Poynton Town Council Response to Local Plan Public consultation on Planning issues

1 Introduction

Poynton Town Council has noted that Stockport Council have begun planning for the future of the Borough to the year 2035 through their own Local Plan. The Borough Council are seeking views about the future of the Borough within the following topics:

Jobs and the role of town and district centres; Health, culture and communities; Where we live and the types of homes we live in; Our green places and spaces; and Transport and infrastructure

The Town Council wish to make comments on those aspects of the Plan which are the most likely to have some impact on the community of Poynton.

By way of background, the Town Council has noted that the Issues Paper states that the Local Plan will need to have regard to the emerging work on the Greater Spatial Framework (GMSF) and the proposals for housing and employment numbers, as well as the allocations and strategic priorities it sets across the whole of . The Issues Paper sets out what those proposed targets are in the main body of the document.

The Issues Paper sets out number of challenges and opportunities facing Stockport Borough now and in the years to come and confirms this is the first chance to start influencing how the Council may address these. It acknowledges that people are concerned about the delivery of housing, both in terms of the numbers and where they are built, and how they might deal with being both a well-connected borough but where the roads are often very congested.

The Town Council notes that the consultation takes the form of a series of questions (21 in total) based on the main topic area listed. We have also noted that there are no specific proposals being made at this stage. Many of the topics listed are of concern to Poynton Town Council.

2 Jobs and town and district centres.

It is noted that both Wilmslow and Poynton are identified as centres on the fringe of Stockport Borough which may provide services to local areas. Bramhall and Hazel Grove are among the list of district centres. Around 8% of Stockport residents work in East while a slightly smaller number of residents work in Stockport. Cheshire East is the second choice Borough preference after Manchester for Stockport residents for work. The major employment areas in Stockport are recognised and have some room for expansion. Stockport has net outflow levels of around 11,000 workers each day and there is a wish to promote local jobs to reduce out-commuting. There is a shortage of larger industrial units which causes a barrier to new firms looking to expand or relocate in.

In terms of the centres to the south of the Borough, Bramhall is defined as a healthy centre while Hazel Grove is experiencing some difficulties. Through the whole Borough, there are 25 local centres of which 11 are experiencing problems at present.

The GMSF for the period 2015 to 2035 sets an overall Stockport employment floorspace requirement of 90,000 sq m, the majority of which could be provided at Bredbury and served off the M60.The focus on office space would be in the town centre.

Poynton Town Council fully supports the wish of Stockport Council to create more local jobs in its industrial parks and town and district centres as being a more sustainable solution to travel to work patterns as well as having the potential to reduce local traffic across the county/borough boundary. The expansion of existing business estates is also a sustainable option. Office jobs within the town and district centre is also to be welcomed provided the adequate infrastructure is available.

3 Living and types of houses

The Town Council is aware of the consultation from the Greater Manchester Combined Authority (GMCA) in Autumn 2016 about the proposed housing numbers and potential sites and locations for these homes. At item 5.2 under Housing on page 31 of the Stockport Issues and Options paper it states as follows:

5.2 The emerging work on the Greater Manchester Spatial Framework (GMSF) will set the overall housing figure for Stockport, and will provide large-scale housing allocations where necessary. At this stage, Stockport's requirement is 19,300 additional new dwellings between 2015 and 2035, although it is subject to change. This works out at 965 dwellings per year. Our current Core Strategy housing target is around 480 dwellings per year and national guidance means that we need to find a way to deliver that revised figure.

The Town Council notes that no further information as to potential sites and locations within Stockport other than the original GMSF material being used as a source.

Poynton Town Council is concerned that it was not clear at the time of the GMSF consultation how the GMCA came up with their total for the city region as a whole and then divided it around the ten boroughs. There being limited evidence underpinning the figure, it appeared that some rather arbitrary figures had been deployed including the number for Stockport of 19,300 proposed homes.

One of the key documents for the GMSF was a scoping report from consultants Arup. The Arup scoping report, on page 23, stated that population growth in Stockport from 2003 to 2013 was 1,532 (0.5%) in total, which equates to an average of 0.05% per annum. On page 24 of this report, it is predicted that Stockport population growth from 2013 to 2037 would be 30,000 (9.6%) in total, which equates to an average of 0.4% per annum over the period. This predicted figure is many times higher [8 times in fact] than the actual figure for the previous ten years. Predictions for other boroughs in Greater Manchester did not show this large predicted increase in the rate of population growth. In addition, the report notes that Stockport has the highest proportion of people who are 65 and above and the lowest proportion of 16 to 64 year olds, compared with any other borough in Greater Manchester. Therefore, this highly inflated population growth prediction for Stockport seems unlikely.

The current Development Plan for Stockport is the Stockport Core Strategy which covers the period from 2011 to 2026. This states that during these 15 years an additional 7,200 new homes will be provided. The housing targets for the next 5 years of the plan period are as follows:

 495 new homes p.a. between 2015 and 2020. Therefore, 2,475 new homes are required for a 5 year supply against the Core Strategy.

