C2 Junction 26 (Wigan) (known as The Bell)

1) The Green Belt in this location borders on the built up area of Kitt Green and its removal would allow substantial development beyond the existing built up area. This would allow sprawl of the built up area and encroachment into the countryside.
2) The Bell provides a barrier between the neighbourhoods of Kitt Green, Orrell and Pemberton and prevents the merging of these areas.
3) The site in question contributes positively to the settlements in the area and is used as a recreational resource for the community. It is the green lung in a built up area.
4) The air quality in this area is already compromised I believe as the site is close to the motorway and the Heinz development which involves a substantial amount of heavy vehicle movement. The cumulative impact of this proposal together with other developments on land off the M6 gives rise for serious concerns in relation to air quality.
5) The removal of this greenbelt would have the potential to undermine efforts to promote regeneration elsewhere in the borough and act as a disincentive to developers to assist in regeneration aspirations. Brownfield sites could be rejected in favour of this more desirable and potentially profitable green field area.
6) There is an acknowledged serious traffic problem in the area of Orrell and the proposed development of The Bell includes a link road to junction 26 of the motorway. This would be a major undertaking and may necessitate the demolition of residential property and potentially involve the Council exercising compulsory purchase powers. Concerns about the feasibility and deliverability of such a scheme, I believe, puts in question the whole proposal.

In connection with the consideration of its Core Strategy, Wigan Council previously included proposals to remove the Green Belt status from The Bell. However, this proposal was later dropped, I understand, because of problems associated with the potential development of this site including the construction of the necessary access link road from junction 26 of the M6 motorway. The problems remain today.

I do not believe the benefits of removing the Green Belt status from this area of land outweigh the detriment to the local area. The Green Belt at this location is still required. I also question if this proposal/development is feasible/deliverable given the difficulties outlined.

OA28 Liverpool Road, Hindley (Wigan) (Development known as South Hindley Urban Village).

It is proposed to remove the Green Belt Status on an area of land required for the link road through South Hindley Urban Village. Whilst I do not oppose this proposal, as I appreciate the road is vital to relieve traffic problems in the area, I would ask that the minimum amount of greenbelt land be removed for the road purposes.

In general I oppose the removal of Green Belt which serves the purposes of preventing Urban Sprawl, the merging of neighbouring towns and encroachment into the community’s greenspace and encouraging the development of derelict and other sites.  It is vital therefore that the green status be removed only from the smallest site required for road purposes.

Your consideration to the concerns raised both in this email and the letter from the group of Greater Manchester MPs attached would be appreciated.

I wait to hear from you.

Yours sincerely,

Yvonne Fovargue MP
Makerfield

I also secured the support of several Greater Manchester MPs who added their names as signatories to the letter below addressed to the Interim Mayor - Tony Lloyd.

Mr Tony Lloyd
Interim GM Mayor and Police and Crime Commissioner for Greater Manchester
Openshaw Complex
Lawton Street
Manchester
M11 2NS

16th December 2016

Dear Tony,

Greater Manchester Spatial Framework

We as Greater Manchester MPs wish to support the ambition of a strategic plan for jobs and growth for our city region.

However, we are concerned about the Draft Plan as published.

The timing of the transport infrastructure to support the expansion of housing and employment sites is crucial. Leaving the infrastructure to be developed piecemeal after developments are completed will lead to inevitable traffic congestion on our already overcrowded road network.

This leads to our second concern, that of air quality. GM already fails to meet required standards and additional traffic, particularly HGV traffic on a grid locked road, can only lead to further deterioration and, potentially, fines being devolved to local authorities.

Combining the spatial plan with the review of the Greenbelt has also raised concerns. Greenbelt was designed for specific purposes, retaining the identity of local communities, preventing urban sprawl and should only be redesignated in ‘exceptional circumstances’. The plan should ensure maximum use of brownfield sites prior to any review of greenbelt.

Additionally the outer Boroughs have concerns that our neighbours plans, which will impact Boroughs in GM have not been considered and there is a lack of joined up working.

We understand all local authorities desire to maximise their business rates to minimise the impact of the new localisation of business rates which will affect some local authorities adversely but this should not lead to a race to the bottom.

Whilst we recognise the need for new housing we are concerned about the apparent lack of affordable homes in these plans. Our young people in particular need access to affordable homes to rent or buy and these needs must be taken into consideration in any housing plan.

The plan should be rightly ambitious for GM but we need the right mix of housing and employment in the right place and this draft doesn’t facilitate this ambition.

It is important that the GMSF is of the highest quality and supports the aspirations of both the combined authorities and the residents of all the Boroughs as Greater Manchester will be the first area to bring forward their plan and should be seen as a trailblazer and a model to which others can aspire.

Yours sincerely,

Yvonne Fovargue MP
Chris Green MP
Kate Green MP
Andrew Gwynne MP
Barbara Keeley MP
Liz McInnes MP
Lisa Nandy MP
Yasmin Quereshi MP

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