Greater Manchester Spatial Framework Representations on behalf of Taylor Wimpey UK Ltd Taylor Wimpey DĂƌĐŚϮϬϭϵ ϲϬϰϬϵͬϬϭͬ:'ͬK ϭϳϬϳϰϲϰϵǀϭϬ ϭϳϬϳϰϲϰϵǀϭϬ 'ƌĞĂƚĞƌDĂŶĐŚĞƐƚĞƌ^ƉĂƚŝĂů&ƌĂŵĞǁŽƌŬ͗ZĞƉƌĞƐĞŶƚĂƚŝŽŶƐŽŶďĞŚĂůĨŽĨdĂLJůŽƌtŝŵƉĞLJh<>ƚĚ Contents 1.0 Introduction 1 Structure 3 2.0 Key Areas of Concern 5 Introduction 5 3.0 Chapter One: Introduction 8 Question 1: What type of respondent are you? 8 Question 2: Contact Details 8 Question 3: Are you over the age of 13? 8 Question 4: If you are submitting a response on behalf of an organisation or group, please also give use their details. 8 Question 5: We would like to be able to publish responses after this consultation closes. Are you happy for us to do this? 8 Question 6: Do you agree that we need a plan for jobs and homes in Greater Manchester? 8 Question 7: Do you agree that to plan for jobs and homes, we need to make the most effective use of our land? 8 Question 8: Do you agree that in planning for jobs and homes, we also need to protect green spaces that are valued by our communities? 9 Question 9: Do you agree that to protect green spaces, we need to consider how all land in Greater Manchester is used? 9 Question 10: Is the approach that we have outlined in the plan reasonable? 9 4.0 Chapter Three: Our Vision 10 Question 12: Do you agree with the Strategic Objectives? 10 5.0 Chapter Four: Our Strategy 12 Question 13: Do you agree with the Spatial Strategy? 12 Question 19: Do you agree with the proposed policy on Northern Areas? 13 Question 20: Do you agree with the proposed policy on M62 North East Corridor? 14 Question 21: Do you agree with the proposed policy on the Wigan-Bolton Growth Corridor? 14 Question 22: Do you agree with the proposed policy on Southern Areas? 14 6.0 Chapter Five: A Sustainable and Resilient Greater Manchester16 Question 28: Do you agree with the proposed policy on Sustainable Development? 16 Question 29: Do you agree with the proposed policy on Carbon and Energy? 16 Question 30: Do you agree with the proposed policy on Heat and Energy Networks? 17 'ƌĞĂƚĞƌDĂŶĐŚĞƐƚĞƌ^ƉĂƚŝĂů&ƌĂŵĞǁŽƌŬ͗ZĞƉƌĞƐĞŶƚĂƚŝŽŶƐŽŶďĞŚĂůĨŽĨdĂLJůŽƌtŝŵƉĞLJh<>ƚĚ Question 31: Do you agree with the proposed policy on Resilience? 17 7.0 Chapter Seven: Homes for Greater Manchester 19 Question 41: Do you agree with the proposed policy on the Scale of New Housing Development?19 Affordable Housing Needs 29 Do you agree with the proposed policy on the Affordability of New Housing? 32 Question 43: Do you agree with the proposed policy on the Type, Size and Design of New Housing? 34 Question 44: Do you agree with the proposed policy on the Density of New Housing? 37 Question 45: Do you have any further comments on the policies and overall approach proposed in Homes for Greater Manchester? 38 Phasing of New Housing in Greater Manchester 47 8.0 Chapter Eleven: Proposed Additional Sites (Allocations) 49 Question 78: Do you agree with the proposed policy GM Allocation 3: Kingsway South 49 Question 111: Do you agree with the proposed policy GM Allocation 36: Gravel Bank Road/Unity Mill? 49 9.0 Chapter Twelve: Delivering the Plan 50 Question 127: Do you agree with the proposed policy on Infrastructure Implementation? 