And then there were 9: Places for Everyone – the new GM Spatial Framework.

Post updated 20 and 25 Sept, 2021 (minor updates and correction to carbon figures).

Background

The final version of the Greater Manchester Spatial Framework is now out for consultation.  Following the withdrawal of Stockport council, it is now a joint plan of the remaining 9 Greater Manchester councils, called Places for Everyone (known as P4E) – link to the plan here.
It is hardly changed from the 2020 draft, which itself was not so very different from the previous plan.  This time, the plan is at “Publication Stage” and the consultation is formal and limited to what is prescribed by national planning legislation and guidance.  This is how GMCA explains it:

“The final stage of consultation will run from August 9, 2021 for 8 weeks, ending on October 3, 2021. However, the plan and evidence base has been available on these pages to view since July 12, 2021, this has meant that people have had time to view and familiarise themselves with the content before submitting responses. [SSM comment – in theory: the plan itself runs to 465 pages and there is a library of supporting documents, some of them also very long, where critical detail can be found. For citizens and community groups who wish to comment this is hugely time-consuming.]
“We are now at the ‘Publication Stage’ of this plan. It is the final stage of consultation before the plan goes to the Secretary of State who will then appoint an independent inspector or inspectors to examine the plan.
“The Publication Plan is the plan that the nine local authorities consider to be the plan they intend to submit to the Secretary of State for examination. This is a formal stage of consultation and at this stage of consultation we are asking you whether you think the Places for Everyone plan meets the ‘tests of soundness’.
“The term ‘sound’ is used to describe a Local Plan that has been prepared in accordance with what Government expects of local planning authorities.”

Those tests of soundness are that the plan has been

a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;

b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and

d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.
Source: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf page 12

However, that leaves plenty of scope for comments.  It is important that in commenting, the guidelines from GMCA are followed – click here to see these consultation arrangements.

The deadline for consultation responses is October 3, 2021.

SSM are putting together our submission which we’ll make available as soon as it is in reasonable shape.  We are concentrating on the consequences for carbon emissions (subject of a Freedom of Information request and our independent calculations) and nature,  the assumptions about economic and household growth, the adequacy of the Integrated Assessment, and the characteristics of the city region that will emerge from these plans.
Our preliminary comments follow.

Loss of Green Space

It is important to be clear about the amount of green space to be lost according to the plan. This information is not presented transparently in the P4E report which presents a figure for net green belt loss. This figure is the total green belt loss minus the re-designations of currently unprotected green space as green belt. While the improved protection for those spaces is welcome, the net figure is misleading since it reduces the total by those spaces that are already green space. So the gross green belt loss is the relevant figure. This is either 2336.9 hectares (the sum of the green belt “allocations”, i.e. withdrawals from the allocations spreadsheet in the supporting documents) or 2429.4 hectares (the sum of the net green belt loss and the green belt additions, from the main P4E paper).

This is not the whole picture, however. P4E identifies non green belt earmarked for building under three categories, housing, industry and warehouses, and offices. The main Places for Everyone report and the supplementary papers give most of the relevant figures, although it takes an effort to put them together, given that they are scattered across several documents. Most of the sites are identified in terms of area, either hectares or square metres, and the former unit is used below. However, non-green belt housing sites did not have areas identified: instead it was the number of housing units. Therefore a series of Freedom of Information Act requests were made to GMCA and the 10 councils for the relevant information in December 2020¹. Note that the plan at that time included Stockport which has since withdrawn. Figures below have been amended to reflect that. Bury council stated that they did not have the information. We asked for an internal review since this was considered implausible but have had no response other than an acknowledgement in early 2021. Therefore Bury’s area of non-green belt housing sites has been estimated from their figure for housing units, using the mean density of the two peripheral neighbouring councils, Bolton and Rochdale (considered more similar to Bury than Manchester and Salford).

