A biased and misleading Option Appraisal
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 sixth 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 a review of the CRR Preferred Options Report (dated 7th August, 2021).
In this blog, we’ll review the CRR Preferred Options Report (7th August 2021), which was referred to within the Scrutiny Committee presentation (12th January 2022) and in the report to Trafford’s Executive of 27th September 2021 (Carrington & Partington Transport Infrastructure – Carrington Relief Road Update). Unless otherwise stated, references to “the document” or “the report” in this blog refers to that CRR Preferred Options Report.
We have reviewed the document in detail and, in common with previous documents about the CRR, it is crammed full of misleading information, inaccuracies, conflicting statements, bias and other issues.
At the Scrutiny Committee meeting, Trafford’s officer stated that the Preferred Options Report is a “very detailed analysis of the options and the benefits and disbenefits”. This is not correct. Some elements of the report are at a very high level and the benefits and disadvantages of the two options have clearly been considered with the aim of ensuring Trafford’s predetermined preference (Option F) was proposed to, and agreed by, the Executive Committee. As an example, the assessment of route option advantages and disadvantages does not take into consideration environmental impacts (air, noise and light pollution), active travel benefits, loss of grade 2 agricultural land, loss of bird/wildlife habitats, and more!
The level of bias is clear, not just from the content of this report but also from the statements set out in previous Option Appraisal (OA) documents. The link to the Outline Business Case (OBC) is included in the introduction to this blog. Click on the graphic below to go to the OA from October 2020.
Scrutiny Committee members rightly highlighted a number of issues with the CRR presentation, including whether the costs of this road can be justified, particularly in terms of the inevitable requirements of climate change and whether bolder alternatives should have been considered.
What about those Cost Implications?
The document states that, despite the pressure on the public purse, the difference in cost should be considered marginal, not impacting option selection. We disagree, especially as many of the Option F costs are excluded from the estimate and Option A (currently estimated at 10% less than Option F), if redesigned (see below), is likely to significantly reduce the costs of the route. The report also suggests that it is a requirement of the Core Strategy that the CRR is provided. This is highly misleading because the road proposed in the Core Strategy was priced at £3m (a much less intrusive plan than the current proposal).
There is confusion about the current costs though! The CRR Update report to Trafford’s Executive Committee (27th September 2021) states that the “current budget for the scheme is £29.4m”. Previous reports have quoted higher capital costs (£34m). We believe it is highly unlikely that, in the current market conditions, costs have come down and, in any event, this Options Appraisal (OA) suggests the cost of the preferred option would be £36m (albeit that this estimate excludes huge chunks of required expenditure). It is also unclear whether the costs include or exclude the active travel routes, bus lanes, traffic calming, crossings (both human and wildlife), flood prevention or biodiversity net gain requirements. In response to the public engagement exercise, we requested more information about these cost estimates. This request has not been fulfilled.
Whilst this OA does not analyse the cost benefits of the road option, this was done in the OBC (December 2019), which stated “Overall, the scheme produces significant benefits, about £132m over the 60-year appraisal period”. The OBC explains that the benefits are generated by travel time savings (£126m) and vehicle operating costs (£29m). This 60-year figure equates to £2.2m per year. As shown in the graphic above, we have estimated the Natural Capital Value of Carrington Moss, based on the GM Natural Capital Account (GMSF, Jan 2019, Natural Environment Topic Paper, figure 1). Our calculations suggest Carrington Moss achieves a Natural Capital benefit of around £15m per year. This certainly should have been considered as part of the decision-making process about the route!
In addition, the journey time saving for Option F is only expected to be “almost one minute”, with such savings possibly being totally eroded as a result of congestion caused by the induced traffic concerns highlighted by Transport for Greater Manchester (TfGM) – see next paragraph. When compared to the destruction of Grade 2 (best and most versatile) agricultural land, woodland, wetland and peatland, Trafford’s declaration of the climate emergency and the emphasis on nature’s recovery, we believe the benefits of this road scheme have NOT been proven.
