Greater Manchester Spatial Framework consultation response

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The Greater Manchester Spatial Framework sets out a strategy for the development of the city region's physical infrastructure over the next 20 years. It's important to Carbon Co-op and our members because it will define how existing housing is managed (and new housing built) over the next two decades as well as how we meet the ambitious carbon reduction targets we know we need to achieve to prevent runaway climate change.

The framework governs the actions of the Greater Manchester Combined Authority (GMCA) and the ten local boroughs that make up the authority in key areas such as planning, transport and the use of local authority land. However, it doesn't cover other areas such as utilities, the actions of public sector or the private sector.  

The public consultation on the framework is open until 11.59 pm on Monday 16th January 2017. This blog is Carbon Co-op's official response to the consultation and is in a draft version. If you'd like to comment or add to this response please contact us by email ( before 9am on Monday 16th January 2017, and include whether you are a member of Carbon Co-op in your response.

You can also submit your own response – via or by email to

The draft framework and associated documents can be found here: with a text-based version here: and the related Greater Manchester Spatial Energy Plan can be found here:

Draft Carbon Co-op response

About Carbon Co-op

Carbon Co-op is a not-for-profit, community benefit society based in Greater Manchester.  We exist to assist our domestic householder members and the wider community to make significant reductions in their domestic energy-related carbon emissions to a level commensurate with what scientific opinion suggests provides a reasonable chance of delivering less harmful future climate change.

Incorporated in to the governance of our organisation are a number of key concepts, namely that:

  • Citizens should own, benefit from and democratically control the means of effecting the transition to a sustainable energy system.
  • Collective action on climate change is more effective than individual action.The transition to a new, low carbon energy system should be fair and just, benefitting all equally and assisting in the re-distribution of resources from rich to poor.
  • The technical solutions to avoid dangerous climate change should be published in open source formats and use open platforms, available for all to use.
  • Successful models for delivering large scale reductions in domestic carbon emissions should be open, shared and replicated.
  • Collaboration with city region and national government administrations is essential to tackling climate change.

With this in mind, we subscribe to co-operative principles and are active members of the Co-operativesUK and international co-operative sector and are also an active members of Community Energy England and within the UK and European community energy sector.

Overarching comments

Energy efficiency is key

In relation to the spatial framework and the energy plan, we believe that energy efficiency and demand reduction is the essential first step in delivering an effective and sustainable future energy system that meets ambitious carbon reduction targets.

Given the need to decarbonise domestic energy usage and the inevitable transition of transport and heating from hydrocarbon fuels to decarbonised electrical power, we believe that demand reduction and energy efficiency is key.

In a domestic housing context, this means taking a whole house and fabric first approach to retrofitting the existing stock, specifying heating systems and integrated technological (sometimes called 'smart') systems only after demand reduction has been achieved.

In the longer term this reduces the need to reenforce or upgrade the electricity grid – a point argued recently by Electricity North West.

2050 targets for housing retrofit

To enable coordinated and effective city region-wide action, absolute carbon emission targets need to be set for housing retrofit performance which will deliver 2050 carbon reduction targets, and robust monitoring and evaluation frameworks introduced in order to assess progress to achieving these.

Carbon Co-op and technical partners URBED, have proposed a '2050 Retrofit' target of 17kgCO2/m2.a and this was incorporated in to the Greater Manchester Housing Retrofit Strategy Discussion Document (2013).

Carbon Co-op's Community Green Deal project (2015) demonstrated that emissions reductions to this target are achievable in standard Greater Manchester housing archetypes within reasonable budgets (around £40,000 per property), delivered by the existing the local supply chain and using well understood, simple energy efficiency measures such as solid wall insulation and triple glazed windows.

A city region-wide strategy

We believe that the Greater Manchester Housing Retrofit Strategy Discussion Document (2013) provided an excellent framework to assist AGMA (and now GMCA) in facilitating whole house retrofit within the city region. We are disappointed that the strategy was never formally adopted by AGMA or GMCA and strongly believe it should be.

We believe that devising and delivering a coordinated approach to retrofit in the city region will have a range of benefits, including:

  • Developing an integrated low carbon economy, leveraging huge quantities of investment in the Greater Manchester area
  • Improving wider levels of carbon literacy among citizens
  • Addressing inequality, health and wellbeing issues associated with poor housing
  • Transforming homes and communities, investing in local housing stock and place
  • Creating green jobs and training opportunities within the Greater Manchester construction supply chain

A Community Energy future

In order to deliver an energy transition of this scope and scale we believe public/community partnerships are necessary: collaborations between Greater Manchester's huge and diverse voluntary sector, working under the banner of Community Energy, and local government.