If the annual requirement of 495 per year over a 20 year time frame is used, then there is a total need for 9,900 houses in Stockport. This is substantially different to the 19,300 in a 20 year time frame proposed. Although there have been changes in national planning guidance following the National Planning Policy Framework in 2012, the concern is that the number proposed for Stockport in GMSF is open to serious challenge and is currently under review by the GMCA with the next round of consultation now proposed for Summer 2018. This figure is however to be used as the starting point for SMBC Local Plan. Furthermore, since the GMSF work was undertaken and publicised, there is now a commitment by government in the Housing White Paper (and elsewhere) to consult on options for introducing a standardised inclusive approach, specifically with reference to older people to assessing housing requirements. Consultation was due to take place in Spring 2017 but has now been confirmed for September 2017. Such a standardised methodology as a future tool to provide a level playing field for plan production for future plans (including both the GMSF and Stockport Local Plan) is to be welcomed.

Accordingly, and for all these reasons, Poynton Town Council wishes to register a strong objection to the approach proposed as being inappropriate for the reasons given. We would also draw attention to the objections raised by the Town Council in respect of the original GMSF consultation (attached as an Appendix to this submission).

4 Our green places and spaces

The Town Council fully supports the emphasis within this part of the Issues paper concerns types and uses of existing and proposed open spaces, uses of brownfield land and alternatives to the use of Green Belt for homes and jobs. No assessment of the quality of the different parcels of Green Belt land has been undertaken to date and there is no reference to such an assessment being proposed. Members may recall that Cheshire East undertook two such assessments as part of its analysis of potential sites to be taken out of the Green Belt and allocated for development (including three strategic sites in Poynton). Within the text, the need for higher densities closer to local facilities and services is identified as one of a number of potential solutions to encouraging the use of brownfield land first.

Poynton Town Council has consistently promoted the need for a brownfield first response as a sustainable solution to the need for more housing and employment development. This was addressed in some detail in our response to the consultation on the GMSF which is attached as an Appendix. The majority of points are also relevant to the Stockport Local Plan. In particular we would refer to section 4 of that response: 4 Proposed spatial distribution of development and use of brownfield sites. If 11 of the 25 local centres within Stockport Borough are experiencing difficulties, high density and sustainable sites for housing within or on the fringe of such centres affords an ideal solution. The centres can secure their regeneration through housing led renewal which can bring investment in local services and shops to serve new community and the brownfield solution requires less or little Green Belt land to be taken for development.

5 Transport and infrastructure

The Town Council notes that the transport section of the Issues paper for the Local Plan has been developed alongside other important transport documents: The Greater Manchester Transport Strategy to 2040 and the SEMMMS Refresh also to 2040)

The NPPF recommends that local plans should support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport. The need for transport policies to consider the impacts of wider transport systems is also highlighted and discussion with neighbouring authorities is recommended. The Issues paper accepts the area suffers from congestion on the roads, caused in part by people travelling through Stockport to get to work or leisure opportunities in other areas (an example being Cheshire East/Poynton residents commuting to and from Manchester centre, universities and airport. Increasing car ownership and people travelling greater distances to work are expected to continue, and this may worsen congestion. The paper states that an effective and sustainable transport system for moving around and getting to and from Stockport is essential for the quality of life of residents and the town’s future development and prosperity.

The Town Council would draw attention to their comments made in section 7 of the response to the GMSF (at the Appendix to this submission) as still being applicable in respect of Transport and Infrastructure. We would request that those comments are also applied to the Stockport Local Plan.

Appendix

Poynton Town Council Response to GMSF Consultation January 2017

Poynton Town Council Draft Greater Manchester Spatial Framework: response to consultation January 2017

The Greater Manchester Combined Authority has commenced consultation on a new statutory development plan for the conurbation – the Greater Manchester Spatial Framework. The Plan covers the period 2015-2035. Consultation on the document ran from 31 October until 16 January 2017. Poynton Town Council welcomes the opportunity to comment on the draft GMSF.

The town of Poynton immediately adjoins the boundary of Greater Manchester and Stockport Borough along most of its northern and western boundaries. The Town Council has major concerns about the plans by Greater Manchester Combined Authority to reduce Green Belt by nearly 5000 hectares (more than 12,000 acres) and to replace Green Belt by proposed growth levels which are unrealistic and undeliverable. As presented for public consultation, the GMSF will fail to comply with Government tests of its soundness as set out in national planning guidance. The Town Council has been actively involved in the public hearings into the Cheshire East Local Plan which have taken place over the last three years as that Council has sought to show how ambitious plans for growth and development needed to be justified.

The Town Council supports the principle of a plan-led approach towards development at different spatial scales and has been preparing its own Neighbourhood Plan in this regard. It is also supportive of a sub-regional strategic plan which seeks to facilitate sustainable development over the next 20 years into appropriate sites and areas and so avoid “planning by appeal” and sporadic development without adequate planning of infrastructure and services in parallel with housing and/or employment development. Many of our residents work and enjoy activities within the wider city region. We hope the GMSF can be refocused into a “brownfield first” plan in which the many vacant and neglected former factory sites throughout the conurbation can once again become useful and attractive places to live, work and play.

