Trafford is making us sick – but do they care???

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In a word, NO!

Local, regional and national policy highlights the importance of ensuring new development does not impact the health and wellbeing of both human and wildlife species.  Whilst this has been partially recognised in the planning application, we do not believe Trafford’s assessments acknowledge the serious impacts that will be incurred by local residents and conservation areas.  This is particularly the case given the flawed approach to calculating the anticipated traffic volumes (many of the expected journeys have been excluded from the numbers and comparisons have been made with districts that have access to wide-ranging public transport services, including railway stations).

The National Planning Policy Framework (NPPF) suggests at paragraph 96 that planning policies and decisions should aim to achieve healthy, inclusive and safe places which (c) “enable and support healthy lives, through both promoting good health and preventing ill-health, especially where this would address identified local health and well-being needs and reduce health inequalities between the most and least deprived communities”.

The Carrington Relief Road (CRR) certainly does not comply with this policy.  It will generate huge increases in traffic, not only along the road itself, but also along the east and west-bound A6144.  This will lead to similarly huge increases in air, noise, light, vibration, dust and water pollution (including from road run-off).  The risks and the impact have been substantially understated, the road will cause ill-health, it will increase health inequalities, and it will affect our financial, mental and physical wellbeing.

The public transport improvements promised for Carrington, Partington and Sale West in the 2006 Unitary Development Plan and the 2012 Core Strategy were never delivered (in fact, bus services have been severely depleted over the past 10 or more years) and the more sustainable solutions set out in those plans were never actioned.

Whilst we can draw on lots of research, including, for example, this Public Health briefing, which suggests that less affluent areas “have a higher density of main roads, leading to poorer air quality, higher noise levels and higher collision rates”, the concerns that have been repeatedly raised about the road are not reflected in the Environmental Assessment.  The research goes on to highlight that health inequalities are further exacerbated because “residents of deprived communities tend to travel less than the better off but feel the impact of other people’s travel.  In short, increasing car dependency has led to increasing unfairness” (our emphasis).  

The vision for New Carrington is a clear example of this, with ONS data showing that around 40% of those living in Partington and Sale West do not have access to a car. 

And don’t let anyone kid you, whilst electric vehicles may reduce air pollution somewhat, there will be no radical reduction in particulate matter (PM2.5s), caused by brakes, tyres and dust, and for which there is no safe level.  Yet it does not appear that local monitoring of existing PM2.5 and PM10 has taken place and, as there is no separate count of HGV traffic (despite it being a Planning Practice Guidance requirement), there is no indication of whether the anticipated increase in HGV numbers (and the associated increase in emissions) have been taken into consideration in the Environmental Assessment.

Trafford should be very concerned about increasing our exposure to these pollutants.  These particles will continue to contribute to prevalence of respiratory diseases, cardiovascular issues, and cancer and the huge increase in traffic caused by the CRR will aggravate and accelerate symptoms.

That same Public Health report suggests that “it has been estimated that half of the UK’s £10bn cost per annum of air pollution comes from road transport”, meaning that the new road will add substantial costs to the public purse, whereas the alternative, more sustainable solutions would reduce pollution and would also reduce those costs.

The Environmental Assessment found no significant effects of air pollution on human or ecological receptors either during the construction or operation of this road and the documentation suggests that the PM2.5 modelling results were ‘negligible’.  This is not a credible outcome given the number of cars and HGVs that will be using the road.  There appears to have been no assessment of the impact on vulnerable residents, including in relation to children on journeys to and from schools. 

It is astounding that significant levels of traffic can be “drawn from” the M60, the M6, the M56, the A56 and other roads, along with the additional traffic due to new developments (the Trafford Green Hydrogen development will result in an additional 700 HGV movements a day, for example, with more from Voltage Park and other proposed developments in the area), causing considerable congestion, and yet, Trafford says the impact of pollutants will be ‘insignificant’!

It certainly will not be ‘insignificant’ for the vulnerable communities at either side of the scheme.  Trafford’s Health Inequalities Data Report (2022) suggests that Partington residents, for example, are already suffering from the effects of air pollution, with those presenting at the two general practices having a significantly higher prevalence of pollution-related conditions than elsewhere in Greater Manchester or in England as a whole. 

The Environmental Assessment incorrectly suggests that any change in the prevalence of Cardio-Respiratory Conditions, for example, will be temporary.  The traffic levels, dust, congestion, and pollutants will permanently increase the risks, particularly for vulnerable residents.  

Those living close to junctions, such as at Isherwood Road and Banky Lane are likely to suffer significant adverse effects of pollutants but to be clear, so will residents all along the east and west-bound A6144.

But, the report does not identify the huge level of adverse effects for affected communities and does not demonstrate that these extensive effects are neutralised by the mitigation measures proposed. 

Active travel users, including horse riders, will be substantially affected by emissions both during construction and once the road is in operation.  Current recorded and unrecorded public rights of way will also be severely harmed because there is almost zero motor vehicle traffic on those routes today.

As mentioned above, there are no ‘safe’ levels of PM2.5 emissions.  Repeated tropes about the benefits of the proposed introduction of active travel routes are meaningless.  Walking or cycling adjacent to a major road, which has a minimum of 30,000 cars and over 3,000 HGVs a day travelling along it will not be healthy, safe or pleasant.  Just breathing in the PM2.5 emissions alone will cause significant increases in respiratory-related health episodes. 

With particulate matter lodging itself in various organs, air pollution has been linked to many health problems, far beyond the lungs, including in the brain and for babies still in the womb.  At the other end of life, components of air pollution also seem to be ‘accelerating the process’ of dementia.

The seriousness of air pollution related health problems has been highlighted in this recent article, which confirms dirty air harms the organs in our body, affecting blood vessels, making heart attacks and strokes more likely.  Inflammation in the lungs has caused deadly tumours, with around one in 10 lung cancers thought to be caused by air pollution in the UK.  A report by the Royal College of Physicians estimates there are around 30,000 deaths a year attributable to air pollution.

The health impact of air pollution appears to be consistently devalued in the various planning application documents, which state, for example, that the impact of air pollution on users of sports facilities is ‘not significant’.  Yet recent research (Air Pollution and Its Impact on Health and Performance in Football Players) suggests that “Even short-term spikes in air pollution have been shown to impair performance, increase respiratory symptoms, and delay recovery in athletes”.

A recent study related to improvements to air quality in the Bradford Clean Air Zone found that air pollution was a contributing factor for 35% of GP visits for breathing issues and 49% of A&E visits for conditions including asthma and chronic obstructive pulmonary disease.  The introduction of the clean air zone resulted in a drop of almost 600 GP appointments a month, including 134 fewer GP visits a month for people with problems with their cardiovascular health.

The Full Business Case for the road should, therefore, include the costs associated with additional primary and secondary healthcare service requirements. 

Air pollution also affects ecological sites, yet the impact on these was also dismissed as ‘not significant’ (assuming mitigation measures are implemented).  Again, we are concerned that the traffic numbers need to be revisited, along with the cumulative impact of all construction in the area. 

The Friends of Carrington Moss has undertaken air quality monitoring (NO2) at several locations in the area, over a number of years, using diffusion tubes that were sent to an official laboratory.  The readings will be a useful comparison in determining the level of increased emissions if the road is approved. 

We are aware that Carrington Parish Council has invested in an air quality monitor, which covers a range of pollutants, but sadly the readings are not up to date on the website. 

So, who will benefit from the road?

Whilst it is clear that those citizens living in the around 40% of households with no cars will not benefit, we should ask ourselves how much of an advantage it will be for any resident to be at a much greater risk of suffering the extensive health and wellbeing impacts of air, noise, light, vibration, dust and other pollutants, caused by the sheer volume of traffic that will be using this road.

Our alternative solution, which would remove the eastern part of the CRR, would significantly reduce the adverse effects of the road because it would no longer be attractive to through traffic, limiting the number of vehicles drawn from the motorways through our residential areas.  There would be many other benefits for local residents too!

Who Benefits from the Carrington Relief Road?

