Another CRR Report, another list of factual errors and misleading statements!

We are amazed that, once again, we are reviewing a report about the Carrington Relief Road (CRR) that is full of factual errors and fantasy proposals.  Does Trafford think that, if they keep repeating such statements, they will morph into accuracy?  See our Letter to Trafford’s Chief Executive back in February 2020, our multiple blogs (some of which are referenced below) and our more recent complaint (for which we are still awaiting a response).

This report to Trafford’s Executive Committee on 25th July 2022 (fast forward to page 443) includes erroneous, mistaken or just plain inaccurate statements, as set out below.

Consultation

On page 19 of the Executive Report, the author states that “There has been significant consultation and engagement carried out as part of getting to the current position.

This is factually incorrect, see our recent blog.  Our Councillors should be asking WHEN there has been ANY consultation.  For the avoidance of doubt, this would have been when Trafford published it on their consultation portal, residents would have been given the opportunity to review detailed proposals and provide their views via a series of questions, posed by Trafford.  The engagement exercise in 2021 simply asked residents to watch a video and raise any questions they had.  This was NOT a consultation.  The communications mentioned a next phase of engagement, but this did not take place and our questions and requests for workshops fell on deaf ears!

Paragraph 1.6 states that the project team has “taken on board the issues that have been raised by the community”.  Which “community” are they referring to?  FOCM, the Parish Councils and a number of other community groups, provided a detailed response to the public engagement exercise, but Trafford has not taken on board our concerns, they were not even mentioned in the Preferred Options Report.  Neither have they taken on board the issues raised by Natural England.

The Executive report also makes a pretence of taking conscientious consideration of resident feedback!  Paragraph 1.9 suggests that a significant package of public transport, road safety and active travel measures were proposed as a consequence of the public engagement exercise

This is totally disingenuous and, once again, incorrect!  We had already been told that these schemes were being proposed long before the exercise and this was confirmed at a presentation given by Trafford Officers on 3rd November 2020.  Indeed, in a response to questions raised by FOCM in 2019, Trafford Council stated (8th March 2019) that: “it should be noted that all roads illustrated on the indicative masterplan are proposed as multi-modal routes and are therefore proposed to include bus and active travel routes”.

We will not hold our breath waiting for the Consultation set out at Section 6.!

Finance/Funding:

In 2012 the budget for this road was £3m, in 2018, it was £34m – it is now over £56m and rising!

It is clear that there is not only a shortfall in the availability of funds for this road but that the price could rise further and the suggested reliance on developers to fund the bulk of the shortfall from S106 monies is deceptive and risks derailing other ambitions, such as those related to affordable housing. 

Now, we know Trafford has a huge development planned here but:
1: the spatial plan has not yet been approved, so it may not (or may not all) go ahead
2: when the planning applications come through they may fail on various grounds (including environmental (and many will certainly be challenged)
3: most importantly, will the developers try to reduce their contributions as much as possible – of course they will!

In addition to all of this, we anticipate costs will continue to spiral, so, what does happen if there is a shortfall in funding? 

This week there has been news that another road scheme has been cancelled “due to Treasury funding pressures”.  Other schemes nationwide have seen Government funding reduced, estimates increased (sometimes by almost 100%) and affordable housing becoming the sacrificial lamb!

What questions should we be asking our Councillors and the Trafford Leadership? 

What should be recognised is that even Labour leaders in other GM boroughs are calling roads “an old world solution and cancelled schemes can have high costs to the Local Authority (see Stockport here). 

Are our Councillors happy about the approach to financing? 

Even the Worst Case Revised Estimate (Table 2) looks very optimistic and the Contingency numbers look very low for a project of this nature!

Elsewhere, the document states that expenditure is being funded via capital receipts as one of the grants is “not receivable until full outline planning permission is obtained.  What if full outline planning permission is not granted?  What if permission is delayed significantly?  Is this a sensible approach?

Public Transport:

Despite being promised, in both the 2006 UDP and the 2012 CS, there have been no public transport improvements in this area (in fact bus services have reduced) and there are NO commitments in Places for Everyone for any public transport improvements (no trams, no trains and no new bus services) we have checked this via a Freedom of Information Act request, but, its ok, we will have a new road for phantom buses to run on.

