26 March 2018
COMMENTS RE: THE GREATER MANCHESTER SPATIAL FRAMEWORK
On behalf of Trafford Green Party
Trafford Green Party wishes to make the following observations on the GMSF. These observations are in two sections – one relating to the document in general and one relating to specifically Trafford issues.
General issues
We are happy to support many of the general aspirations outlined in the document. In particular we endorse the following:
“It is our aspiration that Greater Manchester becomes as well known for the quality of its environment as for its economic success. Our Green Belt plays a role in this but there are important green spaces, parks, rivers and canals in the heart of our urban communities which are equally valuable. The protection and enhancement of our blue and green infrastructure is a central theme of our strategy. We need to be able to plan for schools, green spaces, roads and health facilities alongside new homes, offices and factories.”
However, there is little in the bulk of the document to indicate that policies will coherently underpin this aspiration. There is only very tangential reference to sustainability, which is the “Golden Thread” running through the planning system – as outlined in the National Planning Policy Framework (NPPF) – and many of the land allocations would clearly result in unsustainable development, yet are still proposed. Similarly, there is very little to indicate that any significant attempt has been made to create a strategy that will both take into account the effects of climate change and also plan for its minimisation through planning policies that will relate to a large conurbation with the potential for severe adverse environmental impact.
Continued references to the Northern Powerhouse as justification for much of the economic basis behind this Framework are worrying, since the concept was put forward by the previous Chancellor of the Exchequer based upon his own aims and aspirations with little or no evidential support for what is an over-generalised set of perceptions.that bears no resemblance to the current realities of the situation. The concept, whilst admirable in principle, needs to be totally rewritten before it can be used to drive economic policies for the Greater Manchester area.
Housing and employment land
There are worrying weaknesses in the evidential basis for housing and employment land allocations. The recent vote to leave the EU is generally accepted as one which will have the most significant and wide ranging impacts on the state of the nation in modern times. Objective Need Assessments have however failed to take this into account beyond a general and meaningless statement, as follows:
“Recognising that there have been very few policy announcements concerning the UK exit from the EU, the migration elements of the 2014 SNPP have been reviewed for the purposes of the OAN with a view on exit from the EU, but with an understanding that without any concrete announcements or policy guidance from Government, any change in the ONS 2014 SNPP would be based on assumptions and modelling scenarios.”
The figures for housing need and employment land requirements are, therefore, based upon outdated figures in the light of the obvious changes that will take place with regard to population change and economic growth during the period of the plan. Even without a concrete announcement from the government, it is clear that the prime mover behind the vote to leave the EU was to reduce immigration and it does not need any specific further announcement from the government to establish this point. All respected independent analysts conclude that, in the light of all evidence thus far, there will be reduced immigration and a likelihood of lower economic growth as a result of Brexit. This will reduce the need for housing and associated land release. If it is deemed necessary to wait for concrete announcements from the government before the scale of such reductions can be assessed, then so be it, but important decisions on such matters as release of Green Belt, must not be taken until those announcements have been made and the forecasts and analysis revised accordingly.
A more cautious, flexible approach, which accepts that there is no current need to release Green Belt (see below), would conform to the requirements of the NPPF in Paragraph 14 which states that “Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole”. As noted above, there is sufficient doubt that the objectively assessed needs as outlined in the Spatial Framework are realistic, given the Brexit situation, and that flexibility should therefore be applied – in particular with regard to protecting Green Belt.
Finally The NPPF goes on in paragraph 50 to state that local planning authorities should “plan for a mix of housing based on current and future demographic trends”. Future demographic trends will almost certainly point to a lower housing need than has been assessed in the Spatial Framework using now outdated trends.
Green Belt
The above consideration is particularly important in the light of the following statement from the document:
“There is a strong and continuing emphasis on directing new development to brownfield land in urban locations however the scale of growth requires the release of land from the Green Belt. We have sought to minimise the release of Green Belt sites by exploiting the opportunities to increase development densities in well-connected urban locations and will continue to explore this over the next 12 months.”
There should be NO release of Green Belt land until and unless the need to do so has been convincingly proved, and there is currently no evidence to suggest that any such release will in fact be needed.
