Here is our response PDF Download
To give a flavour, the consultation first asks this question:
Is the approach that we have outlined in the plan reasonable?
What is the reason for your answer?:
Our principal reasons are as follows. More detail to support our points will follow under specific topic questions.
- As a prospective strategic plan for Greater Manchester the draft GMSF begins from the wrong premises. In the publicity for the consultation, the question is posed: “What kind of place do you want Greater Manchester to be?”. It is a good question but not one that is answered by the document which is dominated by the economic perspective. Instead we propose that the plan starts from consideration of “retro-fitting” the city region [see https://steadystatemanchester.net/2017/03/07/greater-manchester-towards-a-retrofit-garden-city/ https://steadystatemanchester.net/2018/05/22/we-need-a-a-social-ecological-spatial-framework/ ] as a network of localities that are relatively self sufficient (cf. the “20 minute neighbourhood” concept developed in Portland and adopted by Melbourne see https://www.eugene-or.gov/1216/What-is-a-20-Minute-Neighborhood ; https://www.portlandonline.com/portlandplan/index.cfm?a=288098&c=52256 and https://www.planmelbourne.vic.gov.au/current-projects/20-minute-neighbourhoods). This would imply a highly polycentric conurbation, where citizens’ needs are mostly met locally, reducing travel and resource use, increasing local community ties and social capital, supporting local business and community enterprise, and protecting the natural world. Building on the new emphasis on town centres, the strategy would strengthen district centres throughout the region, putting most development there, utilising sites within the urban area, and making best use of existing buildings. The construction of “growth hubs” that pull people and resources into themselves would be resisted in favour of strategies for local community wealth building and plugging the leaks by which wealth and money leaches out of both the local community and the city region. Economic growth would not be sought in the aggregate although some parts of the economy would grow, just as others would shrink, so helping Greater Manchester to minimise its ecological footprint while improving population well-being.
- Economic growth projections are inflated. The consultancy used by GMCA, Oxford Economics, routinely makes forecasts at the upper level of the class of UK economic forecasters, as evidenced in their own paper on their GM Forecasting Model.
GMFM 2018 baseline cumulative GVA growth 2017-2023 = 12.38%
AGS 2018 scenario cumulative GVA growth 2017-2023 = 13.93%
OBR forecast, (UK economy) applied to GM 2017 actual: 2017-23 =9.13%
AGS forecast 2017-2038 is a 59% increase in the scale of the economy. This endless growth is not sustainable on a finite planet, nor in a Greater Manchester that aspires to be one of Europe’s greenest cities.
- Housing need projections are based (apparently at government behest) on outdated population figures (2014 rather than the latest, 2016 figures that take brexit into account).
The Housing Minister, Kit Malthouse MP, stated in a Westminster debate on 22 February 2019 and reiterated in a letter to Jim McMahon MP, that the housing need target is not mandatory and an inspector would accept a lower number if there are constraints such as Green Belt. We do appreciate that the guidance from central government has been unhelpfully contradictory but propose that this means that it is inappropriate to attempt to plan for a 20 year period in these circumstances, given that a 20 year plan is not required by central government.
- The plan is not sufficiently explicit about the green space that will be lost, only quoting net Green Belt loss in its main document. We provide the full figures in our response to question 56.
- Identifying so much Green Belt allocation over a 20 year period is unreasonable, given the uncertainties: the danger is that once identified for building it will be difficult to reverse the allocations should building not be required.
We recommend a 15 year horizon for the revised GMSF. Since there is sufficient land supply for this period this will be a win-win resolution. The plan can always be rolled forward with revisions as trends, needs and supply become clearer.
- There is no analysis of the carbon consequences (baseline and opportunity cost) of building on green land, nor of the preferred “Accelerated Growth Scenario”. We have made some estimates based on our own calculations and present these later on, but this should have been part of the integrated assessment or the supporting papers.
- There is only token reference to food production.
Destruction of farmland for housing and commercial development increases reliance on imported food and destroys farming livelihoods. Leaving the EU, from where much of our food is imported, together with the looming threats of climate change and geopolitical supply chain shocks, mean that this is not a good time to increase our reliance on imported food by building on farmland.
- There is insufficient attention to housing types, in terms of design, mix, tenure.
- Carbon reduction and biodiversity still appear largely as after-thoughts – these sections are vaguer, more tentative than the “we will” language used for proposals such as roads, green belt allocations, and major industrial developments.