Is Places for Everyone/GMSF2021 the right plan for Trafford and GM?
Open Letter to All Trafford Councillors
Before you vote on the Places for Everyone (P4E) Spatial Plan for Greater Manchester (previously known as the Greater Manchester Spatial Framework – GMSF), we’d like you to consider the following significant concerns about its acceptability as the spatial plan for GM for the next 16 years:
- We understand that Labour Councillors across GM will be whipped on this decision, which is an odd approach if there is confidence that it is the right plan, setting out the right future, with the right balance of economic, social and environmental goals, making the right decisions for the residents of GM, and, in our case, Trafford. Why is it not possible for Councillors to be persuaded by the evidence that adopting this plan is demonstrably the most appropriate, necessary and commendable option for the P4E Councils?
- All GM Councils, including Trafford, and the GMCA itself have declared a climate emergency, therefore, all decisions made should reflect this commitment to your current and future residents – we do not believe the plan, as currently articulated, has sufficient focus on tackling climate change
- Despite there being no evidence that the proposed release of green belt is justified, anywhere in GM (in fact quite the opposite, as explained below), 2,430 hectares of GM’s green belt will be released for development immediately following plan approval (P4E reports a net loss of 1,754 ha as the Plan proposes adding 675 ha of new green belt)
- Whilst the plan demands that residents must accept a loss of green belt, and the consequent impact to their health and wellbeing, there are no policies that incorporate demands on developers (for example, to build those properties that already have planning permission), there are no policies to prevent developers securing planning permission on what is currently green belt land, yet not delivering against that approval, possibly resulting in yet more green belt land being proposed for release in the future
- Greater levels of division and inequity will be driven by this plan, not just in terms of access to local green belt but also in access to schools, affordable homes (the New Carrington allocation, for example, will now only provide 15% affordable, due to viability issues) and public transport (New Carrington, for example, with 5,000 homes planned within P4E and a further 1,000 homes in the area with recently granted planning permission, has no trams, no trains and no commitment to new bus services – we have checked this via an FOI request)
- Residents will suffer the health impacts of increased air, noise and light pollution and constructing 4 major roads across a peat moss will also significantly affect the populations of red listed birds and endangered wildlife that breed and feed in the New Carrington area
- The New Carrington Masterplan conflicts with many key policies and strategies, not just those set out in P4E but also with the objectives outlined in, for example, the 5 year Environment Plan for GM and the spirit of a number of clauses in the National Planning Policy Framework
- The GMSF has repeatedly been published with flawed, misleading or disingenuous statements, which should not be necessary if there is confidence in the benefits of the plan
- There has been an unprecedented volume of responses from residents objecting to the planned builds on green belt across GM in the previous consultations (2016 and 2019), yet the GMCA continue to propose this!
Available Land Supply:
The documents tell us that the P4E plan area has a projected population increase of around 158,200, and housing occupancy rates averaged at 2.38 people per home (according to Census 2011, latest information from ONS puts occupancy levels at 2.4 but as this would reduce the figures further, we have used the Census figure). This results in a housing need of 66,500 homes for the P4E plan area. This figure can be compared to an available land supply of over 170,000 homes, as set out in Table 7.1 (excluding green belt allocations). Given that this figure is over 2.5 times the need for homes, there is sufficient leeway for larger numbers of single occupancy houses, should this become a requirement of future trends. In fact even without the (20,000) green belt allocations (see Table 7.1), there is more than sufficient land supply (170,000) for every single expected additional member of our population (the increase of 158,200) to have their own home!
It is clear that there is NO justification for the release of green belt.
The P4E document itself states that there is sufficient housing land supply to meet the overall identified need in the Government’s formula/algorithm. The green belt allocations appear to have been made in case developers do not deliver. We believe this issue should be addressed with policies that make demands of developers, not policies that result in the release of our green belt land.
We have heard the mantra “the Government is making us do it” quoted. We recognise that there is mixed messaging, which is unhelpful. The Government has confirmed, including specifically in relation to GM, that the housing need figure is not a target (in both Parliamentary debates and in writing). The recent MHCLG blog (25th May 2021) seems to be pretty clear:
“The Local Housing Need is simply a measure of need and we recognise that not everywhere will be able to meet their housing need in full – for example, where available land is constrained due to the Green Belt and an area therefore has to plan for fewer new homes.”
Given the implications of the climate emergency, Brexit and the pandemic, the GMCA could, and should, have concluded that the sufficiency of housing land supply did not need to be supplemented by a release of green belt at this time.
Green Belt Release:
Yet, despite these numbers, green belt will be released as soon as the plan is approved and P4E proposes a significant loss of green belt across GM – 1,754 hectares in total, equivalent to 2,456 football pitches. For Trafford, at 269 hectares, our loss of green belt represents over 15% of this figure (the equivalent of 376 football pitches). Trafford enters this plan with significantly less green belt land (37.6%) than the GM average (46.7%) and will exit it with a much larger (6.7%) net loss of green belt than the GM average (3.27%). Leaving Trafford residents with even greater inequity of access to local green belt than previously available, with our post plan green belt figure being just 35% of Trafford’s land area against a GM average of 45%.
There are alternative approaches. Oldham, for example, proposes (North-East Growth Corridor) that land will be retained in the green belt “until such time that a review of this Plan and / or the Oldham Local Plan can demonstrate that it is necessary”. All GM Authorities, including Trafford, could adopt similar wording to create a policy that ensures green belt land continues to be protected and is not released whilst brownfield sites are still available for development.
The history of misleading statements that have permeated previous iterations of the GMSF has, disappointingly, continued into P4E, with, for example, the New Carrington Allocation Topic Paper stating (paragraph 12.2) that “Carrington Moss is a former peat bog”. It then goes on to contradict itself by confirming “initial investigation indicates a maximum thickness of peat of 3m, which thins towards the perimeter”. That is 9 feet of peat deposits, which are regularly under significant surface water flooding for at least 6 months of the year (see our website page Carrington Lake). We have requested clarity about this statement from Trafford officers as a recent presentation to residents by the GM Wetlands Project (LIttle Woolden Moss) confirmed that peat can be restored where deposits are as low as 15cm.
The graphic below highlights some of the disingenuous statements included in previous iterations of the plan, along with a summary demonstrating the consistent lack of resident support for the New Carrington Masterplan. As we are not considered to be major stakeholders (the New Carrington Masterplan defines these as landowners and developers), this plan does not consider the views of local residents. This is not the approach the Labour administration has taken on strategic plans for other parts of the Borough. Why are the views of the residents of Carrington, Partington, Sale West and Warburton not considered to be as important as those of Crossford Bridge, Flixton, Stretford and Turn Moss?
There are many other points that we could raise and we will share these over the coming weeks, but for the reasons set out here, and others, we firmly believe the plan will be found to be unsound when examined by Planning Inspectors.
If you would like to discuss any of these points further, please do not hesitate to contact me.
Marj Powner (Chair)
Friends of Carrington Moss