Apologies for this long blog but it is a sad day when residents believe their Local Authority’s process is so grossly flawed that they need to take expert advice! The CRR report for Trafford’s Executive Committee (Monday 27^th September 2021) is yet another example of a biased report relating to this subject!

Natural England had some strong words for Trafford in their response to the information sharing exercise that took place earlier this year – yet these somehow didn’t find their way into this latest report:

3. Route Options

We note that the full Environmental Scoping Report is not yet available but the Options Appraisal Report states that a desktop assessment has been carried out. We are disappointed that the findings of the environmental desktop study are not fully reflected in the appraisal of the route options. Appendix D contains slightly more information on the environmental constraints but is not an accurate representation.

5.3 Option F Risks

The environmental risks have not been included in this section although they were included in Chapter 5.2 (Option A Risks). We think this presents an inaccurate and unbalanced view of the environmental constraints and it is Natural England’s view that Option F would be considerably more damaging than Option A.

Extract from Natural England response 22^nd March 2021

What are we seeking?

We’d like to see the scheme paused until all stakeholders have been appropriately consulted and their views are able to be properly included in the options appraisal

We’d like to see our carbon footprint and the climate emergency taking a more meaningful part of the option appraisal

We’d like to see the options reviewed to allow for less expensive, less environmentally intrusive alternatives to be considered (with entirely separate active travel routes).

What is so wrong with this latest report?

We’ve raised a number of issues below but in summary, what we have looked at is whether two reasonable options have been proposed and whether a fair comparison has been made between those two options.

In short, our key concerns about the Appraisal are:

Our other issues with this report include:

• Creating active travel infrastructure right next to a road which will see huge numbers of HGVs an hour thundering past, will not only be unhealthy, it will be downright dangerous
• Trafford’s suggestion that the road may need to be dualled in the future does not accord with the strategic transport aims for GM
• There is no record that any assessment has been made of the Natural Capital Value of the two routes
• We believe a detailed review of the costings is needed to ensure this proposal offers good value to tax payers
• The contingency figure proposed should particularly be reviewed (especially given the recently reported problems with the supply of construction materials), we understand that a considerable number of road schemes are found to run significantly over-budget.

Residents views? 
Actually, we have not been asked which option we’d prefer!

Let’s start with the Engagement process, which has been extremely poor.  Direction is provided in the Department for Transport’s Transport Analysis Guidance, which does not appear to have been followed.

We don’t believe the approach to date has followed these Principles! 

The decision does seem to be predetermined.  

FOCM worked with local Parish Councils to develop a response to the information sharing exercise that took place earlier this year.  We requested several workshops – our requests have been ignored! We raised a number of questions – we have not had any answers!  We were given 4 weeks to respond – we are still waiting for Trafford to come back to us!

What is clear is that Trafford does not consider residents to be key stakeholders nor are they interested in giving ‘conscientious consideration’ to our ideas.  One of the questions we raised in that information sharing exercise (which Trafford has chosen not to include in the document) was as follows

Residents believe improvements can be made to the design of Option A, how can these be fed into the process?  Our ideas for improvement would reduce the impact of land ownership issues and will significantly reduce traffic disruption during construction.

This was our polite way of suggesting that Option A was not reasonable as articulated but that we did have ideas about how this could be addressed. 

Of course, if the aim is to culminate in a decision to choose Option F, it is no surprise that, despite chasing frequently, we have had no feedback from Trafford, so have not had the opportunity to discuss or share our ideas.  As a consequence, the inclusion of Option A remains a tick box exercise!

With this in mind, it is really enlightening that the report suggests (as part of the recommendations) that the Corporate Director of Place be able to:  “authorise community engagement and consultations where the Corporate Director deems it necessary or advantageous.”  

Advantageous to whom?  Why isn’t it as simple as saying “we will follow the Gunning Principles in engaging and consulting with residents”?.

It should be noted that the “engagement” exercise held earlier this year was not a consultation.  It was merely an information sharing opportunity, which Trafford suggested would be the “first” event and that a Frequently Asked Questions and Answers document would be made available on the Council’s website in the week after completion of the engagement period, which would then be regularly updated.  This has not happened!

As part of this exercise, some information was made available to residents and they were asked to raise any questions they had about it.  They were not asked to give a view about which option they preferred.  It is, therefore, unreasonable to suggest that residents did not express a preference. 

The document incorrectly suggests that we placed a template on our website, we did not.  We shared the questions that we (and the local Parish Councils) had raised with Trafford’s project team.  Our document did not select a preferred option because we were told this was not the purpose of the exercise.  You can find the document and see the full list of our questions on our website here.

It should be noted that, when they have had the opportunity, residents have repeatedly expressed their preference against this road being constructed across Carrington Moss, not only in the previous GMSF responses but also in our survey, which has been completed by 790 local residents, of whom just 4% support Trafford’s plans and 95% support the FOCM aims.

