Places for Everyone Consultation Response

I submitted my response to the Places for Everyone consultation which you can read in full below.

For more information about the consultation, please find this here.


To whom it may concern,


I am writing to respond to the consultation on Places for Everyone (PfE). Many constituents have been in touch with me to share their comments on PfE. I welcome recent improvements in PfE however, I share some concerns from constituents which I detail below.

As the Member of Parliament for Oldham East and Saddleworth my response will mainly focus on the plans for Oldham Borough.


I am aware that in August 2014, the Greater Manchester Combined Authority (GMCA) agreed to prepare a joint Development Plan Document, the Greater Manchester Spatial Framework (GMSF), to set out the approach to housing and employment land across Greater Manchester for the next 20 years. Following the withdrawal of Stockport from the GMSF this has now been superseded by PfE, a long-term plan of nine Greater Manchester districts for jobs, new homes and sustainable growth.

I support this sub-regional approach. Planning for the jobs of the future needs to be done at a sub-regional level to ensure all of our communities benefit, as well as maximising the use of dwindling public resources. So it is entirely appropriate to consider both the housing and business needs of Oldham borough in the context of Greater Manchester’s. Given recent developments however, it is also important to consider the impact of Covid and how this may change commuting patterns and demand for greater flexibility in the work place.

I also support the principle of a strong Spatial Framework for Greater Manchester which shows ambition and confidence. The vision ‘To make Greater Manchester one of the best places in the world to grow up, get on and grow old’ is ambitious and bold. We need to see PfE as a key part of developing a new industrial revolution for Greater Manchester, with Oldham and the other local authorities, transformed to a new glory, taking an unprecedented place in our region’s future, where everyone can fulfil their potential and have a home and leisure space that meets their needs at every stage of their lives.

Greater Manchester’s ambition to be the most dementia-friendly region in the country must also be reflected in its approach to neighbourhood and community planning.   

Since the 2016 and 2019 draft GMSF documents there has a been a reduction in the number of homes proposed on the majority of greenbelt sites, including across Oldham Borough, with the exception of Broadbent Moss. However, I still share concerns regarding the housing targets being imposed by central Government and the number of greenbelt sites required to meet these.

I regret that the Government has not acceded to the three points I made in response to their national planning policy demands on the draft GMSF:

  1. That the Government should develop more realistic population estimates and amend the housing needs identified in Oldham
  2. That the Government should adopt a ‘Brownfield First’ development strategy, so reducing demand on greenbelt land
  3. That the Government should provide remediation funding to enable Brownfield sites to be decontaminated, as necessary

I had hoped that the petition I set up on this would have put the Government under more pressure.

PfE sets out that brownfield land will predominantly be the source of new housing development which is welcome news. However, I recognise that, disappointingly, PfE has also been hampered by national planning policy and as such has not been able to demand that all the brownfield sites are developed first. I believe this is a major error by the Government and the Lib-Dem/Conservative Coalition before it. 7,712 homes are allocated for building on brownfield land compared to 1,276 homes on greenfield land and 2,176 homes on allocations proposed in the Green Belt. Over 136,720 sqm on allocations for industry and warehousing are proposed in the Green Belt compared with 66,269 sqm on brownfield land and 65,252 sqm on mixed sites (brownfield and greenfield land).

I’m pleased that Oldham Council has adopted a Brownfield First policy and has included an extra 2,000 homes in the town centre and a Mills Strategy providing a further 800 homes but I recognise the constraints of the national planning policy that they are working within.  

I am also concerned that the target for the number of homes that we need to build locally as set by the Government, across the plan period the total housing required in Oldham is 10,884 homes, doesn’t reflect our population estimates for the next 20 years, making it more difficult to just build on available brownfield land.

In my discussions with constituents about the draft GMSF, they raised concerns about green belt development both in person and in writing with several local groups coming together to oppose the plans. Since then building on greenbelt land has reduced. 

PfE provides a more balanced mix of homes including a minimum target of providing 50,000 affordable homes up to 2037. In Oldham, we have just under 6,000 households on the housing waiting list which show there is clearly an urgent demand for more housing in the borough. I also understand that there will be an intention to develop an approach to defining what ‘affordable housing’ actually means for Greater Manchester. We need to be cautious about new definitions which may prevent comparisons with other parts of the country and over time. I believe any new definitions should be in addition to current definitions.

I will continue to make the case for affordable homes, and in particular, the need for more social rented homes so we can really start to tackle our housing crisis. I was struck by previous research by First Choice Homes Oldham which showed nearly 1 in 6 Oldhamers can’t afford a social rent.

Over the last 7 years or so, I have stressed the importance of better joined up thinking between different parts of the public sector, for example, planning and transport, planning and education, planning and health. This is the key concern that the hundreds of residents that I have spoken to mentioned about the GMSF and now PfE. In particular the impact on the existing infrastructure, including roads, schools and health facilities is a huge concern. The detailed policies for site allocations set out the details for infrastructure requirements and state that sites will not come forward unless it can be demonstrated this will be provided. However, there is some work to do to ensure residents concern are listened to and that they are aware of plans to ensure infrastructure can cope.

