We have sent the following feedback about the Greater Manchester Spatial Framework to all Trafford Councillors in advance of their discussion about the GMSF on 30th November.
Summarising the issues!
Whilst we totally support the principle of the GMSF, concur with its ambitions, and recognise the considerable effort that has gone into drafting it, we cannot support the current iteration because it still advocates the unnecessary removal of Green Belt land across Greater Manchester, when there ARE clear alternative approaches.
The issued documentation declares that Local Authorities are able to make “adequate” provision to meet housing need numbers WITHOUT releasing Green Belt land. It must also be remembered that, back in 2015, a GMSF Option was considered which required NO use of Green Belt land and a decision was specifically made NOT to take this forward. This suggests that the decision to release Green Belt in GM is a desire of the leadership, NOT a requirement. This assertion is further reinforced by the recognition that, whilst a lot of effort has been made to create exceptional circumstances which support the release of Green Belt land, NO attempt has been made to identify exceptional circumstances to reduce the housing need number to ensure all development is focused on brownfield land.
Given that Local Authorities have identified “adequate” sites to meet housing need numbers, together with the expected changes to working practices post-Covid (which we believe will lead to the availability of windfall sites across GM), the extensive feedback from residents against the release of Green Belt land, and the emphasis of all political parties on nature-led recovery and the climate emergency, the only reasonable approach for the GMSF is NOT to release Green Belt land for development. The GMSF could have been prepared within that constraint and should, if confidence in developer delivery is low, also have proposed that an extensive post-Covid review be undertaken during the GMSF period to determine whether further analysis is needed. The current approach is likely to lead to Green Belt being built on, whilst a huge number of windfall (brownfield) sites are left unused.
Furthermore, at a local level, whilst we welcome the work that has been undertaken to reduce Green Belt release in New Carrington, Trafford’s overall reduction in Green Belt take is significantly lower than that of other boroughs in GM. In addition, the plans as documented are NOT plans that are underwritten by local residents. The New Carrington Masterplan talks about the intensity of discussions with landowners and developers, yet there have been NO workshops about the Trafford allocations with residents or Parish Councils prior to issuing the documentation. It is certainly a very strange type of democracy that has Local Authorities working on secret plans which significantly impact the local communities they are accountable to, despite a Statement of Community Involvement which suggests, in its introduction, that the Council should be “providing opportunities for active participation and discussions with the community as early in the plan-making and planning application processes as possible.”
With this in mind, the Friends of Carrington Moss are working with local Parish Councils and other community groups to develop alternative proposals for the area. There is a lot of talent in our communities and a large number of ideas have been proposed. These alternative options further demonstrate that the release of Green Belt is NOT necessary.
Unnecessary Release of Green Belt Land for Development
We believe that the GMCA is making a deliberate and conscious decision to unnecessarily release Green Belt land for development. Once this precious resource is released, it is irretrievable for the vital purposes it performs. In our view, this approach is unsound because it is neither justified (given the confirmation of adequate housing supply) nor sustainable (given the selective implementation of GMSF strategic policies).
For clarity, the GMSF paragraph 7.12 states that “in numerical terms, the existing supply of potential housing sites identified in the districts’ strategic housing land availability assessments, small sites and empty properties is adequate to meet the overall identified need”. This means Green Belt land is being released to cover a “buffer”, just in case it is needed. This is not justifiable and any buffer required should have been covered by a case for exceptional circumstances, as set out below.
The release of Green Belt will have a particularly severe impact on Trafford as we have the lowest proportion of Green Belt land in the whole of Greater Manchester, other than the city areas of Manchester and Salford. In addition, St Marys Ward has the lowest proportion of Green Space in Trafford, with Bucklow St Martins Ward close behind. These are the two Wards most affected by the plans for New Carrington. Many of our residents are not affluent and have valued free access to this local green space more than ever since the pandemic began. Whilst you may see a corridor coloured green on the New Carrington map, it should be recognised that much of that “green” space is not green and it is not accessible to the public. This reduced green area will be further diminished if Trafford’s planned roads across the Green Belt go ahead, bringing significant air and noise pollution to residents, sports participants and school pupils. The community has developed alternative proposals which make these roads and the release of Green Belt unnecessary.
