Manchester: Core Strategy Examination Documents 2011. Response to Inspector's Questions from Friends of the Earth

24th November 2011

Friends of the Earth response to the Core Strategy public inspection  (Manchester City Council) 2011.

Matter 1: Compliance with Legal Requirements and General Approach.

Q9. Are there any other general aspects of Chapters 1-5 which describe the context, vision and objectives which could be considered unsound?

SO2 states that “The growth of Manchester Airport in line with the Air Transport White Paper will entail a significant increase in employment.” Based on previous evidence, claims of job creation are wildly over-exaggerated – for example Manchester Airport’s second runway was originally purported to create 50,000 new jobs but in reality, five years after the runway opened, the figure was nearer to 4,000. [1] This sentence should therefore be removed.

Matter 2: Economic Policy

Q3. Is the plan in general conformity with RS on the role of the regional centre and economic growth/ employment land provision?

Q4. Is there tension between the first two bullet points in Policy SP1 of the plan, or uncertainty as to whether there should be one or two priority areas for growth?

The proposed expansion around the airport is in conflict with regional policy. The airport was not identified by the North West Development Agency in its list of potential strategic regional sites that were part of development of the Regional Spatial Strategy (RSS). The RSS did not identify the airport as a suitable site for major economic development, instead setting out that any regionally significant business development that is not required for the operation of the airport should be in accordance with the sequential approach and prioritising regional centres (Policy W2; Policy RT5 section
8.20). [2]

The Panel report from the examination in public (March 2007) states:
“we have not indicated the airports as particular centres for growth though
operational development will clearly take place on a substantial scale. In general, however, their edge of town locations and surrounding Green Belts do not fit with our spatial principles for most forms of development” (para. 4.68). “Manchester Airport is a Green Belt area where a policy of restraint applies. We consider that the economic development that it generates, for purposes that are unrelated to aviation, should be subject to the locational  criteria recommended in our proposed revision to Policy W2. The same applies in respect of the region’s other airports. They should not be identified as nodes for major economic growth” (para. 7.48).

Q5. The benefits of physical proximity between firms and high levels of economic activity, known as agglomeration, are mentioned in the evidence base. Is there a risk that agglomeration in the regional centre could be undermined by the planned expansion to the south around the Airport?

Q25. On Policy EC11, is economic development at the Airport a sound
strategy to tackle the problems of Wythenshawe, or would it be preferable to improve public transport links to a wider range of other employment locations and foster small business development locally?

A report by CPRE [3] critiques the economic case put forward for an Enterprise Zone (EZ) at Manchester Airport City and highlights the unsustainability of airports as a location for an EZ. The report finds that based on current evidence it is likely that development which would have gone elsewhere in the region will be attracted to the EZ so that jobs are relocated rather than created. Furthermore, the benefits to urban regeneration of Wythenshawe – as claimed is a key beneficiary – do not depend in any major way on the proximity of the Airport and associated developments, but rather on a wide range of other measures, particularly
social mobility and training.

Q14. Is Policy CC2, with the suggested changes, sound? Is the figure of a minimum of 4,500 sqm net convenience floorspace justified? Is “within the City Centre or as close as possible” consistent with the sequential approach or could it be misconstrued?

Q15. Is it appropriate for paragraph 8.30 to seek larger format convenience floorspace in a City Centre environment with high density development, restrictions on car parking, and potential new demand from small households who may not need access to a superstore? Is Policy CC2 at odds with providing support for the independent retail sector?

We do not think an additional 4,500 sq. m. of convenience floorspace is justified given the recent proliferation of convenience format city centre stores, and we would also question whether additional larger format convenience floorspace near the city centre is either appropriate or desirable. There is already substantial new retail capacity being developed in nearby areas such as the 100,000 sq. ft. Tesco in Old Trafford, and
additional large format stores will also threaten retail diversity.

Independent retailers are operating in a fiercely challenging environment with
unfavourable economic conditions and dominance of the grocery sector by a handful of retailers with the power and resources to use the planning system to their advantage. The current planning system is already stacked in favour of the major retailers over small businesses and communities, with 82% of all retail floorspace approved in 2010 going to the big four [4]. Research earlier this year found that supermarkets are in the middle of an ‘unprecedented expansion drive’ adding another 20% of space in the next three years including convenience floorspace [5].

And the new national planning framework will tip the balance further in favour of the dominant multinational supermarkets over independent food retail – there is no policy in the draft NPPF to support retail diversity. Therefore, it is essential that the Core Strategy plans positively for retail diversity and to support the local economy.

We are also concerned that paragraph 8.30, when taken in conjunction with paragraph 8.31 (which states that new large format convenience provision is unlikely to be found in the heart of the city centre and therefore ‘the Council will support sites which offer the most sustainable connections to the City Centre’ and ‘availability of car parking’), will mean this policy will not deliver sustainable patterns of development, will further entrench reliance on the car, and will not support local independent food retail.

