Representations to the Revised Draft Greater Manchester Spatial … · 2019-09-19 · Representations to the Revised Draft Greater Manchester Spatial Framework 2019 Land off Brooks

Emery Planning 1-4 South Park Court, Hobson Street Macclesfield, SK11 8BS Tel: 01625 433 881 www.emeryplanning.com

Representations to the Revised Draft Greater Manchester Spatial Framework 2019

Land off Shay Lane/Brooks Drive, Hale Barns, Altrincham,

Greater Manchester, WA15 8WD

for Hale Living Limited

Emery Planning project number: 17-230

Project : 17-230 V.4 Site address : Land off Brooks Drive,

Hale Barns, Altrincham, Greater Manchester, WA15

Client : Hale Living Limited Date : 18 March 2019 Author : Paul Forshaw Approved by : Caroline Payne This report has been prepared for the client by Emery Planning with all reasonable skill, care and diligence. No part of this document may be reproduced without the prior written approval of Emery Planning. Emery Planning Partnership Limited trading as Emery Planning.

Contents: 1. Introduction 1 2. Background 1 3. Representations to the 2019 revised draft of the GMSF 4 4. Conclusion 11 5. Appendices 11

Representations to the Revised Draft Greater Manchester Spatial Framework 2019 Land off Brooks Drive, Hale Barns, Altrincham, Greater Manchester, WA15 18 March 2019

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1. Introduction

1.1 We are instructed by our client, Hale Living Ltd, to submit representations to the revised draft of

the Greater Manchester Spatial Framework (GMSF) in relation to the Land off Shay Lane/Brooks

Drive, Hale Barns which forms part of the wider area known as the “Timperley Wedge”.

1.2 A plan showing the location of our client’s site is attached at Appendix EP1.

1.3 These representations respond to Question 130 which asks whether we agree with the proposed

Policy GM Allocation 46: Timperley Wedge. We disagree with the current drafting of Policy GM

Allocation 46. We request that the allocation is amended to include our client’s site within the

proposed development site.

2. Background

Site location and description

2.1 The site is located to the north east of Hale Barns, within the area known as Davenport Green.

2.2 It is bounded by Shay Lane to the west and north west and Brooks Drive to the east and south

east. Both Shay Lane and Brooks Drive are lined by residential development in close proximity

to the site. To the south of the site is Ringway Golf Course.

2.3 The site is approximately 7.5 ha in area and contains Davenport Green Hall, a Grade II Listed

Building, The Coach House and The Cheshire Barn which are in mixed commercial and

residential use and its curtilage. This larger part of the representation site is therefore previously

developed land. The southern part of the representation site comprises pasture land.

2.4 The site is located to the west of and in close proximity to the proposed site of the HS2

Manchester International Airport station. Development on the site would benefit from the rail

link and potentially other public transport facilities that are developed around this transport hub.

Furthermore, it is likely that the site would also benefit from the draft proposals for an extension

to the Metrolink.

2.5 The site is currently within the Green Belt and adjoins safeguarded land to the east.


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Previous representations

2.6 Details of the site have previously been submitted to the “Call for Sites” in the GMSF in 2016, the

subsequent draft GMSF consultation in 2016 and the Trafford Local Plan Issues Paper (Regulation

18) and “Call for Sites” in 2018. These representations supported the removal of the site from the

Green Belt and its allocation for housing. Our client has also been involved in the

masterplanning information gathering exercise led by Trafford Council.

2.7 In the initial “Call for Sites”, Timperley Wedge had been proposed as an allocation but our

representation site had been excluded from the proposal.

2.8 Following our submitted representations the site was included to form part of the wider

Timperley Wedge housing allocation in the 2016 draft of the GMSF (draft allocation ref: AG3 in

the 2016 draft GMSF). At point 8 of the written statement, the draft set out that the allocation

proposes to “protect and enhance the heritage assets within the site, and their settings,

particularly listed structures such as Davenport Green Hall and Barn.”

2.9 The justification referred to… “Residential development exists along Brookes Drive on the

boundary of the area and part of Shay Lane near Davenport Green Hall is within the area. New

development would need to be sensitively integrated into these areas.”

2.10 It went onto state that the proposed allocation is very well-located in relation to the existing

urban area and “Airport City”. It stated that Airport City will see rapid economic growth and

the Timperley Wedge would be well positioned to support such growth.

