22 February 2018
INTRODUCTION AND SUMMARY OF FINDINGS
In order to avoid any potential misunderstanding, we begin these comments with a statement that we find the UA92 proposals, and the consequent attempt by the Council to refresh the Masterplan that was adopted only 3 years ago, unacceptable in both detail and process. Whilst the principle of a University Academy (not a University) may potentially have some benefit to Stretford if planned correctly, the draft Refreshed Masterplan (RM) and the supporting documents are full of inconsistencies, generalisations and unsupported analysis. In addition, the process of consultation has been carried out in a manner and to a timeframe that renders any results untrustworthy and incapable of useful purpose.
We will use these comments to point out the failings of the proposals and the process as well as attempting to find some way of moving the UA92 proposals forward in a way that could possibly be seen as sensible and realistic. We put these comments and suggestions forward in good faith, but would call upon the Council to extend the period of consultation to take into account the very significant information that has only come to light since the process began, and which was not available to many people at the time they made their responses through the survey questionnaire.
COMMENTS ON THE PROCESS OF CONSULTATION
We find the process of consultation to have been totally unsatisfactory for the following reasons.
Firstly, the survey forms and information sheets were presented to the public with sweeping generalisations and the highly emotive title of “once in a generation” which clearly gives the impression that any objection is anti-progress. Much of the most important information only became available as the process of consultation took place, rendering any responses from the public unreliable. We believe many people would answer the survey differently now in the light of certain facts that have only recently come to light. It is not good enough for the Council to plead confidentiality or prematurity. If vitally important information could not be made available at the time the consultation began then the consultation should have been delayed. This is why we call upon the Council to disregard the survey forms already submitted and begin the survey again in the light of up to date information.
Secondly, the manner of consultation was unfit for purpose. A number of meetings were held where tickets basically could only be obtained over the internet. This clearly excludes many members of the community. The meetings themselves were chaotic in that, for the most part, those who attended were put into small groups with members of the Council staff in attendance at each table. For no apparent fault of their own, the council staff often proved unable to give answers to questions either because such information was not known to them, or because of “confidentiality” or “prematurity”. Moreover, different people at different tables were clearly given differing interpretations of the situation and, in some cases different information altogether. There was no attempt to bring threads of information together in a plenary, so most people left very little the wiser as to the facts behind the proposals or what other groups had learnt. This is the philosophy of divide and rule at its worst and most inappropriate.
Thirdly, there has been no sight of any records of what was said at the discussions. FAQs have been published with stock answers, but it is clear that many significant questions that were asked have not been addressed – either because the recording process was faulty, or because certain questions could not or would not be answered. We have no way of knowing, although we do know that many important questions remain unanswered and the process of consultation was therefore faulty. Plenary sessions are vital to ensure that key questions are answered by staff who have access to the facts, and so that all attendees have access to the same information.
COMMENTS ON THE UA92 AND RELATED PROPOSALS
Firstly, we do not see any necessity for the RM. The original Masterplan was adopted only three years ago, and Stretford needs a period of time and stability to enable the basis of the plan to be worked out. To change it after such a short interval is inappropriate, particularly given the limited information available. The UA92 Campus is 1.5 miles away from the Town Centre and has no physical relationship to it. It is questionable, also, as to whether there is any functional relationship between the two, in which case, it would make more sense to wait for a planning application to be submitted, with all necessary information finally available, and then deal with it under normal planning regulations and consultation. Similarly, there would now seem to be very limited, if any, formal relationship between the UA92 Campus proposals and any developments at Turn Moss which is, in any case, completely unacceptable on Green Belt grounds.
For these reasons, we believe that the correct course of action should be to keep the existing Masterplan, with minor adjoining extensions in the area to the south if deemed necessary, and to assess the UA92 proposals as an independent planning application, when all details are available. There is nothing to stop the student accommodation being similarly independently assessed, though we will argue later that the Lacy Street site is completely wrong for such a development.
We consider the use of the phrase “once in a generation” opportunity as somewhat disingenuous, since it implies that all aspects of the proposals, including the UA92 campus and the student accommodation, must be accepted as suggested by the Council, or a last chance for regeneration of Stretford will be lost. This is clearly not the case, since there are several alternative ways that UA92 could be incorporated into the fabric of Stretford without jeopardising the basic idea. As stated above we believe that the UA could possibly have some benefit to Stretford, but not in the form proposed, and not under the apparent tactic of fear engendered by the terminology of the consultation documents amid the unacceptable haste of producing the new Masterplan. It is better to get the proposals right than to rush into a badly thought out scheme.
We have serious reservations about many of the conclusions of the Economic Impact Assessment Report (EIA) produced for the Council, and also with some aspects of the evidence base used. Owing to the time constraints of commenting on the main proposals subsequent to the consultation process, we do not have time to make detailed comments on this, but would point to a random sample of matters which indicate our concerns.