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Not current or new local communities in the surrounding areas, who will suffer from significantly increased traffic, more congestion and the health consequences of air, noise, light, vibration, dust and water pollution, many homes will also be at a considerable risk of flooding

Not horse riders, walkers or cyclists who frequently use the traffic-free routes on, across and around Carrington Moss, whose current safe, healthy and very pleasant trips will be fractured by huge volumes of traffic, they will be required to walk or ride alongside hundreds of highly polluting vehicles, travelling at speed, which will be unsafe, unhealthy and very unpleasant

Not the red listed birds or the endangered wildlife species that breed and feed on Carrington Moss, their homes will be destroyed, their foraging corridors shattered, their lives at risk as victims of roadkill

Government data makes it clear that there are many households in the area which do not have access to a car.  Building a new road will not benefit them at all (but they will still suffer the health consequences of increased pollution that are caused by others driving through their areas).

Over the past almost 10 years, despite confirming that this area is poorly served by public transport, Trafford has been unwilling to explore more sustainable alternatives, such as those proposed by the Friends of Carrington Moss.

We hope you will support our campaign to remove the Eastern part of the Carrington Relief Road (CRR) from the plans.  This will bring numerous benefits to local communities and users of the moss and will reduce the costs to the public purse. 

The submission of a planning application for the road is expected before Christmas.  Once it has been validated by Trafford’s planning team, the documents will be made public, and the Friends of Carrington Moss will review them over the following couple of weeks.  We’ll share our findings on social media, in our newsletter and at our online public meeting.

In the meantime, please follow, like and share our posts on social media and don’t hesitate to send any comments you may have to friendsofcarringtonmoss@gmail.com.

Take Action to Protect Carrington Moss

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By Lorraine Eagling

Breaking News: The Carrington Relief Road Planning Application is expected to be validated in early January, please keep an eye on our website and social media for more information.

We want to protect our local peat moss and other ecological assets, but we can’t do this alone.  Will you help us to prevent the devastation Trafford’s plans will cause to this beautiful place? 

It is a complete betrayal of current and future generations to destroy a 335 hectare irreplaceable habitat, productive Grade 2 agricultural land, woodlands and wetlands, impacting the 15 sites of biological importance and the site of special scientific interest in our area, further depleting the populations of red listed birds and endangered wildlife that have made Carrington Moss their home.  Trafford’s plans for 4 new roads on and across the mossland will also cause a huge rise in traffic, increasing air, noise, light, vibration, dust and water pollution (to say nothing of carbon emissions) and will also result in many more motor vehicle accidents (which could be very dangerous given the number of HGVs carrying hazardous materials through the area).

The best start is to write to your local Councillor to tell them how you feel.  Below is a template letter that you can edit to suit your personal concerns, then email it to you Councillor.  Details of your Councillor and their email address can be found at this link.

Secondly, you can add your name to our mailing list to receive our newsletter at this link and follow us on facebook and twitter.  Please share our posts with your friends, family and neighbours and encourage them to get involved too.

Finally, help us with our fund raising by joining our 200 club.  It is just £22 for a year’s subscription (less than £2 per month) and you will have the chance of winning one of 3 cash prizes each month for the 12 month period.  The more people who join the 200 Club, the higher the prize money.  You can also subscribe to easyfundraising and register the Friends of Carrington Moss as your beneficiary.  This does not cost you a penny but whenever you buy anything online – from your weekly shop to your annual holiday – you will raise free donations for us.

Template Letter

Dear Councillors

I am writing to express my deep concerns that Trafford Council has released 169 hectares of Green Belt for development.  The vast majority of that land is a peat moss that is considered by Natural England to be both irreplaceable and restorable.  Peat mosses are one of nature’s most effective carbon capturing habitats.  Peatlands make up less than 3% of land on earth yet they store twice as much carbon as all the world’s forests combined.  Here in Trafford, we have our own precious peatmoss, but instead of protecting it, the Council plan to decimate it and destroy one of nature’s best carbon sinks, significantly reducing Trafford’s ability to be Net Zero by 2038.

Trafford’s plans also affect productive grade 2 agricultural land.  At a time when food security is a priority, why is the Council even considering building on land that produces food?  They plan to fell thousands of trees to accommodate development.  Why, when there is so much brownfield land available in Trafford and elsewhere in Greater Manchester?

The moss is also home to many red listed birds such as the Willow Tit, Skylarks and Lapwings and rare mammals like the water vole and bats, not to mention all the other fauna and flora here.  This development will destroy and fracture their habitat having a devasting impact on local biodiversity.

In 2018 Trafford Council declared a climate emergency.  Today national and international headline news shows the devastating effects of climate change and locally residents are frequently dealing with the aftermath of flooding and are regularly receiving flood warnings.  Yet the Council considers there is just cause to build roads, warehouses and houses on land that is a natural flood defence, storing huge amounts of water every year.

In addition to the increased risk of flooding and the loss of an irreplaceable habitat, local residents will be adversely impacted by the development on Carrington because:

  • There is no committed funding for sustainable passenger transport in an area that is currently one of the poorest served communities in Greater Manchester for public transport.  The only transport commitment is the Carrington Relief Road, which is currently estimated to cost at least £132 million and will bring no relief to local communities, as it will induce through traffic onto local roads, including the A6144 through Partington and the Carrington Spur, which are already at capacity.  TfGM has announced plans to expand the rapid transit network in their 2040 Transport Strategy, yet despite New Carrington being the largest development in Places for Everyone, there are no plans to bring trains or the tram to Carrington, even though there is a ‘live’ railway line that runs through the allocation.  The £132 million would be better spent reopening this line for the benefit of the communities of Warburton, Partington, Carrington and Sale West. 
  • No sustainable freight transport options have even been proposed, despite the proximity to the Manchester Ship Canal and the former railway line and despite the fact that this development will lead to an increase of thousands of additional HGVs on local roads every single day!  
  • There will be an adverse impact on the health and wellbeing of local residents as there will be a significant surge in air, noise, light, vibration, dust and water pollution caused by the huge increase in traffic, including HGVs, due to the lack of sustainable transport options.
  • There will be challenges relating to school places, along with GPs, dental surgeries and other healthcare services (which are also struggling to meet current demand). 

I am not anti-development however New Carrington will  not be a sustainable development.  The National Planning Policy Framework defines the objective of sustainable development as “meeting the needs of the present without compromising the ability of future generations to meet their own needs” (paragraph 7).  It will decimate a carbon capturing peat moss, significantly reducing the ability of future generations to absorb carbon.  It will destroy important biodiverse habitats that are home to endangered species therefore removing the opportunity for future generations to benefit physically and mentally from these local green spaces.  It significantly reduces the opportunity for future generations to produce their own food locally.  As demonstrated by the Community Planning Alliance (and the calculations in the Places for Everyone Plan), there was no need to release any Green Belt to provide land for housing as there are enough brownfield sites to meet housing need.  There certainly is no need for Trafford to implement plans that will be both detrimental to local communities and are so destructive to our natural environment!

Kind regards

Support our campaign and send your email today!

No Planning Permission – No Protection!

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Julie Hay

Have you noticed changes taking place on and around Carrington Moss?  These changes largely involve the removal and loss of natural habitat or longstanding features of the landscape.  Some are taking place without any planning permission or council oversight at all. 

Residents have noticed changes on Isherwood Rd (on the left as you drive in from the A6144). A large vehicle was observed removing hedgerow recently.  The site was left with ground disturbed and an electric fence installed. 

Many hedgerows are considered to be protected priority habitat.  They are vital for a wide range of species, including birds, insects, and mammals, and provide essential movement and feeding corridors for wildlife.  Because of their high ecological value, the conservation, restoration, and enhancement of hedgerows are typically a material consideration in planning decisions.  Yet, if there is no planning application, there is no protection and no consideration of the Hedgerows Regulations 1997.  Hedges and trees also protect the land from soil erosion and flooding, particularly in areas that are subject to significant surface water flooding, like Carrington Moss. 

Sadly, this hedgerow destruction is not the only example.  The temporary road to the planned Battery Storage System (BESS) will also damage the natural environment.  That environmental damage will be carried out under ‘permitted development’ rules.  This is development which requires no planning permission, there is much less oversight and NO environmental assessment!  So, huge harm to the deep peat in the area, perhaps impacting the wider mossland, no protection for wildlife and birds or the habitats they use for breeding and feeding.  The BESS itself will be adjacent to a Grade A site of biological importance, and the developer identified 79 bird species that will be impacted by their scheme.

