Greater Manchester Integrated Support Team,
P.O. Box 532,
Manchester Town Hall,
Albert Square,
Manchester, M60 2LA.
Monday, November 3rd, 2014
Dear Integrated Support Team,
GREATER MANCHESTER SPATIAL FRAMEWORK STAGE 1 CONSULTATION
ON INITIAL EVIDENCE ON FUTURE GROWTH – SEPTEMBER 2014
The North West Transport Roundtable (NW TAR) is an organisation that promotes sustainable transport and land use. We operate under the auspices of the Campaign for Better Transport (CfBT), formerly Transport 2000. We have much experience of interacting with spatial planning processes especially the Regional Spatial Strategy, and would like to be registered as stakeholders in the preparation of the new Greater Manchester Spatial Framework (GMSF).
Over-arching comments
NW TAR is aware of today’s announcement about the devolution of power from central government to the Greater Manchester Combined Authority (GMCA) and welcomes the idea of a sub-regional planning strategy for the whole of Greater Manchester. A good spatial planning document should be genuinely sustainable and should reduce the need to travel. Our concern is that the GMSF should not become an economic growth strategy that simply mirrors the expansive aspirations of the Local Enterprise Partnership (LEP). From the outset and throughout its evolution this sub-regional spatial plan must retain that all-important balance between economic, environmental and social issues and work within environmental limits. It must comply with the National Planning Policy Framework which opens with a reminder of the United Nations General Assembly’s definition of sustainable development, ie:
“meeting the needs of the present without compromising the ability of
future generations to meet their own needs” (Resolution 24/187)
and the NPPF goes on to quote the UK’s own key sustainability principles:
“The UK Sustainable Development Strategy ‘Securing the Future’ set
out five ‘guiding principles’ of sustainable development: living within
the planet’s environmental limits, ensuring a strong, healthy and just
society, achieving a sustainable economy, promoting good governance
and using sound science responsibly”. (Para. 5, NPPF, March 2012).
Question 1: Do you agree with the general scope of the document? Do you think that anything else should be included within its scope and, if so, what?
Answer: The scope is not sufficiently well balanced. Its perspective is primarily economic based. It needs to broaden out to cover all the aspects that a spatial plan should be expected to cover, particularly quality of life and environmental issues. To accord with Planning Practice Guidance, this Plan should cover air quality, climate change, flood risk, light pollution, noise and important open spaces, sports and recreation facilities as well as tackling how to reduce the need to travel and achieve modal shift. All of these issues cross Local Authority (LA) boundaries.
Question 2: What do you think should be the end date of the GMSF?
Answer: 2033.
Question 3: Do you agree with the proposed process? If not, how should it be amended?
Answer: Yes. We note the promise that it will be thorough and inclusive.
Question 4: Do you agree with the proposed approach to consultation? If not, what do you think we should be doing differently and how?
Answer: Yes.
Question 5: Do you agree that the Vision from the Greater Manchester Strategy should be the basis of the Greater Manchester Spatial Framework? Please identify anything else that that you think should be included in the Vision for the GMSF.
Answer: The Vision would benefit from improvement. It should:
· promise to prioritise the regeneration of those areas most in need
· endorse ‘Smart Growth’ principles and commit to improve the ‘liveability’ of urban areas
· agree to reduce the need to travel through the establishment of sustainable communities
· adopt sustainable transport policies and commit to better facilities for active travel
· recognise that all citizens deserve access to open spaces, countryside and clean air
· re-endorse Greater Manchester’s commitment to reducing carbon emissions
Question 6: Do you agree with the four principles for identifying the area of assessment? If not, what approach would you suggest?
Answer: The four principles identified in paragraph 4.12 are all supportable but there also needs to be one to ‘Monitor and Manage’.
Question 7: Do you agree that Greater Manchester is the appropriate unit of analysis for identifying employment land requirements? If not, what geographical area would you suggest would be the appropriate unit of analysis and why?
Answer: It was very evident when the LEPs’ Strategic Economic Plans were submitted to BIS that all were going for high growth. There appeared to be little or no consideration of adjoining areas and there was undoubtedly an element of double-counting. In order to avoid this in future in economic and land planning, consideration needs to be given to the plans of the adjoining LAs.
Question 8: Do you agree that Greater Manchester is the appropriate unit of analysis for identifying housing land requirements? If not, what geographical area would you suggest would be the appropriate unit of analysis and why?
Answer: In the compilation of their Local Plans, LAs are obliged, via the Duty to Co-operate, to consult with adjoining LAs. This process works quite well on housing matters and is tested by inspectors during the examinations in public on the Local Plans. That said, see the next response.
Question 9: What analysis do you think should take place at the next stage in relation to submarkets within Greater Manchester and potentially extending into neighbouring districts? Are you aware of any specific sub-markets that it will be particularly important to consider and, if so, what do you consider are the boundaries and issues for that area and why?
Answer: It would be best practice to give consideration to adjoining LAs which share a sub market profile – if only to ensure that there is no over provision.
Question 10: Do you think that the 2013 GMFM scenario based on the ONS 2012-based sub-national population projection for Greater Manchester (referred to in the tables above as ‘2013 GMFM higher population growth’) provides a reasonable basis on which to plan? If not, what forecast do you think should be used and why?
Answer: It does not provide a reasonable basis as the population growth estimates were revised downwards by the Office for National Statistics in June 2014. When these lower figures are translated into household growth estimates, these should form the basis for the GMSF.
Question 11: Do you think that Greater Manchester should be seeking to attract more regional and pan regional employment and investment functions? If so, what type of activities do you think could be captured and where?