In view of these matters, and other concerns about the EIA document (which we can discuss if required), we contend that it should be revised to incorporate new evidence, new information, and alternative scenarios
The philosophy behind the UA92 proposals would appear, on the face of it, to be honourable, though the title tends to give the impression that the cult of personality takes precedence – no mention of Stretford there, which gives cause for concern about a possible lack of interest in the location on the part of the developers?
Whilst the proposal apparently has the academic backing of Lancaster University, the University is 50 miles away and the degree of support and commitment from the University could be questioned on this basis. There is no indication so far as we can see of any significant financial contribution from Lancaster, and we have not had sight of any assessment or business plan from the University to indicate that the suitability of the building and campus, along with the likelihood of achieving the student numbers claimed, would in practice match aspirations. Indeed, it would appear that UA92 would be heavily dependent upon the use of Council facilities for its success and this does not bode well for its viability.
Furthermore, we have no indication as to whether any viability assessments that may have been carried out, have included the impact of competition from UCFB, which is based at the Etihad Stadium, or plans by MMU to move some sports related courses to East Manchester. UCFB, in particular, provides degree courses that almost mirror those proposed for UA92. The courses are validated by Bucks New University and are already up and running. They have already been through a QAA procedure and received a good report. Students at UCFB have access to the facilities at the Etihad Stadium, which is a major attraction. All that UA92 can offer at present is nominal, but no practical, support from Manchester United and LCCC. We do not feel that this matches the draw of UCFB and is another reason why we are concerned about the likely success of UA92 in the absence of much more detailed information.
We would be interested to know what advice the Council took before committing to purchase the Kelloggs site, and whether any such advice provided a range of alternative development scenarios to ensure a reasonable chance that if the UA92 proposal did not come to fruition, a suitable alternative could be found. To base a major investment of public money in one clearly risky scheme is worrying for the residents of Trafford, and is another reason for waiting for more reassuring information before amending the existing Masterplan.
In this and later paragraphs we will refer to the Council’s Core Strategy (CS) and, where appropriate, the Composite Policies Map (CPM), as the only formally adopted planning documents relevant to the current development proposals. The Spatial Profile for Old Trafford in the CS notes that “part of the area is ranked among the 10% most deprived areas in the country and as a result is one of the Council’s Priority Regeneration Areas; additionally the Gorse Hill Regeneration Area is within this Place”. We believe that a properly thought out and comprehensive UA92 Campus at Old Trafford could have the potential to assist in the regeneration of Gorse Hill, but only if it is given the maximum chance of success as a fully functioning Campus. For this reason we contend that the suggestions for offices, a hotel and private residential apartments are wholly unsuitable for this location. Bearing in mind the non-availability of the resources at Lancaster to students in Stretford, the Campus needs substantial student accommodation, a learning resource centre, recreational facilities, some limited retail opportunities, and a students’ union type of facility, on site. Only on this basis could the proposal hope to fulfil its potential and, presumably, meet the academic and other requirements of Lancaster University. There is the potential on this site for a high density of development related directly to the UA92 function as an educational organisation.
The CS notes that the LCCC Quarter is a strategic location and that such locations will be programmed for delivery through a further Development Plan Document (DPD). To the best of our knowledge, the Stretford Masterplan is not a DPD and does not feature in the Council’s Local Development Scheme. For this reason we conclude that to extend the Stretford Masterplan area artificially to include the UA92 Campus is inappropriate, and that a separate DPD to cover the overall strategy for the LCCC Quarter, including the possibility of a university campus, should be produced instead – as is required by the adopted CS.
We note that there is no alternative scenario considered for the Campus site and that the obvious potential for the site in a different set of uses cannot therefore be compared. This is worrying, in that the Council now apparently owns the Kelloggs HQ site and could therefore adopt any number of alternative schemes with a range of outcomes – social, economic and environmental. For the benefit of this exercise, we will assume that the refurbishment of the HQ building for academic use forms the centrepiece of any redevelopment of the site – even accepting that such a change of use has not yet been granted planning permission.
The word Campus is defined as meaning “the grounds and buildings of a university or college” (OED). The draft proposals, as shown on the preliminary sketches, do not amount to a Campus but merely to an academic building in the centre of a plot with no other academic buildings. We would be surprised if Lancaster University accepted this arrangement. There is no justification for a commercial hotel or a development of private residential apartments on a University Campus.
