COMMENTS RE: GREATER MANCHESTER SPATIAL FRAMEWORK
Response of Trafford Green Party - General Themes - Summary
Support for:
Negative features:
Detailed Response
Introduction
The broad parameter that is Brexit hangs over this Framework. Many of the assumptions and statistical analyses that underpin the proposals contained within this document will need fundamental re-assessment if the UK leaves the EU – with or without a deal. Scope for such a massive re-appraisal must be allowed for within the timescales involved for the process and procedures relating to the on-going development of the GMSF.
It must also be remembered that the GMSF does not correspond directly with any level of government in the country. Other than through limited Mayoral powers and the potential use of undefined Mayoral Development Corporations, the implementation of the GMSF will be through Local Authority Local Plans. These plans, by their very nature take time to produce and adopt. This time-frame must be added to the uncertainty already inherent in the current Brexit negotiations.
In the light of the above, much of the strategy and the policies within the GMSF have to be prefixed by the words “promote” or “encourage”, which adds further uncertainty to the likelihood of many of the most important elements of the Framework actually being implemented. In the light of austerity, government cut-backs, the decimation of local authority funding in recent years, and the reliance of government policy on the continued privatisation of services, the GMSF must be considered as over-reliant on both rhetoric and also the goodwill of national and international companies to put the needs of the populace over their own economic priorities. It will take strength of will and a solid intent to carry through the necessary radical measures to overcome the hurdles that past and current government policies have placed in the way of achievement of truly sustainable development. At this stage, it is not possible to assess the chances of this happening.
There are a number of fundamental inconsistencies within the Framework. There is a wholly correct emphasis placed on the need for the Northern Powerhouse project to be carried through and prioritised, in order to create a meaningful counter-magnet to Greater London and the South-East. However, the reliance placed in the Framework on massive Airport expansion and a highly dubious HS2 project runs completely counter to this on every level, in that it would place immense pressure on an inadequate supporting infrastructure in a very small part of the conurbation, whilst failing to integrate with the opportunities offered by other parts of the Northern Powerhouse. Moreover, the airport expansion would work against climate change mitigation and reductions in air pollution, whilst HS2 would enable easy long distance commuting to London and put unnecessary and unwelcome pressure on house prices from those choosing to leave London in search of relatively cheap accommodation.
There is a prevailing culture in the document that all inward investment is good, when this is patently not the case. Since the 1980’s large amounts of UK manufacturing have been sold off to foreign companies, with almost all of the economic focus of the country being diverted to the financial sector. Whilst this may have brought some short-term benefits, the country is now seeing global companies taking their investments back to their own countries or, in the case of financial organisations, to other parts of the EU, along with substantial amounts of housing being bought up as investments by foreign companies or individuals with subsequent repatriation of profits. What Greater Manchester needs is the right kind of investment in the future growth sectors of manufacturing, including renewable energy and digital technology, alongside investment in small scale businesses that have a local focus. Greater Manchester needs investment in communities not investment in large scale vanity projects that provide profit for companies outside of the North of England or with a global focus. There is little if any emphasis on this within the GMSF.
We applaud the stated intentions with regard to increasing the percentage of Affordable Housing to be provided within the conurbation, along with the need to foster the health and wellbeing of the population through an emphasis on green and blue infrastructure. We welcome positive statements relating to reductions in air pollution, improvements to public transport infrastructure, support for enhanced education and training facilities, and maintenance of healthy and vibrant town and local centres. Insofar as these coincide with the requirements of the NPPF, and are more than just token gestures, we believe that these could be key elements of the Framework, operating to improve the quality of life of local communities. We remain concerned that the basic thrust of the current document relies too much on unreliable statistics and on an outdated form of economic growth that fails to fully recognise the likely future directions of investment and industry, and the opportunities these offer.
Specific comments
For convenience, these comments will be given in the order found in the document, with cross-referencing as appropriate.
Introduction
Para 1.2 and 1.13 – We do not believe there is a need for net Green Belt loss. Even if it were deemed essential that some Green Belt be released for development – which we do not endorse – there is no reason why an equivalent amount should not be found, in order to protect the purposes of Green Belt as set out in the NPPF.