One Scrutiny Committee member raised the issue about the evidence that a new road will alleviate congestion. In fact, TfGM raised this very issue in their Transport Locality Assessment (TLA), which highlighted their concerns (paragraph 12.3.3) that, as the capacity of the Option F route is increased, it becomes more attractive for road users (ie inducing additional traffic to the route, increasing congestion in the area). Despite this concern, the Preferred Option report quotes TfGM as suggesting that the CRR will result in lower traffic flows and better services for Partington. This is misleading given their comments in the TLA and, as the Option F route only serves a small Eastern section of the A6144, residents in Partington are unlikely to see any changes to their journey times!
The report also suggests Option A will result in a significant increase in traffic volumes at the Isherwood Road junction. Option F is likely to drive much greater use of this junction, as much more traffic from Flixton/Urmston will use the (supposedly) quieter A6144 between Isherwood Road and Banky Lane (another example of the CRR inducing yet more traffic onto the existing road).
No dispute about the A1 route – let’s get it started!
One common aspect of both route options is the plan to open the A1 route, end to end. This is something we believe Trafford could have progressed with landowners already, along with the implementation of traffic calming measures through the village of Carrington. It should be noted, however, that Trafford are NOT planning to close the existing road to HGVs and through traffic (the report states that, for Option A only 60% of the expected traffic will use the A1 route, for Option F only around 64% of the expected traffic will use the A1 route). This means high numbers of vehicles will continue to use the existing A6144. The commitment is only to “discourage through traffic from using this route”. This means that residents will be surrounded by the consequential air, noise and light pollution and bus timetables will continue to be disrupted by slow traffic during rush hour.
As there is no dispute about the A1 route, we will focus the rest of this blog on the analysis of the Eastern part of the CRR (Option A, using the existing A6144 between Banky Lane and Isherwood Road, and Option F, which constructs a new major road across Carrington Moss).
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 as it is not going to relieve anyone). Our response to the OBC (December 2019) detailed our concerns about the lack of 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. We have still not had answers to the questions we raised.
The Spatial Framework has NOT YET BEEN APPROVED!
So, let’s start at the beginning, with the Scheme Objectives. As we pointed out in our previous blog, 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! Trafford confirms that the design team discussed the proposals with TfGM to determine the current issues and future plans for public transport improvements in the area but there has been no response to our repeated requests for workshops with local communities to determine OUR requirements.
The primary objective, as confirmed in the GM Transport Delivery Plan, is all about supporting growth. Yet the spatial framework plans have not yet been approved and the Future Proofing section of the Options Appraisal covers just two proposals: dualling the route and giving access to the new Sale West developments. Despite these plans for the overdevelopment of this area, there has been no consideration of any alternative opportunities to support future growth, such as sustainable passenger and freight transport options. The lack of consideration for such solutions is imprudent and does not suggest Trafford is acting in the best interests of its existing and future residents, especially as the area is right next to the Manchester Ship Canal and incorporates two former railway lines which we understand are capable of restoration.
Given Trafford’s declaration of a climate emergency, and the GM Transport Strategy aims to significantly reduce car traffic and move freight to rail and water-based transport options by 2040 (less than 20 years away), it is astounding that Trafford consider a dual carriageway is a rational or cost-effective solution!
In addition, the document makes it clear that the A1 road cannot be dualled. It is questionable whether the Carrington Spur can be dualled (it was originally designed as a single lane motorway). This will lead to significant congestion (and the potential for accidents) at either end of any dual carriageway.
A very biased articulation of Option A!
It is clear that Option A was described in such a way that it could not be progressed. Back in March 2021, residents asked Trafford how their suggested improvements to the design of Option A could be fed into the process? There was no response and our requests for workshops were also ignored.
It is noted that, whilst some of the obstacles relating to Option F have been highlighted, they have not been considered a barrier to implementation (with, for example, mitigation being mentioned in relation to the ecology/biodiversity concerns, and an extension to scope being proposed, to address the current gap in active travel provisions along Isherwood Road). Yet, for Option A, constraints have been considered to be a total barrier to selection, without any consideration of alternatives to ameliorate the issues, despite resident feedback.
Trafford suggests that Option A is constrained by existing residential properties. This is not the case. It is impeded ONLY by Trafford’s lack of leadership on sustainable transport options. Growth is set out in the Places for Everyone Spatial Plan, which covers a 16 year period, starting at the point of approval (as mentioned above, this plan is not yet approved).
This gives Trafford and TfGM time to develop and implement sustainable passenger and freight transport solutions. Why isn’t this the priority, rather than focusing on increasing road traffic in the area?