Elsewhere on the moss, despite alternatives that would reduce car use to their site, MUFC has created an overspill car park on productive Grade 2 agricultural land, without any planning permission, again impacting wildlife corridors and the land used by red listed ground nesting birds, such as the skylark. 

In addition, numerous large established trees were felled at the back of the National Grid site, leading to the forestry Commission posting notices forbidding any further tree felling activity without permission. 

Nearby, the copse at the junction of Carrington Lane and the Spur Road has been stripped of its trees and shrubs, degrading the land before any potential planning application is submitted.  The remnants of this vital former bird and wildlife corridor can be seen opposite the Mersey Farm pub

So, biodiversity can be seriously harmed without a planning application being put forward and this is all happening in addition to the destruction of the natural environment that will be caused by the proposed developments on and around Carrington Moss, including the Carrington Relief Road. 

It cannot be sustainable to further deplete the populations of threatened or endangered species.  And it is not only the birds and wildlife that suffer, without those trees and hedgerows, where do you think all that water will go???  Your homes and gardens, your health and wellbeing could be seriously impacted – so continue to share your photographs of all the damage being caused on and around Carrington Moss and let your councillors know what YOU think. 

Developer Contributions Consultation

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Also known as Trafford’s New Carrington Masterplan Funding Mechanism and Delivery Strategy Consultation (closing date 15th October)

What is it? What are the key issues? and Why is it important for residents to respond?

As you know, the proposed developments on and around Carrington Moss are huge!  5,000 houses, 350,000m2 employment space and 4 major new roads, all threatening the 335 hectare peat moss (restorable irreplaceable habitat), the productive Grade 2 agricultural land, the woodlands and the wetlands, and all impacting 15 sites of biological importance and a site of special scientific interest, to say nothing of the populations of numerous red listed birds and endangered wildlife species.

Because of the size and scale of the proposed schemes, in addition to the typical costs that would be incurred when they put forward a planning application, developers will be required to contribute to the strategic requirements (such as roads, buildings to support education and healthcare, and utilities), which Trafford describes as ‘hard’ infrastructure.  These costs would not have been required had the development been focused on previously developed (brownfield) land, rather than on former Green Belt and greenfield land in an isolated, unsustainable location.

The consultation documentation aims to set out the proportionate financial contributions for schemes that have not yet secured planning permission.

The strategy focuses on those so called ‘hard’ infrastructure items and supposedly prioritises the delivery of New Carrington “in a comprehensive and coordinated manner”.  The document confirms (figure 19) that almost half of the identified ‘hard’ infrastructure costs will be funded from developer contributions, and the other half will be funded by the public sector and other sources.

Balanced?  Sadly not!

Developer contributions are limited by government guidance.  This means that, for a scheme to be considered viable, developers must achieve a certain level of profit.  The contributions developers pay cannot be increased to the extent that the scheme would be considered unviable (ie they do not make the necessary level of profit).  So, if there are any excluded or missing costs not incorporated within the calculations (and there are a lot of them), the proportions shown in the graphic above are very misleading. 

The total contributions to be paid by the public sector should be explicitly and transparently shown, rather than covertly hidden in an appendix or not included at all!  It is vital that communities understand the full cost of destroying our essential natural resources to facilitate building in such an unsustainable location.

The biggest issue is the lack of consideration of harms to, or destruction of, natural capital assets.

Given the extensive environmental and ecological harm/destruction to be caused as a consequence of Trafford choosing this location for development, the calculations should include the costs related to the mitigation of, or compensation for, the loss of Green Belt, the cumulative harm to natural capital assets (such as, for example, the peat moss, the woodlands, and the farmland).  These have been explicitly excluded from the costs and subordinated to a future phase of the masterplanning work.

This means that the information provided in the documentation is incomplete and does not reflect the actual costs to be incurred if all the proposed developments go ahead.

Effectively, in omitting what we are calling the ‘Natural Infrastructure’ strategy from these calculations, the harms can be caused but funding may NEVER be available to provide the obligatory mitigation and compensation.

Why are we concerned?

Take a look at our response (here), but, in summary, not only have the natural infrastructure requirements been shelved to some point in the future, but our suggested amendments to the proposals have been summarily dismissed, resulting in unnecessarily inflated costs for the public purse. 

The cost of the road schemes, for example, would be significantly reduced if our alternative proposals were accepted.

The eastern part of the Carrington Relief Road (CRR), across the moss, could be replaced with upgrades to existing active travel routes and improvements to existing roads (A6144 and Sinderland Lane).  This would encourage modal change to walking, cycling and wheeling (it will be far more pleasant, safe and healthy to use active travel modes in a countryside setting, rather than next to a major road, with hundreds of HGVs hurtling along it every hour).  It would also discourage the huge levels of induced traffic that will use this road, travelling between motorways and significantly impacting Partington and Warburton.  The western part of the CRR, the A1 road, should be upgraded and opened to general traffic as planned to relieve the current issues in Carrington Village.  The plan for the A1 should be amended to take HGV traffic away from the homes that have been built on Isherwood Road.  This would require a very short road to run in parallel with Isherwood Road/Ackers Lane, rather than a new road all the way to the Carrington Spur.

The latest information received from the CRR team[1] shows that the current road (A6144) is much safer than an average road of the same type and that there is ZERO capacity to increase traffic on the Carrington Spur.  Trafford should, therefore, not be proposing a new road that will allow traffic to travel at much higher speeds (particularly given the hazardous materials carried by some of the HGVs), or encourage more through traffic into the area.

Because it includes the eastern part of the road, the current CRR proposal unnecessarily inflates the cost of construction and ongoing maintenance (including for the attenuation ponds needed to capture all that water[2] currently stored on the moss), and the costs of the mitigation needed to address air, noise, light, vibration, dust and water pollution, along with other environmental enhancements.  Costs will also increase for the NHS and other emergency services because of increased pollution and traffic accidents/incidents, and there is likely to be an upsurge in the requirement for mental health services due to the stresses caused to local residents because of construction, congestion, the loss of green spaces, and, possibly, future flooding!

Facilitating vehicle access onto Firsway from the new Sale West developments (1,500 homes) will significantly increase traffic and will result in that road becoming a rat run from the M60.  It will require the felling of hundreds of trees, drastically affecting the wildlife and birds and impacting the dark skies in this area.  It will also increase safety concerns on Firsway and, consequentially, the costs to the NHS/emergency services of dealing with any resulting pollution related health conditions and accidents/incidents on the road network.  Limiting access through the Firs Plantation to active travel users only, would not only reduce the costs of constructing the Sale West Link Road, it would also reduce the cost of mitigating or compensating for environmental/ecological harms and the costs to the NHS. 

For all the same reasons, we suggested that the Eastern and Southern Link Roads should not connect with each other, as this will result in huge levels of increased through traffic from the M60 and other motorways, particularly impacting Warburton.  The proposed approach will also cause extensive damage to the very deep peat that will need to be compensated for.  As with the other schemes, it will also significantly increase pollution and will impact the dark skies in this area, with consequential costs for the NHS and other agencies. 

All the current proposals for these roads result in the need for higher contributions from the public purse, whilst our alternative options reduce the cost of constructing, the cost of mitigation/compensation for environmental/ ecological harms and the consequential costs to the healthcare sector and the emergency services.

The Healthcare costs included in the calculations seems to be limited to primary healthcare (which comprises doctors, dentists, pharmacists, and opticians), not mental health provision, not hospital provision (known as secondary healthcare) and not other emergency service provision.  All of which will significantly increase as a result of the proposed developments.  Furthermore, the Council does not recognise the impact on the need for increased social infrastructure because of the employment development (our objection to this is explained in our response).

Sustainable Development

The documentation repeatedly suggests that the ‘hard’ infrastructure is of the utmost importance to the sustainable delivery of New Carrington.  Yet, given the definition of sustainable development this is hugely misleading.

The government’s National Planning Policy Framework (known as the NPPF[3]) defines sustainable development as “meeting the needs of the present without compromising the ability of future generations to meet their own needs”. 

Given the proposed harms to, or destruction of, irreplaceable habitat, food producing cropland, woodland and wetland, it seems ‘sustainable development’ has a much narrower definition in this suite of documents.

