Respond to the National Planning Policy Framework consultation

Strapline from government website, "Levelling-up and Regeneration Bill: Reforms to National Planning Policy"

The government is consulting on changes to the National Planning Policy Framework.  This guidance governs the way planing takes place in England.  It covers plan making, for example through the council-level local plans, and development management, for example in determining planning applications.

We think this is an important consultation with lots of opportunities to support needed reforms and to suggest further good practice and policy.

So, we’ve provided a guide to help you make your response easily.  It is a template for a response to all the questions in the consultation.

Please do share it and ask others to make a response. Here is the preamble from the template document – the necessary links for responding are in the document itself.  The deadline is 11.45pm on 2 March.

This is a “template response” for the government’s consultation on the National Planning Policy Framework.    It is what Steady State Manchester will be submitting.    While most of the wording is our own, for some questions we have drawn on draft submissions from Friends of Carrington Moss and the CPRE, where they have added to our own responses and where (as in most cases) we agree.    We are also grateful to the Community Planning Alliance for provision of a blank template with the questions.

As respondents, you may use the wording below, but we strongly encourage you to personalise and amend it.    You can also just use some of the material in your response and there is no need to respond to every question.

Click HERE for the template – it is a .docx format wordprocessor document that, depending on your browser settings, will open in another tab or window.  Please do contact us if you’ve any difficulty using it.

Here are alternative versions:  PDF file and
RTF webfile on cryptpad (open source alternative to google drive) read only.

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Community campaigners probe Labour position on Green Belt development


Save Greater Manchester’s Green Belt Group and Steady State Manchester have written to the leader of the Opposition (Sir Keir Starmer) on behalf of a number of GM community groups to provide evidence about the lack of justification for the release of Green Belt.  We have also requested his support to encourage the GM Mayor and Council leaders to remove the Green Belt allocations from the Places for Everyone (P4E) Plan.  Our alternative solution proposes that previously developed land (brownfield) is progressed as a priority and Green Belt is retained until need is explicitly substantiated.  At each 5-year review point for P4E, all newly available data can be examined and the release of Green Belt can be reconsidered following genuine consultation with affected local residents (which has NOT happened to date).

The email was copied to members of the Shadow Cabinet and Labour MPs in GM.  The full text of the email is available here.

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Places for Everyone: the carbon impact. Revised figures.

We have revised our previously published estimates of the carbon emissions that would occur as a consequence of implementing the Greater Manchester Combined Authority‘s (nine district) spatial plan, Places for Everyone.

That plan is currently going through an extended series of hearings, the Planning Inspectorate‘s Examination in Public.  We have commented here (and here and here) on  the sessions that have covered the overall strategy, the integrated assessment of the plan and some of the cross cutting policies.

We produced our estimates of the carbon impact of implementing the plan last May.  This we did because it seemed that the Combined Authority (GMCA) had not done this work, something that was confirmed by GMCA and the consultancy, Arup, that did the Integrated Assessment.  You might ask how the GMCA could possibly claim that their plan was consistent with the stated policy of carbon neutrality by 2038, if they hadn’t made any quantitative assessment of the emissions that plan implementation would lead to.  We remain puzzled too, despite the GMCA’s lawyer invoking the “Wednesbury precedent”, that it was reasonable for them to do this because other assessors would have done (or rather failed to do) the assessment in the same way.  Our invoking of the Cambridge plan, which did conduct quantitative modelling of the carbon impact of different spatial options, was dismissed as an outlier.  We contend that it set a standard that other plans should be following.

The hearings also produced some clarifications and changes to policies.  In summary these were,

  1.  The policy for buildings to be net zero by 2038 was clarified.  The plan was more ambitious than we had understood from the plan document, particularly on embodied emissions, so we have taken that into account.
  2. The GMCA has backtracked on a number of policies, net zero buildings is now something to be worked towards rather than an expectation, and it will be subject to ‘financial viability’ – the ‘get out of jail card’ routinely used by developers to avoid planning policy obligations.  These two reversals will mean that the net zero buildings policy implementation will be partial.  We have made an estimate to take that into account.
  3. GMCA also backtracked on some other aspects, namely the targets for affordability and the brownfield first preference.  We have not made adjustments to our modelling for these changes as their impact is uncertain, although the weakening of the brownfields first policy (viability again) will surely increase the take of green space and this will have some additional carbon impact.
  4. The Wildlife Trusts provided some evidence about the extent of deep peat in some of the development sites in the plan, and we have uplifted our estimate for the carbon escape from building on peatlands as a result.  The impact is not great in the scale of things (land-related emissions are small compared to the other classes of emission).