50 Question 128: Do you agree with the proposed policy on Developer Contribution? 50 10.0 Conclusion 51 'ƌĞĂƚĞƌDĂŶĐŚĞƐƚĞƌ^ƉĂƚŝĂů&ƌĂŵĞǁŽƌŬ͗ZĞƉƌĞƐĞŶƚĂƚŝŽŶŽŶĞŚĂůĨŽĨdĂLJůŽƌtŝŵƉĞLJ 1.0 Introduction 1.1 Following on from our previous representations in 2014, 2015 and 2016, Lichfields is instructed by Taylor Wimpey UK Limited [Taylor Wimpey] to submit representations on the Greater Manchester Spatial Framework [GMSF] Draft for consultation. Although the representations are prepared on behalf of Taylor Wimpey, they represent Lichfields’ professional and independent work. The draft GMSF and its associated evidence base was published on 21st January and an 8-week consultation period commenced. 1.2 It is important to state at the outset that Taylor Wimpey welcomes the much-anticipated release of the draft GMSF and the efforts made by the GMCA in producing the substantial document and associated evidence base. We consider that it is imperative that Greater Manchester adopts a Spatial Development Plan which accords with national policy as quickly as possible to ensure the correct levels of housing and economic growth are being catered for across Greater Manchester. Given the growth aspiration of Greater Manchester, a comprehensive and up to date plan is essential to direct and drive investment. Taylor Wimpey consider that a ‘Develop Forum’ should be established in Greater Manchester as a vehicle for effective engagement and collaboration with the development industry and Taylor Wimpey are willing to take the lead in the establishment of this group in conjunction with GMCA officers. 1.3 Although the current version of the plan forms a Joint Development Plan Document, it is intended that the GMSF will be the first Spatial Development Strategy prepared outside of London, once the necessary Regulations are in place to allow it. This consultation seeks views on the draft GMSF document and the technical evidence base underpinning it to identify the level of housing and employment growth that should planned for across Greater Manchester over the period 2018 to 2037. The evidence base released by GMCA (January 2019) includes: 1 Housing Topic Paper 2 Employment Topic Paper 3 Green Belt Topic Paper 4 Site Selection Topic Paper 5 Carbon & Energy Topic Paper 6 Natural Environment Topic Paper 7 Transport Topic Paper 8 Physical Infrastructure Topic Paper 9 Social Infrastructure Topic Paper 10 Greater Manchester Strategic Flood Risk Management Framework 11 Natural Environmental Priority Blue and Green Infrastructure 12 Strategic Housing Market Assessment 13 Greater Manchester Forecasting Model 2018 14 Landscape Character & Sensitivity Assessment 15 Greater Manchester Assessment of Proposed Additions to the Green Belt 1.4 These representations are structured to initially set out Taylor Wimpey’s ‘Key Areas of Concern’ with regard to the overall principles contained within the current draft GMSF. Thereafter, it will focus on the draft policies contained in the plan and assess the relevant elements of the evidence base which seek to underpin the soundness of each policy. Taylor Wimpey will also be WŐϭ 'ƌĞĂƚĞƌDĂŶĐŚĞƐƚĞƌ^ƉĂƚŝĂů&ƌĂŵĞǁŽƌŬ͗ZĞƉƌĞƐĞŶƚĂƚŝŽŶƐŽŶĞŚĂůĨŽĨdĂLJůŽƌtŝŵƉĞLJ submitting separate