Para 1.4 and 1.5 – We concur with the challenges and pressures identified. In addition to retrofitting of energy efficiency measures to buildings, all new buildings should have such measures as solar panels and other low-carbon elements fitted as standard. If this requires modifications to regulations then this should be vigorously pursued. Also, rather than planning to meet future pressures on infrastructure etc, we need to be planning to reduce future pressures.
Paragraphs 1.21 - 1.24 – We concur with the thrust of these paragraphs, and request that planning for greater use of electric vehicles from this time forward be given a greater urgency.
Paragraph 1.25 – The mix of housing needs to incorporate a much higher percentage of truly Affordable Housing. Increased densities would reduce the need to release Green Belt land.
Paragraphs 1.28 – 1.30 - More emphasis should be placed on new working patterns associated with new technologies, with concomitant reductions in the need to commute to the current conurbation core.
Paragraphs 1.31 – 1.33 – We agree that infrastructure requirements have an impact on Spatial Strategy and vice versa. However, reducing the need to travel by virtue of an emphasis on mixed use communities and live/work opportunities will have a significant positive impact on reducing infrastructure needs, and this needs to be factored in.
Context
Paragraph 2.9 – Whilst we would not disagree with the key points here, it also needs to be considered that the Core Business Area suffers from excessive air pollution and this needs dealing with – possibly by de-centralisation and localised growth.
Paragraph 2.12 – It is important not to confuse “capacity” for airport growth with the “desirability” of airport growth. Air transport is a major source of air pollution and also a form of transport likely to decrease in use as high tech means of communication take over in the future.
Paragraphs 2.18, 2.19, 2.22 and 2.23 – The concept of Manchester aspiring to be a Global City is totally misplaced. It lacks the scale of Greater London and would be better placed in the “global economy” as a key element in the Northern Powerhouse, with all the dynamic variety and robustness which characterises it. Such grandiose language as used in these paragraphs undermines any attempt to project Manchester as a liveable city with its own character, as opposed to a city that would become prey to the vicissitudes of a global economy that comes and goes according to its own whims. Moreover, HS2 will only help to relegate Manchester to the position of a satellite of London.
Vision
The overall vision is to be applauded and supported. The methodology for achieving it and the detail hidden behind the terminology will be considered in the rest of the document.
Strategic Objectives
These are, of necessity, very general and we can support most of what is said. There are some matters of concern, mainly from the perspective of interpretation and impact upon Trafford Borough in particular:
Objective 2 – This all sounds very commendable, though we have concerns regarding the fact that the objective does not seem to have been applied fully in the case of the proposals for “New” Carrington?
Objective 4 – “Maximising” the potential of the assets identified would appear to conflict directly with the achievement of other objectives. Maybe the use of the word “optimising” would be better?
Objective 7 – The location and scale of “New” Carrington would appear to conflict with the objectives of promoting sustainable patterns of development that minimise the need to travel and contribute to cleaner air, and locating and designing development to reduce car dependency.
Strategy
Inclusive growth – Agree in principle, but the form of economic growth is significant. An unqualified pre-occupation with economic growth, per se, will not guarantee inclusive growth. The emphasis in this section, when taken with other indicators of growth elsewhere in the document, places too much reliance on undesirable growth (the scale of growth proposed at the Airport) or excessively risky ventures (HS2).
Key locations and assets - What should be considered key locations and assets will be dealt with in detail later, but for reasons already noted Manchester Airport and HS2 are, at best, questionable in this regard. The location of GM as a focus within the Northern Powerhouse is a key asset and needs to be stressed much more – not just in the context of rail links, important though these are.
Addressing Disparities – Agree that this is a vital element in the strategy, though this section says nothing about a strategy to deal with the issue.
Efficient use of land resources – Again fully agree, except with the last rider tucked away at the end about release of Green Belt, the need for which remains unproven. The key will be the reduction in land-take by roads by ensuring fully integrated communities where people can live and work without the need for public or private means of transport other than cycles.