Despite what is written in the report (see para 1.4 and 1.5), there is ZERO commitment to public transport improvements, NO promotion of sustainable passenger or freight transport and NO active travel improvements since 2012 either!

Nor will the CRR “assist in creating a safe environment for walking, cycling and public transport” (paragraph 1.3).  Residents will not be encouraged to change their mode of travel to walking or cycling given how unsafe, unhealthy and unpleasant it will be to do so next to a busy major road (and that will be the case for both the new CRR and the existing A6144, which we understand will still be accessible by all vehicles, including HGVs and through traffic, contrary to the statement at para 1.2).

Of course, having two roads, instead of just one, will induce much more through traffic, increasing carbon emissions and air, noise and light pollution in the area.

So, another recurring theme of inaccuracies and deceit! 

In the report they say (para 8.3) the scheme will be delivered in the context of the GM 2040 Transport Strategy, but that Strategy states that the GM Right Mix aim is for

zero net growth in motor vehicle traffic between 2017 and 2040,

which suggests there should be NO requirement to create capacity for increased traffic volumes.  A new road is not the right solution to achieve the aims of the GM 2040 Transport Strategy!

Compulsory Purchase Orders (CPO)

We recognise that the CPO process can include lengthy and often contentious negotiations, as set out in the Preferred Options Report of 8th August 2021 (POR), especially if “Hope Value” is expected by the landowner.

The POR states that “Negotiating with landowners will add significant risk to the programme and budget and CPO is a complex and lengthy legal process is a last resort option for Trafford”.  Yet, there was no mention that CPOs would be needed if the route across Carrington Moss was chosen. 

The POR went on to say “If the space required to construct a scheme to meet the scheme objectives is not available, or if it will lead to lengthy negotiations with landowners, it cannot be considered a suitable route.”  Surely this statement is true of the A1 road, as much as it is for the Option A/F sections?

In relation to Option F, the POR said “A basis for dedication has already been discussed in principle with HIMOR for the land in their ownership that may be required for the relief road.  This significantly reduces the risk of requiring compulsory purchase orders for this land”.  We had assumed this statement related to all Himor (now Wain) land, including that in the area of the A1 road.  It is clear that the POR was either badly worded or deliberately misleading!

The Preferred Options Summary in the POR, under the category Land Availability, says “Both Options A and F will affect the Green Belt, Option F [the route across Carrington Moss] is however more detrimental to the Green Belt as the area will now be severed by two roads as opposed to one if Option A was constructed. However, Option A presents a major issue with the available width being constrained between residential properties which would require demolition of properties, land take of private residential open space and likely requirements for CPO unless the standard of the relief road was significantly reduced through the constrained sections. This would compromise the high-quality active travel provision the scheme is able to provide, which is one of the main scheme objectives. For this reason, Option A is seen as being an unrealistic route choice in terms of Land Availability.”

This is incorrect and is one of the key facets of bias that were deliberately introduced into the POR (see our blog for more detail).  Option A would need NO additional CPOs as active travel could continue across Carrington Moss had that route been chosen.

Producing misleading reports, such as this, discredits Trafford Council.  All Councillors should now call for the decision about the Preferred Route to be revisited.

Sustainability

There is no mention in the report about the impact of the loss of Grade 2, best and most versatile, agricultural land which the Council has previously (Core Strategy 2012 and UDP 2006) pledged to protect – this is surely even more important now we are in a food security crisis, caused by the pandemic and the war in Ukraine. 

There is no reference to the Natural England concerns (again) and the Natural Capital Value of the site has not even been mentioned, yet we understand this is the way GM are assessing the value of their natural assets.  The GM Wetlands initiative want to include Carrington Moss in their latest project, this is also not mentioned in the report.

There is no reference to either GM’s or the Government’s Environmental Plans – so we do have concerns about whether the CRR will be consistent with these?  The GM 5 year Environment Plan highlights the importance of climate change mitigation, air quality, the importance of the natural environment, the aim to be carbon neutral by 2038.  Given that plan aims to increase the use of public transport and active travel and shift freight to rail and water transport, shouldn’t Trafford be spending its finite resources on initiatives that will move those ambitions closer to reality, rather than building yet another road at huge cost to the public purse, the environment and the health and wellbeing of Trafford’s own residents.