The suitability of some of the sites identified for development was also raised. For example, Beal Valley and Broadbent Moss were both described by residents as areas liable to flood and with concerns around local wildlife and habitat corridors. 

Local proposals and concerns raised with me

Locally PfE plans in my Oldham East & Saddleworth constituency include:

-Cowlishaw remains with 460 homes proposed as in the 2019 revised draft GMSF. Beal Valley is earmarked for 480 homes as in the 2019 revised draft GMSF. Both were down on the numbers proposed in the original 2016 draft GMSF. I note both allocations include retaining and enhancing the hierarchy of biodiversity within the site, as well as the need for appropriate infrastructure requirements. However, I am still concerned about the juxtaposition of the Beal Valley and Broadbent Moss with the Cowlishaw development; the infrastructure implications must be well considered.

– The allocation that was Kingsway South, a cross boundary proposal between Rochdale and Oldham, in the 2019 draft GMSF has now been removed. PfE now identifies High Crompton Broad Location. This is noted as a key high growth corridor area in PfE. However no boundary is identified and the site remains in the Green Belt until such time that a review of PfE / Oldham’s Local Plan can demonstrate that it’s release is fully justified. Any development would need to ensure that necessary infrastructure is delivered to accommodate the likely scale of development. I welcome this news.

The PfE does see some improvements in the Shaw, Crompton and Royton area (with the current removal of Kingsway South) which previously included large allocations within a short radius. However Shaw, Crompton and Royton still sees some valued recreational green spaces diminish. Many residents are also still concerned about how roads, air pollution levels, schools and health services (particularly GP services) will cope with the additional homes proposed in the area. There are also proposals for 400 additional homes on the old Shop Direct Mill site off Linney Lane, Shaw. This needs to be considered in the context of plans under PfE. It is important that local residents are engaged throughout and communicated with on recent changes to plans.

-A new tram stop has been proposed for Cop Road to serve the new housing development for Broadbent Moss and Beal Valley as well as bus transit between Rochdale and Oldham. I have noted that developers would be required to be partially fund transport improvements and development would not go ahead without appropriate infrastructure plans in place.  However some residents have raised concerns whether this provision would be adequate given the number of homes proposed across this area.

-Broadbent Moss, near Sholver will see over 1450 homes as well as new employment space. Residents have raised concerns about the use of greenbelt to build homes and the impact on the existing road and other local infrastructure and major pinch points such as Ripponden Road. I understand a new internal spine road will be developed but constituents have still raised concerns on the impact on arterial roads. There are also concerns around flood risks and the impact on local wildlife and habitat corridors.

-I welcome the removal of 50 new homes that were proposed at Spinners Way to the north east of Moorside. Residents previously raised concerns about a change in natural water course and flooding as the land was on a steep slope, lack of available local school places and impact on existing road infrastructure.

-Plans at Chew Brook Vale (Fletchers Mill) also see revised proposals with Chew Brook Vale reduced allocation of homes from 171 to 90. The site area has been reduced to minimise Green Belt release and now only relates to the brownfield mill site. In addition, one site is proposed to be added to the Green Belt in Oldham – Land behind Denshaw Village Hall – 0.6 hectares. This is welcome news.



For many residents the process to reach PfE has been an arduous one and for some there are still a number of concerns. There will never be a strategy that pleases everyone. However, I recognise we do need to put a plan in place for our housing and employment needs otherwise, as the Government have already threatened, if they deem that the local land supply identified is insufficient, we risk it being taken out of our hands locally and the power transferred to developers.

PfE does see more development on brownfield land and a reduction in Greenbelt land for development. This must be welcomed and I applaud Oldham Council on their Brownfield First approach, their Mills Strategy and Town Centre plans all of which have helped reduce the greenbelt take by over 1,800 (across Oldham borough) since the last iteration of the GMSF.

Through the Plan’s liftime we need to ensure joined up thinking between different parts of the public sector, for example, planning and transport, planning and education, planning and health.

At the heart of a future PfE must be the people we serve – these new proposals should fully and meaningfully engage with local people, including all elected representatives. It is important that this process is open and transparent with views sought from residents and stakeholders at all stages and the outcomes from these shared widely. This should go beyond the normal consultation process and include options such as local ballots (used in some parts of London) where residents can have a say in the design of their local area should be considered on a longer-term basis.

Currently, there is a loophole in national policy which allows developers to submit viability assessments with their planning applications, showing that the amount of affordable housing required in a local plan would reduce their profit margin. This can be used to argue that they should be allowed to reduce the amount of affordable housing they build. This is unacceptable and I will continue to oppose it. We need to have stringent processes in place to reduce the risk of this happening locally.


Yours sincerely,

Debbie Abrahams MP

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