Spatial Strategy – Whilst much of the basic analysis can be agreed, there is still an over-reliance on phraseology that considers all economic and employment growth to be good growth. More consideration needs to be given to the beneficiaries of such growth and ensuring that the beneficiaries are not based almost exclusively from outside of the Northern Powerhouse. There is currently overwhelming evidence that earlier global investments are now being removed from the UK, and such inward investment should not therefore be seen as a panacea for the ills of the North of England in general, or GM in particular. It is entirely probable that pinning hopes on Manchester Airport and HS2 will merely play into the hands of investors and others who will see these “assets” as an alternative way to get to London, bypassing those areas of GM that need appropriate growth and investment. Some of the statements on this matter in the GMSF appear as somewhat naïve.
Manchester is a great city but it is in danger of losing its heart and character if the scale and type of development proposed for the city centre actually materialises. Whilst increasing the resident population by way of high density housing makes sense in terms of creating a local city-centre community who could work locally, it could become swamped and congested if over-developed with the type of employment that requires additional commuting. This must be guarded against.
Port Salford is something of a worrying enigma. The analysis justifying the release of Green Belt land, which is also Grade One Agricultural land, for the expansion of Port Salford is confusing and deeply disturbing. Reference to Post-Panamax in the context of Port Salford is particularly confusing. Post-Panamax presumably simply means larger container vessels using the Port of Liverpool. These vessels will need to be off-loaded for trans-shipment of containers, as is the case with existing vessels. Once off-loaded, these containers could be moved anywhere by any form of appropriate transport. It is unclear why such containers should be trans-shipped to Port Salford for off-loading back onto other forms of transport when this could be done at Liverpool, and of course the same applies in reverse. Furthermore, it would appear that “a key strength of Port Salford is its location near to the junction of the M60, M62 and M602 motorways. It is likely that major enhancements to the motorway network around Port Salford will be required, both to support the scheme and address wider congestion issues”. This is sheer lunacy and we are unable to support Policy GM-Strat 4.
We are in general agreement with Policy GM-Strat 5, with the inclusion of an emphasis on the importance of education up to and including Further Education of a vocational nature to enable the inner-city population to access jobs in the emerging growth sectors of the economy.
We would support those policies that encourage and plan for appropriate forms of growth in the north of the conurbation in order to address issues of inequality, subject to minimising impacts on the road system and avoiding loss of Green Belt land. We do, however, have significant reservations about the proposed “Ryder Cup” standard golf course for Hulton. We do not see that yet another vanity project will be of any significant benefit to the population of GM in general, or the local communities in particular and, unless there is some connection to Donald Trump, we can see no logic in it. It should be borne in mind that the Ryder Cup is played in Europe once every 4 years, and that it is spread around a number of existing courses across Europe. The likelihood of this course being used for the Ryder Cup more than once in several decades is remote. There are almost certainly more desirable ways of using this land, which would be a better fit with other objectives of the GMSF.
For reasons already spelt out above, we are unable to support Policy GM-Strat 10. A doubling of the passenger usage at Manchester Airport would run completely counter to issues relating to air pollution, congestion, and the spread of appropriate development across the Northern Powerhouse. This together with the proposed HS2 station would simply focus development on a localised and highly congested, southward orientated part of the conurbation, and offer benefits primarily to London. It is also interesting to note that the publicity for Airport City does not mention HS2 and so it is to be assumed that HS2 is not necessary for the success of such a venture.
There is no clear justification for the assertion that “New” Carrington offers the only opportunity for the development of a new settlement of any size, or that there is a need for a new settlement as opposed to appropriate development of a number of other settlements within the conurbation that would benefit from such investment. Whilst we would support a degree of development here, to take advantage of the re-use of the brownfield land that is the old Shell Chemicals site, the lack of any significant existing public transport infrastructure and the consequent scale of new highway works needed, means that the development as proposed is unsustainable. Moreover, there is no justification for the release of Green Belt here, particularly given the quality of the agricultural land in the area; the significance of Mossland/farm lowland for carbon absorption and bio-diversity, and the potential for recreational and public access uses of this part of the Green Belt. We cannot support Policy GN-Strat 11.