Non-green belt sites are classified as greenfield, brownfield, or mixed. I have not included brownfields and mixed sites. The brownfields classification probably includes some sites that were formerly industrial but then returned to nature but there is no way to quantify that proportion. Moreover, if greenfields are to be protected and some development is to take place, then it will be necessary to prioritise brownfields. The resultant figures are as follows:

Category	hectares	sq miles
Net Green Belt release	1,754	6.8
Green Belt additions	675	2.6
Gross Green Belt loss2	2,337	9.0
(Gross Green Belt loss3	2,429	)
Greenfield non GB sites for housing	1,089.7	4.2
Greenfield non GB sites for industry & warehouses	60.6	0.2
Greenfield non GB sites for offices	24.4	0.1
Total non GB Green Space loss	1,174.8	4.5
Total Green land loss Ha	3,511.7	13.6
sq root (side of equivalent square for visualisation purposes		3.68	miles
		5.89	km

To visualise the area of land that would be lost, the equivalent area can be superimposed on a map showing the boroughs of Manchester, Salford and Trafford.

That is useful background and we’ll come back to the area figures when we look at the consequences for the carbon emissions. However, since the consultation response will need to focus on the soundness of the plan, it is important to review the Integrated Assessment on which the plan rests.

Comments on the Integrated Assessment for Places for Everyone.

The Integrated Assessment (IA) underpins the Places for Everyone Plan (P4E). It includes the Sustainability Appraisal, Strategic Environmental Assessment, Equality Impact Assessment and Health Impact Assessment.  The Integrated Assessment of 2020 was updated with a scoping paper for 2021.  It seems that there are no major changes.

Following the IA Scoping Report baseline evidence update in 2020, no
changes to the IA objectives or criteria are recommended. It is noted that
the declaration of climate emergencies by GMCA and the 10 local
authorities, is the most significant shift since the previous update to the
Scoping Report. The IA objectives and criteria particularly related to
climate emergency have been carefully considered to establish whether
there has been a material change requiring an amendment. As a result of
the update, it is concluded that no additions or changes are required at this
stage, but any emerging evidence will be considered as part of the
updated IA assessment. Scoping Report, page 15.

We make the following comments on flaws that we have identified in the IA.

The IA assesses a number of desirable outcomes (IA objectives) against the P4E Objectives. Table 10: IA Compatibility Analysis of the 2020 draft GMSF objectives is reproduced here with labels for objectives (abbreviated where necessary)

GMSF Objective

IA Objective

Meet our housing need.

Neighbourhoods of choice

Thriving and productive economy

Maximise potential of assets

Reduce inequalities / improve prosperity

Promote sustainable movement.

Resilient and carbon neutral city-region

Natural env. / green spaces

Ensure access phys & soc infrastructure

Promote community health and wellbeing

1 Housing

++

++

O

+

+

?

?

+

+

+

2 Employment

O

?

++

++

+

?

O

O

+

O

3 Transport and Utilities

O

+

O

+

+

++

+

?

+

O

4 Deprivation

+

O

+

?

++

?

O

O

+

+

5 Equality

+

+

+

O

++

?

?

+

+

+

6 Health

?

+

O

O

+

?

+

+

+

++

7 Social Infrastructure

?

?

O

?

O

O

O

+

++

+

8 Education and Skills

O

O

?

?

+

O

O

O

+

O

9 Sustainable Transport

O

++

O

+

+

++

+

?

+

+

10 Air Quality

?

+

O

O

O

+

+

?

?

+

11 Biodiversity/ Geodiversity

O

?

O

O

O

O

O

++

O

O

12 Climate Resilience

O

?

O

?

O

O

+

++

O

O

13 Flood Risk

O

+

O

O

O

O

O

++

O

O

14 Water Resources

O

O

O

O

O

O

O

O

?

O

15 Greenhouse Gases

?

+

O

?

O

+

++

?

?

O

16 Landscape and Heritage

O

+

O

+

O

O

O

++

O

O

17 Land Resources

?

+

?

O

?

O

O

+

O

O

18 Resource Consumption

O

O

O

O

O

O

+

O

O

O

We consider that ratings of P4E Objectives against the IA Objectives are inappropriate. The lack of any negative ratings in the summary table (i.e. that there is some incompatibility between P4E and IA objectives) suggests a bias towards optimism or even the suppression of inconvenient evidence. This point can be made with respect to many of the objectives but the following two will be used illustratively.

