At last, the Greater Manchester Spatial Framework has appeared following Greater Manchester Mayor Andy Burnham’s electoral promise for a radical rewrite.
It’s an enormous document, more than 1,000 pages, with many more than that in the various supporting documents. This puts quite a burden on those who will want to respond to the consultation, now open until Monday 18 March, 2019 (at 23:59).
We’ve been working our way through it and will certainly be responding to the consultation. Meanwhile we have two pieces for you, an article by Mark Burton that appears on the Greater Manchester Housing Action website (also reproduced below), and a presentation that covers similar ground but with a number of diagrams and graphs that underpin that analysis (with one of these above). These aren’t the last words and we’d also make the following points:
The new GMSF is an improvement on the previous draft. The Combined Authority has an unenviable task of planning for the provisioning of its population (jobs, houses, employment) while also keeping within the demanding carbon budget proposed for the region and protecting and enhancing and area as a liveable and viable space and society. It’s hard to fit all that together – our fundamental concern is that the assumptions made (housing growth, economic growth) are fantastic and there is insufficient attention to the ecological and climate crisis and the contradictions of the global economic system that all herald a likely contraction not expansion of economic activity in the years to come. But we’ll have more to say on that in subsequent pieces.
Greater Manchester’s plan for jobs, homes ……. and the environment?
After several delays the Greater Manchester Combined Authority has published the new draft of its Spatial Framework. The previous version, published in late 2016 met considerable criticism, especially from groups campaigning on green space but also from other quarters, including our own critique of its assumptions of accelerated “economic growth”. On the other side the developer lobby suggested those assumptions were timid, arguing for even greater expansion of the economy, and with it building for industry, warehouses and homes.
Before looking at the redraft, we should ask what the Spatial Framework is for. It is both an attempt to produce the first plan for the city region since the 1980s and a way of dealing with pressures from central government. Local authorities have to produce local plans and consult on them, and to ensure a 5-year pipeline of land for new housing, in line with the government’s imposed targets. Through GMSF the 10 councils in Greater Manchester are approaching these problems together, aiming to avoid a situation where penalties are applied due to the lack of plans and a housing land supply, with “the spectre of moving from plan-led development to a developer-led process of planning by appeal, which would be costly for all”. However, the Spatial Framework aims to be more than this, a “plan for jobs, homes and the environment”.
How many homes?
In September, the Office of National Statistics published its projections for household numbers. For Greater Manchester, this was 141,034 new households by 2035. If that translated into new homes, then that number could have been accommodated without building on the green belt. But the government then confirmed that it was not going to use those projections, but instead a formula that used the 2014 ONS population projections (since superseded with lower population growth estimates). It is reasonable to be cautious about the ONS projections since they do not translate directly into actual household formation, which depends on factors such as prosperity and housing availability and affordability. But as Andy Burnham has noted,
“ The truth is I would have liked to go further and get closer to the aim of ‘no net loss’ of greenbelt.
“That was under active consideration but effectively made impossible by the government’s insistence on us using the old population and housing figures, which are significantly higher than the most recent ONS projections.
“It was decided that our plan would be at considerable risk if it diverged from the methodology and the greatest risk of all to our greenbelt is to have no plan in place.”
GMSF 2016 was criticised for its bias to small flats. This aspect is even stronger now, partly as a result of a plan to increase still further the building of flats in the Salford and Manchester urban centres. Together these will account for 4,590 units per year, that’s 43% of the GM total. The overall average occupancy will be just 1.28 people per home, down from 1.3 in the 2016 plan. We have previously questioned the ecological and social desirability of this model of super-concentrated, high rise urban living. And others have argued that the country’s housing crisis will not be solved by building new homes.
Brownfields, Greenfields, and Green Belt
Since the last version, the local authorities have worked behind the scenes to identify more brownfield land for new developments, using the brownfield registers that they now have to hold. Assumptions on the level of economic growth and population have been revised down, largely in the light of brexit. This means that fewer new homes are now planned: 200,980 by 2035 compared to 227,200. There will also be less building on green belt land. The net loss is quoted as 2,419 hectares, compared to 4,900 in the 2016 version. However, the “net loss” figure is a bit disingenuous since is presumably subtracts the new green belt additions (960.5 ha). But that land is already green space: it is good that it has new protection, but it shouldn’t be used to obscure the gross loss. Moreover, analysis of the supporting papers indicates what non- Green Belt green space will be used for housing (1037.7 ha), industry and warehouses (567.51 ha) and offices (272.93 ha). That means a total loss of green space of 5257.64 ha, or 20.3 square miles. This is considerable and it does not include those brownfield sites that have reverted to nature.
Given the Mayor’s aim for Greater Manchester to have net zero carbon emissions by 2038, one might have expected to see an assessment of the loss of this natural “carbon sink”. I asked the GMSF team about this, having raised the matter during the 2016-7 consultation too. I was referred to the background topic paper on Carbon and Energy but there is no such audit there. I therefore produced my own ballpark estimate, using figures from the scientific literature on carbon sequestration by various landscape types, applied to the mix of green space in the city region. I estimated a total of 43,250 tonnes of avoidable carbon emissions from land use change by 2038, and that is not including the emissions from all the building, associated transport, and the energy use of the buildings in operation. This is perhaps small in comparison to the 67,000,000 tonne Greater Manchester carbon budget for the period 2018-2038. However, also foregone will be the possibility, on some of those sites, of considerably increasing the rate of sequestration by conversion to woodland. There is also a proposal for development on Carrington Moss: there will need to be a thorough assessment of the special environment and climate consequences of that proposal.
Housing is just one element of the plan. The other big demand on green space is for warehouses and industry. Assumptions here are based on the use of consulting firm Oxford Economics which produces economic forecasts. They produce a baseline assessment and an accelerated growth scenario. The baseline forecast is for an overall growth in the GM economy of 39.65% by 2037. The accelerated growth forecast “reflects a future where the city plays a lead role in driving forward growth ambitions for the North of England… [and] is consistent with the long-term ambitions for the ‘Northern Powerhouse’. It has the economy growing by 58.72% over that period. Did someone say “finite planet”? no, I thought not. Let’s be charitable and not say this is pure fantasy, but instead just note that Oxford Economics consistently produces higher estimates than the majority of other economic forecasters, all of whom share that belief in the possibility of endless economic growth. It has one of the lower estimates of the impact of brexit. This would not be a problem were not decisions being made on its basis. It means that the region will be speculatively allocating land for industry, warehouses and offices, in the hope that “if we build it, they will come”. This is not the way to plan a resilient future in the era of financial shocks, geopolitical surprises, and collapsing climate and ecological provisioning systems.
The new GMSF is an improvement on the previous version. It does a better job of integrating other policy areas into a cohesive whole. It includes a presumption against fracking and the aim of getting to net zero emissions. It considers transport and other infrastructure more thoroughly (though still celebrating our climate-toxic airport and its expansion plans). It has managed to reduce the destruction of green belt but it still quietly envisages at least 20 square miles of green space being built on. And this is in large part because of being forced to adopt the government’s housing targets and choosing to go with Oxford Economics extremely “optimistic” forecast.
What we really need is an entirely different model of what our city region could be.