We agree that the importance of the Green Infrastructure of GM should not be underestimated and we support policies to maximise the opportunities provided by this rich infrastructure. Unfortunately much of the GMSF does indeed underestimate its importance, and there is a need for joined-up thinking between this policy and other conflicting policies.
We support Policy GM-Strat 14, with the additional desire to see more emphasis on the creation of self-contained neighbourhoods and communities that reduce the need for travel by any form of transport other than walking and cycling.
Sustainable and Resilient GM
We are in general agreement with the Policies in this section, and welcome the emphasis placed on these issues, subject to certain reservations, including the following:
Paragraph 5.4 – The GMSF can, and indeed should, contribute to the overarching goal of sustainable development. Unfortunately, for reasons already mentioned above, and again below, the Strategy does not always reflect this, and the document should refrain from making vague generalisations that are not borne out in the detail if it wishes to be taken seriously.
Paragraph 5.8 – Again generalisations not always borne out in the detail. Fine words.
Policy GM-S 5 – This policy is welcome, and the value and significance of tree planting to the implementation of this policy needs to be clearly identified.
Clean Air – This is absolutely crucial for the health and wellbeing of the population of GM as a whole, but in particular those living close to the Airport and major roads. The production of a Clean Air Plan should be prioritised and the potential for putting the worst offending major roads in tunnel, with appropriate air filtration systems, should be explored fully. This would, of course also release land at ground level for other uses, including safe and convenient cycle and pedestrian infrastructure.
Waste – Again this policy is welcome. Perhaps efforts could be made to achieve a degree of commonality of policy with regard to the recycling provisions of domestic waste across the various districts, to achieve greater economies of scale and clearer understanding of the processes involved.
Prosperity
As a general response on this issue, it would appear to be heavily over-reliant on sweeping generalisation, largely unjustified rhetoric, and a blind faith in the discredited “trickle-down” theory.
Paragraph 6.1 – Economic Growth is not one universally accepted catch-all theory. The statement in this paragraph is therefore largely meaningless.
Paragraph 6.7 – This is a crucial paragraph. Despite all the supposed benefits and assets of GM, it has not proved possible to reduce inequalities on a number of economic indices. The gap between tax income and public expenditure is due to a wildly unequal tax system and a policy of austerity imposed by governments since 2010 that has crippled local government finance. These are the issues that urgently need addressing and yet they remain largely hidden behind excuses relating to a need to maximise growth.
Paragraph 6.10 – Following on from the above, the Northern Powerhouse Review is closer to getting to grips with key issues than the GMSF when it identifies the need for “improvements in skills, innovation, and connectivity”. GM must integrate with this, rather than plough on with its pre-occupation with creating a global super-city out of unfocussed economic growth. An emphasis on education at school and vocational levels is needed to supplement the university sector, together with focussing resources on the inter-connectivity of transport between northern cities and the range of assets available through co-operation across the region.
Paragraph 6.11 – “Growth today must not come at the expense of the ability to deliver sustained prosperity and quality of life”. Exactly! This is why the type, nature and location of growth must be fully considered and why a fairer tax system is needed to underpin this. GMSF cannot ignore these issues and expect to be successful in its ambitions.
Paragraph 6.19 – The ridiculous GPDO provisions that allow free conversion from offices to sub-standard housing must be dealt with before the statements in this paragraph can hope to be implemented. Does this paragraph imply use of Article 4 Directions?
Paragraphs 6.21, 6.30 and 6.33 – The justifications for release of Green Belt land in these paragraphs are weak, vague and unsupportable.
Homes
Paragraph 7.1 – A “huge growth in high-density apartments in the City Centre and The Quays, drawing in people and investment from across the world”. A disappointing scene-setter. Yet again, no attempt to consider the quality or suitability of the investment drawn in. It would appear from latest figures that much of this investment is merely driving up prices and producing profits for foreign companies and individuals.