We can see the potential link up of the main building with a new, larger and better equipped leisure centre, though we would need to see concrete evidence that the UA92 developers will be putting financial support into the new centre to reflect the benefit that students would get, and to ensure the provision of a significantly improved facility over that provided by the current leisure centre. We would point out that the Council has announced intentions to significantly increase recreational activity across the borough. We would also point out that there is an expectation that George Carnall Centre in Urmston will close shortly, and that the Council intends that the new facility will attract clients from private commercial gyms. On this basis, the new proposed leisure centre must be capable of accommodating the existing demand, plus the general increased activity anticipated in Council policy, plus overspill demand from George Carnall Centre, plus new clients attracted from private gyms, plus the demand from over 6000 students who will use the facility as a university sport and leisure facility. If this cannot be agreed and secured, then we cannot support the proposal. If there is a certainty that such a facility would be provided, and that local residents would not find themselves competing for inadequate services, then we consider there is a basis for support in principle.
In the case of the above scenario, the main university building would exist alongside a council-run facility on one side. On another side there are proposed office buildings. We have no information as to the scale of these buildings or the amount needed to cater for UA92 administration and management. We do know from the Economic Impact Assessment produced for the Council that there are high vacancy rates in office buildings nearby. There should, therefore, be no commercial office element within this proposal – and indeed such development would not fit in with the concept of a university campus.
There is no case whatsoever for the proposed hotel and private residential apartments, which would complete the surrounding development. Their inclusion would leave the UA92 building, together with any essential offices, as the only evidence of an academic campus. This makes absolutely no sense, and would be harmful to the status of the university proposal, minimising its presence and providing a totally unsatisfactory environment for learning.
In view of the location of the site, we would propose a high-density development of student accommodation in place of the private apartments and hotel, with more use made of the car park by including not only the playing pitches shown, but also other student facilities such as a learning resource centre and students’ union type use. There would also be scope for limited retail. The site is bounded by a large cricket ground to the south, a large office block to the north, and a tramline to the east. There are tall office blocks across Talbot Road, and such a development as proposed above would benefit the university and fit the context of the locality. There is a large tram depot across the line and the only housing in any proximity is separated from the site by the tram line, and lies to the south-east so it would not be affected by any loss of sunlight or daylight from a high-density development in this location.
We contend that this alternative development proposal would generate as many, if not more, construction jobs than that currently proposed, whilst the input of students would result in local spending and employment generation. This would assist in the regeneration of Gorse Hill, in line with CS strategy, whilst not directly pressurising the local community, which is separated from the site by a large commercial, sporting and administrative area.
Finally, in the light of information provided in the Economic Impact Assessment regarding vacancy and occupation rates in nearby office blocks, we believe that there is potential created by this sub-optimal occupation figures for the adaptation and/or conversion of some of these blocks, or parts of them, for the hotel and residential units proposed for the UA92 campus. Residential conversions are already taking place in this location, and there are many precedents for the mixed use of large buildings for hotel/office/residential purposes.
It is with the proposals for Lacy Street, in conjunction with the strategy for theTown Centre as a whole, that we have the strongest objections. Rather than a “once in a generation” chance to regenerate the Town Centre, we find the proposals to be a “bad fit” development, with significant failings and a missed opportunity for other “once in a generation” opportunities that we consider far superior with regard to the living, working and recreational lives of Stretford residents. These alternatives, which we consider would offer benefits way above those of the illogical and grossly over-scaled proposals relating to the student accommodation, will be outlined below after we explain our serious concerns for the current scheme before us.
The Spatial Profile for Stretford in the CS notes that “The Bridgewater Canal runs north-south through the area and offers potential to improve opportunities for recreation and wildlife”. Indeed this theme relating to the utmost significance of the Bridgewater Canal runs throughout the CS and applies to many areas. The failure to take the opportunity to make the most of the Bridgewater Canal in establishing a sense of place for Stretford and realising the potential that it offers is, we believe, one of the greatest weaknesses of the draft refreshed Masterplan. The Profile goes on to state that “there is a need to provide more facilities for young people in order to maintain and enhance cohesive communities”. This process has begun with the developments at the Public Hall, and could be continued with imaginative proposals for the Essoldo. Such developments can and would reinforce community cohesion, in a way that the imposition of a massive influx of students, who by their very nature are largely transient, cannot.
The key issues facing Stretford are correctly given as including the maintenance of a vibrant shopping centre and maximising opportunities for recreation, including the potential offered by Longford Park and the Bridgewater Canal. The Longford Park issue will be dealt with in detail later, but for both of these areas the refreshed Masterplan proposals would fail abjectly to realise their potential and would, in the case of the Canal especially, be damaging to that realisation for generations to come. The opportunity to make the Bridgewater Canal a focal point for Stretford is a true “once in a generation” chance that we must take.