With that definition in mind, it is clear that the New Carrington allocation cannot be ‘sustainable’, even with the proposed ‘hard’ infrastructure investment, because development here is dependent on considerable harm to, or the complete loss of, a number of essential natural capital assets that future generations will not be able to reverse. 

And, what is worse, as mentioned above, the costs of mitigating and/or compensating for those cumulative harms is not even included in the calculations set out in this consultation and no information has been provided about how such funding requirements will be addressed, or when!

We would encourage you all to respond to the consultation.  You do not have to go into the detail we have in our response, but it is important that the community voice is heard, particularly given that there will be future consultations related to the masterplan. Send your feedback to newcarrington.masterplan@trafford.gov.uk

What should you be asking for (in your own words)?

The masterplan project priorities should be reviewed to ensure that there is a comprehensive understanding of the costs of all elements of these proposals.  The Natural Infrastructure Strategy should be considered a prerequisite to finalising the contributions scheme.  It should be progressed with urgency, with its evolution including extensive engagement with communities.  The land to be used for environmental and ecological mitigation or compensation should also be identified as a matter of urgency. 

The documentation provided in this consultation should be updated and implemented when the full costs of the impact of development are known.

No environmental or ecological harms/destruction should be allowed to be caused until it is confirmed that funding for the mitigation and compensation for the loss of Green Belt and those extensive cumulative harms to the environment and ecology will become available.  We also need confirmation of where any agreed mitigation or compensation will be located – it is possible that, because of the size and scale of the developments proposed here, enhancements will be implemented elsewhere, which means our local communities suffer all the health, wellbeing and traffic consequences of these plans, and others will benefit from environmental and ecological improvements in their areas!

[1] https://www.youtube.com/watch?v=L3uG5SzmzjA

[2] https://friendsofcarringtonmoss.com/carrington-lake-2/

[3] https://assets.publishing.service.gov.uk/media/67aafe8f3b41f783cca46251/NPPF_December_2024.pdf

What is the point of Local Development Plans?

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In a recent Parliamentary statement, the Minister of State for Housing and Planning (Matthew Pennycook MP), suggested that “Planning is principally a local activity.  It is local plans that set out a vision and a framework for the future development of any given area, addressing needs and opportunities in relation to housing, the economy, community facilities and essential infrastructure – as well as a basis for conserving and enhancing the natural and historic environment, mitigating and adapting to climate change, and achieving well designed places.  Local plans are the best way for communities to shape decisions about how to deliver the housing and wider development that their areas need”.

The theory is that if a local authority doesn’t have a Local Development Plan (LDP), it can leave greenfield (land that has never been built on before) vulnerable to speculative schemes from the big developers.  The converse should, therefore, apply.  Having an LDP should increase the amount of development that is based on local need, rather than on corporate greed.

If only this were true!

An investigation by the Competition and Markets Authority (CMA) recently revealed that around “60% of all houses built in 2021 to 2022 were delivered by speculative private development”, and that “the country’s reliance on this model has seen the gap widen considerably between what the market will deliver and what communities need”.

The CMA also found evidence during the study which indicated some housebuilders may be sharing commercially sensitive information with their competitors, which could be influencing the build-out of sites and the prices of new homes.  The Community Planning Alliance responded to a consultation about this issue, stating that the suggested remedy is so insignificant (in both financial and process terms) that it will not deter similar breaches in the future (from these and other providers).

Currently local development plans are not shaped by citizens; they are manipulated by developers.  Resident input is neither welcomed, nor taken into account, as can be seen by the previous lack of effort to involve Trafford residents in either the LDP or the Places for Everyone (PfE) planning processes, nor to address the feedback they gave. 

Despite analysis confirming that over 80% of those responding to the PfE consultation in 2019 either disagreed or mostly disagreed with the New Carrington proposals, the outcome was not to remove this unnecessary, environmentally destructive allocation or reduce it to just the brownfield land.  No, Trafford continued with the developer proposals to damage or completely destroy a 335 hectare irreplaceable habitat (a restorable deep peat moss), productive Grade 2 agricultural land, woodland and wetland habitats, impacting 15 sites of biological importance and a site of special scientific interest, along with populations of red listed birds and endangered wildlife.

In their letter to the planning inspectors, Natural England confirmed that “the combination of the location and the extent of development proposed for this allocation mean the proposed development could not be accommodated without at least causing the deterioration of this deep peat irreplaceable habitat at the site, if not its loss”. 

These damaging proposals were only adopted with PfE in 2024, yet already its policies are being ignored, and the principles upon which the PfE consultation was based, are not being upheld.

The PfE planning inspectors introduced specific policy criteria for the New Carrington Allocation (now known as JPA30 in the adopted PfE Plan). 

Policy criterion 1 (page 447), for example, states that development of this site will be required to be “in accordance with a masterplan that has been developed in consultation with the local community and approved by the local planning authority”.  The criterion continues “Central to the masterplan shall be the consideration of opportunities to restore habitats, strengthen ecological networks, and manage the carbon and hydrological implications of development, having regard to the presence of peat on parts of the site”.

Policy criterion 24 (page 450), requires that developments “Undertake hydrological and ground investigations as necessary to inform the comprehensive masterplan and use of suitable construction techniques to ensure any loss or deterioration of irreplaceable habitat, and adverse impacts on the hydrology of undeveloped areas, is minimised.  Where loss or deterioration is unavoidable, a suitable compensation strategy should be identified and delivered, including the potential restoration of lowland raised bog and complementary habitats elsewhere within the site”.

It seems that the word ‘requires’ in a planning context should be interpreted as ‘required if the developers or the Council want it to be required’!

When taking the PfE plan through the modifications process, the planning inspectors were very deliberate in their choice of wording, adapting policy criteria as they felt necessary.  Where policy criteria are to be subject to ‘get out clauses’ such as ‘where possible’ or ‘where appropriate’ or even where ‘it is not practicable or financially viable’ they included these terms within the criteria.  In fact, several of the JPA30 policy criteria are subject to these limitations.

Criterion 1 has no such restrictions.  Yet, despite the masterplan NOT being developed, AND a ‘suitable compensation strategy’ NOT being in place Trafford has approved a planning application (115160) on 19.9 hectares of very deep peat!

The approval of this planning application has set a number of dangerous precedents, with the interpretation of policy criteria now subject to the whims of specific schemes.  Dismissing the “be required to” means that other criteria can also be disregarded or interpreted in a way that is contrary to general perceptions, in current and future planning applications.

Furthermore, the consultation for PfE was based on the premise that it would “avoid 10 districts proposing further amendments to the Green Belt in Local Plans” and that PfE would be “the only opportunity to make changes” to the Green Belt (see PfE document 07.01.25 Green Belt Topic Paper and Case for Exceptional Circumstances to amend the Green Belt Boundary).  Despite this, the planning inspectorate has since approved development on Trafford’s retained Green Belt and Trafford consider that incursions into retained Green Belt on Carrington Moss for temporary road building “is an appropriate form of development in the Green Belt”. 

Thus, not only are the policies within the PfE plan ineffective, but the basis on which the consultation was undertaken was flawed, as the GMCA and the participating districts are not in a position meet their stated commitment.  This means that the expenditure incurred on examining the policies is also wasted.

One could ask what was the point of spending huge amounts of public money (multiple millions of pounds), over a 10 year period, to agree a spatial plan with careful policy wording that can just be ignored (unless that abhorrent waste of public funds was simply to enable developers to access 2,400 ha of Green Belt land across Greater Manchester, when there was sufficient brownfield to more than meet housing and employment requirements)!  

Finally, unlike developers, communities cannot appeal a planning decision, even when NPPF and/or LDP policies have not been complied with.  This is a gross inequity within the planning system.  It means that citizens ONLY have the option to request a judicial review (JR).  Not only is this an avenue that the government wishes to curtail, it also requires the communities themselves to fund the action (they cannot use public funds, like a local authority, nor can they use a corporation’s funds, which developers can take advantage of).  Given that communities must request donations from the personal pockets of citizens, there is no such thing as a ‘frivolous’ JR from a community perspective (despite this government’s rhetoric suggesting otherwise)!