Only such collaborations are able to leverage the trust and local engagement necessary to deliver the huge energy transition necessary to meet carbon emission reduction targets. In practical terms this means community renewable energy generation, local supply arrangements and energy services companies (ESCOs).

We believe GMCA and its local boroughs should seek to capitalise on the use of public land for clean energy generation through collaboration with local community energy groups.

The possibility of a municipally owned energy retail company and energy system regulatory reform leading to local supply and virtual energy networks, opens up the potential for vertically integrated, publicly and community owned energy supply businesses.

Heat networks

In principle we are not opposed to Heath Networks. However, the Greater Manchester Spatial Energy Plan appears over-reliant on these as 'one size fits all' technical solutions to energy efficiency.

The effectiveness of heat networks in achieving net carbon reductions is in question with their performance reliant on a range of diverse factors including the suitability and density of the housing stock and the source of the heat. Inappropriate biomass solutions may generate more carbon emissions in the long term and add to urban air quality issues. Worryingly, the financial rationale of heat networks, with an incentive to sell more heat, conflicts with energy efficiency improvements and moves to use less heat.

It is likely that heat networks will only be effective in a very narrow set of circumstances, namely high density/high rise housing and where a source of reliable waste heat or truly zero carbon heat is available and scope for energy efficiency improvements is limited.

As such heat networks have limited potential to provide widespread, large scale low carbon heating in the city region and need to be robustly evidenced in advance in planning stages.

Heat Pumps

Likewise, heat pumps can provide an important role in delivering low carbon heating in the context of a decarbonised electricity grid. But experience from installations in the UK to date suggests poor specification and commissioning of systems is common and leads to high running costs, whilst the systems take up lots of space and are noisy.

Again, heat pumps are likely to be appropriate in some scenarios, ie in off gas grid areas or in urban areas where air pollution is an issue.

Greater Manchester Spatial Energy Plan response

The following are specific comments relating to the Spatial Framework discussion document.

18 Carbon emissions


ADD: Formally adopt the GM Housing Retrofit Strategy and 17kgCO2/m2.a target
We propose that the GM Housing Retrofit Strategy be formally adopted by GMCA and its recommendations incorporated in to the framework, in particular that:

“90% of housing stock to be at Energy Performance Certificate (EPC) rating B, and 17 kg/CO2 per m2 by 2035. with the remaining 10% of homes achieving a minimum of EPC C.”

More information:

5. Support the implementation of programmes and projects for retrofitting the existing building stock, especially in those areas where fuel poverty is a significant issue;
REMOVE: fuel poverty ADD: owner occupiers as a key target audience for retrofit

The Spatial Framework rightly identifies retrofitting homes in fuel poverty as a key priority but wrongly places this under decarbonisation.

Studies show many householders in fuel poverty are under-heating their homes and therefore the likely impact of retrofit is a large (and highly necessary) comfort take back. Many homes in fuel poverty may actually increase their net carbon emissions as a result.

If GMCA's priority is de-carbonisation, programmes should target able-to-pay, owner occupiers who typically are large carbon emitters – and therefore have greater amounts of carbon to save from retrofit and greater financial means to pay for these improvements – this is central to a just energy transition, those more responsible for carbon emissions and more able to pay should do so. For more information see:

Retrofit in areas of fuel poverty should be seen as beneficial in social and health terms but not in terms of carbon saving.

7. Support the delivery of renewable and low carbon energy schemes for all development but with particular opportunities for the use of decentralised heating and cooling networks in the strategic development locations.
ADD: “…where robust evidence indicates these are appropriate.”

Evidence suggests, it is likely that heat networks will only be effective in a very narrow set of circumstances, namely high density/high rise housing and where a source of reliable waste heat or truly zero carbon heat is available and scope for energy efficiency improvements is limited. See:

Heat Network developments should therefore only be allowed through planning where robust evidence of their effectiveness and net carbon emission reductions exists.

19 Resilience

ADD: Include a commitment to collaborating with Community Energy organisations and delivering municipal energy solutions.

The delivery of retrofit and the development of new energy generation via Community Energy intermediaries has the potential to increase community resilience, trust and democratic control and accountability and in doing so has the ability to speed the transition to a low carbon energy system.

As the UK Community Energy Strategy (2014) <> shows, Community Energy projects build community cohesion, local resilience and self sufficiency.