A further, and significant change has been made to our estimates of emissions from the increase in passenger numbers that the plan envisages.  Previously we estimated this by taking an average between the unmitigated emissions at current levels and a trajectory based on the UK’s carbon budgets, to net zero in 2050.  Since it is generally understood that aviation emissions can not be mitigated to anything like that extent, on the basis of known and likely technology change, and they would have to be mitigated by further reductions in the other carbon budgets, we have now used the guidance from the government’s independent Committee on Climate Change (CCC) which indicated that aviation emissions are likely to be at no less than 80% of current levels in 2050.  We have made a linear reduction of emission intensity, per passenger, over that period.  Since the CCC notes that most reduction will have to come from demand reduction, we think it likely that we are still being over-generous.  While the policy on the airport in Places for Everyone does not state that passenger numbers will double, other policies make that assumption and the narrative text also makes mentions of this ‘ambition’.  At best, we suggest that the GMCA is taking a laissez faire approach to this area of climate threat.

The changes we have made do not make any difference to our overall message.  Building on the scale envisaged in Places for Everyone will incur significant additional carbon emissions and that will make it difficult for the conurbation to stay within its stated carbon budget, which represents its fair of the Paris agreement, on the basis of a two thirds chance of staying within 2 degrees of average global overheating.

You can read the revised and detailed report, HERE.  Our methodology and assumptions are explained there and the detailed results presented.  We are also clear about the limitations of the work: we will welcome informed contributions to help refine our estimates.

Here are some snapshots of the data but do examine the report for the full story and explanations.

GM 2038 carbon budget and the carbon impact of Places for Everyone - bar graph
Note, all data is presented in tables in the report.

Overall emissions are down from our previous estimate, largely due to assumed mitigation of embodied emissions in buildings.

Pie chart: additional carbon emissions by sector.
Note, all data is presented in tables in the report.

This is the top level of breakdown by sector.  Here and elsewhere we show the additional emissions that the plan would cause.  Aviation, which is said to involve a doubling of passengers by 2037, would be the biggest contributor.

Places for Everyone additional annual emissions by sector (excluding aviation) - line graph.
 Note, all data is presented in tables in the report.This is what the emissions would look like year on year.  See how the embodied emissions fall after 2027.  That assumes they are successfully avoided (by using alternative, low carbon or carbon capturing materials, or by using offsets – problematic as we explore in the report).  We allow a generous 75% reduction in these embodied emissions.  Our previous estimates were over-generous regarding operational building emissions (making a double reduction for the government’s gas boiler ban and the local net zero policy) so we have changed our modelling to reflect what the policy should have stated (and will, in the proposed revision).  Although stock built after 2024 and after 2027 will have lower inherent emissions than that from previous years, the higher (operational) emissions levels will be ‘baked in’ – those buildings will be churning our emissions at a higher level than the later stock every year, unless the owners and occupiers took (costly and inconvenient) steps to retrofit them.

This is what that looks like cumulatively.  This is important since it is the total emissions over the time period that matters – greenhouse gases stick around for a long time!

Places for everyone, cumulative additional emissions (excluding aviation) stacked line graph.  Note, all data is presented in tables in the report.

Finally, let’s look at the two types of transport emissions on the same scale, again cumulatively.  You can see what a big problem all those flights are.  In both cases, again, we just show the additional emissions associated with Places for Everyone.

Cumulative additional emissions, aviation and other transport.
 Note, all data is presented in tables in the report.

And here, again, is the link to the new version of the report.

Finally, as you will probably have seen, the Secretary of State for Levelling Up, Housing and Communities and Minister for Intergovernmental Relations (to give Michael Gove his full, current, title) made an announcement before Christmas that has major implications for the planning system.  For Places for Everyone, it could reduce the level of housebuilding undertaken (we and other objectors believe this to be both inflated and of little real relevance to the housing crisis) and also encourage the use of brownfield sites.  While Gove has responded to back-bench Tory agitation, not the best recipe for policy change, we do consider his statement to be potentially helpful.  We will continue to monitor and report on developments and, if indicated, will update our estimates in the light of policy changes.

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Strategising Degrowth – book review

Degrowth and Strategy

Barlow, N., Regen, L., Cadiou, N., Chertkovskaya, E., Hollweg, M., Plank, C., Schulken, M., Wolf, & V (Eds.). (2022). Degrowth & strategy: How to bring about social ecological transformation. Mayfly Books. Available Picture of the book, Degrowth and Strategyas paperback or a free download at

The current economic and social system is the antithesis of the Viable Economy and Society. Resting on continued material and economic expansion, it fails to provide adequately for huge swathes of national and global populations, generating inequality and poverty on the many at the same time as it lavishes riches on others. Its constant expansion has reached the limits that the planet’s multiple and interlocked systems can bear, a situation of ecological overshoot, foreshadowing societal collapse.