Paragraphs 7,2 and 7.3 - Agree
Paragraph 7.14 – This is indeed a key point, It should be stressed that the most important issue is to get the current population of GM adequately housed, and not to use the relatively affordability of GM housing to attract additional inward migration from more expensive locations, pushing up prices. This is, of course, exactly what HS2 would do!
Paragraph 7.17 – Very important. A key issue that is not addressed is the need to reduce land costs and land values which are inflating house prices. The principle of Land Value Taxation must be adopted and this requires GM to lobby for its introduction. This same issue applies to paragraph 7.26.
Paragraph 7.21 – What is needed is an even higher proportion of high-quality affordable housing, not more high-value housing. There would appear to be no evidence that there is a lack of “luxury/executive” housing in GM given the preoccupation with the marketing of such properties. The corollary of Affordable Housing is Non-affordable housing. All housing needs to be affordable and high-value housing is unnecessary and unacceptable in the current climate.
Paragraph 7.27 – Agree. Increasing densities can mean no need to release Green Belt land at all.
Policy GM-H 4 – Justification 1 for lower densities is not an acceptable justification. There can be no demonstrable need as such for lower density housing and, in any case, it is necessary to plan what is most desirable across the conurbation and the whole range of objectives.
Paragraph 7.31 – Agree that there is a need to reduce vacancy levels. There is however, no evidence to indicate at what point further reductions could hinder people moving home. This needs further research and monitoring, rather than unsupported assumptions.
Greener GM
Policy GM-G 1 – Agree, though this needs to be followed through more overtly in the implementation of other policies
Policy GM-G 2 – Agree. We would urge the protection, enhancement and creation of Wildlife Corridors as part of this Policy.
Policy GM-G 3 – Agree. We support in particular the intention to adopt catchment-wide flood control measures.
Paragraph 8.27 – Some concern here that there is an acknowledgement that there could be justification for development of undeveloped Mossland. Undeveloped Mossland must be protected at all costs as it is of value as a carbon sink, as well as for its biodiversity and health and wellbeing benefits.
Policies GM-G 5-7 – Agree
Policy GM-G 8 – From the perspective of Trafford Borough, it is important to note the inclusion of the Mersey Valley and Carrington as Green Infrastructure Opportunity Areas. “New” Carrington is affected by both of these areas and proposals relating to “New” Carrington would appear to conflict with this Policy. They should therefore be revisited accordingly. It is also relevant here to note that Carrington is shown as a Nature Improvement Area on Fig 8.5.
Paragraph 8.53 – We have major objections to the unqualified and un-evidenced final sentence in this paragraph. The vital importance of protecting soil resources on a number of different levels is made clear, but then the potential release of such valuable land is made possible by a slight of hand when there is no evidence that release of other less productive and valuable land would not, in fact, be possible. This has a negative impact on the credibility of the GMSF with regard to issues relating to climate change, food production, bio-diversity, recreation, health and wellbeing and other equally important benefits. Grades 1 and 2 agricultural land must be kept free from development at all costs, especially when there are other benefits offered by the same most versatile land.
Green Belt
As previously stated, we have fundamental objections to the removal of Green Belt allocation from any land in GM, on the grounds that the need for such a policy is not justified. Increased development density, together with use of other land could nullify this requirement. In the event that a decision is made to release Green Belt land – a decision we would not support – then there must be an equivalent amount of land replaced in order to preserve the functions and purposes of Green Belt in GM.
Moreover, the unreliability of population and housing need forecasts beyond a ten year period points to a situation where release of Green Belt land is clearly not proven, since a ten year provision could be accommodated without such release.
Inclusion
Agree with basic principles of inclusion.
Paragraph 9.4 – Education needs to be prioritised at all levels and not just the higher university and research levels.
Paragraphs 9.8 and 9.9 – Agree. We should aim for developers to produce Community Assessment reports to accompany Design and Environmental Statements. (Maybe within Policy GM-E 1?)
