Dear Sir/Madam,
I am objecting to the Central Retail Park planning permission on the basis of the following two reasons: incompatability with the council's policy "Climate Emergency" (Wednesday 10th July 2019, Item 5), and that the modelling provided in the application is based on faulty assumptions.
At the council meeting of Wednesday 10th July 2019, the council passed a "Climate Emergency" motion which includes the following resolutions:
"Become carbon neutral by the earliest possible date" "Make climate breakdown and the environment, an integral part of activity throughout the Council, including all decision making, ensuring key decisions take into account the impact on achieving the zero-carbon target and including an environmental impact assessment in all relevant committee reports"
The application does not demonstrate the second action, as the modelling undertaken only takes into account transport impact, not environmental impact. Before the application should be considered further, an environmental impact assessment should also be undertaken, so the planning committee can assess the application on the merits of working towards carbon neutrality.
At present, the modelling shows an increase in traffic during the AM peak, which is likely to map to an increase in carbon emissions, in contradiction to the council policy.
Additionally, the "Climate Emergency" resolution included the following actions:
"Encourage involvement in all wards by April 2020 through meetings as part of the Our Manchester strategy, to identify residents and partners who want to be actively involved in achieving the target, with provision for those who cannot attend."
Given that this planning application has generated a significant community response, the planning committee would be encouraged to engage with that community in order to help achieve the council's wider goals.
However, the assessment of traffic impact, which currently shows an increase in traffic during the AM peak is based on flawed assumptions. The modelling is based on the assumption that the site has recently been in full use, which has not been the case for a number of years. Before closing completely, less than half of the units were in use, and many had been closed for years. Therefore the assumption that the overall impact on current traffic through the change of use is flawed. The site closed down in part due to poor business, and a model which assumes that it was fully operational and attracting vehicle users at the level of a fully productive site is inherently flawed. The model should therefore be adjusted to get a realistic traffic impact assessment before the planning committee can make a full and correct judgement on that.
With the flaws in the planning application as it stands, as well as it not meeting the standards expected by the council following the "Climate Emergency" motion, I must implore the planning committee to reject this application until such a time as a change of use application more in line with the council's declared policy is submitted, or at the very least, until the data submitted in the application is of the basic standards required for the committee to make a full and proper judgement.
Regards,
Chris Northwood