GMSF 2020 could have determined not to release Green Belt and could have proposed a post-Covid review, within the GMSF period, to verify whether developer delivery is on target and, if not, whether sufficient windfall sites are available to meet any shortfall. Should that review ascertain that Green Belt release could be necessary, this should be considered further and agreed at that time.
Case for Exceptional Circumstances in calculating Housing Need
We believe insufficient effort has been made by the GMCA to present the case for exceptional circumstances to justify a reduction in the housing need numbers calculated using the Government’s National Formula. This standard method for calculating Housing Need is NOT mandatory. This has been confirmed, both in writing and verbally, by Ministers, on several occasions over the last few years. In a recent example, the Hansard transcript for the GMSF and Green Belt Parliamentary Debate of 18 March 2020 confirms the Minister for Housing’s statement that “It is worth noting that the standard method is not mandatory; in exceptional circumstances, an alternative approach can be used, provided that that reflects the current and future demographic trends and market signals. If my hon. Friend the Member for Altrincham and Sale West cares to check paragraph 60 of the NPPF, he will find reassurance in that paragraph” (Hansard: 18/3/20 Parliamentary Debate).
In addition, it has been demonstrated in responses to previous drafts of the GMSF that a 15-year plan would generate sufficient available brownfield land to meet housing need requirements across the Region, totally removing the need to release Green Belt. A 15-year plan would also allow more flexibility to adapt to the, as yet unforeseen, changes required due to climate change and the current global pandemic (some rethinking of our lifestyles and economy is likely to be required, which will have a direct impact on planning).
So, there are a number of potential exceptional circumstances that do reflect demographic trends and market signals, that could be cited to ensure all development is concentrated on brownfield land. Some examples include utilising the most up-to-date (2018) ONS figures (to determine more accurate local housing need predictions), limiting the GMSF to a period of 15 years (which is all that is required by the NPPF) and confirming a commitment to the post-Covid review (mentioned above). In addition, funding of £81m is now available to tackle the more challenging brownfield sites across the Region.
Addressing the Climate Emergency
We do not believe the plans to release Green Belt in Trafford are consistent with the declaration of a Climate Emergency, made by the Authority in November 2018. The protection of our Green Belt land is now more important than ever as we experience the increasing impact of climate change. As an example, large areas of Carrington Moss were extensively flooded between October 2019 and March 2020 (see our website for photographs and videos), including areas now suggested for housing developments.
The release of Green Belt is also inconsistent with GM’s aim to be “a place at the forefront of action on climate change, with clean air and a flourishing natural environment”. As part of the preparations for the GMSF, GM commissioned The Environment Partnership (TEP) to assess the current state of the natural environment. TEP undertook a review to estimate how many Biodiversity Units (BUs) there are in each of GM’s 10 boroughs. Trafford (at 41k BUs) is the second lowest in the Region, just above Manchester City itself, significantly behind the leading Authority, Oldham (with 139k BUs), and not even comparable to Tameside (95k BUs), which is a similar size in terms of area and population to Trafford.
Releasing the Green Belt in Trafford will reduce our BUs further. The local community has developed an alternative strategy for Carrington Moss which would utilise the area as a carbon and biodiversity bank to “sell” carbon and BUs to businesses and urban developers to help them meet their carbon targets and biodiversity net gain figures and to increase Trafford’s BUs at the same time. Whilst it is impossible to put a price on our green assets, we are seeking to create a viable alternative to the current plans.
All the political parties have a focus on nature-led recovery and the climate emergency. Labour’s Green Economic Recovery paper, for example, quite rightly, suggests that “Future generations will judge us by the choices we make today”. How will a decision to unnecessarily release Green Belt be judged by those who no longer have access to nature and green space, who can no longer see the willow tit and the skylark in their local area (because their breeding and feeding grounds have been destroyed), who can no longer see relatives and friends who have succumbed to illnesses caused by increased air pollution.