That we need degrowth can surely be denied no longer, but how do we get it? How can we, those who understand the predicament and the need, and who struggle for something better, how can we get rapid transformation to a just and ecologically continent economy and society?

The business as usual people have a variety of improbable technological fixes, the green growthers have the Green New Deal, with all its problems but degrowthers have, somewhat unjustly, been criticised for not having a strategy. This book is an attempt to fill that perceived gap.

It is the product of an impressive collaboration between activists and scholars from Europe, both Americas, Africa and Asia, although with a majority from continental Europe. It came out of the work of Degrowth Vienna; their regional conference in 2020 focussed specifically on strategies. However, rather than a collection of conference papers, all 44 authors have written pieces specifically for the book. In doing so they all used the framework for exploring strategic change from the work of Eric Olin Wright.

Wright distinguishes between symbiotic, interstitial and ruptural strategies. Symbiotic strategies correspond to reformist approaches that try to change existing institutions and gaining the power to do so. Interstitial strategies try to invent and promote new arrangements in the spaces vacated or less dominated by the existing power nexus. Ruptural strategies seek to break with the existing institutions and social structures. They map loosely onto social democratic, anarchist and revolutionary approaches, but can’t be reduced to them. In an early and stand out chapter, Ekaterina Chertkovskaya relates these three to five of Wright’s later notions, resisting, escaping, taming, dismantling and smashing. She adds two additional ones, building alternatives and halting, and puts them all into a matrix, a “strategic canvas” for degrowth. This could look a bit rigid but as she explains, and several other authors demonstrate, the distinct modes interact, one, such as “building alternatives” can, under the right conditions increase capacity for “resisting” and “taming” and even lead to ruptural change.

Unfortunately, with the same framework used throughout the book, it can at times become rather over-formulaic, as at times the reader might have the suspicion of ‘writing by box ticking’, as authors put their examples into the pigeon-holes of Wright’s more basic three-fold conceptualisation. However, Chapters by Brand on emancipatory strategy, Koch on the State and Civil Society and Paulson on Strategic Entanglements I found thought-provoking.

The book covers a great deal of ground, especially in part two “Strategies in Practice”, with chapters on food, housing, technology, energy, mobility and transport, care, paid work, money and finance, and trade and decolonisation. I particularly liked chapters by Heindl on housing, Kreinen and Latif on paid work (with a case example on Gatwick airport), Aigner, Buczko, Cahen-Fourot and Schneider on money and finance, and Oyo on litigation in decolonial resistance.

Such a large piece of work (406 pages of quite small type), is bound to be somewhat uneven, and what seems plodding to one reader will enlighten another (and vice versa). I commend the team on a real achievement, one that anyone committed to a post-growth, degrowth, or steady state future will find useful, and which is likely to be a reference point for some years to come as we continue to struggle for a Viable Future for all.

Mark H Burton

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Places for Everyone, week 3 – Carbon emissions

pdf version

On Tuesday, 29 November, the Planning Inspectorate’s examination of Greater Manchester Combined Authority’s Places for Everyone (P4E) plan turned to its policies for sustainability.

Image of the first carbon policy page from the planOur particular interest has been about the plan’s proposals for reducing carbon emissions. There were two key elements in the original plan, both of which we support;

1) “The aim of delivering a carbon neutral Greater Manchester no later than 2038, with a dramatic reduction in greenhouse gas emissions.”

2) “An expectation that new development will … be net zero carbon from 2028.”

These are both quotations from Policy JP-S 2 Carbon and Energy, on page 87 of the published plan. (We reproduce this policy in its entirety, here.) The first comes from the 5 year environment plan which in turn was advised by the University of Manchester Tyndall Centre on Climate Change. The second came originally from the forerunner of Places for Everyone, the GM Spatial Framework: it is reproduced in the Environment Plan.

Changes at very short notice

Greater Manchester Combined Authority (GMCA) came to this session with a number of proposed changes to the policy. Some of these were a result of changes to the context since the plan was published – for example and upgrading of the building regulations. Others, however, were controversial and really should not have been announced in this way, such that those attending the hearings would not have time to consider them carefully. Luckily, we and our allies from Friends of the Earth, Save Greater Manchester’s Green Belt and the CPRE were well prepared and able to respond – to what effect we will discover later.