The Town Council has the following concerns about the current version of the GMSF which are explained in the following sections: 1. Duty to Co-operate 2. Unrealistic growth scenario 3. Alignment between jobs and housing 4. Proposed spatial distribution of development and use of brownfield sites 5. Green Belt release 6. Democracy of GMSF process 7. Provision of infrastructure to serve development 8. Objection to Woodford Opportunity site (OA20) in the GMSF 9. Objection to High Lane site (OA21) in the GMSF

1 Duty to Cooperate

The GMSF fails to demonstrate how the Duty to Co-operate required under the National Planning Policy Framework has been undertaken across the administrative boundary between GM/Stockport and Cheshire East. Paragraphs 54, 178 and 182 are not in our view being met by these proposals. We would refer in particular to the following policies:

 GM1 concerning brownfield development  GM5 concerning housing figures  GM6 concerning accessibility  GM13 regarding the Green Belt  GM24 concerning infrastructure  GM25 concerning many proposed allocations close to and adjoining areas of Cheshire East such as Poynton (sites OA20 at Woodford and OA21 at High Lane for example)

There is insufficient evidence of the effective implementation of the Duty to Co-operate between the association of Greater Manchester Authorities (AGMA), which includes Stockport Metropolitan Borough Council (SMBC), and Cheshire East Council (CEC) in the preparation of the GMSF proposals. The Duty to Cooperate across the Stockport-Cheshire East border has been a source of concern throughout the examination of the Cheshire East Local Plan hearings. Much of the discussion has been about the adequacy of the local highway network to cope with the additional amount of development proposed across the Greater Manchester boundary with Cheshire East. However, the Duty to Co-operate as set out in the NPPF is concerned with a larger range of issues than transport. For example, it suggests establishing joint working arrangements to monitor housing markets. This has never been done in spite of the close interaction between the two markets of south Stockport Borough (which formerly lay within Cheshire until 1974) and North Cheshire. The Cheshire East Local Plan Inspector has indicated that in his view only the minimum legal requirement for the Duty to Co-operate had just about been satisfied.

The Town Council would refer the Combined Authority to the many reports and concerns about the Duty to Co-operate within the Cheshire East Local Plan Examination library. Submissions were made in the different sessions of the examination which first commenced over two years ago. It appears that Stockport Council and the Combined Authority have failed to understand the nature of the Duty to Co-operate. The Planning Inspector who will ultimately examine the GMSF has to be satisfied that the legal duty has been carried out adequately. If it has not, then the Planning Inspector has by law to stop the examination of a plan. Based on our experience of the Cheshire East Local Plan, the necessary arrangements to satisfy the NPPF have yet to be put in place. These are clearly set out in Paragraphs 178 to 181 of the NPPF. Accordingly, this stage of consultation is based on inaccurate assumptions about the nature of cross boundary issues across the Stockport- Cheshire East boundary.

As an example of the current failure to cooperate, there remains the specific matter of the delivery of the required road and other infrastructure to support new development proposals on either side of the administrative boundary which remains a major concern to our residents. We would draw attention to the following evidence:

The SEMMMS A6 - Relief Road (A6MARR) has not been designed to accommodate the impact of the proposals in the Cheshire East Local Plan, or the GMSF proposals. Either of these plans alone would rapidly remove the intended relief to current traffic congestion which the Relief Road seeks to provide. Together the GMSF and Cheshire East Plans would bring very significant challenges which could not be mitigated. The combined proposals are for a total of 16,000 additional dwellings plus further commercial developments to be built within 2 miles of the new A6MARR. Similar problems would arise for the A34 bypass from and northwards, which is also already highly congested at peak times with substantial queueing times.

Furthermore, major representations have already been made by Stockport Council to Cheshire East Council and the Planning Inspector in pointing out the likely traffic volumes which the CEC Local Plan (particularly with respect to the North Cheshire Growth Village) would create for road infrastructure. In a similar vein, we are aware that representations are being made by Cheshire East to the Combined Authority in pointing out the traffic problems that the GMSF proposals would create for road infrastructure across the boundary.

In our view, this further illustrates a failure in the effective implementation of the Duty to Cooperate provisions.

2 Unrealistic growth scenario

Assumptions made are unjustified and unsound as we shall demonstrate. National planning guidance (in the NPPF) recommends that development plans should be aspirational but realistic. The amount of development proposed is overly aspirational and unrealistic which would lead to unacceptable consequences in terms of the environmental impact of such large-scale development over a 20 year period, major loss of Green Belt land, major impact on commuting levels into the conurbation, a mismatch in the balance between jobs and homes and the inability of infrastructure across all sectors to cope with the proposed scale of development. In terms of proposed policies in the GMSF, the most relevant ones to Poynton which reflect such unrealistic growth assumptions include GM1, GM2, GM3, GM5, GM6, GM13, GM24 and GM25.

In November 2015 the Combined Authority consulted on three options which presented three different sets of numbers. It is not made clear how those options (one of which proposed significantly less development than now proposed) have been assessed and are now consistent with the fairly precise figures that the GMSF now states have to be met?

The draft GMSF is based on delivering the rate of economic growth projected by the Oxford Economics’ Accelerated Growth Scenario (AGS) 2015. The AGS suggests a jobs growth rate averaging 0.7% per annum over the 2015-35 period. This scenario aims at expanding the population and economy of Greater Manchester in a very ambitious manner and is wholly unrealistic to achieve given the current and immediate future economic uncertainties. This expansionary vision goes well beyond meeting the expected housing needs of the conurbation and would require the loss of large areas of Green Belt which form part of the character of the Greater Manchester area at present. The implications would be that this level of private sector jobs would require a significant (and unsustainable) increase in net in- commuting from Greater Manchester’s neighbours, particularly from North Cheshire.