We also have a petition, signed by over 1,500 local residents against the construction of this road across the Moss which we would like to present to Full Council in October.

In addition to resident signatures, the petition has been endorsed by the following organisations:

Do the future travel options follow Policy?

The Friends of Carrington Moss (FOCM) has previously raised issues with Trafford about the disingenuous documentation in relation to the plans for this road (which really should have another name, it is not going to relieve anyone).  Our response to the initial Options Appraisal (February 2020) detailed our concerns about the Engagement with residents, the Costings, the Air Pollution, the Strategic Aims for the road and also the Misleading Statements and Factual Errors that permeated the report (as well as other issues).  You can find our letter to Trafford’s CEO here, along with her response and our subsequent feedback.  We still have not had answers to the questions we raised.

It is interesting that the current document states that the “early public engagement exercise” calibrated and refined the scheme objectives.  It seems that this exercise has resulted in the removal of the objective to provide “Improved public transport and active travel provision to existing areas which are poorly served and to housing and employment growth areas”. 

Feedback from FOCM and the Parish Councils suggested that the number one objective should be protecting the health and wellbeing of existing residents.  Sadly, this has not even made it onto the list! 

The traffic figures in the Transport Locality Assessments (part of the GMSF/P4E documentation) have been challenged in terms of credibility. It was also acknowledged in that information sharing exercise earlier this year that the existing road is only busy during rush hour periods (like every other major road in the Country) and prioritising a new major road above public transport improvements is not compliant with Trafford’s Carbon Neutral Action Plan.

More importantly, any decision to go ahead on the basis of this report could also be challenged on the grounds that Trafford has failed to fully take into account its obligations following its declaration of a climate emergency in November 2018. 

With even the Government admitting it must review its road building policy to take into account climate change, it is odd that this document does not reference Trafford’s declaration at all, nor does it mention how it has assessed that, since that declaration, the construction of a road is still an appropriate option.

The report also does not mention that GM’s Transport Strategy 2040 aims to significantly reduce car traffic and move freight onto rail and shipping transport by 2040, less than 20 years away.  So, constructing this road is not in alignment with that Policy, which also suggests that transport investment will follow the Global Street Design Guide hierarchy (it places active travel and public transport first, and people in personal motorised vehicles last). 

Questions should also be asked about why no sustainable options for freight have been considered.  Given Trafford’s approval of overdevelopment in Carrington and the resulting huge number of HGVs on local roads, why has this not been considered a priority? 

Residents have been promised public transport improvements for Carrington, Partington and Sale West since the 2006 UDP (with Trafford reinforcing these promises again in the 2012 Core Strategy). It is, therefore, shameful that, in the largest housing allocation in the whole of GM (as set out within the Places for Everyone documentation), with 6 years’ preparation, there are no sustainable freight options, no plans for trams or trains (even though there is a former railway line running right into Carrington and Partington) and, despite the many disingenuous suggestions in this and other reports, our Freedom of Information Act Request revealed that there are NO commitments to increased bus services for Carrington, Partington or Sale West! 

What about the health and wellbeing of Trafford residents?

There are repeated assertions in the report that the CRR will encourage residents to make healthier life choices and that it will improve the health and wellbeing of Trafford’s residents.  Those people who currently walk, cycle or horse ride on Carrington Moss will have their health and wellbeing severely and negatively impacted by option F.  The professional and amateur athletes that play sports at the Manchester United Training Grounds, the Sale Sharks Training Grounds or the Sale Rugby FC Training Grounds will also be impacted (and sports people themselves have begun to make the connection between air quality and their health https://sustainabilityreport.com/2020/04/23/air-pollution-tackling-sports-invisible-threat/). 

The World Health Organisation has announced (22nd September 2021) that it is reducing the maximum safe levels of key pollutants with PM_2.5: reduced from 10 µg/m³ to 5 µg/m³ (NB the legal limit is 20 µg/m³) and NO₂: reduced from 40 µg/m³ to 10 µg/m³ (NB the legal limit is 40 µg/m³). These levels will be phased towards the 2030 target date but this is clearly something that should be considered.

The reality is that wherever the huge levels of 24×7 traffic is directed, there will be a significant increase in air, noise and light pollution.  The obvious answer is to prioritise the reduction of the traffic (ie public transport and sustainable freight), not to move the problem from one community to another which is the current plan. 

Whilst it is positive that the long-suffering residents of Carrington will benefit from HGV traffic being removed from Manchester Road (particularly given the terrible vibrations they are suffering every single day – and night), this could be achieved by simply opening up the A1 route.  It has to be recognised that the air, noise and light pollution will still be there though, and a large number of Carrington residents will still be impacted by the huge numbers of HGVs travelling through the area. The document does not commit to removing HGVs from Manchester Road entirely.

