The consultation started on 10 July and ends of 21 August.
Details of the local plan can be found at https://www.oldham.gov.uk/info/200585/local_plan
Responses can be submitted online at http://oldham-consult.limehouse.co.uk/portal/oc/planning/spi or emailed to spi@oldham.gov.uk or returned by post to: Strategic Planning and Information, Economy, Skills and Neighbourhoods, Room 310, Level 3, Civic Centre, West Street, Oldham OL1 1UH.
Below is the letter the Liberal Democrats have submitted.
Strategic Planning & Information, Economy, Skills and Neighbourhoods, Room 310 Level 3, Civic Centre, West Street, Oldham OL1 1UH
15 August 2017
Re: OLDHAM COUNCIL LIBERAL DEMOCRAT GROUP – RESPONSE TO CONSULTATION ON THE OLDHAM LOCAL PLAN
The Oldham Council Liberal Democrat Group; the official opposition, comprising of nine elected members of the Oldham Metropolitan Borough Council wish to make this collective submission in response to the consultation on the Oldham Local Plan.
Given that the Oldham Local Plan “will form an integral part of the Greater Manchester Spatial Framework (GMSF)” our response mirrors that made to the consultation on the GMSF.
In the GMSF, the ten local authorities in Greater Manchester have drawn up plans to meet the projected future need for 4,000,000 m2 of industrial and warehousing premises and 227,000 new homes in the county by 2035. The vision projects a population growth of 294,800 and 199,700 additional jobs across Greater Manchester.
In our view, the GMSF consultation document provided insufficient analysis of how these deductions for population and economic growth were made and was therefore devoid of justification for the additional land demands.
The GMSF plan requires 690,000 m2 industrial and warehousing space and 13,700 homes in Oldham Borough.
Housing
Referring first to housing, the monitoring report identifies that there has been a shortfall in recent years in the completion of new dwellings against expected targets and that there is a need to complete an additional 3,560 dwellings by 31 March 2021 to meet the original projections.
Our worry is that the situation may present the danger of unwanted housing development on Oldham’s Green Belt and OPOL (other protected open land).
Under the Greater Manchester Spatial Framework proposals of the 13,700 new homes proposed for Oldham approximately 3,000 will be located on sites in Shaw and Crompton and other tracts of land are designated for industrial development.
To the Liberal Democrat Group, and too many of our constituents, these plans represent a massive and inequitable land grab in Shaw and Crompton with the devastation of our local Green Belt and OPOL (other protected open land).
Under GMSF, it is proposed that new properties will be built at Cowlishaw, in the Beal Valley, Rushcroft, the Whitfield Farm area over to Newhey and around Gravel Hole and Low Crompton.
Adjacent sites at Broadbent Moss (Oldham), Hanging Chadder (Oldham) and land East and West of the A627M (Rochdale and Oldham) if developed would also see a significant erosion of the Green Belt land in the so called “Northern Gateway”.
The Oldham Local Plan monitoring report has a target that 80% of new residential development will take place on previously developed land, yet in 2015/16, 96% of new or converted dwellings were located on this land.
It is the view of the Liberal Democrat Group that there is no justification for reducing our aspiration and effort to build on previously developed land.
We do not believe that there is any need for the construction of a large number of properties (or indeed any properties) on Green Belt or OPOL land. New homes should first be built on Brownfield sites, on sites where planning permission for housing development has already been granted and upon the many derelict and the unloved sites in our town centres and districts.
Furthermore it is our view that conversions should take place so every empty mill and factory, where viable, is utilised for housing and that the large number of empty homes should be brought back into use.
It is our view that the Oldham Local Plan should make plain that these will be tenets upon which housing development will take place in this borough. We should work on the belief that our Green Belt and OPOL sites remain protected.
It is also unfortunate that the GMSF consultation document does not identify the many such sites that are available across the Borough other than those that currently sit outside Oldham’s Local Development Framework (formerly the Unitary Development Plan).
It is our view that the Oldham Local Plan should ultimately list these sites and that team of officers working on the Oldham Local Plan should work with Ward Members and the public to identify appropriate sites with potential for development for inclusion.
Within the Local Plan, housing development should also be apportioned across the whole borough rather than disproportionately in Royton, Shaw and Crompton as the GMSF does at present.
It is our view that the Oldham Local Plan should include a commitment to proportionality so that any one or two districts in the borough are not overwhelmed with new housing, and in order that new householders may have a greater choice of the area in which they wish to live.
Transport
It is important too that the Oldham Local Plan addressed the need for very significant investment in transport infrastructure. Improved transport is a critical obstacle to be overcome to ensure the success of the expansion desired in the GMSF. Many of the strategic allocations are sited near our motorway corridors, ostensibly to take advantage of existing networks.
However, our existing motorways are frequently constrained by high levels of congestion resulting in unacceptable journey times and additional traffic jams on feeder and local roads. The projected growth of industrial warehousing, office space and new homes will require monumental investment in transport infrastructure. It is of paramount importance to ensure that the transport infrastructure is in place before other building takes place.