2.11 The site was assessed in the 2016 Green Belt Review as part of Parcel TF48. In justifying the

removal of the site from the Green Belt, the justification stated that the presence of many

urbanising features have affected its Green Belt function of openness and resulted in much of

the proposed allocation not retaining the character of open countryside.

2.12 The site was identified as forming part of the Timperley Wedge Allocation in the Trafford Local

Plan Issues Paper (Regulation 18) in July 2018.

2.13 On the proposals map of the revised 2019 draft of the GMSF, our client’s site appears to have

been removed from the proposed Timperley Wedge allocation (Policy GM Allocation 46) and is

proposed to remain within the Green Belt. The proposed allocation encloses our client’s site on


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its northern, western and eastern boundaries. However, the text at point 22 of the

accompanying written statement states the following in respect of the allocation:-

“protect and enhance heritage assets and their settings WITHIN the allocation, particularly listed structures including Davenport Green Farmhouse, Hall and Barn;” (our emphasis added).

2.14 The justification at para 11.316 sets out that… “A heritage Impact assessment will determine any

potential harm and opportunities for enhancement of the listed buildings and their setting within

the allocation. A detailed archaeological desk-based assessment will also be required in

advance of and during the construction process”.

2.15 These representations seek the re-inclusion of our client’s site as part of the Timperley Wedge

allocation (Policy GM Allocation 46) and its removal from the Green Belt in the revised draft of

the GMSF.

2.16 The representations set out the following:

• exceptional circumstances exist for the removal of the site from the Green Belt as part of the wider Timperley Wedge allocation; and

• the site would be suitable for housing development along with the remainder of the proposed Timperley Wedge allocation in the revised draft. There is no justification for the removal of the site from the Timperley Wedge Allocation.


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3. Representations to the 2019 revised draft of the GMSF

Policy GM Allocation 46: Timperley Wedge

Question 130: Do you agree with the proposed Policy GM Allocation 46: Timperley Wedge?

3.1 As referred to above, in the 2016 draft of the GMSF, our client’s site was included within the

proposed housing allocation at Timperley Wedge. The proposed allocation identified that there

were exceptional circumstances to justify release from the Green Belt and that it would be

suitable for inclusion as part of the housing allocation.

3.2 Our client’s site now appears to have now been removed from the proposed allocation in the

2019 revised draft of the GMSF and to remain within the Green Belt, as set out in paras. 2.13 and

2.14.

3.3 Our client’s site includes Davenport Green Hall and barn and the policy text refers to them

being included “within the allocation”. The text and the accompanying plan therefore are

inconsistent.

3.4 If the site is proposed to be excluded from the allocation, then no evidential base has been

provided to justify this. Without compelling justification the site should be retained as part of the

Timperley Wedge proposal and removed from the Green Belt, as it was in the 2016 draft of the

GMSF.

3.5 We set out our reasoning for this below, making reference to the following:

• the site would no longer perform the 5 purposes of the Green Belt, if the currently proposed allocation is removed from the Green Belt. Therefore it should also be removed from the Green Belt;

• the site would be suitable for housing development to support the remainder of the proposed mixed use Timperley Wedge allocation in the revised draft;

• if not included in the proposed allocation, the site would appear as an incongruous finger projecting into the proposed Timperley Wedge development;

• a large proportion of the site is previously developed land and its development would help to make effective use of available brownfield land in accord with Chapter 11 of the Framework; and


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• the land is available for development and our client is willing to bring the site forward as part of the Timperley Wedge allocation.

Removal of the site from the Green Belt

3.6 The Green Belt Topic Paper, which forms part of the evidence base to the 2019 revised draft of

the GMSF, demonstrates that there are exceptional circumstances to release land from the

Green Belt to meet development needs, as required by paragraph 136 of the Framework.

3.7 The contribution that our client’s site and adjacent parcels of land make to the 5 purposes of

the Green Belt, as set out at paragraph 134 of the Framework, was assessed in the 2016 Green

Belt Review which formed part of the evidence base to the 2016 draft of the GMSF. The site and

adjacent land was identified as parcel TF48 in the assessment. It concluded that it made a

strong contribution to the purposes of the Green Belt, but in the context of Green Belt land

needing to be released to meet the housing requirement set by the 2016 draft of the GMSF, the

site was identified for removal from the Green Belt along with the adjacent parcels of land (ref:

TF47 and part of TF49 in the Green Belt Review).

3.8 We understand that the 2016 Green Belt Review still forms part of the evidence base of the 2019

revised draft of the GMSF and no further or updated Green Belt assessment has taken place.