The report mentions in several places that the road will benefit the Partington community, suggesting that the “accessibility of Partington will be significantly enhanced by the scheme” and that it will benefit from “improved sustainable transport access, and to embrace new and improved active travel modes linking to the wider area” but that the impact on Partington traffic is expected to be unaffected by the route option choice.  This is rather odd, given the comments about Option A.  We do not know what sustainable transport access the document is referring to because, as mentioned above, there are no commitments to public transport improvements. We are not convinced Partington residents will see any benefits from this road at all, especially given the planned increase in traffic volumes.

What about the losers?

The obvious losers are the red listed birds and endangered wildlife that have made Carrington Moss their home, the local rural businesses (including agriculture, stabling, livery and their supply chains) that will be heavily impacted and, of course, Trafford’s residents in Sale West will suffer the significant rise in air, noise and light pollution that will be caused by the proposed location of this road.  Sale West residents will also suffer the effect of the construction traffic too. 

The other big losers are the younger generation, who will no longer have access to a huge area of grade 2 best and most versatile agricultural land, that could provide future sustainable food sources. 

In addition, it seems there is more work to do to determine whether the route will disturb the peat deposits, and once again, it is the younger generation who will suffer as a consequence of the lack of restoration action. 

Trafford needs to take another look at this initiative to prioritise the actions needed to address the climate emergency!

We’ve set out our high level thoughts on the Appraisal below, but we would encourage you all to look carefully at the information provided. 

Appraisal Criteria	Best Performing Option/Marginal Difference	Key Points	FOCM Response
Ability to deliver the required network capacity	OPTION F	Option F delivers the required network capacity in a less disruptive and more robust manner. It also provides greater network resilience and better access to sites, particularly towards the east of the area	Given that the Strategy is to significantly reduce car traffic and move freight onto rail and shipping we believe this needs to be reviewed
The ability to create improvements for public transport and active travel	OPTION F	Both options will allow public transport improvements, but Option F allows greater flexibility in routing and will allow for more flexible services and provide better journey time reliability for buses	Both options could provide better journey time reliability for buses.
Carbon Budget	MARGINAL	Both schemes have been modelled, each resulting in a similar carbon budget	The carbon comparisons need to be reviewed, we understand PAS2080 has a carbon reduction hierarchy that does not seem to be reflected here.
Road Safety	OPTION F	The directness of the route, the potential for diverting traffic away from already congested areas, the lower number of junctions and reducing traffic on a road which already has a history of collisions makes Option F the better performing option	This is interesting – in the information sharing paper the document states “There may be speeding and overtaking issues using the whole A1 route due to its long linear alignment”!  With our suggested modifications to the proposal Option A would be the safer option.
Environment, Ecology and Heritage	MARGINAL	The analysis indicates that there are potential environmental, ecological and heritage impacts with both options. Any scheme taken forward would be subject to a comprehensive statutory process of environmental impact assessment incorporating a wide range of surveys and studies	See the response from Natural England at the beginning of this blog. Option F has a much greater impact on the environment and the ecology.
Availability of land	OPTION F	For the offline option (Option F), the developer owns the land required and has committed to making it available for the scheme. In order to widen and improve the A6144 Carrington Lane (Option A), there would be a requirement to acquire property through CPO and demolish buildings	This is based on the biased version of Option A.  Given that our amendments to create a more sensible Option A have not yet been considered this needs to be reviewed.
Geotechnical Assessment	MARGINAL	From information available to date, there is no basis on which to score either scheme differently. There is already physical site survey data available for Option F and analysis of this concludes no adverse issues from an engineering perspective	Obviously, Option A is yet to be assessed.
Drainage and Flood Risk assessment	OPTION F	Overall, from a drainage and flood risk perspective Option F performs better than Option A, with the exception of the requirement for a greater volume of attenuation required. Option F is therefore considered to perform best in terms of drainage and flood risk	If Option F is chosen what guarantees will Trafford provide to the residents of Sale West that their homes will not be impacted by surface water flooding.
The ability to create new landscape or environmental Improvements	OPTION F	Option F would be the preferred landscape solution as it provides more potential for landscape treatments, recreational areas, more opportunities for walkers, cyclists and horse riders.	At the moment, you can stand on Carrington 1 PROW and see right over to the hills 20 miles away, in the future you will be looking at (and hearing) 200 HGVs an hour thundering down a road directly in front of you.  Not the peaceful place of quiet reflection and birdsong that it is today.
Construction Phase Impact	OPTION F	If the A6144 was widened, this would require a significantly longer construction period and impact more heavily on the network with a higher number of road closures and temporary traffic restrictions	This response is based on the biased Option A response rather than on a sensible Option A.  In addition, the construction phase impact of Option F on the residents of Sale West will be more than significant.
Assessment of the impact Statutory Undertakers equipment	OPTION F	The presence of existing Statutory Undertaker services running alongside the existing A6144 would present a significant challenge to the option for widening the carriageway	Again, based on the biased version of Option A.  This should be reviewed following some listening to residents!