We picked up a problem with the wording of the first of the two key aims, becoming carbon neutral. We pointed out that “carbon neutrality”, is defined in the 5 year Environment Plan (Page 17, aim no 1) as, “For our city region to be carbon neutral by 2038 and meet carbon budgets that comply with international commitments”, and the Tyndall report, which underpins the plan, on page 3 defines carbon neutrality in 2038 as ‘emitting no more than 0.6 Mtonnes CO2 annually, just 3% of the 1990 levels’. However, there is no definition in P4E. We therefore suggested that this two-element definition be included, as a footnote, thereby correcting the vagueness in the aim as described.

It was in respect of the second aim, buildings being net zero carbon by 2028, that GMCA introduced two problematic changes.

Firstly, they wanted to change “An expectation that new development will be net zero carbon from 2028” replacing the words “An expectation…” to the weaker “Work towards…”

We argued against this on two grounds.

1) The wording was already not definitive: you can expect something but it won’t necessarily happen.

2) A further weakening of the aim will reduce the region’s ability to meet the requirement to be carbon neutral by 2038. As Manchester FOE pointed out, it will mean homes being delivered that then have to be retrofitted with better heat tightness, and better heating systems, before 2038. As we noted, that will place additional costs on the new occupiers (who would already be paying more than they would have needed to in fuel costs) and not on the developers who will have taken their profits by then.

It is pressure from the developers that is almost certainly responsible for this change.

There were some other changes proposed by GMCA to the wording. They conceded that footnote 31 is confusing and it was helpful that GMCA had on hand Adam Mactavish of the consultancy firm Currie and Brown to explain what was actually envisaged. He was one of the authors of the  first of three supporting papers on Carbon and Energy1 and the proposal had rather got lost in translation. He made it clear that there were actually three stages to the policy implementation.

From 2025, the critical requirement is that regulated operational energy use2 be within set limits (an 80% reduction in energy use). From 2025 to 2028, unregulated energy use3 would also be subject to set limits . Remaining emissions would be offset through a scheme devised by GMCA (see below). From 2028, the full UK Green Building Council definition of net zero buildings would be met, namely, both the operational energy use (that of running the building) and the building’s product and construction stages (including “embodied energy”) are negative or net zero. Note that, according to the definition, part of the former could be a result of electricity grid decarbonisation or local renewable generation, and some operational and construction emissions could be offset at each of the above steps – a question we’ll also return to.

We welcomed the clarification, especially the commitment to making the building’s embodied emissions negative, since these are the biggest (in the medium term) and most problematic element. We suggested the footnote be corrected to cover all three phases.

In a further concession to the developers, GMCA proposed adding the words “subject to viability assessment” to the policy on net zero buildings (even though the construction cost of low carbon buildings can be no more than 1 to 2.5% higher than for standard builds – a differential that will fall still further as low carbon building supply chains mature).  As we pointed out, the National Planning Policy Framework (NPPF) already has this provision which is widely used as a “get out of jail” card by developers, sometimes with the willing collusion of councils keen to get the supposed benefits of more building in their patch. So the addition of those caveating words looks like a kind of inverted “virtue signalling” – to the developers.  As we have seen, there are grounds for doubting the thoroughness of GMCA’s commitment to carbon neutrality: Places for Everyone, despite some good policies, is, as a whole, likely to make it harder for the region to avoid prematurely burning through the already overshooting carbon budget. This implied bending of the rules, or deferment of action, rings more alarm bells. That is notwithstanding the excellent proposals in the policy as published.


What about those offsets in the policy though? The Tyndall report that laid the ground for the GM carbon budget gave this advice4, which is worth reproducing in full.

Ambition for ‘carbon neutrality’ is often accompanied by commitments on ‘carbon offsetting’. Carbon offsetting refers to the purchase of a tradeable unit, representing emissions rights or emissions reductions, to balance the climate impact of an organisation, activity or individual. Although they can be stored and traded like a commodity, they are not material things; offset credits are not literally “tonnes of carbon” but stand in for them and are better regarded as intangible assets or financial instruments. To act as an offset, units must be cancelled to represent a reduction and prevent further trading.

In this report, the term ‘offset’ refers to the purchase and cancellation of tradeable units representing emissions reductions or sequestration outside the boundary of Greater Manchester to compensate for ‘residual’ carbon emissions. All carbon offset arrangements are open to criticism as being ineffective at reducing emissions. ‘Carbon neutrality’ achieved this way is an accounting procedure rather than a physical status. These procedures and the context under which they operate are liable to change through time, for better or worse. In light of this, we would not recommend entering into offset relationships. If GMCA identify financial resources and the necessity to pursue this path then they should i) only consider regulated systems and purchases, ii) revisit the available tradeable units at the time of purchase to consider which are the most robust and reliable, iii) recognise that this will be a controversial approach potentially drawing criticism, and public and professional cynicism.