1, Biodiversity / Geodiversity Full definition (our emphasis): “Conserve and enhance biodiversity, green infrastructure and geodiversity assets.”

Criteria:

1. 1. “Provide opportunities to enhance new and existing wildlife and geological sites?

   2. Avoid damage to, or destruction of, designated wildlife sites, habitats and species and protected and unique geological features?

   3. Support and enhance existing multifunctional green infrastructure and / or contribute towards the creation of new multifunctional green infrastructure?

   4. Ensure access to green infrastructure providing opportunities for recreation, amenity and tranquillity?”

P4E objectives 1, 3 and 5 (housing, thriving economy, increased prosperity), as the plan proposes to meet them, are relevant to this objective in that the projected loss of green space proposed in the plan (3,511.7 hectares or 13.6 sq miles, for all green space and 2,336.9 ha or 9.0 sq miles for green belt allocations, is potentially highly incompatible with this IA objective.

Likewise, P4E objective 4, (maximise use of assets) is likely to be relevant in that it entails impacts on natural assets and wildlife.

15, Greenhouse Gases Full definition: “Increase energy efficiency, encourage low-carbon generation and reduce greenhouse gas emissions.”

Criteria:

1. 1. “Encourage reduction in energy use and increased energy efficiency?

   2. Encourage the development of low carbon and renewable energy facilities, including as part of conventional developments?

   3. Promote a proactive reduction in direct and indirect greenhouse gas emissions emitted across GM?”

P4E objectives 3 and 5 (thriving economy and increased prosperity), as the plan proposes to meet them, are relevant to this objective in that the projected levels of economic growth, with the consequent material and energy usage (in construction, embodied and operational), together with loss of green spaces are potentially highly incompatible with this IA objective.

Likewise, P4E objectives 1 and 4, (Housing and “maximise use of assets, insofar as the latter entails airport expansion) are clearly relevant and again potentially threaten the objective of reducing greenhouse gas emissions (and staying within Greater Manchester’s Carbon Budget).

With regard to the inadequate assessment of impacts on these environmental processes and resources, it is worth noting the government regulations on strategic environmental assessment (which form part of the integrated assessment). The assessment needs to assess the following.

f) The likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscapes and the interrelationship between the above factors. These effects should include secondary, cumulative, synergistic, short, medium and long-term permanent and temporary, positive and negative effects⁴.

We submit that the Integrated Assessment fails in meeting this requirement, since it does not take into account the systemic interrelations among these factors, including the cumulative impacts. Instead, a simplistic checklist approach has been taken, which is insufficient for proper understanding of impacts and how they combine.

We propose that the relevant (Strategic Environmental Assessment) sections of the Integrated Assessment be conducted again, to the required standard (or above).

The Health component of the IA is supposed to take a number of determinants of health into account. In particular we highlight “Climate change, Biodiversity, Natural Environment: Natural habitat; Air; Water; land”. These are listed but again the P4E objectives that are identified as covering them (10, 11, 12, 14) are limited to those that deal with these elements directly. However, as indicated above, P4E objectives 1, 2, 3, 4, 5, 9 will all impact on these determinants of health. The Department of Health HIA screening questions, quoted on page 17 (logical page number 23) of the IA report are (we have numbered them),

1. Will the proposal have a direct impact on health, mental health and wellbeing?

2. Will the policy have an impact on social, economic and environmental living conditions that would indirectly affect health?

3. Will the proposal affect an individual’s ability to improve their own health and wellbeing?

4. Will there be a change in demand for, or access to, health and social care services?

5. Will the proposal have an impact on global health?

We submit that the proposals in the plan under objectives 1, 2, 3, 4, 5, 9 will either directly or indirectly have impacts under all the above questions. This is because reducing access to green space, reducing the carbon sequestration resource and natural capital resource, and emitting significant constructional and operational emissions, will affect people’s opportunities for recreation and connection with the natural world, will reduce the scope for mitigating both greenhouse gas emissions and their impact, for populations locally and globally, and will with some likelihood indirectly lead to an increase in demand for health and social care services.