We would challenge the overall vision and number predictions. Firstly, the proposals are based on an “Accelerated Growth Scenario” which aims at expanding the population and economy of Greater Manchester, with a target of 227,000 new houses. Secondly, the supporting document by Oxford Economics admits that this aims for growth rates above the baseline by around 59,700 houses and that it would increase commuting. Thirdly, the Objectively Assessed Housing Need (OAN) dated November 2015 concluded that 217,350 new dwellings would be needed over the period of 2014-2035. The report also noted that this was a high figure and therefore questioned whether it was realistic or desirable. Finally, the consultation version of the GMSF proposes even higher levels of housing at 227,000 homes which is more than 4% above the OAN. There seems to be little supporting evidence to justify this increase above OAN, particularly in a situation where in the south of the Combined Authority areas most of the areas proposed for housing release lie in Green Belt. Paragraph 14 of the NPPF provides that within Green Belt areas, development should be restricted and the OAN need not be met there.

The NPPF requires that Local Plans, should as far as is possible, reflect a collective vision and a set of agreed priorities for the sustainable development of their area (paragraph 155 refers). We can find little evidence that the current population of the Greater Manchester conurbation (totalling around 2.7 million people) would wish to see the scale of economic and population growth and urban expansion of the manner now proposed at the expense of the massive loss of Green Belt land shown on the draft site allocations. We look forward to commenting on this particular matter at a later stage as many of our residents have strong links across the administrative boundary for work business, leisure, family and many other reasons.

We also raise concerns about the reliability of some of the data being deployed including for example the predictions for population growth, especially in the uncertain climate following the Brexit vote of June 2016. Again, we have recent experience of limited and/or inaccurate data arising from our close involvement in the Cheshire East Local Plan.

We are also aware of the need for Strategic Environmental Assessment on the assessment of the effects of the GMSF on the environment. We are particularly interested in how any alternatives to the “accelerated growth scenario” have been assessed and will continue to be assessed as the GMSF develops through its further stages of preparation. For example, what types of scenario would take the pressure off the release of so much Green Belt land for development.

From the GMSF documents published to date, there seems to be little or no evidence that by increasing the amount of urban development and urban scale of the city region, there would be a consequential increase in productivity and/or economic performance.

3 Alignment between jobs and housing

Experience from the examination into the Cheshire East Local Plan has confirmed the need for a close alignment between the provision of jobs, houses and floorspace for different employment sectors. From the documents supporting the GMSF, it is unclear how the GM authorities in supporting the AGS 2015 have derived the estimates of housing provision across the ten boroughs within GM area from the proposed levels of job growth and employment floorspace. There is no justification provided for the means by which job growth and employment floorspace link and align to the amount and distribution of housing. The potential impact is that the supply of workers will not match the amount of housing delivered leading to unsustainable forms of development as workers commute. There is no justification or explanation in the documents of the link between housing and jobs/floorspace.

In terms of proposed policies in the GMSF, the most relevant ones to Poynton which reflect the lack of alignment between jobs and housing include GM1, GM2, GM3, GM5, GM6, GM13, GM24 and GM25.

The Planning Inspector examining the Cheshire East Plan has provided in his Further Interim Views of December 2015 a checklist of matters which need to be addressed for the Combined Authority in order for a later version of the GMSF to comply with national guidance and found sound. He wrote (para 19 of his report of that date) as follows: Having considered all the evidence, discussions and statements at the hearing sessions, CEC seems to have adopted a balanced and rational approach to economic and jobs growth, which is both ambitious and aspirational, yet realistic and with a reasonable prospect of success; it balances migration and commuting to ensure sustainable movements and patterns of development, and is based on up-to-date, proportionate and robust evidence. CEC also seems to have considered all the relevant economic factors, including the likely future economic performance of Cheshire East and future employment land requirements. The amended economic growth strategy not only aligns with the LEP’s economic plans and strategies and considers cross-boundary implications, but also takes account of recent employment projections and likely trends. There also seems to be a more direct relationship and closer alignment between the economic and housing strategy than in the previous submitted Plan, and it seems to be justified, positively prepared and soundly based.

The GMSF recommends a jobs growth rate of 0.7%/year which is the same as that for the Cheshire East Local Plan, a figure which was revised upwards from 0.4% proposed in the Plan submitted to the Inspectorate in May 2014. Cheshire East were then able to show this growth rate equating to the provision of 31,400 new jobs (2010-2030) and 378ha of employment land, compared with a jobs growth rate of 0.4%/year, 13,900 new jobs and 300- 351ha of employment land in the submitted Local Plan. The GMSF does not show this linkage and relies it seems to this Council on the figure of 0.7% having been broadly endorsed by the Cheshire East Inspector.

In terms of floorspace/ employment land estimates the GMSF documents do not seem to include any information on the amount of employment land that the proposed level of floorspace provision translates into. The GMSF should make it clear what assumptions have been made about matters such as development ratios, plot ratios and the impact of different sectors on such matters. Assumptions have not been set out as to how these assumed values convert floorspace into an employment land requirement.

Regarding the density of employment land, the main document and supporting evidence do not make it clear what assumptions have been made regarding employment densities either in total or for different employment sectors.

The Town Council has some concerns about the assumptions being made concerning commuting and migration which they would like to have discussed with Stockport Council or other appropriate officers. Our request for a meeting with Stockport Council within the consultation period was not accepted, although a number of questions have been responded to by Stockport Council officers.