So, given those timescales, the GM Transport Strategy aims and Trafford’s declaration of a climate emergency, there is no requirement for Option A to secure land (via Compulsory Purchase Order or otherwise) or to demolish existing properties.
In comparing the land needed for Option A and Option F, whilst Trafford emphasises the requirement for CPOs for their current articulation of Option A, they make no mention of the land status of Option F, which is Grade 2 (best and most versatile) agricultural land, wetland, woodland and peatland, all of which should have a measure of protection, according to planning guidance.
Trafford’s officer suggested to the Scrutiny Committee that Option F will provide much safer cycling provision. This is not the case. With Option F, existing walking, cycling and horse riding routes will be severely fractured, leaving residents and users unable to travel from one side of the moss to the other without crossing a major road or taking a long detour. There is nothing in the documentation which suggests there will be crossings, for humans or wildlife. This could lead to a significant increase in accidents and health related incidents.
In addition, Trafford suggests that Option A would “compromise the high-quality active travel provision the scheme is required to provide, which is one of the main scheme objectives”. This is, again, incorrect. If Option A was chosen, high-quality active travel routes can be provided across Carrington Moss. Public Rights of Way (PROWs), such as Carrington 1 (which runs in parallel to the existing A6144 between Banky Lane and Isherwood Road) should be upgraded to encourage modal shift. Trafford also suggests active travel commuters would prefer Option F. This is, once again, incorrect, as shown by the feedback to the WCHAR exercise. Active travel commuters would prefer Option A, so they have uninterrupted routes across Carrington Moss (which, as noted in the report, is the shorter route). This is also true for leisure users, as routes across the moss will be much more pleasant, healthier and safer (rather than walking, cycling and horse riding next to huge volumes of speeding traffic that creates significant levels of air, noise and light pollution). With this segregated active travel approach, the redesign would mean Option A does NOT require carriage widening.
The document suggests Option F would result in the A6144 becoming a more friendly route for active travel users “over its full length, on a quieter, reduced speed road”. This is also incorrect for three reasons. Firstly the A6144 runs from Sale to Warburton, Option F covers only a very short Eastern stretch. Secondly, the document confirms that only 64% of vehicle traffic is expected to use the new route (furthermore, as mentioned above, the Option F route is likely to induce additional traffic from Flixton/Urmston to the A6144 on this stretch of the road). And, thirdly, the document states that the A6144 is expected to have a design speed of 40mph (discussed below). All in all, a very misleading suggestion.
Those active travel routes will need to be maintained. The document suggests that this places a greater burden on Option A but, in fact, the greater burden is on Option F, which will need to provide crossing points and connections between existing PROWs. These do not appear to be included in the current costings.
The document states (page 6) that both options are expected to have a design speed of 30mph along the existing A1 route and 40mph elsewhere. This suggests that the A6144 route would be a 40mph road. We believe this would be dangerous for local residents, particularly because of the high volume of HGVs that will use both routes. Speed limits on the A6144 should be reduced to 30mph to decrease the risk of collisions, creating less pollution and less congestion.
Know your place! Only disruption for drivers is considered to be an issue!
Whilst we recognise that any work on an existing route (Option A) would be disruptive for vehicle users, if a redesigned Option A is considered, the disruption caused by addressing statutory services and road construction issues will be significantly less than currently estimated.
The document does NOT consider disruption for anyone other than those driving vehicles. So, the disruption caused by Option F to users of Carrington Moss, the adults and children who play and train on the sports grounds and the people who live in Sale West, is not even mentioned in the report. In addition, Trafford’s statement that access and egress for Option F will add minor disruption to Carrington Lane is a massive understatement given that there will be 30% more HGVs for this route option!
The document also suggests that there are minimal receptors to be affected by the noise, vibration and dust nuisance for Option F. This is also incorrect. The residents of Sale West will be significantly affected, as will the users of Carrington Moss, including those using the sports grounds. In addition, there will be a huge environmental impact. We have significant concerns about the populations of red listed birds and endangered wildlife that breed and feed on the moss.