We therefore submit that the Health Impact Assessment component of the IA has not been carried out adequately.

We recommend that it be carried out again, to at least an adequate standard, utilising expert advice from the experts on the relationships between public health, the natural environment and climate change.

Carbon

This section expands on the comment on the Integrated Assessment, that the carbon consequences of the plan have not been properly assessed. If we are to evaluate a spatial plan then we need to understand the likely carbon impacts of development on what are now green spaces.

Freedom of information request and GMCA’s refusal.

A Freedom of Information Act (FOIA) request was made as follows on 17 August, 2021.⁵

1) Assessments and/or calculations of the projected carbon emission impacts of the Places for Everyone 2021 plan. This should cover,
a) Gains and losses of carbon sequestration due to proposed land use changes in the plan.
b) Embodied carbon estimates due to the proposed building programme in the plan.
c) Carbon impact of projected aggregate GVA growth that the plan assumes.
d) Carbon emission estimates from changes to journeys made by GM’s population and to transport infrastructure.
e) Carbon emissions estimated due to the proposed near doubling of flights from Manchester Airport.
2) Estimates made of the carbon emissions consequences (as defined in a, b and d above) for each of the 38 Green Belt Allocations identified in Places for Everyone.
3) In the event of the above information not existing, please supply details (including minutes, correspondence, reports) of the process by which it was decided not to make these assessments and how these relate to both the GM and UK government Climate Budgets.

GMCA responded to our request on 14 September with a refusal. They say that the information requested is in the P4E main document and supporting documents, referring us to several documents. Having checked those documents we can confirm that the information requested is not there. Most significantly, there are no calculations of the carbon consequences of the developments proposed and the green space lost.

Accordingly, we have made our own calculations to arrive at estimates of the likely scale of the carbon emission consequences.

Carbon metrics

The areas for consideration in understanding the carbon consequences of development break down into the following components.

1) The changes to carbon fluxes (that is carbon emissions versus capture, or sequestration) from the land.

2) The carbon emissions from the new development, a) the emissions from constructing the new development: average figures are around 0.34, 0.50, 0.67, 1.18 tonnes for 1, 2, 3, and 4 or more bed housing⁶, and b) ongoing emissions from the buildings, roads, etc.: this would seem to be in the region of 0.53 ktonnes p.a. for the year 2017-8⁷, c) the loss of locked up carbon in the soil and the biomass.

3) Carbon consequences of new economic activity as a result of the development. These are the knock-on, or multiplier effects of the development i.e. the carbon impacts of economic growth, not including the above two elements.

These notes deal with the first of these components, showing how estimates can be arrived at for the proposals to build on green spaces in Places for Everyone, the 2021 version of Greater Manchester Combined Authority’s (GMCA) strategic and spatial plan. The estimates that we have arrived at are provisional. There are a number of uncertainties and it was not possible to make a detailed assessment for each green space since we do not know the ecological breakdowns and as a small NGO we do not have the capacity to do such detailed work. However, our work can be treated as a “proof of concept”, that it is possible to make ballpark estimates of changes to carbon sequestration and emissions resulting from urbanisation, and moreover we note that any attempt to do this appears to be missing from the inadequate Integrated Assessment. The calculations that follow make use of the figures cited above on the loss of green space entailed by P4E.

Finding the relevant carbon flux figures.

The next step was to find figures for average emissions or capture from representative land types. There are a lot of uncertainties here. Reviews by Isabel Alonso and colleagues at Natural England do provide some estimates⁸. The review first appeared in 2012 and was updated this year. Not all the estimates from the early report appeared in the second report. I have used the later estimates where they are available.

The figures from the above reports are for annual carbon fluxes. However, what about the missed opportunity to improve carbon sequestration by the green land lost to development? To estimate this we used a figure quoted (but without a primary reference source) by the website Farm Carbon Toolkit⁹.