The second Carbon and Energy background paper, from The Centre for Sustainable Energy5, looks into offsetting in detail, making recommendations for how such a scheme, for residual emissions, might operate in Greater Manchester. It is a very thorough report, with a lot of technical detail on the administration of a GM offsetting scheme in which developers would pay an offsetting levy for residual emissions. The recommendations are for a departure from the green washing kind of offsetting that is so common elsewhere.

The climate emergency, the UK wide 2050 zero carbon target and the Greater Manchester 2038 net zero carbon target fundamentally challenge the conventionally accepted approach to additionality and carbon offsetting, in that within these timescales, effectively all carbon emissions will need to be avoided or sequestered in carbon sinks.

Thus the timing and rate at which emission reductions are achieved is critical, in that if Greater Manchester is to meet its commitment to become carbon neutral by 2038, the residual emissions from new development would also need to be offset by the 2038 deadline rather than over the lifespan of the measure funded – which has typically been used in the past.

To give an idea of the kind of things that the Environment Fund resulting from offset payments could finance, they suggest, as priorities,

    • Energy efficiency retrofitting of housing (council housing and private rental sector), community and council buildings, including council run projects and funding applications from the community.

    • Community energy projects, adapting the Greater Manchester Low Carbon Fund to offer funding to community energy projects, or developing a new funding route, similar to the Urban Community Energy Fund

    • Domestic Renewable energy projects, for example a Greater Manchester Reverse Solar Auction and / or rooftop solar installations on council buildings

    • Carbon sequestration through tree planting and peat bog restoration

This is probably as good as offsetting is ever going to get. The scheme might not actually fully compensate for the emitted carbon (and monitoring arrangements are proposed, so we should eventually have a good idea about its effectiveness) but it would facilitate a significant degree of carbon reduction.

Developers’ stories

We heard a lot from the developers at this session. They were largely directed at reducing the strength of the sustainability policies, effectively increasing the wriggle room they would have to avoid aspects of the policy and so protect the levels of profits.

The GMCA’s “brownfields first” policy, (SP-1) was a particular bone of contention. In a particularly spurious argument, Christopher Young KC, representing Peel Holdings, suggested that it would increase homelessness and that greenfield sites, not brownfield sites deliver affordability. He referred to an article in Manchester Evening News that showed how few affordable homes had been built in Manchester and which analysed the causes of the surge in homelessness in the city. In fact, as the Evening News article made clear, Manchester’s homelessness problem is partly attributable to the council’s policy choice in Manchester to not build homes for social rent. That policy has been reversed following a backbench rebellion. By the government’s figures, delivery of affordable homes in general (and homelessness relates to a shortage of a sub class of these, with affordable, “social rents”) has been creeping up. Salford has a better record. In both cases it is clear that it is not the developers that will delivering a solution to homelessness. Some years ago, Salford established its own company to do just this, and Manchester has more recently done the same thing. There is a lot more to do, but the fact that developers in Manchester have been able to use the viability get-out to get planning permission for their many schemes gives the lie to the idea that unconstrained developer freedom will be a cure for homelessness (see this book review on the developers’ culpability for homelessness*). The idea that the kind of greenfield sites favoured by private developers will somehow be a solution to homelessness is specious: those developments are not developments for social rent either. While we are indeed critical of much of the P4E plan, we do commend the targets in it for the proportion of affordable and social rent homes.  However, on Thursday, that 50,000 affordable homes pledge was relegated from the policy to the descriptive text, effectively making it more of an aspiration rather than a commitment.

Another argument offered, this time by Ian Gilbert, for Barton Willmore, seemed to be that decarbonising buildings depended on the decarbonisation of Grid electricity. Now it is true that a lot of the recent reduction in UK territorial carbon emissions has been due to the closure of coal-powered generation and the increase in renewable energy. That trend will continue, but not fast enough. However the argument ,that this means that zero carbon homes cannot be delivered, makes no sense. It is possible to reduce operational energy to very low levels by making the building heat tight, using energy efficient heat sources (this usually means heat pumps). By generating energy at the building development, usually via photovoltaic panels, energy used in the home can be “paid back” into the grid (or, albeit with a greater demand on materials, in a local battery). To the extent that a surplus of energy is produced, and exported, then it is possible to achieve net zero carbon emissions. Embodied and construction emissions are certainly more difficult but do not come from the still carbon emitting part of grid energy.