site-specific representations on its land assets across Greater Manchester in conjunction with these representations. In summary, Taylor Wimpey’s sites comprise: 1 Gravel Bank Road / Unity Mill, Stockport (Policy GM Allocation 36) 2 Broad Lane, Rochdale (Policy GM Allocation 3) 3 Littlemoss, Ashton-under-Lyne, Tameside 4 Starling Road, Bury 5 Plodder Lane, Bolton 6 Orrell Road, Wigan 7 Jacksons Lane, Stockport 8 Wigan Road, Hindley 9 Land at High Lane, Stockport 10 Ditches Farm, Bolton 1.5 As these representations cover Taylor Wimpey’s interests, they focus on housing matters and specifically those elements of the evidence base that have helped to define the housing requirement, its spatial distribution, proposed density and overall approach to housing delivery. As such, we have largely confined our review to the relevant elements of the evidence base that specifically cover housing and associated economic issues. 1.6 The National Planning Policy Framework [The Framework] sets out the planning system should be ‘genuinely plan led’. Furthermore, succinct and up-to-date plans should provide a positive vision for the future of each area [§13]. Finally, policies in local plans and spatial development strategies should be reviewed to assess whether they are up to date ‘at least once every five years, and should then be updated as necessary’. With this in mind, Table 1.1 sets out the year of adoption of the most recent Local Plan for each of the Greater Manchester authorities. This indicates that only 3 of the 10 authorities have had plans adopted since the original Framework was published in March 2012 and emphasises the necessity for the GMSF to progress as quickly as possible. dĂďůĞϭ͘ϭ>ŽĐĂůWůĂŶ^ƚĂƚƵƐ >ŽĐĂůƵƚŚŽƌŝƚLJ ĚŽƉƚĞĚĞǀĞůŽƉŵĞŶƚWůĂŶŽĐƵŵĞŶƚ zĞĂƌ ƵƌLJ ƵƌLJhŶŝƚĂƌLJĞǀĞůŽƉŵĞŶƚWůĂŶ ϭϵϵϳ dĂŵĞƐŝĚĞ dĂŵĞƐŝĚĞhŶŝƚĂƌLJĞǀĞůŽƉŵĞŶƚWůĂŶ ϮϬϬϰ ^ĂůĨŽƌĚ ŝƚLJŽĨ^ĂůĨŽƌĚhŶŝƚĂƌLJĞǀĞůŽƉŵĞŶƚWůĂŶ ϮϬϬϲ ^ƚŽĐŬƉŽƌƚ ^ƚŽĐŬƉŽƌƚŽƌĞ^ƚƌĂƚĞŐLJ ϮϬϭϭ ŽůƚŽŶ ŽůƚŽŶŽƌĞ^ƚƌĂƚĞŐLJ ϮϬϭϭ ůůŽĐĂƚŝŽŶƐW ϮϬϭϰ KůĚŚĂŵ KůĚŚĂŵŽƵŶĐŝůʹ:ŽŝŶƚŽƌĞ^ƚƌĂƚĞŐLJĂŶĚĞǀĞůŽƉŵĞŶƚ ϮϬϭϭ DĂŶĂŐĞŵĞŶƚWŽůŝĐŝĞƐ dƌĂĨĨŽƌĚ dƌĂĨĨŽƌĚŽƌĞ^ƚƌĂƚĞŐLJ :ĂŶƵĂƌLJϮϬϭϮ DĂŶĐŚĞƐƚĞƌ DĂŶĐŚĞƐƚĞƌŽƌĞ^ƚƌĂƚĞŐLJ :ƵůLJϮϬϭϮ tŝŐĂŶ tŝŐĂŶ>ŽĐĂůWůĂŶŽƌĞ^ƚƌĂƚĞŐLJ ϮϬϭϯ ZŽĐŚĚĂůĞ ZŽĐŚĚĂůĞŽƌĞ^ƚƌĂƚĞŐLJ ϮϬϭϲ 1.7 Given the scale of the housing and employment requirement over the plan period and its spatial distribution across Greater Manchester, a bold approach to Green Belt release is unavoidable. The Greater Manchester Green Belt has remained relatively unaltered since its inception in the early 1980s and it has served its function of directing growth to the urban areas and WŐϮ 'ƌĞĂƚĞƌDĂŶĐŚĞƐƚĞƌ^ƉĂƚŝĂů&ƌĂŵĞǁŽƌŬ͗ZĞƉƌĞƐĞŶƚĂƚŝŽŶŽŶĞŚĂůĨŽĨdĂLJůŽƌtŝŵƉĞLJ regenerations many areas across Greater Manchester. However, brownfield land is a finite resource and it is clear from the evidence presented that insufficient capacity exists to deliver the required growth over the Plan period. 1.8 We do not under-estimate that scale of the task facing the GMCA in pursuing a Spatial Development Document for all 10 Greater Manchester authorities and we trust that this level of co-operation and far-sightedness on the part of the political leaders of all ten authorities continues through to the