However, whereas the 2016 draft of the GMSF proposed to remove our client’s site from the

Green Belt, and notwithstanding the inconsistencies between the plan and the text of the draft

GMSF, the revised draft now appears to propose that it remains within the Green Belt.

Nevertheless, the revised draft proposes to remove parts of the adjacent parcels of land (TF47

and TF49) from the Green Belt as part of the Timperley Wedge allocation. No evidence has

been provided to justify the removal of the site from the allocation.

3.9 As a result of this revision, our client’s site would remain as an incongruous “finger” bounded by

the allocation proposed for development and the existing built-development on three sides,

with the golf course to the south the only area of open land. This development would

significantly diminish the contribution that the site makes to the openness and purposes of the

Green Belt. We consider therefore, that the site should be removed from the Green Belt and

included as part of the Timperley Wedge allocation in Policy GM Allocation 46 in order to assist

in delivering the level of housing needed as part of a mixed use development.


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3.10 The table below summarises the diminished contribution that the site would make to the 5

purposes of the Green Belt as a result of the proposed revised allocation.

Green Belt purpose Contribution of site to meeting that purpose

a) To check the unrestricted sprawl of large built-up areas

The site already contains built-development (Davenport Green Hall, Coach House and Barn) and is bordered by built-development on its western and eastern boundaries (along Shay Lane and Brooks Drive). This significantly diminishes the openness of the site. With surrounding land proposed to be removed from the Green Belt as part of the Timperley Wedge allocation, the site would form a small finger of land with-development on 3 sides. Therefore, it would not play a role in preventing the sprawl of built up areas. Development of our client’s site, as part of the wider allocation, therefore would not result in development extending any closer to Hale Barns than the currently proposed allocation and existing built development It is considered that the golf course to the south is an appropriate boundary for the Green Belt. The golf course forms a defensible barrier, would remain open and would maintain a significant gap between our client’s site, thus preventing the proposed allocation from merging further with Hale Barns.

b) To prevent neighbouring towns merging into one another

Being left open and in the Green Belt, the site would not prevent the proposed Timperley Wedge allocation from merging with the existing built up area of Hale Barns. Indeed, the proposed allocation extends further to the south of our client’s site on both the western and eastern sides and merges with Hale Barns. The golf course to the south provides a defensible boundary for the Green Belt.

c) To assist in safeguarding the countryside from encroachment

If the currently proposed extent of the Timperley Wedge allocation is adopted, our client’s site would play no role in safeguarding the countryside from encroachment. It would be physically and visually separated from the remainder of the countryside to the north, beyond the proposed allocation. It would form an incongrous “finger” surrounded by development on 3 sides.

d) To preserve the setting and special character of historic towns

The 2016 Green Belt Review acknowledges that our client’s site does not have a role in preserving the setting and special character of historic towns. It states that the site has limited visual or physical relationship with any of the historic settlements of Hale or Northernden and does not contribute to their setting. It specifically makes references to areas of existing urban development providing screening.

e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land

It has been acknowledged that there is insufficient land within the existing urban areas to meet the housing requirements set out in the GMSF and it will need to allocate land that is currently in the Green Belt. We note that very little of the land currently proposed to be included within the Timperley Wedge allocation is previously developed land. The site is partly previously developed land. It contains the curtilage of Davenport Green Hall, coach house and barn which are in mixed commercial and residential use. Including our client’s site within the proposed Timperley Wedge allocation would therefore assist in enabling the reuse of previously developed land.


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3.11 Paragraph 136 of the Framework confirms that Green Belt boundaries should only be altered in

exceptional circumstances through the preparation or review of the local plan. The release of

Green Belt land for housing is necessary in order to meet unmet and future housing needs of the

city-region as evidenced by the wider Timperley Wedge allocation. This comprises exceptional

circumstances for the purposes for the Framework.

3.12 The release of Green Belt land across the city-region should also be seen within the context of

the following bullet points of paragraph 139 of the Framework:

“When defining boundaries, local planning authorities should: • ensure consistency with the Local Plan strategy for meeting identified

requirements for sustainable development; • satisfy themselves that Green Belt boundaries will not need to be altered at the

end of the development plan period; and • define boundaries clearly, using physical features that are readily recognisable

and likely to be permanent.”

3.13 With regard to the bullet points set out above, the release of our client’s site for housing would

help to meet the identified housing requirements for sustainable development.