That Green Economic Recovery paper also highlights the importance of not only solving the decarbonisation challenge but also in igniting the “broader preservation, enrichment, and protection of the UK’s natural ecosystems and biodiversity”. The Labour document also mentions the importance of restoring peatlands and we agree that significant action is “needed in order to accelerate the benefits of nature restoration and recovery” and that there is “an abundance of natural restoration projects that could begin right now”. The plan for New Carrington is NOT an example of how we can achieve these great ambitions, it also directly contradicts many of the environmental policies set out in the GMSF.
In addition, the 2020 GMSF proposes to expand Manchester airport. It is already a source of considerable air pollution, noise nuisance and contributes to greenhouse gas emissions. Until green aviation fuel has been developed, which is not likely within GMSF period, there should be no further expansion of the airport or increase to the agreed number of flights (a reduction would be more sensible to align with the GMSF stated aims for carbon neutrality and clean air).
Other points to consider
Whilst the GMSF incorporates a number of aims and ambitions that are laudable, somewhat summarised in paragraph 1.6, which states that “Our ambitions to be carbon neutral by 2038 have never been more necessary – we need to support the creation of resilient, liveable places where walking and cycling are the obvious choice for shorter journeys, where facilities and services are accessible and close at hand and where the past dependency on the car is superseded by a reliable and responsive public transport system.”, the selective adoption of the policies and strategies encompassing the GMSF means that the desired equality objectives cannot be achieved.
One equality objective is to “Prioritise development in well-connected locations” and another is to “Deliver an inclusive and accessible transport network”, which will improve air quality across GM. Paragraph 5.50 states that “The most significant role which the GMSF will play in this respect [improving air quality] is to locate development in the most sustainable locations which reduce the need for car travel, for example by maximising residential densities around transport hubs”.
The New Carrington development is NOT currently a sustainable location and we do not believe it will be transformed to a sustainable residential and industrial location. Public transport improvements have been promised to Carrington, Partington and Sale West in the 2006 UDP and the 2012 Core Strategy but in fact, bus services have reduced in these areas. The GMSF does NOT COMMIT to increasing public transport, instead, the Masterplan suggests “improving bus accessibility to New Carrington, Altrincham, and Sale should be encouraged” and the TfGM Transport Delivery Plan 2020-2025 states that “In the next five years, we aim to complete business cases for early delivery of… New bus services to support the New Carrington and Sale West allocations”. That is not reassuring given residents have been waiting for over 15 years for improvements to public transport.
Furthermore, it is unsustainable to consider the use of Green Belt land for warehouses and industrial with the clear aim of using road transport. The community has developed an alterative Transport Strategy which proposes a new bridge across the Ship Canal, to provide access to Irlam Wharf and Port Salford for businesses in Carrington. This approach, which we have discussed with local businesses, would mean HGV traffic can be significantly reduced and that there is no requirement for a Relief Road across Carrington Moss.
The GMSF 2020 places great emphasis on economic growth, appearing to give this a higher priority than the well-being of residents, yet the importance of access to green spaces and nature for physical and mental health is now well documented. It is recognised that the impact of Covid and economic uncertainty will hit our most vulnerable residents the hardest, yet the GMSF, despite acknowledging the “state of flux”, does not address the inequities that will inevitably follow.
There is also an equality objective to “Strengthen the competitiveness of north Greater Manchester”, yet the largest residential allocation is in Trafford. This means that Trafford residents do not have equity of access to Green Belt areas, they have their access to green space further reduced and for residents of North Manchester, growth is not being prioritised as suggested in the GMSF.
Finally, there are issues about the heritage assets in the area (including the peat moss itself, of course), the harm to be caused by the loss of Green Belt (which is acknowledged in the Masterplan) and the loss of income to local businesses (including riding centres and farmers), which of course impacts Trafford’s local economy too. The New Carrington allocation remains unsound for the many reasons that have been vigorously expressed by local residents in the previous consultation.