Green and Blue infrastructure
We fully support policy GM7 on Green Spaces. This underpins the aspiration that “Greater Manchester becomes as well known for the quality of its environment as for its economic success”. Whilst we have concerns over what is understood by the term economic success, we believe that the quality of the environment, including air quality, is crucial to the delivery of any kind of economic development, in that a poor quality environment is detrimental to the attraction of job-creating industries. This also ties in with absolute protection and retention of the Green Belt.
Affordable Housing
We have significant concerns regarding the approach adopted in the document for consideration of affordability of housing. The analysis in the Strategic Housing Market Assessment (SHMA) uses mean household income to determine affordability. Whilst in statistical terms, “mean” is commonly used to denote “average”, it of course ignores the reality that the vast majority of households have an income below “mean” and for whom, therefore, such housing is unaffordable. The analysis maintains that “a household on the GM mean income can afford a property up to about £145,000 (assuming 85% LTV mortgage and 3.5 times income at 3.5% interest over 25 years) and there are a significant amount of property sale transactions carried out at this level”. However, the reality is that this assumes that the mean household can raise a deposit of £20000, while evidence from the consideration of median incomes makes it clear that the vast majority of households could not in fact afford what is seen as a relatively low priced dwelling. This means that the only housing available to low income households is in the rental sector.
The Evidence Paper on Site Optimisation uses a range of density indicators for differing locations with regard to housing development. The figures could easily be increased in all locations in order to provide more housing more cheaply than that allowed for in the Strategic Framework. This is even acknowledged in the document itself where it states that in the lower density locations “30 dwellings per hectare (dph) would be appropriate, although consideration could be given to raising this to 35 dph or even 40 dph”. We would advocate using the higher figure in order to minimise the land take (including reducing the need to take Green Belt land) and provide cheaper housing.
We consider the approach to housing affordability extremely limited, when the true issues lie in inflated land costs and low densities. There has been continued reference in documents preceding the current Framework to the value of land with planning permission for housing. This is of course a hope value and, in the case of large land holding development companies, a bookkeeping exercise. There is no reason why land with a very low current use value could not be bought and sold for much less than the going rate for housing land with consequent reduction in house prices. However, in the absence of a truly radical and effective solution to escalating house prices – such as Land Value Taxation – which is beyond the scope of the Strategic Framework, increasing both density and the emphasis on the affordability of housing within the given parameters, should be a feature of the document.
Accessibility
We endorse the following statement in the Framework:
“Central to the overall approach must be the delivery of a major increase in the proportion of trips undertaken by walking, cycling and public transport, as expanding highway capacity to meet an ever growing demand for car travel is not sustainable, or physically or financially practical. Walking and cycling need to become the natural choice for shorter trips, and public transport for longer journeys. A comprehensive package of measures will be required to deliver this, and careful coordination will be vital to ensure that they all pull in the same direction. This will include controlling the location and design of new development, carefully managing car parking provision, investing in infrastructure improvements, reallocating road space to pedestrians, cyclists and public transport, redesigning services and routes, and using technology such as real-time information to influence the decisions of travellers and systems operators. Increasing the use of sustainable modes of travel will also have wider benefits in terms of reducing carbon emissions and pollution, and delivering health improvements through active travel.”
Such an approach will require significant investment in infrastructure and services. The funding of this should be prioritised over the “white elephant vanity project” that is HS2. There is still a strong and respected body of opinion that HS2 represents extremely poor value for money, and that even if it takes place, it would be highly likely to run in over budget, and that it would benefit London far more than the regions. To base a significant number of the policies within the Framework on the chance that HS2 might arrive in Manchester by the early 2030’s is frankly worrying. A better return on investment would result from spending the equivalent money on northern inter-region transport links and local integrated public transport schemes that would benefit local people and help to link up the inter-related industries – present and future – that use the skills and historical know-how of northern towns and cities.
In addition, we have grave concerns for the general assumption that Manchester Airport will continue to grow, when air travel is acknowledged as a primary cause of climate change, and when many trips, especially business trips, can be avoided by the use of new forms of communication or improved public transport nationally. The mantra of job creation can just as easily be applied to more socially and environmentally beneficial projects that are being squeezed out by over-emphasis on a poorly thought out set of unsustainable grandiose schemes.
Issues specifically affecting Trafford
The general concerns, as outlined above, have repercussions for the proposals relating to the Borough of Trafford. Chief amongst these is the impact of the proposals on the Green Belt in Trafford.