We also question other aspects of paragraph 8.31, specifically the regeneration benefits of large format superstores: ‘The potential for food store development to include associated elements which contribute to wider regeneration priorities is also important. The Council will take account of this contribution, especially in terms of economic development (with reference to policy EC1) and public realm, when assessing proposals for City Centre food stores.’  The negative impact of supermarkets on jobs and local economy is well documented. For example, the development of a supermarket has been shown to result in a net loss of jobs and retail diversity, with one major study finding a net loss of 276 jobs with every new superstore. [6] Research has also highlighted the huge inaccuracies and flawed accounting used for job creation claims [7] and that last year, despite adding an extra 2,750,000 sq. ft. between them, the number of people both Tesco and Sainsbury’s employ has actually fallen by over 400. [8]

Matter 3 : Manchester Airport
Q1. Paragraph 8.92 of the plan explains that the forecasts for passengers at the Airport were revised down in January 2009, but:
• Is Policy MA1 and the scale of growth it envisages justified, given the seriousness of the threat of climate change and the most recent
statements at national policy level on tackling it?
• Should more weight have been given to the responses from consultees who argued against airport expansion?
• Is Policy MA1 in conflict with Spatial Objective 1 to “provide a
framework within which the sustainable development of the City can
contribute to halting climate change”?
• Has the impact of the proposed extensions on the local community and the environment/ land around the airport been fully and fairly
assessed?

In August 2011, the Department for Transport further revised down its forecast for passenger numbers at Manchester Airport in 2030 from 45 million to 35 million. [9]  Notwithstanding this, there are clear social, environmental and economic reasons why scale of growth envisaged in policy MA 1 is not justified.

Even with this reduced growth in passenger numbers, DfT forecasts that CO2
emissions from the airport will increase by over 60% by 2030 (from 2.3 to 3.7 million tonnes). In contrast, the Government has a legal duty to cut UK emissions by 60% by 2030, and Manchester’s climate change strategy, A Certain Future, has a target to cut Manchester’s emissions by 41% by 2020 (from 3.1 to 1.8 million tonnes).

There are a number of other social and environmental impacts of the proposed expansion of the airport. As well as increases in air and noise pollution and damage to biodiversity, there will also be a significant impact on road traffic, with roads around the airport already heavily congested at peak times – the airport’s Ground Transport Strategy forecasts that non-Airport related traffic could grow by 12% between 2004 and 2030 and Airport road traffic growth could more than double.

We would also question the evidence for the alleged economic benefits of airport expansion. Based on previous evidence, claims of job creation are wildly overexaggerated – for example Manchester Airport’s second runway was originally purported to create 50,000 new jobs but in reality, five years after the runway opened, the figure was nearer to 4,000. [10]

Not only this, Friends of the Earth research found that regional airports are
responsible for a substantial economic deficit as the amount of money spent in the UK by overseas visitors is far less than the money lost to the economy as a result of UK residents holidaying abroad. [11] For the North West, this tourism deficit amounted to £2.2 billion in 2005, and was forecast to double by 2020. This could equate to a net loss of 111,000 jobs in the North West by 2030. [10]

Q3. Should new hotels and car parking be permitted in the proposed Airport Operational Area?

We do not think new hotels and car parking are appropriate uses of the Airport Operational Area.

Q4. Are the alterations to the Green Belt in Policy MA1 consistent with PPG2: Green Belts, having regard for the aim and purposes of green belts and alterations to them (paragraphs 2.6 and 2.7).

Given the negative social, environmental and economic impacts of the expansion of Manchester Airport, we do not believe there are the exceptional circumstances needed to justify alterations to the Green Belt.

Notes:

[1] Sewill B, Aviation Environment Federation, 2009, Airport jobs, false hopes, cruel hoax
http://www.aef.org.uk/uploads/Airport_jobs___false_hopes_cruel_hoax.pdf

[2] GONW, 2008, The North West of England Plan Regional Spatial Strategy to 2021.

[3] CPRE, 2011, Analysis of the Manchester Airport City Enterprise Zone:
http://www.cprelancashire.org.uk/uploads/reports/MAEZ%20MTRU%20print%20july.pdf

[4] The Grocer, 4 September 2010

[5] Channel 4 News, 19 May 2011, Supermarkets set to expand 20% by 2014:
http://www.channel4.com/news/supermarkets-set-to-expand-20-percent-by-2014

[6] National Retail Planning Forum, 1998, The Impact of Out-of-Centre Food Superstores on Local Retail Employment

[7] Association of Convenience Stores, 2010, Job Creation Claims Study:
http://www.acs.org.uk/en/info/document_summary.cfm/docid/3085F364-0B2F-4E34-870FCA2DA3A6D86D

[8] Association of Convenience Stores, 2011, Leading Supermarkets Fail to Deliver on Jobs for UK Communities: http://www.acs.org.uk/en/Press_Office/details/index.cfm/obj_id/FB65A0DCE4DB-408E-8B9827661172EAE2

[9] Department of Transport, August 2011, UK Aviation Forecasts:
http://assets.dft.gov.uk/publications/uk-aviation-forecasts-2011/uk-aviation-forecasts.pdf

[10] Sewill B, Aviation Environment Federation, 2009, Airport jobs, false hopes, cruel hoax
http://www.aef.org.uk/uploads/Airport_jobs___false_hopes_cruel_hoax.pdf

[11] Friends of the Earth, 2005, Why airport expansion is bad for regional economies
http://www.foe.co.uk/resource/briefings/regional_tourism_deficit.pdf