Clean Air

It was a long day. In the main we wanted to be supportive to GMCA, which is at least committed to emissions reduction. However, we were not impressed by the late announcement of measures that would weaken the policies. Another topic concerned clean air, which is another policy on which the GMCA, and the mayor himself, has backtracked on shamefully with the unicorn proposal currently before government of a clean air zone with no charging. Friends of the Earth pointed out that the WHO guidelines on pollutant levels had been revised downwards since the plan was published and it was agreed that reference would now be made to the new levels. We anticipate that the government will reject the GMCA clean air zone proposal. In London, the Mayor has decided to extend the ultra clean air zone to most of Greater London – what a contrast.

You can watch the session here



*html version updated with further links to relevant articles, 4 and 6 December.

1 Carbon and Energy Implementation Part 1 – Technical Analysis

2 Energy use that is subject to building regulations, i.e. that used for space heating, hot water and lighting together with directly associated pumps (for circulating water) and fans (eg for ventilation).

3 Energy use not controlled by building regulations: In homes this includes energy use for cooking, white goods and small power (eg, TVs, kettles, toasters, IT, etc). Broadly speaking, energy for the things you plug in.

5 Carbon and Energy Implementation Part 2 – Carbon Offsetting

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Places for Everyone, week 2 – Green Belt and Airport

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 (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.

3Aviation 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 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.

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What has an arts festival to do with a viable future?


by Carolyn Kagan

An open air Chorlton Arts Festival Event with Jam Tribe

An open air Chorlton Arts Festival Event with Jam Tribe

Steady State Manchester’s keystone Viable Economy and Society points the way forward for a way of living that is environmentally, socially and economically viable. It points to a possible future where human flourishing is the focus of economic activity, within planetary boundaries – achieved through activity at different levels, from households and neighbourhoods to Governments and coalitions of Governments. A socially viable economy, inseparable from the economic and environmental economies is, in part, one founded on stewardship, of increasing human and social capital, that does not waste people’s energies and talents, including everyone; it is one with an increased space for non-commercial transactions, widely known as the collaborative or solidarity economy.

What are the social aspects of a viable future?

"Mini masters" from St John's Primary School - a display of many pictures

“Mini masters” from St John’s Primary School

A viable future will depend on acts of solidarity, connection, and living with abundance but not with current levels of consumption. It will be one where people’s needs can be met locally, in diverse and pleasant places.

Whilst much can be achieved through national and regional policy making, it is at the local, neighbourhood level that communities will develop resilience and become better places to live. This will be achieved through developing complex networks of contribution rather than exchange; care not individual advancement; shared purpose not competition and profit. We need to strengthen and build new social infrastructure – that is, the spaces and places that bring society together: a social infrastructure that enables conviviality – those forms of social organisation that enable social trust and mutual dependencies, not self interest.

One such activity that we have been involved with is the local community arts festival; the Chorlton Arts Festival.

The Chorlton community Arts Festival: a case study of building social infrastructure for a viable future

Graphic produced live by artist Jenny Leonard at the 2022 Festival launch

Graphic produced live by artist Jenny Leonard at the 2022 Festival launch

The Chorlton Community Arts Festival is an arts festival run by local people, for local people, involving local artists. It is not a festival that brings in elite acts to attract visitors from afar. It is a Festival in which everyone from organisers to artists to venue hosts are local and give their time voluntarily and are not paid.

This year’s Festival was throughout the month of May and involved 169 events featuring hundreds of individual, or groups of, artists; 7 schools and 45 local venues. In addition some community groups put on their own mini-festivals lasting a week or a weekend during the month.

Artists included visual artists; photographers; film makers; online graphic artists; musicians; singer songwriters; choirs; poets; dancers; literary artists; puppeteers; sculptors; environmental artists; crafters; performance artists.

Events included exhibitions; performances; plays; choral sessions; films; classical music; jazz; hip hop; world music; poetry slams; puppet shows; book readings; cabaret; comedy; DJ sessions; participative drumming; workshops.

Venues included: private homes; streets; cafes; bars; golf club; community centres; sports and social clubs; church halls; local parks.

Audience sizes ranged from 6 – 200.

How did the festival contribute to social infrastructure, conviviality and a viable future?

The carbon footprint of the Festival was tiny – we printed some leaflets and programmes, but being local meant transportation costs were very low. We collected information via surveys of artists, venue hosts and visitors, as well as from the volunteers attending events in situ. We found a number of things.

Both artists and visitors enhanced their sense of place – visiting parts of the neighbourhood they had not previously known.