All the sites identified, especially those in Shaw and Crompton are devoid of good vehicular access and there is no obvious way to make the necessary improvements.
Cowlishaw has no acceptable roads leading into the proposed site. The topography around the Whitfield farm area makes it difficult to envisage an elegant solution to site access. Similarly the Beal Valley site is currently served only by a narrow road and the desire to facilitate access to this site by enhancing links to Shaw and Crompton Metrolink Station seem incredulous; the only current access, via Beal Lane, is saturated with existing traffic and HGV movements to and from existing businesses which are large distribution centres.
Other Infrastructure
The increase in population will necessitate provision of additional services. It is vital that the Oldham Local Plan addresses these needs and the GMSF fails to do so.
In Shaw and Crompton, the necessary infrastructure to support even our existing population is lacking. We have primary schools that are already overcrowded and full; a secondary school that is falling apart; a dilapidated Health Centre that is near cardiac arrest; no swimming facilities or dry leisure provision; precious few youth facilities and no municipal tip.
Under the proposals, 3,000 homes will be built in Shaw and Crompton for growing families.
These new residents will need more primary and secondary school places; more GPs and dentists; leisure and shopping facilities; and new highways and more buses and trams to get them there.
And Oldham Council’s decision to close and not replace the Crompton Pool and Gym now looks a little short-sighted given the number of new young residents that will need to learn to swim and the number of adults that will want to keep fit.
The Environment
It is vital that the Oldham Local Plan contains a strong commitment to retaining and enhancing our local beauty spots and sites of biological and scientific importance.
An important vision of the GMSF is that Greater Manchester becomes as well known for the quality of its environment as for its economic success.
Green Belt plays a role in this but there are important green spaces, parks, rivers and canals in the heart of our urban communities which are equally valuable. The protection and enhancement of our blue and green infrastructure should be a central theme of our local strategy.
In view of the above aspiration, it was frustrating and difficult to understand why the specific green sites in Shaw and Crompton were proposed with the GMSF. There was been a lack of balance in the review and failure to give necessary weight to environmental and quality of life issues.
The vast majority of sites are notably attractive open spaces that provide pleasure, relaxation, and health benefits to local residents as well as our wider community. The sites include public footpaths enjoyed by many dog-walkers, ramblers and walking groups. Many of the Public Rights of Way are important to the historic Shaw and Crompton Beating of the Bounds walk and Crompton Circuit walks. These locations also provide one of the few opportunities for people to undertake horse riding in safety which is particularly of concern for young and inexperienced riders.
These sites are further enhanced by a diverse range of flora and fauna and importantly provide those ‘green lung’ areas which minimise urban sprawl between built up conurbations.
Two of the sites include small but nevertheless important rivers within their boundaries; the Rivers Irk and Beal (Cowlishaw and Beal Valley respectively) help to prevent flooding and are attractive features of the two sites.
Additionally the Cowlishaw site is renowned for upwell of numerous local springs and given to serious flooding. The area has deep unstable subsoil that will require significant pilings leading to excessive construction costs.
Cowlishaw and Beal Valley also contain Sites of Biological Importance and these must be retained.
In regards to Saddleworth there is only one Strategic Site in the Greater Manchester Spatial Plan, which is Robert Fletcher’s in the Greenfield valley, which has long been seen as needing a strategic view and plan to avoid piecemeal development. Indeed the Parish Council presented an outline plan for the valley some years ago and has done so again in response to the spatial proposals.
The plan proposes some 120 houses and 100 ‘lodges’ which one assumes, given past happenings, would become houses for some 220 residences.
These houses given the lack of public transport or facilities and the preference for high value housing would do nothing to lessen the need for affordable housing in the area.
The topography and lack of transport links and the high value of local scenery makes other large sites hard to find in Saddleworth especially given the presence of the Peak National Park there.
Saddleworth is, however, very vulnerable to the number of other smaller sites, some of them astoundingly unsuitable, offered for development in addition to those in this strategic framework.
The Green Belt and open spaces within Oldham are areas of pleasant natural beauty that make us unique in Greater Manchester.
Conclusion
The key point in our submission is that the Oldham Liberal Democrat Group firmly believes that in the Oldham Local Plan our precious Green Spaces should be protected.
We strongly advocate that no building on Green Belt or OPOL be undertaken until developments are first undertaken on Brownfield sites, on sites where planning permission for housing development has already been granted, and upon the many derelict and the unloved sites in our town centres and districts; and also after the conversion of every mill and factory into housing use and after every empty home has been brought back into use.
Only when all of these things have been done should we then, and only then, consider developing any part of our precious Green Belt.
This must be the central tenet and heavily emphasised as Council policy in the finalised Oldham Local Plan.
If this runs contrary to the Greater Manchester Spatial Framework then, in our view, so be it. It is important that our Oldham Local Plan emphasises what is right for Oldham, its environment and its people, not what other parties across Greater Manchester might think is right in development terms for our Borough.
Yours sincerely,
Councillor Howard Sykes MBE