“Work completed by the FCT has demonstrated that every hectare of land that raises its soil organic matter levels by just 0.1% (e.g. 4.2% to 4.3%) can sequester approximately 8.9 tonnes of CO₂ per year at 1.4 g/cm³ bulk density). This is an extraordinary figure; in practice that is not only possible but being exceeded by farmers and growers building healthy soils.”¹⁰

Since not all the Greater Manchester green space would be suitable for such improvement, applying the above 8.9 tonnes figure to just 30% of the land would seem a reasonable procedure.

Applying emissions/sequestration rates (flux) to the green spaces to be developed under Places for Everyone.

Table 2 of the Greater Manchester Natural Capital investment Plan Baseline Review¹¹ gives areas for Greater Manchester’s Green Spaces as follows.

Greater Manchester’s Natural Capital assets (Broad UK habitats)	Area (ha)
Arable	9,264
Broadleaf woodland	11,118
Built-up areas and gardens	58,537
Coniferous Woodland	190
Freshwater	1,450
Improved grassland	29,871
Mountain, heath, bog	8,423 ( > 4,000 ha of which bog)
Semi-natural grassland	8,761
Total	127,613

The flux figures from the Natural England reports were then applied to these categories, where relevant. Built up areas and gardens and freshwater were excluded. As we do not have a category breakdown for the sites¹², the flux figures were applied first to the areas in the above table and then a simple ratio applied for the area of the green space to be lost. This will not be accurate, for example, there will be little development in the mountain heathland area but proportionately more in the grassland areas) but should serve to provide an order of magnitude estimate. The result is in the following table.

Natural Capital assets in GM (Broad UK habitats)	Area (ha)	Estimated kg sequestered annually	Notes
Arable	9,264	-2,686,560
Broadleaf woodland	11,118	119,518,500	This is average for woodland 30 and 100 years old (combined range 2-25.5 tonnes)
Built-up areas and gardens	58,537		not included as not subject to change
Coniferous Woodland	190	4,180	not given in 2021 report: used 2021 figure
Freshwater	1,450		Have taken average for lakes and ponds: carbon burial rate.
Improved grassland	29,871	10,754
Mountain, heath, bog 13	8,423 ( > 4,000 ha of which bog)	-1,684,600	Note that peatland is a large carbon store, but currently emitting CO2e. Not possible to give an overall figure due to diversity of peatlands nationally and in GM. Note, however, that Restoring Bogland from Drained to a Near Natural state Saves 3.46 tonnes / ha / yr
Semi-natural grassland	8761	0	Negligible carbon flux as in approximate equilibrium
Total	127613	115,162,274
Applied to the Places for Everyone Area	3511.7	3,169,076	3,092.3 ktonnes per annum
Applied to the Green Belt allocations only	2336.9	2,108,897

That is 25.35 ktonnes over the 16 year plan period) assuming that development proceeds at an even pace (16/2 x the annual figure).

This estimate makes no allowance for the opportunity cost of not making improvements to carbon sequestration in lost areas, e.g. by tree planting, wetland restoration, or improved agricultural practices. If 30% of this land raised its soil carbon content by 0.01% per year of the 16 years of the strategic period, then,
Additional sequestration per ha per year = 0.0089 ktonnes.
Additional sequestration for 30% green space loss per year = 9.4 ktonnes.
Additional sequestration foregone over the plan period = 150 ktonnes

Total estimated carbon sequestration cost of Places for Everyone = 175.37 ktonnes.

There would also be a further direct carbon loss due to development from released soil carbon and growing biomass. Using a total figure from Gregg et al. For the UK as a whole, I estimate that this would add a further 0.534 tonnes of emitted carbon per hectare, or 1.83 ktonnes for all the green space. This is small in comparison to the sequestration losses.

Furthermore there would be embodied carbon emissions from all the new build. From the housing alone we calculate that this could be in the region of 83 ktonnes.

What is concerning is that no attempt appears to have been made to assess this in the IA.

We acknowledge that a fair comparator for P4E is not zero development. It is up to the GMCA to suggest what a plausible null case for comparison would be. It is salient to point out that should the Green Belt allocations not be utilised,  some 65% of this lost sequestration could be avoided.