3.14 If the proposed extent of the Timperley Wedge allocation is adopted, our client’s site would not

contribute to the purposes or openness of the Green Belt. It would form a small, isolated area of

Green Belt surrounded by built development on 3 sides and cut off from the remainder of the

Green Belt and open countryside. Given that the site would not perform any of the 5 purposes

of the Green Belt, it is not necessary to keep it permanently open.

3.15 We therefore request that our client’s site is removed from the Green Belt, as was proposed in

the 2016 draft of the GMSF.

3.16 If our case for removing the site from the Green Belt and allocating it for development as part

of Timperley Wedge is not accepted now, then in order to provide sufficient flexibility the site

should be designated as safeguarded land in the event that allocated sites and / or SHLAA sites

do not deliver as envisaged.

3.17 The designation of safeguarded land would accord with bullets 2 and 3 of paragraphs 139 of

the Framework which set out that:

“When defining boundaries, local planning authorities should:


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• where necessary, identify in their plans areas of ‘safeguarded land’ between the urban area and the Green Belt, in order to meet longer-term development needs stretching well beyond the plan period; and

• make clear that the safeguarded land is not allocated for development at the present time. Planning permission for the permanent development of safeguarded land should only be granted following a Local Plan review which proposes the development.

3.18 For the reasons set out above, we consider that in future the site would not perform a Green

Belt function and as such, should be brought forward early for development as part of

TImperley Wedge, rather than be safeguarded for longer term development.

Suitability

3.19 The January 2019 Site Selection Topic Paper, which forms part of the evidence base to the

revised draft of the GMSF, was used to identify potential sites / areas to be considered for

allocation. Figure 1 of the Topic Paper sets out a number of desirable criteria that would be

considered when determining whether a site / area would be allocated and identifies “Areas of

Search” that meet these criteria. Our client’s site, along with the land currently proposed as the

Timperley Wedge allocation in Policy GM Allocation 46, is included within Area of Search ref:

TR/MA-AS-1.

3.20 We consider that the GMCA’s approach is far too simplistic and it does not provide a sound

basis for identifying potential new sites. It results in Areas of Search being clustered around

existing public transport nodes, close to town centres and within or close to wards identified as

being the most deprived in England. It is not clear how this relates to the wider challenge of

addressing the major housing and economic challenges across the city-region that require

transformation and radical policy responses.

3.21 The simplistic way in which sites are filtered out through the methodology does not appear to

serve any meaningful planning purpose. At Stage 3, the Site Selection Topic Paper considers

potential planning constraints. However, we highlight the following points:

• There is no available land availability assessment carried out in relation to potential Green Belt sites, which could inform the GMCA as to the availability, achievability and suitability of potential development sites. This is a requirement of the PPG, which makes it clear that this forms an important part of the evidence base in the plan-making process and for the purposes of identifying new sites.

• There is no consideration as to the availability and achievability of the sites through the evidence base. For instance, there is no evidence that the GMCA has considered


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matters relating to land ownership and viability. It may be that there is no realistic prospect of a site coming forward for development over the plan-period for the GMSF, although this exercise has not been carried out.

• There is no consideration as to the potential sites to come forward within the early part of the plan-period (i.e. the first 5 years) in order to identify a 5-year housing land supply. As noted through our representations to the strategic policies of the GMSF, there is an urgent need for housing of all types and tenures to come forwards as a matter of urgency in order to meet unmet housing needs. Our client’s site is capable of being delivered within the first 5 years. There are no known site constraints.

• The GMCA has paid little regard to the potential for planning constraints. It has simply mapped certain identified constraints with factual commentary against each but with no assessment or commentary as to the implications e.g. distance to a statutory ecology site or distance to a school.

3.22 Turning to the Green Belt, the GMCA lists whether a wider land parcel as assessed through the

Greater Manchester Green Belt Review 2016 performs strongly, moderately or weakly. There is

no consideration as to the performance of a specific site or its relationship to the wider Green

Belt boundaries and functions. There is no assessment by the GMCA as to the requirements of

paragraph 139 of the NPPF in terms of defining boundaries clearly and ensuring that boundaries

are readily recognizable and likely to be permanent.

3.23 A strategic Green Belt review across Greater Manchester has not been undertaken since the

early 1980s. In the meantime, the need to review the Green Belt boundaries has not been

undertaken at various local plan stages at district level on the basis that there will be a strategic

Green Belt undertaken at some point in the future. This review is now being undertaken some 35

years since the previous review was adopted. However, the GMCA does not seek to engage

with the findings of the Green Belt Review 2016 or the requirements of paragraph 139 of the

NPPF in ensuring readily recognisable and clearly defined Green Belt boundaries.