We also recognise that the current design of Option A results in a preference for Option F from a fluvial flood risk perspective. It should be noted, however, that if Option A were redesigned in line with the resident views set out above, this would no longer be an issue. Our proposed Option A would also require fewer materials for construction. With this in mind, we believe a redesigned Option A would have significantly lower costs for the public purse (and much lower ongoing maintenance costs).
Inconsistencies in the Document!
Trafford do get very confused in their document, which has a number of conflicting statements. They suggest, for example, that, if Option A is progressed, the active travel facilities that could be provided along the A6144 Carrington Lane will be limited due to constraints but if Option F is chosen, the existing road (ie the A6144 Carrington Lane) will be upgraded to provide active travel provision. Surely, this would not be possible, due to those constraints! In addition, this would add to the costs.
Furthermore, Trafford suggest that, for Option F, active travel provision would be fully segregated from the carriageway. That is not how the images in Trafford documents show the provision (see the New Carrington Masterplan, figure 4.7 and the graphic above). In addition, the Options Appraisal document states that due to Option A being longer, Option F would be more desirable for active travel users. Yet, in confirming Option F is the shorter route, this suggests that active travel routes across Carrington Moss would be the most beneficial for such users, making the redesigned Option A the better solution in this category. In fact, Option F has far less flexibility for active travel users but this is not highlighted anywhere in the report.
Trafford describes Option F as removing “the majority of the through traffic from a long section of the existing A6144”. This is misleading to the extreme. It is a very short section of the existing A6144 (which runs from Sale to Warburton). Whilst, indeed, 64% is the majority of the traffic, the document does not highlight that over a third of vehicles will continue to use the existing route. In addition, the statement that Option F will reduce vehicle-to-vehicle collisions on the existing road is deceptive because there are likely to be collisions on the route across the Moss AND the existing A6144.
Still trying to understand the Carbon figures!
We have requested the detail behind Table 3 (Carbon Emissions Summary) but have not yet been provided with this input document. Trafford assert that Option F requires 30% more construction journeys, yet the carbon emissions for Option A are higher than those for Option F. In addition, we do not believe Option A requires the level of vegetation removal suggested by Trafford, which would significantly reduce the loss of sequestration figures (Table 4). Furthermore, Trafford does not appear to have captured the total loss of sequestration required for Option F.
Whilst Trafford states they have only found a “thin layer of peat in an isolated trial hole” the Government has a Strategy to restore England’s peat mosses and any drainage in the vicinity of the huge area of remaining peat on Carrington Moss (325ha in 1995, 3m in depth), could impact its ability to be restored, resulting not only in a loss of future sequestration opportunities, but also the loss of a recognised irreplaceable habitat.
We believe the peat moss at Carrington is capable of restoration and as such, should be treated as an area of high conservation priority. To propose a road option that could result in such restoration not being possible is, once again, imprudent, especially given Trafford’s declaration of a climate emergency.
More about those Environmental Issues!
We were shocked to discover that the ecological/biodiversity risk does not affect the route option selection, with the document asserting that the ecological impact of Option F can be mitigated and offset by careful planning and early engagement of ecologists. This is incredibly misleading, especially if the route does impact the irreplaceable habitats mentioned above.
In any event, the first step in the Government’s Planning Guidance relating to the Natural Environment is Avoidance, with the advice stating “Can significant harm to wildlife species and habitats be avoided; for example by locating on an alternative site with less harmful impacts?”
In this case, yes it can!
Furthermore, it is astounding that Natural England’s feedback is not even mentioned, never mind the document highlighting their view that Option F would be “considerably more damaging” than Option A. Given that they raise such major concerns about the findings of the desk top study not being fully reflected in the Option Appraisal, that there is “not an accurate representation” of the environmental constraints, that the “environmental risks have not been included“, creating an “inaccurate and unbalanced view of the constraints“, we believe this should have been highlighted, not only in the report but also to Trafford’s Scrutiny Committee!
Suggesting that both Options impact the green belt but not then providing the scale of that impact is also highly misleading. Constructing new carriageways across the green belt will result in a considerably higher level of green belt harm than upgrading the existing road.
The other environmental assessments are incomplete, inaccurate and misleading. There is no assessment, for example, of the air, noise or light pollution impact on the residents of Sale West, nor on the users of Carrington Moss, including those who train and play on the sports grounds and, specifically, there is no assessment of the impact on the ecology, biodiversity, the birds and wildlife, all of which will be considerably affected by the construction of Option F.
