Manchester Friends of the Earth response to the Greater Manchester Spatial framework consultation.

15th January 2017

Our response to the Greater Manchester Spatial Framework sets out the following objections:

* Failure to tackle the site specific and broader issues of air quality
* Unnecessary release of green belt
* Failure to promote healthy living and tackle health inequalities
* Inadequate waste and minerals consideration
* Lack of targets to tackle environmental issues
* Failure to set out a vision for a sustainable economy for the long term future

Manchester Friends of the Earth welcomes the development of a plan that will shape the region’s development over the next 20 years, and seeks to address key issues such as health and well-being, inequality and environmental protection and improvement. However, we would highlight the inconsistency between the health/well-being, inequality and environmental protection/improvement policies outlined in the GMSF thematic policy section and the choice of development and site allocations.

The following is a summary of Manchester Friends of the Earth’s objections.

The Greater Manchester Spatial Framework (GMSF):

* fails the test of soundness set out in the National Planning Policy Framework (NPPF) at paragraph 182 in terms of whether the plan is “Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.”

* fails on the basis of the lack of robust evidence (in line with the principle of sound science) on housing figures, air quality emissions, and greenhouse gas emissions impact.

* fails to be compliant with NPPF paragraph 80 on green belt purpose and paragraph 83 in terms of ‘exceptional circumstances’ through local plan review. The spatial framework has not engaged (for example as would be required under the duty to co-operate) with the local plans for the areas which it covers, nor have exceptional circumstances been demonstrated.

* fails to maintain the previous target for re-use of brownfield in line with the ability of plans to continue to set targets, and without the evidence for reducing the target.

* fails to be compliant with NPPF paragraph 95 on planning for new development in locations and ways that reduce greenhouse gas emissions.

* fails to be compliant with NPPF paragraph 124 on air quality, particularly given the ClientEarth case of last year.

* fails to be compliant with national policy on coal phase out which combined with paragraph 149 of the NPPF requires a restrictive approach.

* given the context of Brexit, we remain concerned that vital environmental protections of species and habitats are not present in this plan.

* we object to the setting of targets for development quantum while targets for environmental enhancement and climate change mitigation are absent.

The full Manchester Friends of the Earth response is available via Dropbox (PDF).

The deadline for responding to the Greater Manchester Spatial framework is 16th January 2017.  To help people respond Manchester Friends of the Earth have set up an easy to use email action.