We further note, from the Place Objectives in the CS, that the current proposals would fail completely to meet Objective STO1 which is “To establish a better balance in housing types and tenure to meet people’s needs in the area”. As will be discussed below, we believe that the use of the Lacy Street site for a mix of private and social housing, including a substantial amount of affordable housing, and using the opportunities outlined by the Prime Minister in November this year1, would represent a better use of the site, and one that would have a more significant impact on the vitality and viability of the shopping centre, than the use of the site for student accommodation. Moreover we note the fact that Trafford Council cannot demonstrate a 5 year supply of housing, and the development of Lacy Street for such a purpose, especially given that the Council has complete control over the car park site, would be a great opportunity to move towards the 5 year supply needed. Once again we have not been presented with any alternative scenarios for the development of the site, which is council-owned and which brings in no income as a free car park and which, therefore, must have a range of development options open.
We believe that the current proposals for Lacy Street fail to meet any of the other Place Objectives for Stretford, and we call for the Council to investigate thoroughly alternative options that would prove a better fit against the Objectives of the adopted Development Plan.
First and foremost, we believe the concept of student accommodation on the Lacy Street site to be totally misguided. We also note that the use of the term “Student Campus” is inaccurate and serves only to highlight an attempt to create a somewhat spurious linkage with the Kelloggs site, which we have discussed above. As a point of clarification, we reiterate that the word Campus is defined as meaning “the grounds and buildings of a university or college”. The proposals at Lacy Street have nothing to do with any Campus as such, but are merely a scheme for the imposition of a massive and inappropriate development for a single user group that has no relationship with the Town Centre as a focus for the local community.
While we have no issues with student accommodation per se, this is the wrong proposal in the wrong place. We have noted the justification put forward for the proposal, but we have found a number of errors and inaccuracies in the analysis which we have alluded to earlier. Suffice it to say here, that we are convinced that a viable scheme more in keeping with the regeneration of the Town Centre as a local community hub would be possible and desirable.
In particular, the density of development is excessive and the sketch proposals indicate that the opportunity to open out the Bridgewater Canal to local Stretford residents would be lost for ever. The illustrative plan on the consultation brochure gives a false picture, in that it fails to show that planning permissions have been given for blocks of flats on the Boatyard site and the Royal Canal Works, such that there will not be an open green area on the opposite bank of the Canal. Furthermore, residential development is proposed for land behind the Essoldo. All this would mean that any development close to the towpath of the Canal at Lacy Street, as is proposed, would take up the last chance to create a genuine community open space beside the Canal for the recreation of local people. Such a space exists at Sale Waterside with seating and open space behind the towpath, and including places to eat and drink and an Arts Centre.
If the Policies relating to the Bridgewater Canal in the CS are to be adhered to, and if the Council still believes in those Policies that it only relatively recently adopted, then the basic concept of the proposals for Lacy Street must be drastically altered in favour of development geared to the direct needs of the local community – which currently are affordable housing and a meaningful open space that utilises the attraction of the Canal. As an addendum to this, such active use of space beside the Canal could result in a Water Taxi stop in Stretford, which would be both an attraction and a useful off-road transport facility.
We believe that the majority of student accommodation should be placed on the UA92 Campus, but that some smaller pockets of such accommodation could be located around other parts of the area such that the students could be better integrated into the community, rather than overwhelming one small part of it. As an example, if, as is suggested, there is scope for Arndale house to be converted to residential or other uses, then there must by definition be potential for its conversion to student accommodation – possibly even along with some new accommodation on the site of the demolished segment of the Mall. This would bring students, in a sensible number, into the centre of Stretford, where they would still be attracted to use the Mall in addition to the permanent local community residents from the Lacy Street development.
Furthermore, we are concerned that by emphasising student accommodation on this site the Council may be jeopardising potential New Homes Bonus monies as well as being unable to collect Community Infrastructure Levy (CIL) money and future Council Tax payments. In addition, there is scope for the Council here to support housing development that could be created using the Community Land Trust Model – an innovative way of encouraging local community involvement in the development of affordable housing. We contend that the scheme for student accommodation on the Lacy Street site will represent very poor value for money and a wasted opportunity to create a truly sustainable local community in close proximity to the Mall.
With regard to the Essoldo building, we note that this is a Listed Building which must be developed carefully. It is an iconic building, as is the Public Hall opposite and should be used first and foremost for community type uses. Subject to full surveys on the likely impact of certain uses, we would suggest as possible uses a food/drink/market area along the lines of that in Altrincham, possibly with an Art Cinema/theatre and/or young peoples’ uses such as a roller rink, and/or craft market/workspaces. At all times we would suggest that any potential competition with the uses and activities at the Public Hall should be avoided. We contend that the proper place for UA92 student facilities is on the Old Trafford Campus and should not be located in the Essoldo.
We believe that the greatest problem facing the Town Centre is the separation of the Mall from much of Stretford by two major roads – one the A56, which is a six-lane dual carriageway, and the other being Kingsway, which is a four-lane dual carriageway. In this regard we believe that the second paragraph on page 4 of the “refreshed” Masterplan very clearly and accurately sums up the fundamental problem facing the Mall and the Town Centre in general. The decline in the fortunes of the Mall can indeed be traced to the widening of the A56 to six lanes, and successive Councils have done little or nothing to deal with this situation.