As Paragraph 1a of the Planning and Compulsory Purchase Act 2004 makes clear,

“Development plan documents must (taken as a whole) include policies designed to secure that the development and use of land in the local planning authority’s area contribute to the mitigation of, and adaptation to, climate change.”¹⁴

We submit that P4E falls far short of this requirement.

We propose that the plan be rewritten to a) estimate its carbon consequences and b) to build in proportionate and adequate mitigation and preventative measures, together with proposals for radically increasing the carbon sequestration from the City Region’s green spaces.

Growth assumptions

P4E makes very high assumptions about the overall growth of the Greater Manchester Economy.

This plan supports high levels of economic growth across Greater Manchester and seeks to put in place the measures that will enable such growth to continue in the even longer-term.

However, delivering these high levels of growth will become increasingly challenging. Beyond the slowdown in productivity growth seen across the UK economy, and increasing international competition for trade and capital, Greater Manchester also faces the challenges of accommodating rapid technological change, and political risks and economic shocks such as Brexit and Covid-19. Greater Manchester will therefore need to continue to invest in the sites that will make it an even more attractive place for businesses to invest, bringing high-value, well paid jobs, to the city region, and supporting the continued progress towards a low-carbon economy¹⁵.

GMSF Growth Option 2: “Meeting assessed needs” was the preferred one which informed the two previous versions of GMSF. However, “the assumed path of GVA for GM under the Accelerated Growth Scenario (AGS-2019) used to inform the GMSF Growth Option 2: “Meeting assessed needs” was, over this period around 2.4% pa.”¹⁶ i.e., despite the GMCA choosing option 2, it used option 3 (Accelerated growth) to inform it.

The Nicol report, commissioned by GMCA, suggests:-

1) Likely 2-3%¹⁷ smaller UK economy as a result of EU exit and Covid19. This works out at about -0.1% to -0.2% p.a. (note that this is cumulative). The AGS scenario had a “deliberately ambitious” 2.4% pa. There is evidence that GM is slightly worse affected than the UK economy as a whole.

2) Increased need for warehousing and logistics as a result of a 5% (residual) shift to internet shopping and need for higher stock inventories due to EU exit. However, SSM argue that the total volume of sales is not likely to be higher, and given economic scarring could be lower. The increase in Internet retail will be subject to a ceiling (it cannot increase for ever). Moreover, the biggest increase is likely to have happened already: this appears to have been absorbed by current infrastructure. (the Savills report cited by Nicol consulting) indicates that there is still a 5% level of spare capacity). “The effect of Covid-19 and the lockdowns has been to “supercharge” what was already an established trend”. So it seems unlikely that this will in the medium to longer term alter the level of requirement for this kind of industrial space.

3) There are some indications that demand for office space will decrease as a longer-term impact of working from home arrangements. Firms and other organisations have discovered that they can reduce accommodation costs by maintaining in part these arrangements.

4) There is uncertainty about the future pattern of housing need as a result of Covid-19 and EU exit. Household formation rates could reduce in the near term but affordability could increase due to reduced competition.

“As of March 2021, our conclusion remains broadly similar to that set out in August 2020. This was that given the significant degree of uncertainty that exists about future events and their implications for GM, there is not sufficient certainty/evidence currently available to inform a robust “reasonable alternative” growth option for purposes of the PfE 2021 Plan.”¹⁸

However, SSM argue that there is certainly no cause to argue for greater levels of growth. The consensus view of the UK’s annual growth rate in 2024 (after the misleading annual gains in earlier years, which are an artefact of recovery from the very depressed levels during the Covid lockdowns) is that growth will be well below 2%¹⁹. The annual rate for the North West in that year could be 0.2% below the UK rate²⁰. The question is what will be the reduction on the forecasts and scenarios that informed GMSF and continue to inform P4E?

It is worth noting that in the last 13 years there have been three major economic disruptions. The Great Financial Crash, the Global Covid pandemic, and Brexit. It seems, a priori, unlikely that there will not be further major economic shocks²¹ over the 17 years of the P4E plan. Therefore the economic scenarios used in P4E would likely be over-”optimistic”.