Three main areas are earmarked for development, all of which have worrying implications with regard to release of Green Belt land. These will be considered in turn after setting the background for such release from the framework itself.
The Framework states that “Our approach to Green Belt release is to maximise sustainability by focusing on a relatively small number of large sites allowing for the creation of new mixed use neighbourhoods supported by proper infrastructure and services”. It goes on to say “For each site allocated in this plan, it will be expected that the developments on it will collectively fund the infrastructure required to support its delivery. This will be reflected in any land value assumptions that are considered acceptable in viability assessments. It will be a requirement that all sites are delivered comprehensively, and no individual developments will be permitted on them without a commitment and proportionate contribution to the necessary supporting infrastructure”.
The proposed development areas in Trafford comprise two large sites at Carrington and Davenport Green, with one much smaller site at Flixton Station. All involve the loss of some Green Belt land.
As noted earlier, we do not believe that there is a proven need to release Green Belt land in order to meet the land use requirements of the Greater Manchester region. A stronger focus on affordability of housing for local people, with concomitant higher development densities, would result in the need for less land being taken. The SMHA acknowledges that Trafford is the least affordable of any of the ten boroughs and this should be the basis for all policies relating to housing and land release. It is also important to keep in the forefront of any discussion the issue of sustainability, and the need to ensure that new developments are properly planned in relation to the provision of infrastructure and accessibility issues.
Policy GM13 of the Framework relates to the Green Belt. It states that “positive and beneficial use of the Green Belt will be supported where this this can be achieved without harm to its openness, permanence or ability to serve its five purposes. In particular, the enhancement of its green infrastructure functions will be encouraged, such as improved public access and habitat restoration, helping to deliver environmental and social benefits for the residents of Greater Manchester and providing the high quality green spaces that will support economic growth” It should be accepted that positive and beneficial use will include recreational and leisure facilities, particularly given the emphasis both nationally and locally on enabling and supporting physical activity for the benefit of the health and thus productivity of local communities. Special emphasis should be given to protecting those areas of Green Belt that have public access.
The NPPF identifies 5 purposes of Green Belt:
and other urban land.
These are all equally important. The Green Belt Assessment (GMGBA) underpinning the Framework considers each area of Green Belt land against each of these purposes, measuring them as performing weakly, moderately or strongly. However, by separating out each area of land it becomes impossible using this approach to consider the vitally important purpose of assisting in urban regeneration, since this is a function of Green Belt land in general and not the role of any one individual area of land. This is a fundamental weakness of the analysis. Indeed, the inspector who approved the Greater Manchester Structure Plan in the 1970’s (the plan which defined the current Green Belt) noted that “…in parts of the County, it is appropriate and often necessary that it should act as a severe restraint on development, thereby bending past trends…and directing development in such a manner as to serve to implement the primary theme of urban concentration”. Green Belt policy, as outlined in the NPPF continues this theme to this day.
The GMGBA itself states that it “finds that each parcel assessed in the study makes some form of contribution against each purpose, whether that is ‘weak’, ‘moderate’ or ‘strong’. The NPPF does not require all the purposes of Green Belt to be met simultaneously and a ‘strong’ rating against a single Green Belt purpose could be sufficient, on its own, to indicate an important contribution. Equally, even if an area of Green Belt scores strongly against one or more purposes, the NPPF does not suggest that a review of its boundaries would not be appropriate, so long as exceptional circumstances are demonstrated. (our emphasis).
It goes on to say that “The GMGBA makes a recommendation that the GMSF should include a strategy to secure greater positive use of the Green Belt, as encouraged by the NPPF, with the aim of enhancing the environmental and social benefits derived from the land and helping to underpin the ambitions for economic growth and regeneration. This aspect was not assessed by the GMGBA but the study notes that the Greater Manchester Green Belt does include significant areas of productive agricultural land, country parks, sports pitches, golf courses and areas of moorland, woodland and floodplains with much scope to provide informal recreation close to the conurbation. (Again our emphasis)
In the light of the above, it is necessary to consider each of the proposed development areas in Trafford in turn.
