Letter to P4E Planning Inspectors
The SGMGB Management Committee has raised a number of issues with the Planning Inspectors who are Examining the Places for Everyone Spatial Plan. We have concerns about the significant changes that are being proposed by the GMCA, which mean that the Plan is considerably different to that which was consulted on in October 2021. You can read our letter below and here on this link as a pdf document.
Dear Mr Fieldhouse, Ms Gibbons and Mr Lee
Thank you for changing the agenda of the Hearings to provide an opportunity to raise our
questions and concerns about the GMCA’s revised approach to Green Belt additions. We thought it may be helpful to share the key issues raised by our members in advance of the session on 28th March:
1. The GMCA’s withdrawal of its support for 32 of the proposed Green Belt additions appears
to have arisen due to the Solihull vs Gallagher appeal judgement from 2014, a case which
the GMCA’s legal representative was heavily involved in. It is not clear to us why the
GMCA concluded that these Green Belt additions met the legal threshold in 2021, when the
decision was made to progress to the regulation 19 consultation, and they presumably still
held this view when the Plan was submitted for Examination. Our members request that
the Inspectors seek clarification from GMCA on this point and that the reasons behind this
change of opinion at this late stage are published, ideally prior to 28th March.
2. The Gunning Principles are established by case law and require that consultation includes
sufficient (and accurate) information to enable consultees to give intelligent consideration
and provide an informed response. Given that around 27,000 GM residents objected to the
release of Green Belt and that these additions were a key compensatory measure for the
losses proposed, it is clear that there would have been significant feedback, had they been
withdrawn prior to the regulation 19 consultation. We request that you consider whether
this a justifiable modification to the Plan at this late stage?
3. These Green Belt additions represent a significant component of the submitted Plan, so
procedural questions have also been raised following this proposed radical change. Should
all the Green Belt additions be fully examined as submitted (as was the case with the
Walshaw Allocation, which was proposed for removal)? We would welcome the Inspector’s
guidance and feedback on this matter.
4. There are significant concerns that such a huge modification of the Plan has been
introduced, in a Hearing Session (with no prior notification), giving limited opportunity for
those not attending to contribute to the subsequent discussion. Many of our members work
full time and are not able to attend additional Hearings at short notice. Would the
Inspectors accept written submissions from anyone unable to attend but who wishes to
provide input?
We appreciate that the proposed modifications are precisely that, and that they may yet be
rejected if they do not contribute to making the Plan sound. Our members have, however, raised the following points that are not specific to the major modification above and, given the vast number of substantial changes now proposed, question whether the Plan was actually ready for submission to the Planning Inspectorate:
5. During many of the Hearing Sessions, the GMCA has introduced significant policy changes,
materially altering the Plan, and weakening the policies in the consulted version. We
question whether these are necessary to make the Plan sound, including those relating to
changes in affordable housing policy, a loss of focus on Brownfield Preference, district level
employment targets and the significant weakening of JP-S2, along with the policies that are
proposed to be deleted entirely.
6. Most of these modifications were proposed shortly before the relevant Hearing Sessions
(for example, the proposal for the district-level employment targets was published on the
day before the Hearing). These short notice changes meant Hearing attendees did not
have adequate time to review the proposals in detail and formulate a considered response
and other potentially interested Examination participants had even more limited
opportunities to contribute to the subsequent discussions.
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7. Much time has been taken up in the Hearings by editorial/textual changes proposed by the
GMCA, some of which we feel have little-to-no bearing on the soundness of the Plan. We
believe these changes are unreasonable and the approach is inconsistent, given that the
GMCA has suggested that points raised by others should not be considered on the basis
that such changes are not necessary to make the Plan sound?
Given the excessive number and impact of the proposed changes, we request that the Inspectors consider removing all proposals for Green Belt change (Allocations and Additions).
Alternatively we feel the Plan should be resubmitted for consultation at the Regulation 19 stage, so communities and other stakeholders have the opportunity to comment on what is now intended.
Yours sincerely,
Zoe Sherlock (Chair) – Save Greater Manchester’s Green Belt Group
Mark Burton- Steady State Manchester