All in all, if the policies in the NPPF and an LDP can be cherry-picked to meet the needs of Councils and corporations, they are not providing good value for public money, nor are the associated decisions made in the public interest.  Sadly, what we are seeing demonstrated here is a gross betrayal of current and future generations!

If you’d like more detail, read on!

Quick background for those who are unaware

A Local Development Plan (LDP) comprises all the documents that guide development and land use within a specific local authority area, providing a clear set of planning policies that should determine where and when development can and cannot happen to ensure transparency and consistency.  Once adopted, these documents become statutory, they are supposed to be legally binding and must be taken into account when making planning decisions.

When planning applications are submitted, they are assessed against the policies in the LDP and also against the policies set out in the government’s National Planning Policy Framework (NPPF).

If an LDP is out-of-date, there is a presumption that the Local Planning Authority (LPA) will grant planning permission for sustainable development.  This is called ‘the presumption in favour of sustainable development’ and is set out at paragraph 11 of the current NPPF. 

The term ‘sustainable development’ is not clearly defined (probably deliberately, as successive governments have been keen to ensure developments are approved no matter what harms they cause).  Some authorities, developers and planning inspectors appear to only consider the materials a building or road is constructed with, and do not (for example) take into account whether an irreplaceable habitat will be damaged, whether there is sufficient social and economic infrastructure to support the scheme or whether there will be other environmental impacts (increased air, noise, light, vibration or water pollution, increased carbon emissions, increased risk of flooding, for example).  New Carrington certainly cannot be considered to be a sustainable development but its allocation for development has been approved by the planning inspectorate!

As an aside, there is also Permitted Development, which means that some specific types of development do not need a planning application (such as the conversion of offices and shops to housing).  These schemes could, potentially, override agreed LDP policies.

What about Trafford’s LDP?

LPAs should develop their LDPs in consultation with their local communities, to ensure the plan reflects local needs and aspirations.  Back in May 2025, FOCM responded to Trafford’s latest consultation on its new Local Plan.  A quick review will show that we made lots of comments.  We await the next iteration to see if any of them have actually been taken into account. 

We certainly do not feel that our previous inputs were taken seriously.  It is clear that Trafford’s proposals for New Carrington were fixed and firm BEFORE the public consultation.  Whilst there has been some reduction in scale, this was not at the same level as in other districts.  Given that Natural England also objected to the harms proposed to what they describe as a 335 hectare restorable and irreplaceable deep peat moss, it is astounding that the development was not restricted to brownfield land (there is plenty of it in the area).

The consultation process for PfE was abysmal.  Residents were not made aware of the environmental and ecological harms proposed, nor of the size and scale of the proposals (which were originally 16,000 houses and 7m m2 employment space).  In the 2019 consultation, there were over 150 documents (comprising over 14,000 pages) to review.  These documents were full of factually incorrect and/or disingenuous statements.  The Friends of Carrington Moss was actually constituted following the introduction of signage on the public rights of way that stated ‘Trespassers will be prosecuted’.  A clear indication that the developer considered the allocation to be a done deal!

What actually happens?

Well, there is an immediate ‘get out’ clause in the government’s guidance, which states that there is “a requirement set in law that planning decisions must be taken in line with the development plan unless material considerations indicate otherwise”.

And there’s the rub!

Material planning considerations are the things an LPA must take into account when deciding whether to approve or decline a planning application.  It is assumed that these considerations help to ensure that planning decisions are rational and are based on established policies and evidence.

Can it really be considered rational to:

  • build on an irreplaceable habitat, in an area that hosts 15 sites of biological importance and a site of special scientific interest?
  • develop in an area that hosts significant surface water flooding every year?
  • significantly increase air, noise, light, vibration and water pollution, for populations of humans and endangered wildlife and birds?
  • put even more pressure on local resources (such as schools and health services), especially in an area that Trafford considers to be poorly served by public transport?
  • destroy woodland, wetlands and productive Grade 2 agricultural land when there are a significant number of brownfield sites in Trafford and elsewhere in Great Manchester?

Maybe those who have a short term, increase my wealth agenda, think it is rational?  We disagree!

The planning officers consider what is known as ‘the planning balance’.  This is a process of supposedly weighing the benefits and harms of a proposed development.  In determining whether the potential benefits of a development outweigh the negative impacts, or vice versa, the planners use their ‘judgement’.

In the Officer Report for planning application 115160 (Battery Energy Storage System adjacent to the Shell Pool Reserve and the Flare Stack), Trafford set out which documents represent the LDP:

  • The Places for Everyone Joint Development Plan Document (PfE), adopted on 21st March 2024
  • The Trafford Core Strategy, adopted 25th January 2012
  • The Revised Trafford Unitary Development Plan (UDP), adopted 19th June 2006
  • The Greater Manchester Joint Minerals Plan, adopted 26th April 2013.

Trafford decided that the application should be approved, despite:

  • The ground investigation reports revealing that the land was very deep, restorable peat
  • The application not complying with the LDP policies, including the requirement for a Masterplan and a ‘suitable compensation strategy’ for the harms to be caused to the peat (the lack of a final Peat Management Plan agreed with Natural England)
  • Pitiful compensation (via Biodiversity Net Gain) of just 1.15 hectares
  • The visual impact on nearby residents (especially given the flat mossland landscape)
  • No calculation of the carbon impact of removing or piling the peat (despite Trafford’s Carbon Neutral Action Plan and the Greater Manchester aim to be Carbon Neutral by 2038)
  • The document confirming that this “site is allocated for employment use within the New Carrington Allocation”, yet the development will not result in a single local job being created and using the site for this purpose will reduce the potential for employment opportunities for local residents (its previous use as productive Grade 2 agricultural land did provide jobs for local people), another indication of unsustainable development

That the planning officer suggested the application proposals are unique is bizarre.  There are now 3 BESS within Carrington and a further 2 elsewhere in Trafford.  Another rather surprising conclusion reached by the planning officer is that the Friends of Carrington Moss represents a single household and, due to written objections being limited to just “5 addresses, including Friends of Carrington Moss”, they did not meet Trafford’s threshold (10 addresses) for raising the application with the Planning Committee.

In relation to the New Carrington Masterplan, the planning officer did not consider the need for mitigation of the environmental and ecological harms to be caused, both within the site and across the allocation in general but limited their assessment to whether the scheme would be impacted by one of the 4 proposed new roads!

To date, there has been no consideration of how the harms to, and losses of, natural capital assets will be addressed across the allocation area (either in PfE or through the Masterplan discussions).  So, how does the planning officer know that premature planning applications, such as this one, will not conflict with the eventual requirements.  

In fact, the planning officer states that, in relation to this planning application, “it is considered that the site itself is not needed immediately to contribute to the site-wide green and natural infrastructure strategy”.  Given that this 19.9 ha site comprises deep restorable peat, this suggests that decisions have been made about the natural infrastructure strategy in advance of any collaboration with local residents!

Interestingly, their ‘judgement’ was that there was “no fundamental conflict with the emerging masterplan, that would preclude this development from coming forward ahead of it. Nevertheless, this approach can only be supported if the application makes the appropriate financial contribution set out in the Council’s latest Interim Planning Strategy (IPS) for New Carrington (February 2024)”.  In other words, if the developer pays towards the Carrington Relief Road, approval could be granted, if they didn’t it could not. 

We fundamentally disagree with this premise.  Whilst we believe developers should fully contribute to infrastructure requirements, their contributions should not determine whether a scheme meets other policy needs, including the impact on natural capital assets!  It should be noted, however, that Trafford has recent lost an appeal where they refused a development because the applicant (Peel) did not agree to fund the infrastructure requirements according to Trafford’s formula.

The planning inspectors held a specific hearing during which Natural England confirmed that the 335 hectare peat moss at New Carrington (then JPA33) was irreplaceable and restorable.  Yet, in their final report (paragraph 235), having taken NPPF guidance about irreplaceable habitats into account when considering whether the allocations were ‘sound’, the planning inspectors determined that, despite there being sufficient brownfield land to exceed housing ‘targets’, they were content that the GMCA was entitled to make the judgement that an allocation that could completely destroy a 335 hectare irreplaceable habitat (paragraph 635) met the wholly exceptional reasons test (now NPPF 193c).  This decision was strongly challenged by Natural England at the hearing and local communities also disagree that the public benefit clearly outweighs the loss or deterioration of the habitat given the amount of brownfield land available across the urban areas of Greater Manchester. 