Paragraph 9.13 – This is significant. The GMSF does not appear innovative in the context of the heritage of GM. It appears to be embracing past and present economic trends in a hope for old-style growth, rather than showing vision for the necessary changes to enable meaningful progress towards a new emerging economy for the whole GM community.
Policy GM-E 4 – We are pleased that education and training is given a high profile. The balance identified in section 1 across all education sectors is particularly welcomed. There remains, however, too much emphasis on the university sector. Whilst this is undoubtedly important, top highly skilled jobs are, of course, fewer in number than highly skilled “shop floor” type jobs, and the role of further education in preparing the workforce for such jobs in the emerging industries is equally important.
Policy GM-E 5 – Agree. There is also a need for specific reference to the relevance and importance of clean air to the health of the community of GM.
Policy GM-E 6 – Agree. Paragraph 9.34 emphasises the importance of Carrington Moss to the health and wellbeing of the local and wider community, and the danger of over-development of this area.
Connectivity
The most important elements of connectivity have to be accessibility of local services and jobs to local people, followed by connectivity to the rest of the Northern Powerhouse. The out of date and short-sighted model that emphasises an unacceptable growth of the Airport and the unreliability of HS2 should be re-considered in its entirety. The current perspective must change. Once again we stress that the proposed expansion of the Airport runs counter to all objectives relating to air-pollution, climate change and congestion, while the case for HS2 is completely unproven. All supposed benefits of HS2 must be re-considered in the light of cost over-runs, proposed reductions in speed and regularity, damage to the environment, and the likelihood of GM becoming merely a satellite of London.
Paragraph 10.11 – A large part of the reduction in in-bound car trips to the City Centre is due to the reduction in accessibility of the City Centre by car due to road closures and constraints, improvements to the cycle system, and improved priority to public transport. These policies should be rolled out across the other main centres and towns of the conurbation. On this basis, we fully support the sentiments set out in Paragraphs 10.16 – 10.18, along with those improvements to digital infrastructure that have the potential to reduce the overall need to travel, as outlined in Paragraph 10.22.
Policy GM-C 3 – We support this Policy, but wish to stress that merely improving cycle and pedestrian networks alongside heavily polluting roads will have little positive impact on either enhancing the desirability of such modes of travel, or on the health and welfare of cyclists and pedestrians. More needs to be done to decrease in absolute terms the number of car journeys made, and to plan for those older residents who will not be able to walk or cycle long distances but will need safe, clean and convenient local routes to access local goods and services. Consideration should be given to putting existing main roads in tunnel, with appropriate air filtering systems, leaving ground level to local traffic (mainly cycles and walking).
Paragraph 10.33 – We continue our opposition to HS2 and large scale Airport expansion.
Paragraph 10.36 – This could be paid for out of the rapidly expanding HS2 budget, if this vanity project were to be cancelled and the monies re-allocated.
Policy GM-C 4 – Northern Powerhouse interconnectivity we support. HS2 is a complete waste of public money and an environmental disaster in the making. We fundamentally object to this.
Policy GM-C 5 – On the basis that there is likely to be a significant (though hopefully continually reducing) number of car journeys for the foreseeable future, the role of GM as a pioneer of electric charging networks should be stressed as an immediate priority - to encourage a significant switch to electric cars at the earliest opportunity.
Policy GM-C 6 – The potential for putting the most polluting sections of main roads into tunnel should be fully explored as a means of reducing air pollution along their route and, in particular, at the most congested junctions. This would improve air quality, allow for safer and more convenient cycle and pedestrian networks, improve the efficiency of buses on the remaining quieter and smaller local roads, provide more land at ground level for appropriate development, and offer potential for the rolling out of provision of heat networks in multi-use and multi-purpose tunnels.
Paragraph 10.53 – Improving the connectivity between the existing freight terminal at Trafford Park and the Port of Liverpool would reduce the need for expansion of Port Salford. There is no logic or rationale for the scale of the proposed expansion at Port Salford, which relies on wholly undesirable new works on the nearby motorway network, release of Green Belt land, and loss of Grade 1 Agricultural Land. Transhipment of containers twice (once at the Port of Liverpool, and again at Port Salford) makes no sense whatsoever. A smaller scale Port Salford would clearly be adequate.
