Our Struggle to Secure Robust, Genuine Consultation
At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps.
A member of the Scrutiny Committee requested a more balanced representation of the facts. The Carrington Relief Road documentation does seem to be plagued by the sheer volume of misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).
This is the fifth in our series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.
This blog focuses on Trafford’s Statement of Community Involvement and resident perception of the “consultation” process.
One of the most interesting parts of the presentation to the Scrutiny Committee was the discussion about public engagement, which many members of the Committee highlighted as a concern.
One of the aims of the Friends of Carrington Moss is to increase the level of community involvement in decisions related to the future of Carrington Moss, including appropriate levels of timely and genuine community engagement on all planned developments.
Sadly, we have been totally unsuccessful in achieving this goal. In fact, we’d go further and say that, despite all our efforts, we have not made any difference at all to Trafford’s approach, which is summarised below (this is a recommendation in the Carrington Relief Road (CRR) Update report to Trafford’s Executive on 27th September 2021)
“authorise community engagement and consultations where the Corporate Director deems it necessary or advantageous”
Necessary or advantageous to whom? Trafford has a Statement of Community Involvement (SCI). Shouldn’t the community engagement and consultations be consistent with that document and with the Gunning Principles (see below), against which any legal challenge regarding the consultation will be measured?
The words of Councillor Aidan Williams (Extraordinary Council meeting, Warburton Bridge Toll decision, 13th January 2022), resonate strongly. Councillor Williams talked about the “huge amount of effort that has been invested by local people, over a vast period of time, into trying to get MSCC to understand the perspective of local residents regarding the toll bridge. Unfortunately, those efforts have not been rewarded”.
We, and other local groups, have tried to help Trafford to understand the perspective of residents about the New Carrington development, the CRR and the importance of Carrington Moss, without success!
What does the SCI say?
The opening paragraph of Trafford’s current SCI document states that “The planning system in Trafford should be as transparent, accountable and socially inclusive as possible. There should be as many opportunities for successful and meaningful public participation as there can be. Trafford Council wants to have even more effective community involvement, providing opportunities for active participation and discussions with the community as early in the plan-making and planning application processes as possible.”
Well, there is a lot of work to do before Trafford meets this goal. We have lots of examples of non-compliance around the whole of the New Carrington development but sticking to the topic of the CRR, let’s look at what we have experienced.
On 8th March 2021, the Friends of Carrington Moss, representatives from the Parish Councils and a representative from Peak and Northern Footpaths society met with two members of the CRR Project Team, having sent a list of questions in advance of the meeting. None of our questions could be answered but the Project Team did manage to clarify some aspects of the scope of their particular phase of the work.
As part of our feedback, following this “engagement” session, we requested the following:
- A specific workshop on traffic modelling covering the anticipated traffic levels (including HGVs) from both residential and employment sites, including current volumes and all planned and expected growth
- An active travel workshop at the earliest stage of the WCHAR process
- A workshop to discuss the design of the two routes in more detail (we mentioned that we have ideas that will make Option A workable, we said we’d also like to ensure the final report is more balanced and highlights all the environmental issues, the costs and the risks related to both options)
Despite chasing this request with the Amey Project Manager in late March 21, we had no response. We forwarded the request to Trafford’s Director of Growth & Regulatory Services in June 21 and to the Corporate Director of Place in July 21 and we still have had no workshops and no explanation of why such sessions could not be arranged, despite the SCI confirming (paragraph 3.11) that consideration “will be given to requests for Virtual Stakeholder events”.
Among much more guidance for the consultation process, Trafford asserts (in paragraph 3.1) that it will “carry out appropriate consultation during the preparation of plans and supporting documents” and that “Comments will be invited on what these plans should contain, what supporting evidence there should be, what the key issues are and how they can be addressed. Consultation will take place at early stages of the plan-making process and continue throughout. Any comments that are submitted will be considered and taken into account during the next phase of the plan-making process”
These assertions are not what has been experienced by residents in relation to the CRR. We do not believe our comments have been conscientiously considered, nor taken into account. As an example, we raised a specific question in our response to the Public Engagement which took place in Spring 2021:
“Residents believe improvements can be made to the design of Option A. How can these be fed into the process?”