The benefits the planning inspector’s refer to in their decision are also set out at paragraph 635, which suggests that “The allocation would make a very significant contribution to Trafford’s housing and employment needs, as well as contributing to the strategy of sustaining the competitiveness of the southern areas.  It would also involve substantial regeneration of previously developed land, bringing with it associated social and environmental benefits”.

Local communities must monitor that these so called ‘benefits’ are actually achieved (no one else will do that).  If they are not delivered, Trafford has sacrificed our much-used local green space, irreplaceable habitat and other natural capital assets for huge developer profits, with no mitigation or compensation for communities or the many local populations of red listed birds and endangered wildlife!

Public Money (ie YOUR money) wasted as Trafford ignores its own policies!

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By Lorraine Eagling

Trafford Council has approved the development of a Battery Energy Storage System on Carrington Moss (the third in Carrington, with more elsewhere in Trafford). This scheme will not only result in the loss of productive Grade 2 farmland (essential for food security), and the food and foraging corridor of 79 red and amber listed bird species (which the applicant notes are utilising the adjacent site of biological importance), it will also necessitate the removal of up to 192,000 cubic metres of peat moss, which will release tens of thousands of tonnes of carbon into our atmosphere.

The approval is contrary to Places for Everyone (PfE) policy, which specifically states that no development can take place on Carrington Moss until the New Carrington Masterplan is in place.  The PfE plan was only adopted in March 2024, after 10 years in the making. At barely a year old, and despite the millions of pounds of public money spent on its development, its policies are now being disregarded by Trafford Council!

The scheme is also contrary to the brownfield first policies in PfE, which has Strategic Objectives for both housing and employment sites that confirm Greater Manchester WILL “Prioritise the use of brownfield land“.  There are acres of vacant brownfield land adjacent to the site in question, so why isn’t this land being used for this development?

Despite past reassurances, from Trafford Council’s Strategic Planning and Development Department, that policies will be ‘rigorously’ applied and no development will take place until the Masterplan is in place, the same department did not object to this planning application. 

Even more concerning, this controversial application did not go before the planning committee, which would have allowed local residents to raise their concerns to Councillors. Despite repeated objections, including in relation to the health and safety of residents, and the lack of compliance with policies in the development plan, this planning application was approved by a Council Officer, with needless haste.

I have written to the Council (copy below) requesting an explanation as to why this decision has been made, contrary to policy.  Local Councillors have been copied into the email and I have invited them all to come along for a walk across the moss, so they can see first-hand, the impact this and future developments are going to have to this unique habitat.

Letter to Trafford Council’s Strategic Planning and Development Department:

Thank you for your response. I fully appreciate that this is not a simple or straightforward process.  I too get bogged down with the paperwork and reading.  It is no wonder that very few members of the general public have the time to read the masses of paperwork in order to fully understand the implications of The New Carrington Masterplan. 

I did receive your email of 22nd May with the updated schedule.  My subsequent email was in response to the approval of the BESS, despite it being contrary to criterion 1 of JPA 30 and your reassurances that the council is ‘rigorously applying’ criterion 1.

For the sake of those reading this email trail for the first time, criterion 1 states ‘Development of this site will be required to be in accordance with a masterplan that has been developed in consultation with the local community and approved by the local planning authority. The masterplan must include a phasing and delivery strategy, as required by policy JP-D1. Central to the masterplan shall be the consideration of opportunities to restore habitats, strengthen ecological networks, and manage the carbon and hydrological implications of development, having regard to the presence of peat on parts of the site. It should also have regard to the anticipated Hynet North West Hydrogen pipeline (as relevant). The masterplan will be prepared in partnership with key stakeholders to ensure the whole allocation is planned and delivered in a coordinated and comprehensive manner with proportionate contributions to fund necessary infrastructure‘

I fully support green energy and understand it’s role in achieving net zero, but apart from this approval being contrary to the above policy, the destruction of a peat moss to develop a BESS is illogical. The release of carbon during construction will outweigh the carbon benefit of the facility.  The development will involve the excavation of up to 192,000m3 of peat which will release at least 35,000 tonnes of carbon.

This development is certainly not sustainable, (‘a development that meets the needs of the present without compromising the ability of future generations to meet their own needs’) as it will not only destroy premium agricultural land that provides food security for future generations, but will negate the ability to restore the precious carbon capturing peat that is one of our best defence against climate change.

It should also be noted that of all the boroughs in Greater Manchester (with the exception of Oldham and Rochdale who were unable to provide me with the information) Trafford will lose the most agricultural land (481 hectares) under Places for Everyone.  At no point in the development of this plan, has the livelihood of the tenant farmers been mentioned.

I understand that this decision was made by the planning officer, but I have to express my deep concerns that despite the fact that the Masterplan has not been developed, according to the officer’s report, your Strategic Planning and Development Department made no objection to the application. 

Why didn’t this application go to the Planning Committee when it is such a highly sensitive application?  Also, what was the burning platform that made it impossible for this application to wait for the Masterplan to be agreed?  The Places for Everyone Plan took years to develop at a cost of tens of £millions to the public purse, but within months of its adoption, the policies therein are not adhered to.

This approval calls into question just how ‘robust’ the masterplan will be if applications are already being approved. Once a precedent is set, it is unlikely the plan will able to ‘withstand challenge and scrutiny’.  This is played out in the officer’s statement ‘It is noted that there have been two recent appeal decisions in Trafford for BESS applications where the Battery Energy Storage System compounds were in the Green Belt – Land Off Golf Road APP/Q4245/W/24/3343250 and Land at Wild Fowl Farm, Carrington Lane, APP/Q4245/W/24/3354822. The Inspectors concluded in both cases that Green Belt and any other harm was clearly outweighed by the very significant benefits in supporting the transition to net zero and in helping to secure stability and security in energy supply. Although not directly comparable, these cases are material in terms of the recent approach taken by Inspectors.’

It is hard to understand why the officer has approved this application when they themselves state ‘‘The NPPF, at paragraph 11, introduces ‘the presumption in favour of sustainable development.’ For decision-taking purposes, paragraph 11c explains that ‘the presumption in favour’ means approving development proposals that accord with an up-to-date development plan without delay’.

This application does not accord with the most up to date plan (Places for Everyone) as the Masterplan is not yet in place.

The officer also states ‘Where a planning application conflicts with an up-to-date development plan, planning permission should not normally be granted, paragraph 12 of the NPPF explains. The Places for Everyone Joint Development Plan was adopted on 21 March 2024. As development plan policies in Places for Everyone are very recently adopted, they are up-to-date and should be given full weight in decision making’.

With reference to factors that must be weighed in the balance, the officer’s report states that ‘The supporting documents states that the planning application is located on this land due to its close proximity to the Daines National Grid substation. The Applicant holds a grid connection agreement with NGET to connect the proposed BESS project to this substation’.

Whilst this is true, this site is grade 2 agricultural land that is constantly used for growing crops and is home to land nesting birds.  However, there is 27 hectares of vacant hard standing brownfield land directly North of the site which is equidistant to the Daines National Grid substation and would be suitable.  Why wasn’t this fact weighed in the balance when making the decision, particularly when one of the Government’s Golden Rules is ‘Brownfield First’ and one of the Places for Everyone’s Objectives is to put brownfield first for both housing and employment.

It should also be noted that some of the Officer’s knowledge of the New Carrington Allocation is incorrect as they state that there will be ‘major investment in public transport’.  Sadly, this is not the case.  Even though New Carrington is the largest allocation in Places for Everyone, there is no commitment for investment in public transport infrastructure.  Furthermore, despite the Governments recent announcement of a £2.5 billion funding boost for public transport in Greater Manchester, Carrington, Partington and Sale West have not been earmarked for any of this.

As you appreciate, my main concern is the loss of green and natural infrastructure.  The Officer states ‘Taking all of these factors into account, it is considered that the site itself is not needed immediately to contribute to the site-wide green and natural infrastructure strategy. That strategy and the subsequent JPA 30 compliant masterplan is capable of being produced and implemented without the application site in the first instance, as it will be able to have regard to its longer-term availability.