3.24 The purpose of the site selection methodology is to identify new sites for development within the

Green Belt. A thorough consideration as to the way in which potential new sites relate to the

Green Belt boundaries is an essential step in carrying out a justified and meaningful site

selection process in accordance with national planning policy guidance.

3.25 Finally, there is no clarity provided within the Site Selection Topic Paper as to how officers have

bridged the gap between information gleaned at Stages 2 & 3 and draft housing allocations.

The evidence base is silent on how certain sites have been selected as draft allocations and

others have not. Appendix 7 of the Site Selection Topic Paper summarises how each draft


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allocation in the Draft GMSF performs against of the 7 stated criteria by way of a tick; the draft

allocation at ‘Ashton Road Corridor’ for 260 new homes (GM Allocation 13) does not mean any

of the stated criteria:

Extract of the summary table at Appendix 3 of the Site Selection Topic Paper

3.26 We do not highlight the Ashton Road Corridor allocation in order to necessarily say that this

means that this site is unsuitable as a draft housing allocation. Rather, it only serves to

emphasise our points that it is not possible to make an informed assessment of the way in which

the GMCA has selected sites as there appears to be no reasoned rationale underpinning the

site selection process.

3.27 Our client’s site, which was previously included as part of the Timperley Wedge Allocation in the

Draft GMSF 2016, has not been properly assessed as a potential allocation through the site

selection process.

3.28 The site is suitable for development in that it:

• Provides a logical boundary to the Timperley Wedge allocation.

• It would deliver housing development in a sustainable location alongside the remainder of the allocation.

• It would deliver housing on a part previously developed site, as encouraged in Chapter 11 of the Framework.

• It would benefit from the proposed HS2 airport station and other proposed public transport improvements.

• Is situated in close proximity to the proposed HS2 station, the Manchester International Airport Metrolink Extension and the new spine road connecting Altrincham and Manchester Airport. Development of this site would be a sustainable urban extension and would support and complement the delivery of these projects.

• There are no known physical, infrastructure, ecological or flood risk constraints.


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• Appropriate space and landscaping would be retained around the listed building to preserve its setting, the details of which would be determined at a later stage.

• Proceeds from development could be used to carry out needed repairs and refurbishment of the listed building: Davenport Green Hall.

3.29 Furthermore, there is a willing landowner who wishes to engage in delivering the site as part of a

comprehensive masterplan for Timperley Wedge.

3.30 Therefore, in response to Question 130 in the revised draft GMSF consultation document, we

disagree with Policy GM Allocation 46: Timperley Wedge as currently drafted. We consider that

our client’s site, as shown edged red on the location plan attached at Appendix EP1, should be

included within the proposed allocation.

4. Conclusion

4.1 These representations are submitted on behalf of Hale Living Ltd in relation to the land off Brooks

Drive, Hale Barns, as shown on the location plan attached at Appendix EP1.

4.2 The representations respond to question 130 of the revised draft GMSF consultation document.

4.3 The site performs poorly against the 5 purposes of the Green Belt at paragraph 134 of the

Framework and, as part of the Timperley Wedge Area of Search, its Green Belt function would

be significantly diminished if the currently proposed extent of the Timperley Wedge allocation is

adopted.

4.4 We disagree with the current drafting of Policy GM Allocation 46: Timperley Wedge, and

request that our client’s site is included within the allocation.

5. Appendices

EP1. Land off Brooks Drive location plan

EP1

1823 _ Hamptons Hale

1823-1000

Hale Living

1:1000 @ A1

-

07.08.18 MM

Information

dwg

scale

rev

issued

mcnulty architects ltdDesignworksThe Colony WilmslowAltrincham Road SK9 4LY

[email protected]

01625 468 991

mcnulty architects

This drawing is for design intent only

Do Not Scale

If in doubt, ask. All discrepencies to bereported to the architect before

manufacture, fabricationDrawings are to be read in conjunction

with all relevant specifications andconsultant information

This drawing is not to be re producedwithout express permission of the architect

and only used for the purposes shown withinthe titleblock status bar. This drawing and all

associated designs indicated remain thecopyright of the architect.

date drawn checked MM

Site Plan

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Representations to the Revised Draft Greater Manchester Spatial … · 2019-09-19 · Representations to the Revised Draft Greater Manchester Spatial Framework 2019 Land off Brooks