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Request for Support in Representing Communities: Places for Everyone Examination in Public Hearings

Request for Support in Representing Communities: Places for Everyone Examination in Public Hearings
RHS Garden Bridgewater, Occupation Road, Worsley, Manchester, UK - Credit to Andrew Hall

By Marj Powner (Vice Chair, Save Greater Manchester’s Green Belt Group)

Save Greater Manchester’s Green Belt group (SGMGB) are seeking pro bono legal representation at the Places for Everyone (P4E) Examination in Public (EiP) Hearings. This blog post details the background context on this case, and encourages any pro bono managers or legal professionals capable of responding to this call to do so, by contacting Marj Powner via her LinkedIn. The SGMBG thank you in advance for your consideration of this case, which has the potential to completely transform the Green Belt around Greater Manchester.

What is the Background of this Request?

Despite extensive research, investigation and detailed reporting, community groups are, typically, not considered to be experts in the topics that will be raised in the P4E EiP and we believe some of our contributions will have more credibility if delivered by a legal professional.

We have identified a small number of matters which we believe would benefit from legal representation and we are hoping to identify individuals who can support us on a pro bono basis at the P4E EiP Hearings.

We have little funding (particularly as the pandemic severely impacted our ability to host fundraising events with our communities), so we are hoping to limit the costs of support as much as possible. This does, of course, demonstrate just one element of the imbalance in the existing planning system. Public bodies and developers are NOT restricted in the legal advice available to them because of the funding they are able to access. This obviously leaves community groups, like ours, at a huge disadvantage, and we do have legal arguments we would like to advance. Sadly, we are clearly not in a position to appoint a paid Barrister, so it is not a level playing field. Hence, this request for support.

Tandle Hill March, Save Royton's Greenbelt, January 2017 - Credit to Save Royton's Greenbelt

What is the Background to the Greater Manchester Spatial Strategy?

The Places for Everyone (P4E) Joint Development Plan document covers Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Tameside, Trafford and Wigan. It is considered to be a long-term plan for jobs, new homes and sustainable growth. The Greater Manchester Combined Authority (GMCA) suggest the aim of the plan is to maximise the use of brownfield land and urban spaces, whilst protecting Green Belt land from the risk of unplanned development. Yet, over 3,500 hectares of Green Belt and greenfield land will be sacrificed if this plan is agreed. The GMCA’s aim is also to sustainably integrate all new developments into GM’s transport network. The plan period stretches to 2037.

The previous iterations of this plan were known as the Greater Manchester Spatial Framework (GMSF) and also included Stockport, the tenth district in GM. Stockport’s politicians voted against the GMSF in December 2020 because of the continued requirement to release Green Belt land.

The Regulation 19 version of P4E was submitted to the Secretary of State on 14 February 2022, by the GMCA, on behalf of the 9 local planning authorities. The Secretary of State has now appointed three Planning Inspectors to examine the P4E Plan. Their role is to consider whether the Plan complies with relevant legislation and is “sound” (positively prepared, justified, effective and consistent with national policy). Described by the Planning Inspectorate as the “largest plan we have ever examined”, this is a large and complex suite of over 150 separate documents (more than 14,000 pages) in the Plan itself, plus a further 4,000 representations in response to that Plan, together with a number of additional documents created in response to the Planning Inspectors’ questions.

Save Royton's Greenbelt has been successful in saving Hanging Chadder and Thornham Old Road from development (pending Government inspection), but the Greater Manchester Spatial Framework is still proposing to building thousands of homes there.

The GMCA believe they have submitted a “sound” Plan and the Inspectors will start from the premise that the Plan is “sound”.  SGMGB and other community groups in GM believe there are a number of serious anomalies within the Plan that make it “unsound” and in need of modification. The planned unnecessary release of Green Belt is one of those issues.

On 26th July 2022, the Inspectors confirmed that the Examination in Public will start on 1 November. The Hearing sessions are likely to continue until Spring 2023 in blocks of 2 or 3 weeks (with gaps of 1 or 2 weeks between blocks and a longer break over Christmas and New Year). Details of the venue, along with a provisional programme for the Hearing sessions, will be published in due course. Information about the P4E Plan and the Examination is available here, including the link to the submitted documents. The Planning Inspectorate has produced a Guide about Local Plan Examinations which is available here. The Planning Inspectorate have also produced a guide about taking part in examinations which is available here.

The best and most versatile, Grade 2 agricultural land that will be sacrificed in Carrington Moss for roads, housing and employment, despite being afforded a level of protection in the NPPF - Credit to Friends of Carrington Moss

Representation at the Examination in Public Hearings

In addition to representation at the EiP Hearings, we would welcome legal input to the final versions of our responses to the Matters, Issues and Questions (MIQs). There are specific word limits for the questions, so we may have challenges in drafting some of our responses. We hope to be able to access legal expertise for those specific points that will be best covered by a legally qualified professional (currently three topic areas), who will be able to invoke case law and legal precedent.

We would be delighted to discuss our request for pro bono legal support with you. If you are interested, please get in touch as soon as you can.

What is currently unspoiled views on a beautiful country walk will soon be replaced with brick walls, plastic roofs and lots of HGVs if the Plan goes ahead - Credit to Friends of Carrington Moss

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