Referring to the ecological surveys, the document asserts “It is difficult to conclude which route option is more favourable until this survey work is completed”, then continues with confirmation that those surveys will be carried out early in the planning application preparation stage, after the route selection has been made. This appears to suggest that those ecological surveys will only be carried out on Option F!
There are other environmental issues too. We have a problem with the way Option A and Option F are described in ecological terms, and the claim that the proposed attenuation ponds and landscaping areas along the Option F route will enhance the ecological habitats in the area, is bizarre. Are Trafford aware of how much water will need to be captured? If not, take a look at our video. How large will these attenuation ponds be?
The document confirms that Option F requires 2.5 times more water storage than Option A. Unlike parts of the area required by Option F, the existing road (Option A) is typically not regularly under significant water levels.
The document suggests that mitigation measures could include installation of a ditch to reconnecting water to the current outfalls, further suggesting that Option F has more flexibility and would provide short-term volume storage for the existing overland flow. Given the existing ditch system does not contain the surface water, we believe this assessment is too simplistic and that Option F poses a considerable risk of future flooding to homes in Sale West.
A quick reminder of those consultation issues
The Public Engagement feedback was considered in detail in our previous blog which mentioned that there has not yet been any formal consultation on this road and the public engagement to date does not meet Trafford’s Statement of Community Involvement nor the Gunning Principles.
Furthermore, Trafford has not followed the approach set out in their own CRR Options Consultation Report (dated 18th December 2020), which 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. There will then follow a period of analysis and design development work on the shortlisted options, which will seek to address issues raised. Following completion of this work a summary report will be produced setting out the recommended next steps.”
Given the information we have provided in this series of blogs, we believe strongly that there should now be a formal, genuine and robust consultation about the requirements and route of this road, which includes accurate, up-to-date, unbiased assessments of the alterative options (including information about the practical timescales for sustainable transport solutions).
There are sooooooooooooooooo many other examples we could highlight about this Option Appraisal, but we think you will, by now, recognise that it is not a document that is capable of robustly supporting such an important decision, one which will have such wide ranging impacts on current and future generations of both humans and wildlife.
As has been shown above, there are a variety of contradictions within the Option Appraisal but there are even more when you consider this document against previous reports on the CRR. As just one small example, the OA talks about the importance of the directness of the route, suggesting this makes Option F the safer solution. Yet, in the Public Engagement exercise, Trafford highlighted that the long linear alignment of the A1 may result in speeding and over-taking issues. Surely this would also be the case for the Option F route across Carrington Moss!
Trafford also suggests that Option F provides greater potential for landscape treatments, creating recreational areas and more opportunities for active travel users. It will actually reduce all three, harming the existing open, rural, landscape features, fracturing routes across the moss and reducing the ability of local people to use the area for recreational purposes (it will not be pleasant, safe or healthy to visit green space next to a heavily trafficked major road, that is creating significant levels of air, noise and light pollution). And, all the while, having a substantial impact on bird and wildlife habitats and their populations.
This has clearly not been a genuine appraisal exercise. Option A was deliberately articulated as an impractical route, when this is not the case. We believe there are less expensive, less environmentally intrusive options that can be considered by Trafford. At the very least, resident requests to discuss a revised design should have been accommodated prior to the decision to choose Option F being made.
In addition, the document states that Option A has been “ruled out” based on meeting the requirements of the scheme objectives and in terms of feasible deliverability. Yet, the assessment of the two options against those scheme objectives is fundamentally flawed, fails to acknowledge the induced traffic concerns raised by TfGM, incorrectly assesses the active travel benefits and contains a number of misleading statements such as the one suggesting that “Option F provides relief to the entire A6144 route for a greater distance”. This is incorrect, Option F provides “relief” to a very short stretch of the A6144 (with the document confirming that Option F is the shorter route).
In summary, whilst construction of a brand new road will add capacity in the short term, there has long been evidence that such improvements are quickly eroded by induced traffic. Trafford should be introducing a scheme which is deliverable without impacting the health and wellbeing of existing or future local residents or further harming the populations of red listed birds and endangered wildlife in the area. Their scheme should be futureproofed via sustainable passenger and freight transport options, NOT by encouraging more and more vehicles onto local roads.
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.