We did not receive any feedback and the decision has now been made by Councillors to move ahead with Option F, despite Officers being fully aware that there could be opportunities to ameliorate Option A (a solution which we believe would result in lower costs for the public purse, be less environmentally damaging and more acceptable to local residents).
This is one of many questions from our response that did not make it into the report to the Executive, discussed later in this blog. We do understand that Officers are working to challenging deadlines, but it is totally unacceptable that our questions and requests have been ignored by both Trafford and Amey. There are NO forums for residents to input into the plans for the area.
The SCI document states (paragraph 1.3) that “The SCI will guide all community involvement on planning matters in Trafford, ensuring that people know when, how and for what reason they will be able to take part in plan-making and planning application processes.”
Yet, there was clearly a disconnect between what was publicised and what Trafford presented to the Scrutiny Committee (which stated that “The early public engagement exercise aimed to assist in the selection of a preferred route option, calibrate scheme objectives, and to inform the subsequent development”). Here, the presentation echoes paragraph 3.4 of the Preferred Option Report (7th August 2021) and the report to Trafford’s Executive (27th Sept 2021).
Scrutiny Committee members expressed their surprise that Trafford’s analysis of the 123 responses revealed that “just 21 respondents expressed a preference between Option A (on-line widening) and Option F (new build)”.
To be clear, residents were specifically told that responses to the public engagement were NOT expected to include preferences about the route option. The exercise was limited (as explained in Trafford’s leaflet, their website and their news article) to raising any questions residents had about the CRR and the Option Appraisal process.
Neither the leaflet, which Trafford confirmed had been sent to 10,000 homes and businesses (despite the spelling error) nor the Trafford news article (produced to accompany the launch of the CRR page on their website) suggested that residents were expected to express a preference in relation to the route options.
Had residents been aware that route option preferences were expected, there would have been a significantly greater number of responses returned!
This public engagement exercise did not provide any questions for residents to respond to, nor was the “event” published on Trafford’s Consultation Portal. Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.3) that “As part of the consultation stage there will be the opportunity for the public to register questions and concerns that will be collated for consideration as part of the next phase of engagement.”
Note: This was NOT a “consultation” stage and there has been no “next phase of engagement”!
The leaflet also mentioned the next phase of engagement, suggesting it would be “a series of more focused sessions which will answer your questions”. There has been a deafening silence since this public engagement event. No information has been forthcoming from Trafford Officers to the community, no frequently asked questions document has been produced and no responses have been received either to our questions or, as mentioned above, to our requests for workshops.
Importantly, none of the public engagement communications to residents suggested that there will be NO statutory consultation on both routes!
Table 5 of the Preferred Option Report (7th August 2021) included the following question:
“Q8. When does consultation period start? More information is required about the next steps in the engagement process, particularly when the Frequently Asked Questions document will become available and when the actual consultation about this road will start? Asked 37 times”. The response to this question was: “Q8. Not applicable to route option selection.”
This is an inappropriate response. This question IS applicable to route option selection. Residents expected to be formally consulted on both routes.
In another question in the same Table, residents asked:
“Q9. How has the decision-making process been conducted to ensure it is as transparent and unbiased as possible? Has an independent review been conducted? Asked 36 times”
The response to this question was “Q9. The decision process for the preferred option is detailed in Section 1.2. of this report. The preferred option will be determined based on the agreed criteria and the reporting and conclusions will be subject to both Amey and Trafford check and sign off procedures.”
Section 1.2 of the report is a summary of the Route Options. There is no information about the decision-making process in the report. This is an important question and the decision-making process should have been transparent to residents and to the Scrutiny Committee.
Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.4) that “Once feedback has been collated and categorised, the project team will then host online feedback sessions which tackle individual areas of interest or concern such as traffic congestion, environmental impact, drainage and flooding, and so on.”
Residents have not been invited to any such sessions. There has been no feedback, online or otherwise. In fact, there is rarely any contact with Trafford that is not instigated by residents!
Residents have had no involvement in, or input to, either the creation of the proposals/options or the development of a genuine and robust public engagement approach.
Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 5.1) that “It is recommended that this proposal be accepted to ensure that an open and fair engagement process with the public is carried out and to give the Council the opportunity of further understanding and addressing issues of concern.”
With all the above in mind, along with the points made below, we DO NOT consider that Trafford established
an open and fair engagement process!
Neither has the Council addressed the issues of concern. In fact, in choosing the route across Grade 2 best and most versatile land, woodland, wetland and peatmoss, rather than hear resident suggestions about how Option A could be improved, the huge levels of concern about the environmental issues (highlighted by Trafford’s Officer) have been significantly exacerbated.
Other issues remain ignored. As mentioned in our previous blog, residents have been requesting details of traffic numbers for the area for over 2 years, including as part of this exercise, without success.
Has resident feedback enriched the project?
It is not clear that the engagement exercise itself resulted in any changes to the scheme. There were some surprising anomalies in the resulting Option Appraisal document. Some examples are outlined below.
The presentation (and para 3.4 of the Preferred Option Report) also stated 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” which was listed as one of the CRR Objectives in the Engagement Presentation.
Scrutiny Committee members should ask why this change was made and who requested it!
The report to Trafford’s Executive (27th Sept 2021) stated (paragraph 5.1) that “the public engagement process has enabled Trafford Council to enhance and update the required deliverables, having taken on board the issues that have been raised by the community.”
This cannot be correct because the majority of our questions (21 out of 23) were NOT covered by the summary in the Executive report, nor have we had responses to them. Our response can be found here.
Furthermore, Table 8 (Other Criteria Summary) of the Preferred Option Report (7th August 2021), includes the following under “Engagement Feedback”:
“a preferred option has not been identified from the engagement responses”.
The table concluded that “No Clear Preference” for the Option was stated. An astonishing statement, given that residents were not asked to provide their preference, giving rise to considerable concerns about the bias throughout this Preferred Option Report! This topic will be covered further in a future blog.
The item in the Table goes on to say “This section does however demonstrate the feedback provided has been considered in the overall preferred option selection and there is a requirement for further engagement and consultation prior to submission of the preparation of the planning application.”
Yet another incorrect and misleading statement.
As mentioned above, the majority of our questions do not appear to have been considered, there will be no opportunity for residents to respond to a formal consultation on Option A and a decision has been made about the route without any engagement with residents about their ideas to improve Option A.
It should be noted that giving the option to ask questions (but not get answers) is not engagement. Engagement is getting residents around the table, finding out what OUR key objectives are, listening to our proposed solutions and acting on them or explaining why this is not possible!
One of our questions related to the objectives of the CRR. We asked why protecting the health and wellbeing of existing residents is not the number one objective. Not only did this suggestion not make it to number one on the list of objectives, it did not even make it onto the list itself!
The report to the Executive continues (paragraph 4.8) with the statement “Every comment received has been evaluated in detail and recorded on a response tracker. Many individuals raised a number of points, so their responses were recorded separately in all relevant categories. The team created a list of 11 “standardised questions”, under which response themes could be allocated.”
We raised questions about, for example, other (more sustainable) options that could have been considered (such as the bridge across the Manchester Ship Canal), dualling capacity and the costings. We also asked (having recognised that the existing option appraisal is quite basic) when will a more detailed review of both options take place? None of these (and many others) have been included in the report.
In addition, Natural England’s response had some strong words for Trafford – yet these somehow didn’t find their way into either the report or the presentation to the Scrutiny Committee:
Was Trafford only prepared to include information in the Option Appraisal and Committee Reports that supports their predetermined decision to choose the Option F route? Again, this is an example of the bias demonstrated in that Option Appraisal report.
It should be noted that we have been raising issues about Trafford’s reporting on the CRR for the past 2 years. Our letter to Trafford’s CEO (28th February 2020) raised numerous issues, including the lack of engagement with residents. We particularly highlighted the statement that the project “is expected to be managed using PRINCE2 principles” (paragraph 7, Outline Business Case, Executive Summary, December 2019). In its methodology, PRINCE2 has specific requirements relating to stakeholder engagement and, as residents should be considered to be THE KEY STAKEHOLDER, we were (and still are) keen to understand who our representative on the Programme Board is. Once again, we have been unsuccessful in our attempts to solicit responses from Trafford in relation to our questions on this matter.