The Government’s 25 year Environment Plan specifically mentions that “Our traditional farmland birds have declined by more than half since 1970.”  Casually suggesting (Executive Report, paragraph 9.5) that “Mitigation for these species will be incorporated into the scheme design with the aim of maximising opportunities for enhancement” is just more blah, blah, blah!  Destroying the habitats of red listed birds is not mitigation or enhancement!

The report’s response to Carbon Reduction does not say there will be carbon reduction!  There is clear and recognised evidence that new roads bring new traffic – the carbon implications of this road are huge, not just in terms of the lost opportunities as a consequence of concreting over a vegetation-rich area that may include peat, but also in terms of the increased vehicle traffic using this route and, as mentioned above, there are no commitments to sustainable passenger and freight transport here! So, suggesting (paragraph 8.4) that this road will bring significant carbon enhancements to the area is pure fantasy. 

Health and Wellbeing

The health implications have been significantly understated and the report is completely disingenuous to suggest that the construction of this road will improve the health and wellbeing of Trafford’s residents.  As mentioned above, modal shift, using either of the two busy, toxic roads, is highly unlikely because active travel will be unsafe, unpleasant and unhealthy! 

In addition, there will be a huge increase of air, noise and light pollution which will massively impact the health and wellbeing of local people, including users of Carrington Moss, the pupils and staff at All Saints Catholic Primary School, and the residents of Sale West (to say nothing of the wildlife and birds that breed and feed on the moss). 

The document suggests (para 1.1) “local residents will have their quality of life improved”, which residents do they mean.  Carrington residents will be surrounded by traffic (on two routes rather than one), Partington residents get no benefits at all from this route and Sale West residents will experience massively increased air, noise and light pollution, along with traffic congestion at Mersey Farm

Programme Risks:

Paragraph 4.2 (Table 4 Risks) – states that “The project team is working to a detailed programme of activities which takes into account all activities which are associated with preparing a complex major scheme planning application”. The document we have received in response to a FOI request, which is available here, is not detailed and does not include all the workstreams one would expect for a programme of this nature. 

We are concerned that Trafford has not demonstrated that this road is viable and deliverable, especially given the funding issues mentioned above.

There is a huge risk that the Strategic Outline Business Case (para 3.1) will also include factually incorrect and misleading statements.  This could mean the funding is not approved.  In addition, the City Regional Sustainable Transport Fund states that “Bids must propose a programme of investments that reduce carbon and particulate emissions from transport”.  We have been requesting this information for some time.  Based on other information made available about the CRR, we are concerned that, when produced, it will not be accurate.  This could again, impact funding approval.

The are no risks highlighted about National Highways inputs or Natural England’s environmental concerns.  Nor are any risks highlighted about the potential for the planning application to fail due to community objections or legal action.

Trafford’s 2012 Core Strategy (CS):

In the Relationship to Policy section, the document states that the CRR “is a requirement of Trafford Core Strategy (2012)”.  This is incorrect!  A “link road” was certainly included in the CS but it was priced at £3m – clearly not the same type of road as the one now being proposed for almost 60m – see our blog confirming what was (and what was not) in the 2012 Core Strategy and the 2006 UDP here. The CS (and the UDP) also included, for example, provision for a bridge across the Manchester Ship Canal – but no work has been done to progress that scheme (we have checked via an FOI request). The documents also mentioned the potential for rail links, given the disused train lines to Carrington and Partington (but that has not progressed either).

Conclusion

This report continues to replicate the incorrect and misleading claims made in previous Trafford documents!

The decision of the Executive Committee on the route for the road was based on a flawed and biased Preferred Option Report – there are alternative options which would be much cheaper for the public purse, much less environmentally damaging and much healthier for Trafford residents. 

It is clear that creating another road (rather than upgrading the A6144 and retaining active travel routes across Carrington Moss) will increase traffic, increase congestion and will increase the number of large polluting vehicles, such as HGVs using local roads!

In progressing this scheme, Trafford is prioritising the convenience of the car driver above a sustainable future for our descendants.  It should be noted that those who do not drive, or cannot afford a car, will be breathing in the toxic air caused by traffic coming to or through the area, yet those residents will gain no public transport options to reduce their exposure!

Can Trafford (and its residents) really afford the financial, environmental and societal costs of a scheme that provides so few benefits?

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