The only effective solution to the problems being experienced by the Mall would be the redesign of Kingsway and the tunnelling of the A56 between the M60 and the Bridgewater Canal. We are convinced that a full cost-benefit analysis of such a proposal would produce a positive result in favour of the investment. This is dealt with in more detail below, but we believe that linking a tunnel project with the concept of and financial support from the Northern Powerhouse would be in the interests not only of Stretford residents and the wider North Trafford Community, but also car users who simply travel through the town and currently add to the pollution experienced along the Town Centre part of its length. It would prove to be good value for money, and would effectively enable the two sides of Stretford to be more closely and safely linked together.
In terms of environmental and public realm matters, we will deal with this below in the section which concentrates on “corridors” and accessibility.
Innovation Corridor
We find it difficult to know where to start when commenting on the frankly ridiculous and irrational belief that there is an innovation corridor in Stretford, or that such a corridor would be created by the UA92 proposals. As things stand, there are two main elements of the UA92 proposals – the University Campus and the student accommodation. There is nothing in the way of a related development in between the two. They are 1.5 miles apart. There is only one potential development site between the two – the Iltron site – and its development will be completely independent of and unrelated to the existence or otherwise of the University. This is not a “corridor” and never could be.
Certainly there are roads between the two elements. One is the A56, which is heavily polluted and intensely trafficked. It will never be fully safe for cyclists regardless of any introduction of cycle lanes, nor will walking down it alongside heavily polluting vehicles become attractive. There is no room for effective tree planting, other than trees that are already there. The other road is Talbot Road, which is less busy, but has no development along it that has or would have any relationship to the University until LCCC is reached – and it unclear whether there will be any relationship even here, since all we know is that the LCCC “support” the proposal.
The “Green” route between the Town Centre and Turn Moss, is a busy road that is already tree-lined with beautiful mature trees. There are already cycle lanes (that are usually parked over by cars). The concept of a Green route here is a fantasy that can only have been designed to make the walk from the proposed student accommodation, to Turn Moss sound more attractive. It is fine as it is, apart from the excess of commuter and school traffic, which will not be changed by mere designation of a name.
Finally, the “processional route” from LCCC to the Football ground and beyond is puzzling. A “processional route” was part of the sweetener that accompanied the misjudged approval of the planning application for the Tesco Superstore. It runs from the side of the Town Hall to Chester Road. It serves little practical purpose but presumably was adopted because it sounded “pretty” when the application was live. Now apparently another route, that runs parallel to the existing route and just the other side of the Town Hall, is deemed necessary. This seems to us to indicate either that the existing route was never a good idea and that it is in the wrong place, or that processional routes are seen as essential makeweights to all new and contentious developments in the Old Trafford area.
We reject the idea of an innovation corridor as having any valid claim to existence – either now or in the future. We do not accept that student accommodation should be located on the Lacy Street site, but even if it were, it will take more than students walking or riding or bussing along the A56 and Talbot Road to create such a corridor. The reality is that the proposed developments shown on the “refreshed” Masterplan represent a pair of disparate and spatially separated developments.
The A56 Corridor
With regard to the A56, as stated above we consider this to be the single most intractable problem facing the true regeneration of Stretford as a place. The existence of a major 6-lane (and, at the junction of Chester Road and Edge Lane/Kingsway, 8-lane) highway running through the Town Centre, means that there are effectively two halves to the Town, with the main Town Centre shopping facility on one side of the A56, and the Metrolink Tram Stop, the Bridgewater Canal, Longford Park, Turn Moss and the Mersey Valley, on the other. Then there are, of course, major housing areas on both sides also. In addition to the divisive effects of the road, there are issues of air pollution, congestion, road safety and wastage of valuable land covered in tarmac to be considered.
We applaud the introduction of a 30mph limit along the A56 in recent times, but all other projects carried out by the Council have been, unfortunately very little short of a waste of public money. We understand that the works carried out at the junction of Chester Road with Edge Lane and Kingsway have cost around £2 million. This seems very poor value for money for Stretford people in that it appears to have been carried out largely to enable a marginally quicker right turn for traffic travelling north. Whilst we can understand that many people felt the subways to be unsafe, the ground level crossings are intimidating due to the volume and complex turning movements of traffic – and this might have been anticipated. In addition, we find the claim that the works have enabled improvements to the public realm to be somewhat specious, in that it largely comprises some strange street furniture and new seating areas in very close proximity to a major highway, where locals can sit and watch vast amounts of passing traffic, and breathe in the toxic fumes of 5 lanes of traffic when lights are on red. This is, we are sad to say, inadequate.