Up to date evidence?
The SCI mentions (paragraph 2.18) that the “Council’s evidence base contains up to date and regularly monitored information from surveys and evidence gathering exercises. The evidence base helps to inform the preparation of planning policies and the contents of plans. Information contained within the evidence base can also highlight the need to prepare or review a plan. Where appropriate, the Council will seek the involvement of relevant groups and organisations in the development of this evidence base so that it has the most reliable and robust information available.”
The graphic below demonstrates the feedback that has been received to date about the New Carrington allocation, which includes the CRR, and our specific petition against roads being built across Carrington Moss. Residents have consistently disagreed with Trafford’s proposals, yet there has been NO consideration of alternatives, despite the alternative propositions put forward by residents.
And what about our petition?
Councillor Wright mentioned that “you’ve got to bring the communities that already live there on board with all those new homes and all of that change”.
Newsflash! Residents do not feel “on board”!
As our Secretary said to Full Council on 13th October 2021, “Local people feel powerless, fearful, and angry that planning and development feels to be carried out DESPITE rather than FOR community members.”
Councillor Wright mentioned that the majority of the 1,632 signatories of our petition did not live in Carrington or Partington. We believe we could have significantly increased the number of signatures further had we not been in a pandemic. Councillor Wright continued, suggesting that the people who are going to be most affected by the road live in Carrington and Partington.
This is incorrect!
Whilst Carrington residents may benefit from the opening of the A1 route (if the existing road is closed to HGVs and through traffic), we do not believe Partington residents will see any benefit from the construction of this road, especially given the amount of traffic it is expected to induce into the area.
The disputed part of the CRR (the part which runs across Carrington Moss) will affect the residents of Sale West the most, especially those with children at All Saints Catholic Primary School, who will be particularly impacted by
huge increases in air and noise pollution
It is Sale West residents who will be impacted by any flooding caused by concreting over this part of the Trafford’s largest Natural Capital Asset, and they could also be impacted by large scale vermin infestation when the construction commences.
The other populations most impacted by the Option F route are the users of Carrington Moss (including the sports professionals and children who play and train there), the horse riders, cyclists and walkers whose routes across the Moss will be fractured (which could lead to serious accidents) and, again, they will be hugely affected by air and noise pollution. Of course, nature and wildlife will be impacted too, we will cover that in a future blog.
When presenting our petition to Full Council on 13th October 2021, we asked Trafford to consider:
- More consultation, we asked for a seat at the table and involvement in the design of the plans for our locality
- Genuine and sustainable alternative options to building of roads across Carrington Moss, and
- More consideration of the environmental impact of the CRR, especially given Trafford’s declaration of a climate emergency
We have not been offered any of these things, nor have we been told why they cannot be addressed. In fact, we have had no formal response to our petition from Trafford at all.
Given all the issues mentioned above, perhaps the Scrutiny Committee could recommend that Trafford activates the option in paragraph 5.26 of the SCI, which states that “In certain circumstances the Council may decide to undertake Re-consultation”.
In the report to the Executive (27th September 2021), Carrington & Partington Transport Infrastructure – CRR Update, the paragraph labelled “Consultation” suggests that the report “sets out in detail how the public have been engaged so far.”
It should be noted that there has, as yet, been NO consultation about the CRR.
We are delighted that members of the Scrutiny Committee requested that future consultation proposals are reviewed by Scrutiny Committee in advance of publication. Perhaps that will signal a change in approach?
When it comes to consultation, the courts apply a set of rules known as the ‘Gunning Principles’ to decide whether a consultation is lawful. These Gunning Principles are considered to be fair to both Consultor and Consultee and are increasingly being used to measure the legitimacy of consultations in legal cases.
We’ll cover compliance with the Gunning Principles in a future blog. Legal processes are time-consuming and costly for all concerned, even the winners, so let’s hope such action is unnecessary!
What are our asks?
We set out our key asks in our previous blog. Without the information we request, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal.
For more information about our previous analysis relating to the Carrington Relief Road, please check out the Carrington Link Road page on our website.