The Festival was fully owned by the community – organisers, sponsors, patrons, and the great majority of artists were all local or had strong connections with the neighbourhood. The Festival built on strengthened and extended existing social networks and gave opportunities, in local places for people to meet and enjoy themselves, thereby building social capital. Many of the venues were commercial venues and audiences spent money on food and drinks, locally, rather than travelling out of the neighbourhood for social activities. The festival afforded opportunities for developing skills, for both artists and organisers and Festival volunteers. Looking through a well-being lens, the Festival was built on giving away expertise and talent and sharing with others; it enabled audiences to experience local art with wonder, taking notice of things they had never before experienced; some events opened people’s eyes and ears to historical threads of art or to the possibilities of learning new techniques, or to participate in a hands-on workshop; the festival enabled people to connect with friends and new acquaintances in convivial surroundings. As the Festival was local and everything was within a short walking distance, visitors to the Festival were able to keep active.

Craftwork making the link between art and food

Making the link between art, activism and food – Chorlton Craftivists

Most importantly the arts festival enabled people to enjoy themselves in the company of others – whether this as part of the organising team, meeting strangers in the same exhibition, talking to an artist, going with the family to drumming in the park or celebrating with other artists at the launch event. Cafes and bars and restaurants offered hospitable surroundings where art could be appreciated. For one month the streets of the neighbourhood resounded to joyous, thought provoking and often unexpected interactions and experiences.

One of the artists summed up the Festival:

It’s brilliant to be able to share in such a festival and to see and encourage all the talent in the area. A great opportunity to come together as a community


This micro example, a community arts festival, illustrates some of the features of a socially viable future. A local arts festival, open and inclusive, has a part to play in contributing to a viable future. Its elements prefigure, for a short time, different ways of living – ones built on care, sharing, conviviality, well-being, flourishing and resilient communities, a contribution to places that support good lives for all. It encourages a focus on collective well-being, on fostering connections with others and a sense of purpose not competition or profit. It enables people to experience in action values of stewardship, community and social justice.


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Places for Everyone hearings: the first week

post updated, 10 November

The Greater Manchester Places for Everyone Plan is now being examined in a series of public hearings by the Planning Inspectorate. As one of the parties that made critical consultation comments on the plan, we have the right to both submit written statements and to attend relevant sessions. This is a huge plan. There are three inspectors conducting the hearings which will continue until the end of March.

The venue for the hearings (via Google maps)

The first week has covered legal and procedural matters, the amount of land needed for building and the spatial strategy itself. We attended sessions on Thursday and Friday but also watched much of the livestream for the previous days. Our written submissions1 summarise and highlight points made in our “section 19” consultation response while our verbal contributions were able to focus and build on our submissions. We are told that everything submitted in both the consultation2 and in written statements will be considered as well as our verbal input.

The hearings follow a standard format with the inspectors asking questions, first of Greater Manchester Combined Authority (GMCA), whose team is fronted by a barrister, and then the other parties. The first three days illustrated the politics of development: massed ranks of developers, usually represented by their paid consultants or agents, sat along one side of the table, below the inspectors’ high table. On the other side sat community groups and individual citizens, mostly unpaid and voluntary. Despite the formal design of the hearings, they are conducted in a fairly informal way so that participants who are not used to such settings are encouraged and enabled to present their views. In fairness to all participants, the atmosphere is friendly and civilised despite our very real disagreements.  (Update: Place North West has an entertaining account of the first two days).

The procedural rules and agenda do nevertheless constrain the discussion, and this is a characteristic of the rules of the planning system itself rather than the individuals leading the sessions. So the discussion that we watched on day 1 of the flaws in the consultation process was limited to the question as to whether GMCA and the councils followed their Statements of Community Involvement (SCI) or not. This meant that questions of the quality of consultation were not deemed relevant, although the community groups did make their concerns known. An example: one authority placed a hard copy of the plan in each of its libraries. It did not make available paper copies of the supporting documentation. At the critical period, the libraries were apparently not open on Saturday or evenings, so someone working Monday to Friday would have great difficulty in accessing the plan. Because of the limited information and opening hours many people without broadband were unable to participate effectively in the consultation because 99% of the information was only available online. None of this apparently conflicted with the council’s SCI which committed to putting a hard copy of the plan in the libraries. Similarly the intelligibility of the very wide and long tables in the Integrated Assessment report, which would really require a multi-screen set up to scan and to make proper comparisons, and when printed have text too small to read, apparently did not contravene the legality of the consultation. As we have shown and argued elsewhere3, consultation on public policy is generally very poorly conducted.