We call upon the Council to give serious and very careful consideration to the only possible solution to these problems and that is to put the A56 into tunnel from a point close to the M60 to a point just before the road crosses the Bridgewater Canal. If the Council is genuine in its desire to see Stretford regenerated, then a full cost-benefit study must be carried out, since we believe it would show significant benefits that would outweigh the costs of construction. We accept that all transport projects have costs attached, which means that they are only carried out, therefore, if it is felt that the benefits are worth it. It is not sufficient just to claim that costs would be excessive, when there is no context in which to judge “excessive” and when the benefits are ignored. We would respectfully put forward the following to justify such a scheme:
We have two major concerns with the proposals here. The first relates to the misleading information provided on the Leisure Facilities handout that was provided at the commencement of the consultation process. The second concerns the inappropriateness of the proposals in the context of national and local Green Belt Policy, as expressed in the National Planning Policy Framework and Core Strategy Policies R4.1 and R4.2.
With regard to the consultation process, the leaflet gives a clear impression that investment and upgraded sports facilities would be accessible to the local community. It also shows diagrammatically the inclusion of new training pitches, a goalkeeper training pitch, a training mound, facility offices, café and childrens’ play area. We have subsequently learned that the training pitches/mound are to be leased to a semi-professional football club from outside of the Borough and that the café is apparently to be managed by the club as a commercial enterprise. We are convinced that this is not what the majority of local people expected or wanted – including those who perhaps indicated support on the survey forms for what they believed to be a local community facility. Indeed there is almost certainly a large number of people who still do not know the full implications of this proposal. We call upon the Council to re-commence the consultation/survey in order to gain a true picture of local opinion based on all information and fact now available.
With regard to the proposals themselves, we are surprised that the Council has entered negotiations with a football club from outside of the Borough - Salford City FC - to lease land for a purpose that is clearly inappropriate to a Green Belt location. The National Planning Policy Framework (NPPF) states that “The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” It goes on to state that “Once Green Belts have been defined, local planning authorities should plan positively to enhance the beneficial use of the Green Belt, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land.”
In this case, the proposals would be harmful to openness; would reduce access to public open land; would reduce the amount of land available for the outdoor sport and recreation of the local community; and would be detrimental to the landscape, visual amenity and biodiversity. Since the land is not damaged or derelict, this issue is not relevant.
With regard to Green Belt, the NPPF indicates that a local planning authority should regard the construction of new buildings as inappropriate in Green Belt, and therefore by definition harmful to it. There are exceptions, where development may not be inappropriate, including appropriate facilities for outdoor sport and recreation, but only if it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it. In this case, the proposals would not preserve the openness of the Green Belt, and would, in addition, conflict with the purpose of safeguarding the countryside from encroachment.
The following are relevant considerations in support of our conclusions:
Aside from issues relating to Green Belt deriving from the NPPF, there are other concerns. The Council’s CS, in policies R4.1 and R4.2 supports National Green Belt Policy, and for reasons stated above, we believe that Local adopted planning policy must also be adhered to. The NPPF makes it clear that the ‘very special circumstances’, as mentioned in Policy R4.2, that could supposedly support inappropriate development, will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. There is nothing anywhere to suggest that leasing open land to a commercial business, with the associated engineering and other operational developments, would clearly outweigh the harm to the Green Belt, and the other harm to the visual amenities, open public access, biodiversity, traffic/parking considerations, and harmful competition to facilities in Longford Park, that would result.
In addition to Green Belt policy, the Council’s adopted Policy Map (PM), which forms part of its Development Plan suite of Documents, shows Turn Moss as an area designated for “Protection of Landscape Character” and as “Protected Open Space”. We would contend that the current proposals put forward for Turn Moss would not protect its landscape character or its crucial Open Space function.
Other concerns that we have relate to the lack of definitive information on the proposed terms of any lease given to Salford City FC. We note that Salford City FC is part-owned by the so-called Class of 92, and partly by a Singaporean Billionaire. Aside from potential conflict of interests that this might suggest with the UA92 proposals, which has the same backers, it is clear that the football club, which currently leads the National Division North, is intended for significant further investment to ensure its progress up the football ladder. The facilities proposed by the club so far are substantial for a club in its current position, and we fully expect the needs and demands of the club to increase as it progresses, raising the likelihood that it would require additional land and/or buildings in the future, and would not wish to move away to get them. This is worrying, given the lack of consideration given by the Council thus far to planning and community considerations in entering negotiations with the football club.
Finally, we note the proximity of Longford Park to Turn Moss. Longford Park is a Conservation Area as well as being the primary Town Park for Trafford. The Management Plan for the Park was adopted in 2016 and notes that enhancements to the park would be beneficial to the Conservation Area, for example the upgrade of Pet’s Corner, improvements to the tennis courts, and ongoing renewal of children’s play areas and equipment. Further, it indicates that “New development within the Conservation Area that seeks to enhance the visitor experience of the park is to be encouraged. For example …… installation of interpretation and improvements to the tennis courts, play facilities and Pet’s Corner.”