Davenport Green
This area, which has a target of some 3300 homes, is in close proximity to Manchester Airport and the proposed HS2 station, and it links in with related proposals for development on the Manchester side of the Borough boundary around the airport. It would also be served by a proposed Metrolink extension between the airport and Altrincham. Our concerns regarding HS2 and the airport expansion, together with the questionable need to release Green Belt land, have been outlined earlier, but in the light of the proposed Metrolink extension, Davenport Green would be a relatively sustainable location and one which would be expected to be developed at an accordingly higher density. In the light of the lack of affordability of housing in Trafford as a whole, we consider that this area, if it were to be developed, should be developed at a high density to maximise access to local people and the accessibility of those people to employment opportunities in the Airport area.
We have significant concerns that if the HS2 station were to go ahead, that this area would effectively become a dormitory suburb for London workers, who could access jobs in London very easily, whilst taking relatively cheap housing (in their terms) away from local people in Trafford. This area of land must be utilised in a way that maximises its potential to deal with housing needs of the local community. A high density development would also potentially minimise, or even remove, the need for release of Green Belt land.
Carrington
The Partington/Carrington area has been a long neglected and somewhat isolated part of the Borough. Subject to our concerns relating to release of Green Belt land in general, we consider that this area would generally benefit from substantial growth, on the proviso that significant developments in infrastructure, together with much improved public transport facilities, were an integral part of the planning of the area. The area is currently relatively poorly served by buses, and the nearest rail station is at Flixton, which has a totally inadequate service to deal with the scale of growth proposed at Carrington. In addition, Flixton station is not within easy walking distance of any of the Carrington site and so would only be accessible to car owners, which would put additional strain on an already stressed local road system and raise issues of car parking in the vicinity. The Carrington site can only be justified if comprehensive improvements to bus services or other public transport facilities can be provided from the outset, along with other essential services.
It should also be noted that the reasoned justification for this development site identifies the ability of the site to meet the needs of Greater Manchester well beyond the plan period. On this basis, there is likely to be a built-in flexibility to accelerate development during the plan period should the need arise.
Flixton Station
We have fundamental reservations regarding the release of Green Belt land in this area. This is a relatively small site that will have minimal impact on the provision of housing need in Trafford as a whole. It represents only some 3% of the total planned housing provision, which is less than the 5% buffer over and above currently anticipated need for the whole of the 20 year period covered by the Framework. Even accepting the current forecast need (which we consider to be excessive), this could easily be made up by increasing density in other areas and/or by use of new brownfield sites that are already being identified and becoming available, following the assessment carried out for the Framework over the past two years. There is also the flexibility offered by the Carrington site to cover the loss of this parcel of land in the unlikely event that existing identified needs fall short of actual requirements.
There is no justification for release of this part of the Green Belt. It is part of site TF02 in the GMGBA and is assessed as performing Strongly against Green Belt purpose 1, Moderately against purpose 2, and Weakly against purpose 3. We would contend that it should be classified as performing Strongly, or at least Moderately against purpose 3 in that it has the characteristics of countryside, it has little or no urbanising influences and is open. It is occupied largely by a Golf course and playing fields, there are no urbanising influences other than a golf clubhouse, the Listed Flixton House and a station building, and the area is an important, publicly accessible open area that forms part of the link into the Mersey Valley in the Flixton area. In view of its strong showing against Green Belt and the lack of any exceptional circumstances, this site should not be released.
In addition to the above, the site has a positive use within the Green Belt, as a Municipal Golf Course, which will increase in usage and value as a local recreational resource if the Carrington site is developed. This accords with advice in the NPPF and with other national and local policy on encouraging greater physical activity for the social and physical health and welfare of the community. The GMGBA acknowledges that such issues were not assessed as part of its work, but we contend that it should have been, in order have a full appreciation of the essential character of the Green Belt in this area and around the conurbation. Moreover, the site accords with Policy GM7 of the Framework on Green Spaces which states that “the green infrastructure network will be designed, managed and protected so as to help deliver the following key priorities for Greater Manchester……1. Improve public access to green infrastructure and provide a broad range of recreation opportunities.”
Finally, this site is unsustainable for housing development in that public transport facilities in the area are wholly inadequate and there is no likelihood of significant improvement. The so-called “transport hub” consists of a rail station with very limited frequency of service and equally limited bus services that have to cope with severe road congestion. This site fails on a broad front of considerations and should be excluded altogether from the land use allocations in the Framework.
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