We submit that the plan has consistently over-estimated future growth rates. It has failed to make sufficient adjustment for the reduced GVA growth rate following recent and future systemic shocks.

We propose that the plan be amended to reduce the growth assumptions to no more than 1.5% p.a. overall. This should be supplemented by an assessment of the impact of moving to a steady state economy, the adoption of which is indicated by the climate crisis²².

Housing

Population

Population increase, 2021-2037 for the nine districts is now projected to be:

2021 (ONS mid year estimate): 2,554,000

2037 (P4E): 2,712,194

Change: 158,194 (6.19%)

Interestingly, the equivalent figures for the GM Area, i.e. including Stockport are
2021: 2,848,286

2037: 3,038,286

Change: 190,000 (6.67%)

In other words, taking Stockport out has decreased the projected population growth rate significantly: Stockport will now have to accommodate that change within its own boundaries, reducing pressure on the other districts, principally Manchester and Salford.

Households and housing

P4E projects building 164,880 homes over the 16 year period 2021-2037. That is 10,305 per year. Note that this figure is the result of using the standard government Housing Need Methodology.

This gives a ratio of 1.04 people per home. That’s an extraordinary ratio, although it assumes that the inhabitants of the new homes are those counted in the population growth figures. Instead, we should take account of the rehousing of people presently in the population and also assume that some of the population growth would be accommodated in the existing housing stock. To estimate that we can compare the two overall ratios of people per homes at the start and end of the plan.

2021: People: 2,554,000 Homes: 1,064,167 Occupancy: 2.4

2027: People: 2,712,194 Homes: 1,229,047 Occupancy: 2.21

But we should assume that some of the population growth would be assimilated by the existing housing stock.

If we did take the new average occupancy figure of 2.21, then the new population could be accommodated by 71,687 homes. Even if we took a mid point figure, between 2.21, the projected overall occupancy level (from P4E figures) and the apparent occupancy P4E assumes for new stock, 1.04, i.e. 1.625, then there would be a need for 97,350 new homes.

Yet the housing land supply in P4E is estimated at 170,385 before Green Belt allocations. That gives an excess of 73,035 housing units. Indeed, the sites identified as brownfield alone provide for an estimated 135,140 homes. Indeed, as Friends of Carrington Moss have noted,

“ even without the (20,000) green belt allocations, there is more than sufficient land supply (170,000) for every single expected additional member of our population (the increase of 158,200) to have their own home!”²³

Even if some of those sites turned out to be unfeasible, it seems unlikely that the additional population couldn’t be accommodated there, particularly as some of the increasing densification of housing (e.g. building several houses on an existing housing plot, or extending existing houses to accommodate additional family members, or to add flats) is not accounted for in the P4E projections.  Nor, apparently has an estimate been made of the impact of the  conversion of office accommodation to residential use.  While in some cases this has been undesirable, given the poor resulting quality, that need not be so.

We consider this grounds for GMCA to argue that it should not follow the standard Housing Need Methodology but instead apply one of its own, more appropriate to the characteristics of the GM population.

P4E identifies one location as a potential Green Belt withdrawal, the High Crompton Broad Location in Oldham [our earlier version mis-identified this as in Rochdale]. That land is not to be considered as a Green Belt allocation at this stage, awaiting demonstration that it is required. The same arrangement could be applied to most, if not all the allocations, rather than at this premature stage, assigning all of them.

We submit that the housing need projections are manifestly implausible. We acknowledge that this is a result of using the government’s recommended methodology. However, when it was seen how absurd the figures were, GMCA should have made the case that an alternative method should be used (indeed they did do something like this in the earlier stages of the GMSF process).

We propose a recalculation of housing need based on plausible occupancy and population growth figures. However, there could be an uplift for the accommodation of climate refugees²⁴ (internal and international) over the plan period.

We also propose that any Green Belt allocations be given the same status as the High Crompton location.  That will reduce the likelihood of developers opting for a greenfields first strategy and also reduce the risk of speculation and land banking.