4 Proposed spatial distribution of development and use of brownfield sites

The GMSF proposes the whole GM area as one housing market. However, specific borough wide housing figures are then allocated between the ten local authorities. Little explanation or justification is given as to the methodology which underpins this spatial distribution of development. This is a significant omission in that the allocated Borough wide figures are then deployed spatially leading to the proposed loss of major areas of adopted Green Belt. The close relationship between the objectively assessed need (OAN), the total and borough wide housing requirement figures and the spatial distribution of the main development needs is not properly explained and is poorly expressed as the basis for a plan-led approach to development.

In terms of proposed policies in the GMSF, the most relevant ones to Poynton which reflect the lack of justification for the proposed spatial distribution of development and use of brownfield sites for housing and other uses include GM1, GM2, GM3, GM5, GM6, GM13, GM24 and GM25.

The GMSF requires substantial more evidence through urban capacity studies or similar to address the need for brownfield development to have been explored first. Furthermore, the Framework should preferably be consistent across all Boroughs to seek a common methodology to demonstrate that brownfield opportunities have already been fully considered.

National policy in the NPPF provides that Green Belt boundaries should only be changed in genuinely "exceptional circumstances." The AGS and its need for related economic growth do not justify consideration as an exceptional factor. With regard to the high levels of projected housing demand (especially when based on artificially inflated projections), neither does this in itself amount to the "exceptional circumstances" required to justify amending green belt boundaries and the release of Green Belt land in the manner proposed.

The proposed amount of development in the Green Belt appears to represent an easy and cheaper solution to meeting growth aspirations whether or not they are in themselves realistic. Firstly, brownfield sites should have been assessed by a consistent range of criteria across the conurbation. Once the potential for brownfield had been fully explored and exhausted other options needed to be considered. The Town Council has noted that the amount of development proposed on brownfield land may appear relatively high at 70%. However, set in the context of previous regional planning documents, this is not the case. Previous targets of the North West Regional Spatial Strategy were set when local planning authorities in the region had targets of between 95% and 85%. Many boroughs including those within Greater Manchester were successful in achieving them. The GMSF provides limited justification for the new lower figure. Brownfield development is by definition more likely to achieve the status of sustainable development as set out in national planning policy at all spatial scales.

If the city region is to develop in accordance with principles of sustainability, more innovative solutions are required. The role of town and district centres within the conurbation for example is changing as a result of internet shopping and other market conditions. There is considerable scope within many town and district centres (including Stockport) for housing led-regeneration including low cost, sustainable housing near to employment, local services and amenities. In similar vein, more creative and innovative solutions which align with the “Smart City” objectives are needed along with other ways to address needs. The work done for the Altrincham Town Centre Neighbourhood Plan within Trafford Borough is an example of how local communities can plan together to solve existing problems and support the regeneration of existing centres whilst producing sustainable planning solutions which also support local facilities.

The Town Council is aware that there are different amounts of urban land availability across the Greater Manchester conurbation. The documents presented for public consultation however fail to demonstrate how the proposed spatial distribution of development addresses the need to promote sustainable patterns of development including brownfield opportunities. If green field development is required, this should be phased until later in the plan period in order that priority should be given to brownfield use first.

5 Green Belt release

The amount of land proposed for release from national Green Belt is on a vast scale. However, the NPPF is clear in setting out the exceptional circumstances to justify any alterations to the boundaries of Green Belt. The Town Council is extremely concerned at the scale of Green Belt release around the southern parts of the conurbation which immediately adjoin Poynton. These allocations are in addition to the proposed site allocations in , Wilmslow and Poynton within the Cheshire East Local Plan. As set out, the GMSF fails to justify both the total amount of Green Belt release and its location within each Borough. The scale of development is the equivalent of another Manchester city (or two Stockports) within the Greater Manchester conurbation. It is estimated that a loss of 4,900 hectares of Green Belt land is being proposed (or more than 12,000 acres). It is also estimated that this amount is around 8% of all the Green Belt within the conurbation. The Combined Authority proposals have been received by many communities both within and adjacent to the GM boundary as not only being unacceptable and unjustified but also contrary to existing NPPF and local plan policies.

In terms of proposed policies in the GMSF, the most relevant ones to Poynton which reflect our concern about the justification for the proposed release of large areas of current Green Belt for development for housing and other uses include GM1, GM2, GM3, GM5, GM13 and GM25.

Although the Town Council has noted that an assessment has been undertaken of the Green Belt within the city region, that assessment fails to reach any overall conclusions on the extent to which each green belt parcel has value. This contrasts markedly with a similar report undertaken for the Cheshire East Local Plan which did seek to deploy a methodology for grading the different areas of Green Belt which might then be deployed for informing site selection. Without this degree of detail, the quality of the Green Belt assessment work is limited and must be questioned as any aid to site selection notwithstanding the general objections to the principle of Green Belt release, particularly on the scale proposed.

The Green Belt within the conurbation is critical to the future success of the city region. There is mounting evidence supporting the mental and physical health benefits of time spent in the countryside for rest, relaxation and outdoor pursuits. In sacrificing areas of land currently protected from development by Green Belt, and encouraging urban development instead may well reduce the health, happiness and productivity of the population, which runs counter to one of the stated aims of the GMSF.

The Green Belt areas proposed for development do not appear to be been assessed and justified as to their impact on the adjoining areas of Green Belt within Cheshire. There is limited evidence in the documentation about the rationale for each area to be included, other than they are large areas of open land which just happen to be in the Green Belt. This is not only disappointing but clearly fails to comply with national planning guidance as set out in section 9 of the NPPF concerned with Protecting Green Belt land. The sites selected have to be fully justified for development and any revised boundaries altered only in exceptional circumstances. Each site would need to be considered on its own merits as has occurred at the Cheshire East Local Plan examination this autumn. To do this, some appropriate planning criteria would be needed which included different factors to be taken into account.