We also watched the sessions concerned with how much land is needed for development. Clear evidence was presented by Save Greater Manchester’s Green Belt that the housing need figures used are inflated. CPRE endorsed the point that housing built recently exceeds the rate of household formation and there is a case for exceptional circumstances to be made for a different housing need methodology from the government’s prescribed standard one (we made the same call in our consultation response). GMCA reject this argument saying that they have adopted the “safe haven” of the standard methodology. That methodology uses 2014 population estimates which have since been shown to be inflated. Indeed we now have the far more dependable 2021 census figures. Some safe haven! Developers of course push for more and more building, reiterating that they support a higher figure. Lichfields for example pointed out that the standard method set the floor, the minimum need, not the number that will be built, which could be higher, yet they still advocated a higher level of economic growth as per the Plan’s rejected growth option 3. In this case the constraint comes from the government policy of using those outdated population figures to forecast housing need. No local authority to date has successfully argued the case for using an alternative method and there was a long process of lobbying by Greater Manchester leaders on just this point at an earlier stage of the process. Sadly they appear to have thrown in that towel and accepted the palpably absurd method.

We were similarly rather constrained by the parameters of the discussion on the sustainability appraisal (or more formally the Strategic Environmental Assessment, part of the plan’s Integrated Assessment). Here we had to argue that the assessment was not legally compliant, in other words not sound. While we think we, with colleagues from Save Royton’s Green Belt and Friends of Carrington Moss, did this, the argument from GMCA’s barrister was that so long as the assessment would be judged reasonable by someone (implicitly another professional) carrying out this assessment task then that was sufficient. In response we made the point that without any quantitative estimates of the carbon impact of doing all this building, it was impossible to either assess the environmental impact or compare spatial options adequately. Whether or not the sustainability appraisal met the requirement of legality, it did not provide GMCA with the quality of information needed to understand the environmental impacts of the plan. We will have to wait and see what the inspectors conclude. Meanwhile we have carried out our own evaluation which highlights the large carbon impact of all that building.

On this question of carbon impacts, there are some helpful precedents. Firstly, the sustainability assessment for the Cambridge Local Plan did make quantitative estimates of the carbon emissions from each of the spatial alternatives considered. While GMCA seemed to imply that this was an outlier, we would argue that it establishes a standard that other plans should follow.

Secondly, last year the controversial Tulip proposal in the city of London was rejected by the Inspectorate on the grounds that the very high levels of embodied carbon (i.e. carbon emissions that take place where the building materials are extracted, transported and processed) were not deemed to be justified by whatever benefit the tower might bring. The high, and difficult to mitigate levels of embodied carbon inherent in a programme as ambitious as Places for Everyone are a material consideration too in the light of the requirement to consider climate in Local Plans (Places for Everyone is a Joint Plan that covers the more strategic elements of the 9 districts’ Local Plans).

Update:  However, in two rather ominous developments, 1) we read that in West Oxfordshire, the Planning Inspectorate has decided to remove critical climate targets from the proposed West Oxfordshire Area Action Plan for a new garden village. The Town and Country Planning Association argue that the Inspectors have misunderstood the law in relation to carbon targets.  2) We have also been told that the Inspectors will not add our carbon impact report on Places for Everyone to the Examination documents database.

On Thursday, we were not alone in arguing that GMCA should have considered a spatial option that reflected current thinking in many world cities, that of the polycentric city or city region where citizens can meet most needs within their local area (often articulated as the 15 or 20 minute neighbourhood). Instead, GMCA persisted with what another participant characterised as a backward looking model with its specialist areas for housing, commerce and industry, which bakes in high levels of travel. While GMCA argued that they did not have to consider all possible alternatives, we contend that this is a well established alternative that forward looking cities should consider in these times of climate breakdown for improved liveability and attractiveness of localities.

One thing struck me with force: Places for Everyone would build on some 13 square miles of what is currently green space, much of which, but not all, is in the green belt that reaches into the conurbation, separating the distinct population clusters. Come the end of the plan, when that has been lost, should things continue in the same way (the threat of economic and social collapse4 suggests they might not, of course), then that green space will have gone, effectively for ever, and the developers will come again for yet more. Might we one day say, “the city is complete: let’s stop building”?

The sessions will resume after a two week break: there is a lot more to be said and covered, and we will be attending sessions on Sustainable and Resilient Places (Including carbon issues) and on Greener Places (Habitats Regulation Assessment).

1 Available on the Examination Documents List, from the inspection website:

2 Available on the Supporting Documents List, from the inspection website: see SD75 to SD 85.

3 A Viable Future (2021) section 8, ‘Done Deals: citizens and urban planning’.

4 See the Postscript to A Viable Future, our book referenced above.

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