Answer: Whilst it is entirely appropriate that Greater Manchester should seek to attract more employment and investment functions, the ‘planning’ around this activity should not assume that more jobs equals the need for more land to be allocated for employment. There is a very strong and growing trend for more home working. Already in the North West, according to the ONS, over 12% of people with jobs work from home all or part of the time.
Question 12: Do you have any other industrial and warehousing market information that should be taken into account?
Answer: It is essential that an up-to-date employment land survey is carried out in order to ascertain how much employment land is being utilised, how much is vacant and where land currently allocated for employment can be re-allocated for other uses.
Question 13: Do you have other office market information that should be taken into account?
Answer: Now that office buildings can legitimately be turned over to apartments, there needs to be an assessment of the unused office buildings that exist to establish where office buildings could be re-modelled, especially in the light of the continuing escalation in home working.
Question 14: Do you agree that these are the key attributes/ opportunities that could help to boost Greater Manchester’s economic competitiveness? If not, what other key attributes/ opportunities should be taken into account?
Answer: The attributes that help to address economic competitiveness are many and varied. When competing globally for talent, a key factor is the ‘liveability’ of towns and cities. This includes factors such as the quality of the public realm and cycling and walking experiences within them. These issues influence young highly qualified workers. We also note that no value appears to have been placed on the countryside. This is a major failing. The setting of cities and towns and access to the countryside are crucial as are attractive open spaces within urban areas.
Question 15: Do you agree that it is appropriate to assume that the continuation of past development rates for both new office floorspace and new industrial and warehousing would be consistent with the 2013 GMFM baseline employment forecasts? If not, what assumption do you think should be made?
Answer: Past assumptions are definitely not the basis of planning in respect of employment land requirements for the reasons already stated. Home working has been growing rapidly. This upward trajectory should be factored into future land use planning for employment.
Question 16. Do you agree that it is appropriate to assume an average 10% vacancy rate in new employment floorspace? If not, what figure do you think should be used and why?
Answer: There clearly needs to be a small amount of leeway to enable the market to function but, bearing in mind that the growth in home working means that less and less employment floorspace will be required in future, a lower percentage is probably appropriate.
Question 17: Do you agree that it is appropriate to assume an average office job density of 14m2 gross internal area per full time equivalent employee? If not, what figure do you think should be used and why?
Answer: Ever more employees are hot-desking and working from home more of the time, a trend that will increase with the universal roll out of fast broadband. The result will be a reduced need for floorspace for office workers. We suggest that 10m2 would be more than adequate.
Question 18: Do you agree it is appropriate to assume an average industrial and warehousing job density of 59m2 gross internal area per full time equivalent employee? If not, what figure do you think should be used and why?
Answer: We would suggest aiming for a lower figure. Land should be treated as the finite resource it is. We suggest something closer to 50m2.
Question 19: Do you agree that it is appropriate to assume an average 48.8% displacement rate for jobs in any new employment floorspace provided above past development rates? If not, what figure do you think should be used and why?
Answer: Reading paragraph 6.90, it is apparent that insufficient evidence has been gathered on this subject. More evidence needs to be collected before it is possible to answer the question. As already stated, in response to Question 12, there is a need for an employment land survey.
Question 20: Do you agree that a 12% uplift in industrial and warehousing development rates compared to the average over the period 2004-2012 is the minimum that Greater Manchester should be planning for over the period 2012-2033?
Answer: No, we do not agree. There is no evidence to support this. Before deciding what the uplift should be, there needs to be a full employment land survey. In any examination in public into a spatial plan, a planning inspector is going to expect to see an employment land survey.
Question 21: Do you agree with the three options for industrial and floorspace provisions that have been presented? If not, what other options do you think should be considered?
Answer: Here again, we would call for a full employment land survey to establish what uplift is required. We suspect the actual requirement is probably quite modest.
Question 22: Do you agree that Option 1W1 is the most appropriate basis on which to plan?
Answer: No.
Question 23: Do you agree that an average plot ratio of 35% is appropriate for new industrial and warehousing? If not, what figure do you think should be used?
Answer: This seems high.
Question 24: Do you agree with the three options for office floorspace provision that have been presented? If not, what other options do you think should be presented?
Answer: We do not agree. See our answer to question 17.
Question 25: Do you agree that Option OFF3 is the most appropriate basis on which to plan?
Answer: No, it is not sustainable to assume that over-optimistic modus operandi are appropriate. It is essential that the dramatic rise in home working is taken into account. Working patterns are changing and the approach to planning for a future workforce needs to change. We suggest that OFF1 on page 104 - or less than that - would be a far more appropriate basis on which to plan.
Question 26: Do you agree that the use of an average plot ratio for offices would be misleading? If not, what figure do you think should be used?
Answer: No: The problem with average plot ratios is that they are based on historic trends. Trends are changing rapidly. Less people are working full time in offices. More are working part time or full time from home. It is imperative that GMCA/ AGMA factor into all their calculations the huge change that is taking place in the workforce that is evident from the ONS data.
Question 27: Do you agree with our assessment of the industrial and warehousing floorspace requirement for Greater Manchester over the period 2012-2033? If no, what would you suggest an alternative assessment would be and how would you calculate this alternative?
Answer: We do not agree for the reasons already stated in response to a number of previous questions. Please see answers to questions 11, 12, 15, 18, 20 and 21.
Question 28: Do you agree with our assessment of the office floorspace requirement for Greater Manchester over the period 2012-2033? If no, what would you suggest as an alternative assessment would be and how would you calculate the alternative?
Answer: We do not agree for the reasons already stated in response to a number of previous questions. Please see answers to questions 11, 13, 15, 17, 24 and 26.