Further consideration of the resulting Green Belt boundaries would also be required, as well as an assessment of the impact of release on the surrounding Green Belt areas.

In terms of the loss of Green Belt closest to the Poynton area in both Cheshire and GM plans, we would like to record the current position as follows:

Woodford Aerodrome (within the Green Belt in the Stockport UDP and confirmed in Core Strategy) planning permission granted by Stockport Council for 145 dwellings in Phase 1 and outline planning permission for a further 775 dwellings plus a care home and commercial premises at the Woodford Aerodrome site. Current total 920 which may increase with amended planning applications.

Cheshire East Local Plan Handforth. The CEC Local Plan proposes substantial Green Belt release, including 105 ha for development of 1,650 new houses plus commercial premises in the North Cheshire Growth Village (NCGV) (site ref. CS30). Current total 1,650 awaiting decision of Local Plan Inspector.

Cheshire East Local Plan Wilmslow. The CEC Local Plan proposes 150 dwellings on land at Heathfield Farm Dean Row, Wilmslow (site ref CS62). Current total 150 awaiting Local Plan Inspector.

Cheshire East Local Plan Poynton. The CEC Local Plan proposes 150 homes off Hazelbadge Road (site ref CS57), a further 150 homes at Sprinks Farm (site ref CS58) and 150 dwellings on 4 ha of land south of Road in Poynton (site ref CS59). Current total 450 dwellings awaiting Local Plan Inspector.

Cheshire East Safeguarded land Green Belt land for future development, including 14 ha adjacent to the NCGV in Handforth (site ref CS34), plus 9 ha at Heathfield Farm Wilmslow (CS63), plus 22 ha at Woodford Aerodrome (site ref. CS65). Current total 45 hectares of developable land.

GMSF Woodford (ref. 0A20) 238 ha to accommodate further housing. Current total 2,400 homes. GMSF (ref. 0A22 land off A34) land to accommodate housing. Current total 3,700 homes. GMSF Land at (ref. 0A23) to be allocated for houses. Current total 2,000 dwellings. GMSF Land at High Lane (0A21) to be housing. Current total 4,000 homes

The cumulative impact of these developments could amount to around 15-16,000 additional homes within a mile or two of the GM/Cheshire boundary. It would result in the removal of the Green Belt between settlements in Stockport and the settlements in Cheshire East of Handforth, Poynton and Wilmslow. This would be contrary to national Green Belt policy as set out in the NPPF as all purposes of the Green Belt therein are clearly performed by many of the sites. Furthermore, such changes are also contradictory and contrary to the GMSF’s own policy aims (ref. policy GM13). A lack of co-operation and co-ordination between the planning authorities on both sides of the administrative border can once again be seen.

6 Democracy of the GMSF process

The Town Council has a number of concerns about the democracy of the GMSF process. Firstly, according to the data held by the Combined Authority, there were around 60 responses to the previous round of public consultation held in 2015. There are around 2.7 million residents. It is estimated that more than half of those responding did so on behalf of the development industry which has a vested interest in seeing the maximum amount of development to meet their business needs. Accordingly, it is also evident they these respondents supported option 3 at that time as the most pro-growth scenario. Residents and other groups responding all supported the lower growth options 1 or 2. So not only was the response from a tiny number of local communities on behalf of the city region population, this would also suggest that one of the reasons why a high growth option has been supported is the influence of the development industry. This fails the tests set out for early and meaningful engagement set out in the NPPF (paragraph 155 refers).

Secondly, we are surprised that the vast majority of councillors who represent their local communities within their respective borough and city councils within the GM area have been unable to participate in the current round of setting the vision and priorities for the Plan. This also does not fit well with the national guidance which inter alia suggests engagement and collaboration with neighbourhoods, local organisations and businesses. We understand that many local councillors within the city region area are expressing their concerns in various ways about the manner in which the current documents were approved for public consultation purposes. We are also mindful that there are few town and parish council within the GM area with which local planning authorities can engage to good effect in the various stages of development plan making. The general public and their elected representatives seem to have been largely unaware of these plans. We would question whether the process, to date, has been balanced, democratic and reflective of national planning guidance. We would hope that both local councillors and local community organisations within the city region are provided with full opportunities to engage with future plan making for the GMSF at this strategic scale.

7 Provision of infrastructure to serve development

The Town Council is concerned about the lack of strategic policies for infrastructure which should be planned positively and alongside development as the NPPF. We are aware again from our experience from the Cheshire East Local Plan that there is a problem of a consistent approach to solving the disconnect between housing and infrastructure delivery. Some matters are assessed whilst others are inconsistently handled. Limited modelling for many services seems to have taken place as to what the actual impacts of the major increase in housing in some areas will be and over what time periods.

In terms of proposed policies in the GMSF, the most relevant ones to Poynton which reflect the lack of provision of infrastructure to serve this amount of development include GM1, GM2, GM3, GM5, GM6, GM18, GM21, GM22, GM24 and GM25.

The fall-back position that infrastructure can be dealt with at the planning application stage is unacceptable given the scope and ambition of this plan. Such an approach is short sighted and has failed previously in many areas. Investment in infrastructure requires a long term plan and some ground rules to be agreed between the main parties (local authority, service suppliers, landowners, developers) as to who does what and when particularly for the larger schemes, development areas and impacts. That is not the case with this plan and we are disappointed that the Combined Authority is unable to combine the planning for both development and infrastructure at this stage of the Plan.