Policy GM-C 8 - We support this policy and would like to see formal acceptance of a “20’s Plenty” speed limit policy across all local, and especially residential, roads in the conurbation, such that it becomes an acknowledged norm and is built-in to the psyche of all drivers in all districts. This would result in health benefits, particularly with regard to reduced accidents, along with potential for greater overall pedestrian and cycle safety and convenience, and other community benefits.
Allocations
Since we are not fully aware of the specific local considerations of all of these sites, we will concentrate simply on those sites located within Trafford Borough, although general significant concerns regarding certain allocations – eg Port Salford – have already been made.
However, as a general introduction we are concerned about the implication in Paragraph 11.8 that there is a shortage of high value homes. There is a shortage only of homes that can be realistically afforded by local people. There is considerable evidence that marketing of homes in GM has for some time been concentrated on “luxury, executive” homes and this has one of the reasons why housing has become an investment market rather than a means of enhancing local communities. There should be no more “high-value” homes until the need for affordable homes has been met. There is no evidence that more high-value homes will benefit the economy of GM, or that people seeking such homes will bring any sustainable benefit to the region.
There are two allocations in Trafford, both of which require the release of large amounts of Green Belt land (despite the fact that Trafford has relatively little such land) and both of which are premised upon highly questionable assumptions.
New Carrington
Given the confusion over government statistics and housing need calculations, not to mention the implications of Brexit (Deal/No deal – Brexit/No-Brexit), the basic and fundamental assumptions that there is firstly a need for the scale of development proposed and, secondly, that this site is, in any case, the only one capable of accommodating such growth across GM, must be seriously questioned and re-assessed. Whilst we broadly support the re-use of the brownfield site opportunity offered in the area, and the potential for limited development to support the sustainability of the existing settlements of Partington and Carrington, the scale of development proposed is unacceptable for a number of reasons, including:
These are just some of our fundamental concerns, but they are, in themselves, sufficiently important that this whole proposal should be revisited, in conjunction with the local communities, to assess the realistic scope for development in the area.
As an addendum, we note a somewhat inexplicable reference to HS2 here (point 24) - other than the fact that maybe it hasn’t been mentioned for a few paragraphs? –, although we do also note that there is an acceptance here that it would have undesirable noise implications.
Timperley Wedge
Given the dependence of most of this proposal on the delivery of an HS2 station, we object in the strongest terms to this proposal. HS2 has not yet been formally adopted and it is becoming increasingly clear that there is every chance that it will not materialise for good and valid reasons, including public opinion, increased costs, likely reductions in speed and frequency nullifying supposed benefits, negative impacts on land and the environment, and unproven benefits to the North. As a result, whilst there may be scope for some development in the vicinity of the Timperley, the scale of development as proposed is inappropriate for a number of further reasons, including:
Specific to the HS2 proposals:
Delivery
Paragraphs 12.1 and 12.2 – These demonstrate very clearly the fundamental weaknesses of this Strategy.
Firstly, the whole strategy is based upon an outmoded and largely discredited theory of economic growth that is short-sighted. Moreover, it fails to give due consideration to the fact that local authorities are increasingly adopting policies to plan for mitigation of Climate Change issues, and yet the GMSF fails to get to grips with this in any meaningful way whatsoever. Most of its grandiose rhetoric runs counter to measures that would actually help the conurbation to play its part in dealing with climate change, and to take advantage of the economic, social and environmental benefits that would accrue from a whole-hearted pursuit of the new industries and alternative growth models that accommodate trends towards environmental sustainability.
Secondly, the delivery of the GMSF is, of its own admission, reliant on other plans and strategies for its implementation. There are good words about the historical ability of GM to meet challenges, but the challenges resulting from this poorly conceived strategy require a different, forward looking approach, rather than a reliance on the good old days. This is particularly the case given that there is little evidence that the government will significantly relax the stranglehold of austerity on local authorities and other public bodies, (who have already been victims of ideological privatisation), or of acknowledging the wastage associated with the spending of public resources on vanity projects such as HS2.