We contend that the proposed café and childrens’ play area at Turn Moss would be unacceptable competition that would be harmful to the future use of, and investment in, the similar facilities currently available in the park, and which are most appropriate for an established urban park as opposed to an open countryside location. As such the Turn Moss proposals would conflict with aims and objectives of the Management Plan for the Longford Park Conservation Area, recently adopted by the Council.
SUMMARY
CONCLUSIONS
We are unable to support the proposed refreshed Masterplan for the following reasons:
Whilst we consider the case for the proposed University extremely thin, and worryingly short on necessary detail and background analysis, we offer the following suggestions for a more rational approach to the whole UA92 and Stretford Town Centre scenario, in the unlikely event that the proposal demonstrates the possibility of viability, and in the hope that it might, on this basis, enable the Council to cover its borrowing costs using a coherent strategy.
Firstly, the proposal should be called University College Stretford, in order to bring the maximum value to the community in which it is based.
Secondly, The University Campus should be designed as a campus to include a teaching building; the minimum necessary associated offices; a much enlarged Sports and Leisure Centre (part-funded by the University); high-density student accommodation; a learning resource centre; a student union or similar; car parking; limited retail. This would maximise its credibility and ability to deliver a meaningful curriculum to a standard expected by a validating University, and create a vibrant campus environment.
Thirdly, since the Lacy Street car park is owned by the Council and currently brings in no income, we believe that there is no reason why the site could not be profitably and more usefully developed for the purposes outlined in the existing Masterplan. Stretford, as with other areas in Trafford and more widely, is in urgent need of housing, and especially affordable housing. Given the recent commitment by the Prime Minister to support the provision of more affordable housing and social housing, we believe the Lacy Street site should be developed for high density private and social housing, including affordable housing, and not as student accommodation. A high value use of this nature would also enable the development to include the GPO and Atlas Bathrooms sites, creating an opportunity to maximise the potential of the Bridgewater Canal to provide the setting for a meaningful open space/leisure/bar-café area for the local community.
Fourthly, the proposed demolition of part of the Mall would create an opportunity for the provision of limited student accommodation in Arndale House as well as perhaps within any new development that takes place on the demolished area. Limited student accommodation – as opposed to massive and intrusive blocks of such accommodation – would enable suitable integration of students with the wider community, and would add some of the supposed spending benefits of students to the spending power of the permanent community located on Lacy Street.
Fifthly, the A56 should be placed in a tunnel. The rationale and case for the benefits of this have been explained earlier. No meaningful regeneration of the Town Centre can happen with the minimal incremental programmes suggested so far by the Council. The full benefits of regeneration will only be felt when the two sides of Stretford are brought closer together by the replacement of the existing divisive and highly polluting six-lane highway that is Chester Road at this point, with a small local distributor road. We believe that a bold vision and desire to access available funding relating to air pollution improvement schemes and the Northern Powerhouse etc would be successful and would reap dividends.
Sixthly, since it would appear that the local community can be expected to function successfully with the number of existing sports pitches available at Turn Moss (on the basis that the pitches created by Salford City FC would not be available for public use anyway) we believe that there is no planning purpose satisfied (or indeed Stretford Masterplan purpose) by the proposal as it stands. If the University needs playing fields it could use the existing pitches, which are not used significantly mid-week, and could provide funding for their improvement, along with funding for basic improvements to the existing changing facilities. That way the Council and the local community wold gain some benefit from the existence of the University, who would benefit in turn by not having to create and provide its own facilities from scratch.
APPENDIX
Specific comments on the Draft Refreshed Masterplan content.
As a general comment we find the Draft Refreshed Masterplan full of sweeping generalisations and misleading information. There are references to emerging opportunities, although only one is mentioned and dealt with. This does not give the local community any options in terms of how to respond or indeed to what to respond. Most of our serious concerns have been dealt with in the body of this report, but more specific comment is included here for completeness.
Progress on the existing Masterplan has been significantly overplayed on page 1. We applaud the disposal of the Public Hall to the community, although we consider this to be the only true progress made by the Council. We are happy to see an Aldi Store anchoring the depleted Mall, but we do not see how this is Council-led progress. The public realm works carried out as part of the A56 developments are disappointing to say the least. There seems to be a confusion between road junction works and public realm works. A lot of money has been spent on helping more vehicles turn right from Chester Road onto Edge Lane, and the subways have been filled in to create more land for development at the Lacy Street car park, but the only actual public realm works have been the uninspiring light stands at the entrance to the Mall, coupled with new seating very close to a 6-lane highway. To call this progress is something of an overstatement.
