The Planning Inspectorate continues its Examination in Public of Greater Manchester’s nine district Places for Everyone joint spatial plan (known as P4E). We previously reported on week 1. Last week they discussed matters concerning the brownfields first policy, the justification for the need to release green belt for building, and the methodology for selecting sites. Then they went on to policies covering the different key strategic areas, the urban core and inner areas and the northern and southern belts of development. We didn’t attend this week but watched a number of the sessions on the live stream, now available on YouTube – see https://www.hwa.uk.com/projects/gmca/ (events still listed as livestreams that have already taken place are available as recordings at those links). So we will just pick out a few interesting points that emerged.
Brown and Green
The developers, as we’d expect, pushed hard to make the case that a) brownfield first threatens the economic viability of their developments (ie. profitability, but expressed via a standard formula, which is covered in the background papers to the plan), especially if the plan’s proportions of “affordable” units are included. b) Secondly they argued that they will need more green belt land to be released. No surprises there. GMCA make a flexibility allowance when putting the scale of development from their (we believe flawed) modelling against the known land supply on non-protected land. It is that allowance, also known as the “buffer”, that makes their case for taking green belt land – otherwise there would be enough land available in the urban area. The developers contend that the flexibility allowance is set too low. The environmentalist and community groups, the “peasants, according to a recent blog, that was presumably alluding to the power and resources imbalance, contend the opposite – the buffer is too big.
From the various discussions we learned that while P4E sets out what the GMCA and the constituent councils believe to be the land requirements at this time, the Local Plans made by each council could subsequently make the case for exceptional circumstances to take more land from the green belt. At this point it is worth noting that “green belt” is not just a ring around Greater Manchester but includes stretches of land reaching into its heartlands. In our consultation response we drew attention to the precedent of High Crompton in Oldham. Originally one of the green belt ‘allocations’, it is now all on its own as a ‘broad location’, a kind of reserve list:
“The land will remain in the Green Belt until such time that a review of this Plan and / or the Oldham Local Plan can demonstrate that it is necessary.”1
Now, if this land can be held back until there is a clear case for its use, then why not the other green belt allocations: from allocations to broad locations? For housing, the biggest taker of land, the government does not require a land supply pipeline to be in place for the whole plan period. Following the precautionary principle, i.e. protecting green spaces, preventing land values escalating and planning blight setting in, all the allocations could still be in a flexibility buffer but not designated sites for development until the case is properly made. If this is not done, then we know what will happen, they will be built on, the soil sealed, the living biomass removed, the sprawl added too, well before there is a clear case that they are required for a rational plan of development. As it is, it works like a ratchet: get the green belt allocations listed in P4E so they go into the local plans and then the local plans could add further land. Easy to put in – hard to take out.
How were green belt sites chosen for building on?
We heard rather a lot about the site selection criteria. These criteria were established in 2019 after the initial listing of the development sites in 2016. The suggestion was made, to the indignation of Christopher Katkowski KC for GMCA2, that officers had reverse engineered the criteria so that the bulk of sites were included. It may be more the case that the criteria are insufficiently clear, and they lack key elements, so that sites got included too easily. Either way, it is process biased towards their inclusion. Peasant objectors also made the case that the criteria failed to include sufficient environmental and climate-change related criteria, notably the presence of peat. We learned that, according to the Wildlife Trusts, using publicly available data from Natural England, eight of the allocations, including the largest, ‘New Carrington’, include deep peat, which as we know is a very significant carbon store, with prospects for enhanced sequestration of carbon given restoration and appropriate management – indeed P4E proposes to do just that in respect of non-allocated peatlands. We also learned that, like as in the flawed Sustainability Appraisal, all criteria had equal weight, which is at best counter-intuitive.
Does the plan really aim at doubling journeys from Manchester Airport?
On Friday, the policy covering the airport was discussed. Now these P4E policies are the bits of text on a yellow ground. The Inspectors made it clear that these are the key bits they are interested in, and not what was described as the “purple prose” surrounding them. Environmental groups, ourselves included have been very critical with the aspiration in the plan that the number of airport passengers could double by 2037. As we stated in our written submission,
“Using the Committee on Climate Change aviation decarbonisation trajectory (reduction of carbon intensity per flight unit of 20%)3 and applying it to a doubling of Manchester Airport’s flights (current emissions level, 121 kg per passenger4), indicates an increase in CO2e emissions in the order of 23 Mtonnes.”
Now because this doubling of flights was not mentioned in the relevant policy, Policy JP-Strat 10, the matter was not pursued. Yet although this growth in aviation was not mentioned in this policy which it even claims will be “delivering a sustainable world class airport which will help to address issues raised by climate change”, it is clearly implied in other policies in the plan, namely,
Policy JP-J 1 Supporting Long-Term Economic Growth para G iv:
“…the expansion of the airport as the UK’s primary international gateway outside London and the South East..”
Policy JP-C 6 Freight and Logistics para 3:
“…the expansion of air freight activities at Manchester Airport….”
In addition to these, are we to ignore the multiple references to the expected growth of the airport throughout the rest of the document?
We did hear the airport’s representative talk about the airport becoming net zero by 2028. Now, any reduction in emissions is to be welcomed but these targets apply to ground operations and domestic flights. The latter account for just 4% of UK attributable flight emissions.
There is no credible strategy in place for seriously reducing the emissions from aviation, other than demand reduction – i.e. less flying, but P4E chooses to ignore this physical reality. It really does seem as if, despite the relatively ambitious policy on carbon emissions, the airport is to be left to destroy our chances of making a fair contribution to the global effort to keep greenhouse gas emissions within supposedly safe limits.
1 Places for Everyone, page 62-63. The plan goes on, “ The opportunity presented by the High Crompton Broad Location would serve to meet future employment and housing needs and demand of businesses and local communities in this part of the conurbation well beyond the end of the Plan period.” It might as well say, “Oh yes, we’ll continue to concrete over green spaces after this planning period finishes. High Crompton, you have a deferral, not a reprieve.”
2 Familiarly known as Kit Kat, as he told us on the first day.
3 “Aviation emissions could be reduced by around 20% from today to 2050 through improvements to fuel efficiency, some use of sustainable biofuels, and by limiting demand growth to at most 25% above current levels. This is likely to be cost-saving. There is potential to reduce emissions further with lower levels of demand” https://www.theccc.org.uk/wp-content/uploads/2019/09/Letter-from-Lord-Deben-to-Grant-Shapps-IAS.pdf However, “sustainable biofuels”, at least at the scale required here, is almost certainly a chimera.
4 Manchester Airport Group, Greenhouse Gas Emission Report, 2019/20. Page 12. Table 9. GHG Emission inventory, Manchester Airport. https://www.magairports.com/media/1688/mag-emissions-report_2019-20_final.pdf