We would challenge the deliverability of much of the infrastructure to support the GMSF in the south of the plan area. For example, the cumulative amount of new development in south Manchester/Stockport and east Cheshire amounts to many thousands of new dwellings. Much of the traffic generated would aspire to join the A34, A523 and A6MARR corridors. Any upgrade would require huge increases in investment such as flyovers at major junctions and other improvements in infrastructure, especially roads, to support it. Without it, already congested traffic would increase in volume without either some radical solutions or gridlock. We would question the feasibility to achieve and co-ordinate this. Meanwhile, we would welcome further information concerning the timescales for the extension of the A6 MARR, from High Lane to Bredbury to better cope with the potential extra vehicles on these roads.

8 Objection to Woodford Opportunity Area (OA20) within Stockport Borough as site allocation in the GMSF draft Plan

The Town Council wish to object to the proposed allocation of two sites lying in close proximity to Poynton. These are the sites numbered OA20 the Woodford Opportunity Site and AO21 land at High Lane, Stockport. We further wish to request their deletion from future versions of the GMSF. These are our initial reasons:

OA20 Woodford Opportunity Site 8.1 The scale and impact of this development in Woodford will directly impact on communities within Cheshire, particularly Poynton. Combined with the redevelopment of the aerodrome, it will completely change the character and role of Woodford as performing essential functions appropriate for a Green Belt location. Of the five purposes of Green Belt set out in the NPPF (para 80), the Woodford site clearly serves four of them. Its retention as Green Belt would check the unrestricted sprawl of the large built up area of Stockport/south Manchester. It prevents the neighbouring towns of Bramhall, Poynton, Wilmslow, Handforth and Cheadle Hulme of merging into one another. It would assist in safeguarding the countryside from encroachment by sustaining the existing pattern of countryside-related uses which could not be located within more urban areas due to the lack of space and convenience. Finally, its retention as Green Belt would assist in urban regeneration by encouraging the recycling of derelict and urban land within the nearby large town of Stockport and smaller town just referred to.

8.2 The development will have significant impacts on the whole transport system on the A34 corridor to and from destinations on both sides of the boundary. The Town Council is aware that this corridor is already the subject of a “holding objection” to proposed development in Cheshire East from Stockport Council pending a review of the SEMMMs schemes, the work for which should by now have commenced. The Inspector into the Cheshire East Local Plan had previously expressed concerns about the lack of mitigation being proposed which has led to this review. The GMSF site allocation if approved would require a further new approach to transport along this corridor.

8.3 The A34, A555 and future Poynton Relief Road would provide firm physical boundaries separating Woodford from the adjoining areas of Green Belt located in Cheshire including Wilmslow, Handforth, and Poynton. Removal of the site (OA20) from the Green Belt would not respect the geography and physical boundaries on the ground. The existing Green Belt areas in both Cheshire and GM serve a number of Green Belt functions set out in national advice. Loss of this large area combined with the existing redevelopment of the former aerodrome currently underway would effectively join Woodford to these other settlements and remove any sense of openness between them.

8.4 The current redevelopment of the former aerodrome as a large housing estate will present challenges for local infrastructure such as schools and health facilities. The housing development was not plan led, rather led through a Supplementary Planning Document and planning applications. Some of those impacts will be in Poynton as the nearest substantial town. The Town Council has found this matter a real concern in its preparation of a Neighbourhood Plan for Poynton.

8.5 Many parts of the proposed site are known to be either undeliverable or expensive to develop by local land owners and residents. For example, the Woodford area lies on a variety of soils with large areas of impermeable clay, patches of glacial boulder clay, running sand, and peat. Parts of it are liable to flooding or subsidence. Large parts of OA20 would be unsuitable for development.

8.6 The proposed site (like elsewhere in Woodford) is rural with a very limited service by public transport. Poynton and Bramhall railway stations are a substantial distance away which is likely to deter commuters. Services through Poynton are also limited to destinations within the city region which would not encourage further patronage without changes to timetables and destinations.

8.7 The Woodford area currently has a number of thriving rural businesses which serve a larger area including adjoining towns including Poynton. There are a number of small holdings, farms and equestrian businesses as well as a large and popular garden centre and nursery gardens which contribute to the economy. Some of these would fall within OA20 proposed allocation and would cease to be viable businesses.

8.8 The Green Belt in Woodford enjoys many beneficial uses of the Green Belt including public access for walking and cycling, for other forms of outdoor sport and recreation, visual amenity and biodiversity. The area serves as a valuable resource for the wider communities living in the surrounding towns and suburbs. The NPPF provides for the different roles and character of different areas to be taken into account in plan making and planning decision. The inclusion of Woodford within the GM area is purely historical and based on the then location of the Woodford Aerospace factory lying to the north of the airfield itself. The airfield closed a number of years ago. There is also evidence which supports the physical and mental benefits of exercise in green places, which in turn is now reflected in NPPF section 8 concerning Healthy Communities. The proposed site allocation should be retained for the benefit of the wider communities which surround it.