Thirdly, the fact that Greater Manchester does not correspond to a level of government responsible for implementing an overall strategy is a major weakness. It is all very well claiming that the devolution of some limited responsibilities gives GM some control, but this ignores the fact that it only has control over seriously under-resourced services. The GMSF can only work through the full support of the people of GM (largely through democratically elected representatives) alongside other Local Authorities within the Northern Powerhouse. This is where the emphasis must lie, and not in some vain hope of turning Greater Manchester into a global powerhouse to the exclusion of neighbouring areas.
Paragraph 12.12 – Financial issues are paramount. We agree that there is a desperate need for Social Infrastructure across the conurbation. Unfortunately, the purse strings for education and health are held by central government, which has over many years begun a privatisation process in both areas that has wasted public money in order to boost private profit. GMSF needs to acknowledge the realities of the situation and use whatever limited powers it has to lobby and pressurise for additional resources, not just for GM but also for the wider Northern Powerhouse. GMSF needs to be more creative and more pro-active with communities to overcome the financial hurdles created by central government. Currently it is failing even to attempt consideration of such measures.
Paragraph 12.13 – We welcome the commitment to include natural capital accounting. Such an approach has been advocated across a wide range of organisations for many decades. There are mechanisms for valuing natural capital and these need to be used across the GMSF. Appropriate use of such an accounting system, incorporating the true value of natural capital, would show that such proposals as New Carrington, amongst others, are poorly conceived and poor value for money in the long-term.
Paragraph 12.17 – We agree that “developments will need to deliver, or help to enable the delivery of, infrastructure required to support sustainable communities” through funding mechanisms, but only on the proviso that such mechanisms can be used in a way that prevents increased development costs being passed on in the form of increased prices, which would merely be counter-productive.
Paragraph 12.20 – Interesting but effectively says nothing. Is there an action point missing?
Paragraph 12.22 – Monitoring is vital. Who is going to do it and who is going to pay for it?
Appendix A
There would be only a very small addition of Green Belt in Trafford despite a massive loss of Green Belt land and a relatively small amount to start with. This is unacceptable.
Conclusions
The GMSF misses an opportunity to tune in to modern alternative growth patterns that do not rely on purely economic measures, such as GVA. Greater Manchester does indeed have a superb heritage in research and innovation, but to subsume this within an outmoded attempt to turn GM into a supposed global city is misguided. If the population of Greater Manchester is to benefit from its assets, the various communities that make up GM must be engaged in the development of the Strategy. So far all that has happened is that those communities have been presented with rhetoric designed to give a false impression that the way to make GM great is to embrace globalisation.
GM, despite its size and assets, is considerably smaller than London and other global cities. If the conurbation is to prosper in a way that benefits its existing residents rather than multi-national companies, the concept of the Northern Powerhouse must be harnessed to create an effective counter magnet to London. Only in this way can the vital non-economic assets of the North, including GM, be fully protected and enhanced for the benefit of the communities of the North The quality of life of the population of the Northern Powerhouse communities cannot be measured in terms of GVA.
Insofar as the Strategy makes mention of the introduction of natural asset accounting; prioritisation of Green Space infrastructure; mitigation of negative climate change factors; emphasis on reduction of car journeys; improvements to the public transport, cycling and walking infrastructure; support for inclusive and sustainable communities; and zero-carbon initiatives, we can support these principles of GMSF.
However, many of the objectives and policies of the GMSF appear to run counter to these principles when analysed in detail, and it would appear that the emphasis on the out-moded growth theories of the past would threaten the positive forward-looking principles of sustainability. In particular, the following issues, amongst many, are of concern and need to be addressed:
In the light of the above, our support for this document is significantly limited and can only be of a very qualified nature. We continue to have major objections to certain aspects, as outlined above.
J D Westbrook (on behalf of Trafford Green Party)