References to increased footfall at the Mall refer only to the last full year and this follows years of decline. It would seem likely that much, if not all of this is due to the new Aldi, and it will not take into effect the closure of the Tesco store. References to reduction in vacancy rates contradict statements on high vacancy rates made in the Economic Impact Assessment (EIA) and perhaps ignore the planned closures of the southern arm of the Mall? This is not clear – as with so much of the document and the proposals themselves.
On page 2, references to UA92 are consistently presented as if a done deal. The consultation process has been less than satisfactory but it has revealed more of the UA92 situation, and there is clearly little in the way of concrete evidence that the proposal could be viable. The Proposed University Campus is 1.5 miles from the Town Centre and can have no direct relationship with it, whatever the Council may like us to believe. Moreover, in terms of the Town Centre opportunities themselves, we do not believe that the Council has sufficiently explored other avenues, particularly in the field of housing, which could have equal or greater beneficial impact on the viability and vitality of the Centre.
We believe that the second paragraph on page 4 very clearly and accurately sums up the fundamental problem facing the Mall and the Town Centre in general. The decline in the fortunes of the Mall can be traced to the widening of the A56 to six lanes, and successive Councils have done nothing to deal with this situation. This is the reason why we advocate the tunnelling of the A56 through Stretford, and now is the time to prepare for it with potential sources of funding to deal with air pollution and financial opportunities linked with the Northern Powerhouse.
On page 6 the document states that ”in meeting the needs and aspirations of the community it will be important to create a distinctive place that reflects the cultural mix of the area and complements other provision in Trafford, ensuring a long term sustainable future for Stretford and the Town Centre. The proposals set out in the refreshed Masterplan will provide investment of the scale required to deliver this effectively.” Once again, there is an implication that only UA92 can provide the investment needed. This is not the case. Whilst the University may, if it ever gets off the ground and then proves successful, generate investment, there is no attempt by the Council to consider alternatives. It is not good enough to present only one possibility – and that highly speculative. If the Council cannot point to other potential schemes then it seems highly probable that this is due to looking in the wrong places or making the wrong offers to the wrong people.
One thing for certain is that the imposition onto a single site of a mass of students that represents an increase of 5% on the current population of the whole of Stretford will do nothing to help with the integration of the student community into the life of the town. Moreover, it is not possible to ensure a long-term sustainable future on the basis of a student population that by its very nature is transient.
The concept of the “Innovation Corridor” is meaningless. The Map on page 9 shows lines connecting different parts of the town, but this does not make a corridor. There are no related developments planned anywhere along the 1.5 mile route between the town centre and the proposed university campus. The Green Route serves no apparent purpose, and just shows the current Edge Lane, which is a major and heavily trafficked route between South Manchester and Stretford. The “processional route” runs parallel in part to the earlier such route from LCCC to Tesco. It is unclear what purpose, if any, this would have other than to take visitors to the football ground along the roads from the Metrolink Station.
Page 13 launches into a vision for Stretford Town Centre and then focusses entirely on UA92 which is noted as having “potential” to achieve a number of benefits. At one point it is referred to as “it will” which gives the worrying image that regardless of any consultation, the Council intends to pursue the project regardless of any issues that may arise. We are very worried that so much hangs on the words “potential to”, when there is little or no evidence to suppose that any of that potential will materialise. It is impossible for the people of Stretford to make a meaningful judgement on the basis of such hypotheses and assumptions. There are alternatives, and these need to be explored first.
The word “will” keeps reappearing in the vision statement on pages 13 and 14. Again this shows lack of respect for the local community, and appears, on the face of it, to be telling local people that this is what the Council will do for their own good. There is at least an equal chance that the UA92 proposals will not come to fruition, and that if they do, competition from other universities in and around Manchester, which already offer similar courses, could easily prevent the supposed benefits from materialising.
The fact is that the Council has borrowed money to undertake a very risky investment at the Kelloggs site, and it now gives every appearance that it has no Plan B for the site. This would explain why the refreshed Masterplan is needed in such haste to give the appearance of some support for its plans. We consider such a risky venture to be undesirable, giving the appearance of gambling with public funds and the future of the local community.
The vision goes on to state that “there will be a clear and distinctive identity for Stretford taking advantage of its heritage assets, existing town centre facilities and access to environmental assets including Stretford’s parks, the Bridgewater Canal and the opportunity to create new landmark buildings.” The proposed student accommodation would not create a clear and distinct identity, but would swamp the existing community. Furthermore, it would not take advantage of the key asset that is the Bridgewater Canal. Instead it would condemn the Canal to be nothing more than a towpath in a tunnel of medium to high-rise blocks on both sides. This would be unacceptable by virtue of failing to meet the Plan’s own vision statement.
In short the “vision” is contradictory, constrained, misleading and thoroughly disappointing to the extent that any worthy elements are completely overwhelmed by the sweeping and unsubstantiated generalisations that pervade it.
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