8.9 The Green Belt in Woodford is known locally for its high environmental value with species rich hedgerows, native trees and ponds which provide habitats for wildlife and wildlife corridors linking to neighbouring countryside. In preparing a Neighbourhood Plan, the Woodford community has obtained substantial evidence about the local environment which are supported by the Cheshire Wildlife Trust which would be disrupted by such a major development. It should be retained for the benefit of the wider ecosystem essential to support flora and fauna.

8.10 The Town Council has been made aware of the concerns of Cheshire East Council in respect of the proposed developments adjacent to the boundary. We would fully endorse the comments about Transport made in that section of their submission and are enclosed as an Appendix to this statement.

9 Objection to land at High Lane (OA20) within Stockport Borough as site allocation in the GMSF draft Plan

9.1 This site is proposed in policy OA21 for around 4,000 dwellings, all on land currently lying within the Greater Manchester Green Belt. High Lane adjoins part of Poynton along its southern boundary. Currently, the village of High Lane is understood to comprise around 2,000 homes with a population of around 5,500 people. This scale of development could triple the amount of development and erode the Green Belt between High Lane and adjoining areas.

9.2 The village of High Lane lies on the route of the existing A6 road, one of the major non- motorway traffic entry points into the GM area from the south east and easterly directions. There are already many concerns in this area about both the amount of traffic and nature of that traffic which has a high proportion of heavy good vehicles operating on a regional basis. The effect of this traffic at the present time is congestion at junctions and resulting poor air quality. The function and purposes of the A6 corridor needs to be fundamentally re- appraised if this proposal is to be pursued in the GMSF. Many Poynton residents use the A6 route in both directions and for different purposes so are familiar with its constraints, limitations and the impacts on driver choice across the wider highway network as drivers seek alternatives to the A6. Current highway and air quality problems would be exacerbated and existing problems magnified if this allocation is to proceed.

9.3 With regard to public transport services as the other main transport mode, these are known to be inadequate for a number of reasons. Firstly, the area is on the periphery of the GM area and therefore at the end of some Transport for Greater Manchester routes especially buses. Secondly, bus routes are vulnerable to reductions arising from wider local authority budgets. Bus services are limited within the Poynton area and the same will be the case for High Lane. Thirdly, in view of the large increase in use projected for Poynton railway station due to the Woodford developments, consideration should be given to the inclusion of Poynton railway station within the Greater Manchester ticketing boundary. Poynton does not currently benefit from subsidised rail fares as other towns do such as Glossop, Hadfield and .

9.4 We have referred previously (section 4 of this statement) to the need for a full and realistic assessment of all brownfield sites in particular and of relevance to both High Lane and Woodford for those sites closer to the town and smaller local centres within Stockport Borough. The southern part of Stockport Borough may be a very pleasant area to live in but national planning policy (NPPF) requires special circumstances to be demonstrated for Green Belt land to be released for development. Within Cheshire there is evidence that the development industry has taken the opportunity of a lack of an up to date Local Plan and five year supply of housing to select green field sites for development (or for future longer term land banking) rather than give priority to brownfield sites. The GMSF needs to give more priority to supporting brownfield both through planning policy and support for implementation of brownfield schemes in other ways, including identifying sustainable locations in terms of recycling previously used land that is already served by existing public transport services.

9.5 The sheer size of the proposed allocation of 4,000 homes would mean around an additional 10,000 people living in the High Lane area. Such a significant amount of development could take several decades to develop fully. If it is selected for allocation, Poynton Town Council would support a Masterplanning approach to its development to ensure that the appropriate level of facilities and services are provided at the right time to meet the needs of the new residents and help to mitigate the impact on existing residents.

Appendix

Cheshire East Council Report to Strategic Planning Board 14 December 2016 Extract from report concerning proposed Cheshire East Council response to GMSF

Transport Transport for Greater Manchester have recently consulted on a separate transport strategy – and so there is a need for both this and the GMSF to fully align. Cheshire East shares several key cross-boundary routes with Greater Manchester, including the A34 and the A537. Several (congested) junctions are located either on or just within the CEC administrative area. The scale of growth close to the Cheshire East boundary renders the refresh of the South East Manchester Multi Modal Study (SEMMMS) more important than ever. Cheshire East Council believes that good cross boundary travel is mutually beneficial – in that it supports the role and function of and other centres within the conurbation, whilst also allowing southward travel to employment and leisure opportunities within Cheshire. Cheshire East Council encourages the GMCA to fully align the GMSF and GM transport strategy Both strategies should properly recognise the cross boundary implications of travel in and around the conurbation. Cheshire East Council is concerned at the limited information on transportation and its role in site selection Sites should be selected so as to favour access to heavy Rail or Metrolink corridors wherever possible. There are significant two-way commuting flows between the North of Cheshire East and South Manchester. Much of this commuting is focussed on an increasingly congested highway network. Without improvements, the level of congestion on cross boundary routes would be severe, impacting key junctions on both sides of the boundary. There is no information on the level of impact the plan proposals have on key junctions within Cheshire East. The SEMMMS refresh will report what future transport schemes are possible to provide future capacity in our cross boundary networks. The conclusions of this report are not yet available and without this information of what future interventions are required (and possible) it is difficult to comment on the suitability of the proposed development locations. Equally, it is not clear that the site selection process has adequately considered the relative spatial impacts of development with regard to environmental factors such as air quality. References to sub-regional and local accessibility in policy GM6 should recognise the importance of accessibility in the wider travel to work area outside of the administrative boundary. Measures should be included in the supporting plan policies to encourage more sustainable modes of cross boundary commuting into / out of Cheshire East along.