Here the officer is referring to the long-term plan to restore the peat at this site once the BESS is decommissioned.  This raises two questions that should have been taken into account; a) the removal of 192,000 m3 of peat will limit what can be restored in future, b) why isn’t the peat being restored now to protect future generations, in twenty years time it will be too late?  Another consideration is, if this development does go ahead, who will be responsible and has the expertise to ensure the peat extraction will be in accordance with the Peat Management Plan?

The officer goes on to say ‘However, since the application proposals are not in accordance with Criterion 1 of Policy JPA 30, any approval must robustly secure the compensation, so that it can contribute and link to the site-wide green and natural infrastructure’.

Already, the ability to robustly secure the compensation is compromised, as Manchester United have built a car park on land which is designated as the green corridor in JPA 30.  I await the findings from your planning enforcement officers regarding this car park. 

In the New Carrington Ecological Assessment which was in your last email, the Greater Manchester Ecology Unit states ‘GMEU has not itself carried out large-scale, detailed field-based ecological assessments of the entire allocation. Such a level of survey is regarded as beyond the scope of the assessment, generally carried out at the masterplanning or planning application stage of the land-use planning system’.

Is this large-scale, detailed field-based ecological assessment underway as part of the Masterplan, to ensure any approval will robustly secure the compensation, so that it can contribute and link to the site-wide green and natural infrastructure’?  This is urgently needed to ensure a holistic approach, to not only help in the fight against biodiversity loss and climate change, but to ensure that existing communities are protected from flooding, air pollution, noise pollution and a loss of having access to open green spaces for mental well-being. 

At one of the drop-in events for the Carrington Relief Road, the information boards said, in relation to BNG measures, “the scheme aims to transform what is currently unused land for the better with planting proposed on what is currently a brownfield site”. When questioned where this brownfield is located, the staff at the session pointed to the green belt agricultural land.  When this was highlighted, they admitted that they were not entirely sure where this unused land will be.

In an attempt to clarify where these BNG measures will be, the question was sent directly to the team at Amey in February, together with a number of other questions, including ‘In relation to the attenuation ponds, are these being constructed to mitigate the impact of the road alone or are they expected to also mitigate the impact of other development in the eastern part of New Carrington?

Unfortunately, we had no response from Amey, so a freedom of information request was done to which we had a reply this week.  The response to the BNG question was ‘The brownfield land is the Shell Carrington Estate’.  The response to the attenuation ponds was ‘These are designed based on highway drainage, not relating to developments’.

Clearly describing the brownfield land as the Carrington Estate is very vague, and the response to the attenuation ponds demonstrates the ad-hoc nature of the planning applications for this site.  Without a holistic approach, there is greater risk of flooding and a greater loss of biodiversity. This is why the inspectorate set out criterion 1 and emphasised the need for a Masterplan to be in place before any applications are approved.

It begs the question, how did the officer come to the conclusion that ‘As such there is no fundamental conflict with the emerging masterplan, that would preclude this development from coming forward ahead of it’ when there has been no discussion with stakeholders regarding the natural infrastructure, no evidence that there is any site-wide plan with regards natural infrastructure and that this site may be needed for mitigation and compensation under the masterplan.

All that the community have ever asked for is to be listened to.  For years the communities have put forward sustainable alternatives that would benefit the communities of Partington, Carrington and Sale West, without the need to destroy a peat moss, wetlands, woodlands and agricultural land. Unfortunately, all of the ideas and the advice of other stakeholders, such as Natural England, have been ignored.  So, the promise of stakeholder meetings at which we could discuss the issues that matter the most to us, in particular the green infrastructure, was really appreciated.  At the one meeting so far, which was last July, we did not get the opportunity to raise our concerns and put forward our suggestions.  Instead, we were asked to submit our thoughts with the promise that there would be further stakeholder meetings.  I hope that these will recommence soon, as you suggested in your previous email.

I sincerely apologise for the length of my email.  I appreciate you are working hard on this project, but to be honest, I have lost faith in the whole system.  Who will benefit the most from New Carrington?  Not the communities or future generations.  They will face more traffic, air pollution, no improvement to public transport, social isolation and inequalities, less green space, a loss of biodiversity, flora and fauna essential for well-being, a loss of identity due to urban sprawl, higher risk of flooding, the list goes on.  The winners will be the developers, who’s only objective is to make as much profit as possible irrespective of the costs to humans and nature and the planning system facilitates this.

We have little influence of what happens Nationally and Globally when it comes to the destruction of the natural world.  Here we have an opportunity to do the right thing, to put nature before profit, to look at the alternatives and ensure we leave a legacy that will benefit future generations.  If all decision makers did this, we would not be in the middle of a climate crisis. 

My invitation to you to take a walk across the Moss still stands (although cycling would be best as the site is huge), so that maybe you will understand why we feel so strongly about its destruction.  I welcome Local Councillors along too.

A final thought, ‘Let’s put GDP growth aside and start a fresh with a fundamental question that is what enables human beings to thrive? A world in which every human being can live a life with dignity, opportunity and community and where we can all do this within the means of our life-giving planet’.  Kate Raworth, Senior Teaching Associate at Oxford University.  I believe this is possible, so I will continue to fight to protect Carrington Moss, if only so that in years to come, I can look my children and grandchildren in the eye and say that I tried my best.

Kind regards

Lorraine Eagling

Poor Public Transport for the New Carrington Allocation Area

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Lorraine Eagling

The Bee Network High Frequency Routes Map shows all the routes in Greater Manchester that have buses or trams every 12 minutes or less. 

It is disappointing to see that, compared to the rest of Greater Manchester, Trafford has the least number of high frequency buses.  Whilst all the other boroughs have at least two high frequency services, Trafford’s only frequent service is from Manchester City Centre to the Trafford Centre.

It probably comes as no surprise to the residents of Trafford that they have no high frequency buses, especially the residents of Partington, Carrington and Sale West, where the most frequent bus is every 25 minutes in rush hour, every half an hour during the day and every hour in the evening.

Residents are failed again

New Carrington will be the largest development in Greater Manchester, with 5,000 new homes and 350,000 square metres of industrial/warehousing across Carrington, Partington and Sale West. Despite what is set out in Appendix D of the Places for Everyone Plan, there is no formal commitment to invest in any public transport infrastructure. No trams, no trains (despite the former railway lines running through the allocation area) and no commitment to additional bus services.

The only transport commitment for New Carrington is the £132 million Carrington Relief Road.

In fact, according to the New Carrington Transport Strategy 2023, (page 63), bus services will “fall short of the currently unachievable addition of around 25 – 30 new buses which would be required for a fully sustainable Scenario 3, and which would enable a reasonably comprehensive network, along with 15-minute headway service to both Stretford and Sale Metrolink stations”.  So, not only is there no commitment to public transport infrastructure investment but the proposed bus service will be inadequate for a development of this size.

Residents of Carrington, Partington and Sale West were promised improved public transport connections in Trafford Council’s 2006 UPD and in the 2012 local plan.  These improvements never materialised and, despite the size and scale of the allocation, and the opportunity to finally deliver these promises, what we have seen is a clear lack of ambition to achieve what is required by the regulations, sustainable development!

An Unsustainable Development

As mentioned above, the only actual commitment for transport in New Carrington is the £132million Carrington Relief Road. This road is not only expensive, but will not benefit existing communities, particularly in Partington and Sale West as we have set out in our previous blog.

As the public transport options will NOT be ‘reasonably comprehensive’, New Carrington will be unsustainable, car dependent sprawl that causes huge amounts of harm to our natural capital assets.

In most cases, residents in New Carrington will face the higher costs of car dependent living. For those who do not have a car, their ability to enter paid employment or the training needed to secure a well-paid job, is constrained by the lack of local public transport options. Also, local public amenities are already oversubscribed, so, once the housing developments are occupied, residents will have to have to travel further afield to access schools, doctors, dentists etc.

Increased Air Pollution

The Carrington Relief Road is forecast to induce more motor traffic into the area, with the Environmental Impact Scoping Report confirming (paragraph 14.46) “Traffic flows are likely to increase due to the improved desirability of the route”. 

The Let Manchester Breath Coalition’s response to the GM Clean Air Plan shows that Greater Manchester consistently has the highest levels of Nitrogen Dioxide in the country, car ownership is increasing well above the national average and Manchester ranks in the top ten for highest number of emergency admissions and deaths for lung conditions across the UK.

Air pollution is a public health emergency, so it is inconceivable that the only transport infrastructure for the largest development in Greater Manchester is a £132 million ‘relief’ road, that will be built on Grade 2 agricultural land.  It will impact 15 sites of biological importance and a site of special scientific interest, along with woodland and wetland habitats.  It will also damage (or lead to the destruction of) a 335-hectare peat moss that has the potential to absorb five times more carbon than a forest of an equivalent size. This is a complete betrayal of future generations.

Meeting Targets Will Be Impossible

Furthermore, the Greater Manchester Transport Strategy set out the “ambition to improve the transport system so that – by 2040 – 50% of all journeys in Greater Manchester are made by public transport or active travel“. 

Car centric developments like New Carrington will make it impossible for the Greater Manchester Transport Strategy’s target to be met. 

It certainly feels like the residents of Greater Manchester are being failed.  Economic growth and profit are being put before public health and equality? Compare Andy Burnham’s plans for GM with those of David Skaith, the Mayor of North Yorkshire, who has said he will prioritise improving public transport in the region rather than campaigning for the A64 to be dualled!

Yorkshire has the opportunity to achieve sustainable development, New Carrington certainly does not!

The Greater Manchester Green Belt Lie!

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There has been lots of commentary about Stockport’s withdrawal from the Greater Manchester Spatial Plan (Places for Everyone, or PfE) since they made the decision in 2020, especially about the consequential risk that being out of the plan will lead to more Green Belt release and speculative development.  The same threats are being made to those who, more recently, want to remove Oldham from PfE, with some Councillors suggesting the arguments in favour of withdrawal are misleading residents and that this approach “would lead to further developments on the greenbelt”.

Breaking News!

It doesn’t matter whether you are in or out of PfE that risk is still there.  Trafford’s rejection of a Battery Energy Storage System (BESS) on retained Green Belt has been approved on appeal by the Planning Inspectorate, despite participation in PfE that supposedly gave protection to that land!

Given the £millions of public money spent on Places for Everyone over the more than 10 years it took to bring the plan to fruition, why hasn’t the media picked up on this issue and who is auditing this failure to achieve even the basic aims of the plan?

Places for Everyone is supposed to be a brownfield first plan, it is supposed to protect retained Green Belt from development, it is supposed to help resolve the housing crisis in Greater Manchester. 

It does none of those things!

Green Belt allocations are coming forward across the region (much reported in local press and the MEN) and are being approved in advance of all the swathes of brownfield land available for development (despite huge amounts of public money being made available to regenerate that previously developed land).

Retained Green Belt is not protected by participation in the PfE plan. In the particular case mentioned above, the Planning Inspector used the Government’s ‘Grey Belt’ rules to assert that it is appropriate development.  There were no concerns raised about the number of fires that have occurred on such developments, including the BESS fire in Liverpool that burned for 59 hours, or more recent fires in Essex and Aberdeen.  At least there will be plenty of water available from the River Mersey should a fire break out, but All Saints Catholic Primary school is just down-wind of the site, so alarms should be raised to alert the school and local residents if a fire or the associated toxic fumes are released.  Nothing was mentioned about this by the Planning Inspectorate, which seems to be blindly allowing as much development as possible to support the Government’s war on nature and communities.

There are many ways to resolve the housing crisis, none of which require the release of Green Belt.  These are outlined in the Community Planning Alliance Homes for Everyone Report. 

The Government and Greater Manchester’s leadership are explicitly ignoring the data that shows:

  • There is sufficient brownfield land available to deliver at least 1.2m homes nationwide
  • There are 1.55m empty homes across England and Wales (including 70,000 homes owned by councils and housing associations)
  • There are an estimated 165,000 empty commercial properties that could be turned into houses and/or flats
  • More innovative solutions could also be looked at, such as promoting the 26m empty bedrooms in the UK that could provide income for the householder and a place to live for someone on a waiting list.

Shockingly, there are many sites which have been granted planning permission but have not been developed that could provide over 1m new homes – yet there is no impetus from the Government to ensure these sites are brought forward BEFORE any Green Belt is released.

Finally, the biggest issue with the housing crisis is the lack of genuinely affordable homes (social or Council housing).  This is an issue that has been disregarded for many years and the current Government has not even set a target to ensure Councils increase the number of these homes to address the huge and growing waiting lists.  Places for Everyone should have been renamed ‘Places for those who can afford to buy’ because the target for all affordable housing was removed from policy during the modifications process and the target for social housing was removed from the plan altogether!

We have frequently highlighted the impact on nature’s recovery, climate mitigation and our future food security when Places for Everyone was adopted by the Greater Manchester leadership in March 2024.  The consequence of the loss of environmentally and ecologically rich Green Belt land which provides all these benefits, along with the other issues set out above, shows the extent of the betrayal of future generations that is now becoming increasingly obvious.

The Planning and Infrastructure Bill (published by the Government on 11th March 2025) intensifies the Government’s war on nature and communities by reducing democracy and weakening protections for flora and fauna.  It introduces Spatial Development Strategies, similar to Places for Everyone, but without the consultation previously required.  We’ll say more about this in a future blog, but it appears to be yet another Developer’s Charter, as someone else succinctly put it – another Government initiative providing

Developer Net Gain!

Call for Action 2 – Carrington Relief Road!

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There have been numerous concerns raised about the route of the Carrington ‘Relief’ Road across Carrington Moss, as it will cause significant harms to both human and wildlife populations and several of our members have suggested that there is a significant lack of awareness shown by those making the decisions about this proposal. 

With this in mind, we hope you will all join us on a walk along the public rights of way near to the Carrington Moss part of the route for the new road.  We plan to meet on Dainewell Park on Saturday 8th February at 2pm. 

We’d like you to invite your Councillors and your MP to join us on the walk, so we can share our concerns.  If you are not sure who your Councillors or your MP are, click on this link to find out.  You just need to put in your post code and, hey presto, the information is there.  When the details come up, you will see a link at the right-hand side which says “Write to all your Councillors”.  You can drop them a note and invite them to come along.  If you click on your MP’s name, you can also send an email to him inviting him to come along and hear your concerns about the road.  The more invitations the politicians receive, the more likely they are to join us on the walk.

As we mentioned in our previous blog (Call for Action 1 Respond to the Consultation), the Friends of Carrington Moss welcome the long-awaited opening of the A1 route through the employment area of Carrington, but all HGVs should be required to use that route, rather than travelling along the A6144 through Carrington Village.  The CRR consultation confirms that “HGVs will not be banned on the A6144” but this should be challenged in consultation responses. 

It is disgraceful that Trafford Council have enabled the current situation being experienced by Trafford residents living in Carrington, including the air, noise, light and vibration pollution they are suffering day and night.  During the past more than 10 years of planning for unviable and unsustainable growth here, Trafford Council has not identified and/or committed funding for sustainable passenger and freight transport solutions for the area.  This is particularly shocking given the anticipated number of HGVs using local roads each day, including those that will carry hazardous materials.  There are various alternative options Trafford could have considered, including using the former railway lines, the Manchester Ship Canal and the potential to deploy pipelines (there are several of these in the area already)!

We do, though, have major concerns about the part of the route which runs across Carrington Moss.  Not just because of the impact it will cause to Sale West residents and the lack of benefits to surrounding communities, but also because of the harm it will cause to the 335-hectare peat moss (described by Natural England as irreplaceable and restorable), the productive Grade 2 agricultural land, the extensive woodland and the wetland habitats.  All of which are essential to a sustainable future for our children and grandchildren.  The road, and the wider plans for New Carrington, will also significantly impact 15 sites of biological importance and a site of special scientific significance.

Click here to join our online public meeting on 28th January at 6pm to discuss these issues further.  All are welcome.

Finally, despite highlighting previous inaccurate, incomplete or misleading information in CRR materials, the consultation resources (letters and website) have yet more examples.  We will be requesting a further Call for Action from local communities.  Look out for our next blog for more information on this.

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