An appraisal of the New Carrington plan shows that development here will NOT meet the Public Interest Test! 

Some words we have heard frequently during the Places for Everyone (P4E) Hearings is that the Plan is “Reasonable”, that, with the “Planning Balance” in mind, the Allocations should be approved and that the proposals meet the “Public Interest Test”.

So, what about Places for Everyone and the New Carrington Allocation?

Now, we appreciate new homes are needed in Greater Manchester (GM), particularly genuinely affordable homes (social housing).  Jobs are vital too, not only for the economy but also to ensure individuals are able to meet their obligations and, hopefully, achieve some of their aspirations.  Residents also need access to school places, health services and community facilities.

On the other side of the scale, we also fully understand the importance of our Green Belt and all the natural capital and ecosystem services it delivers.  Given the climate emergency, mitigation is essential.  We recognise the need to reduce GM’s carbon emissions and to ensure residents are not exposed to high levels of air, noise, light, vibration or water pollution.  We must also consider that all development should be demonstrably sustainable (something we discussed in a previous blog).

National planning policy states that “At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs”.

Flooding, for example, not only damages property, it impacts the mental and physical health of both human and wildlife populations.  With this in mind, the wetlands at Carrington Moss should be retained to continue to deliver the ecosystem services they have done so well, for so many generations.  In addition, the superior carbon capture capabilities of restored mosslands could be achieved here, bringing numerous ecosystem benefits. 

In summary, the graphic below highlights that New Carrington does not meet the Public Interest Test, as the levels of harm far outweigh the benefits accrued. 

Residents, and their views, have been supported throughout the P4E Hearings by a number of MPs, including, for example, Trafford’s Sir Graham Brady (who can be heard here at the New Carrington session) and Salford’s Barbara Keeley MP (who can be heard here).  Our MPs raised a number of very important points which highlight that the Public Interest Test has not been met on the sites they are discussing.

These are all very important issues for existing local residents, whose objections to this Plan have been resoundingly ignored.  In addition, the GMCA have made substantial changes to the version of P4E that has been consulted upon, weakening a number of Policies and removing over 520 hectares of Green Belt Additions (which were proposed in part as compensation for the extensive Green Belt release) with no notice or scrutiny of the decision.

As we have said before

Given there are no other places in Trafford where we can:

• restore peat, to more effectively capture and sequester carbon, so future generations can breathe cleaner air
• grow crops and alleviate surface water risks, so our descendants have fresh food, with a low carbon footprint, and residents are not fearful of flooding every time it rains
• increase significantly the populations of endangered birds and wildlife, to help nature’s recovery, increase biodiversity and mitigate the impact of climate change

this rich habitat, known as Carrington Moss, with a long history of extensive surface water flooding, should not have been included in the P4E Plan for development, but could have been highlighted for protection. 

We, therefore, disagree that the Planning Balance has been achieved in favour of development at New Carrington and strongly believe it would be unreasonable to release the land from Green Belt here.

All in all, the harms extensively outweigh the benefits of this Allocation.  So, for the reasons summarised in the graphic above, and set out in more detail in the paragraphs below, an analysis of the New Carrington Allocation resoundingly demonstrates that the site does NOT meet the Public Interest Test.

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Read on for more information about those pros and cons:

Housing

This local analysis used Census and ONS data to highlight that more houses are being built in GM than the number of households being formed.  Trafford, for example, built almost 3,000 more homes, during the 10-year period, than the number of households created (and that figure excludes the empty homes brought back into use).  The data also draws attention to the Government’s defective 2014-based formula, which significantly over-estimates housing need requirements.  P4E confirms that GM has sufficient existing housing land supply (without releasing Green Belt) to exceed the Government’s overstated calculation.

GM’s existing land supply is sufficient to meet the needs of an additional population of around 400,000 new residents, the equivalent of two new boroughs in GM, representing huge growth on the projected population increase of 158,200.

In addition, more brownfield land comes forward for development every year.  The importance of these windfall sites is demonstrated in the recent CPRE State of Brownfield report, which singles out the North West and Manchester as places with high brownfield capacity.  At New Carrington 23% of the land for residential development is on brownfield (so the release of Green Belt is not necessary to achieve the benefits of those developments, they already have planning permission).

Windfall: sites which become available for development unexpectedly and are not included as allocated land in a planning authority’s development plan Brownfield: previously developed land (which is, or was, occupied by a permanent structure) Greenfield: a site that has never been previously developed Affordable (homes): housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and social housing) Viability: an assessment to determine whether a site is financially viable, by looking at whether the value generated by a development is more than the cost of developing it.

Furthermore, despite being labelled ‘Places for Everyone’, we do not believe that this Plan will deliver housing for those GM citizens who need genuinely affordable homes (social housing).  GM has c72,000 households on local authority registers, and the Plan estimates that “around 38% of newly forming households are unable to afford to buy or rent a home at lower quartile prices”.  Yet during the P4E Examination, the Affordable Housing Policy has been weakened considerably, removing the specific targets from Policy, and relegating it to a mere aspiration. 

In New Carrington the number of Affordable Homes (including affordable routes to home ownership) was originally set at 30%, but the scheme was found to be unviable.  The number of Affordable Homes was then reduced to 15%, but the scheme was still unviable.  Trafford then decided to increase the house prices at New Carrington by 10% (challenging to achieve at this time of financial difficulties).  At the recent New Carrington Hearing, Trafford proposed a further reduction in Affordable Homes (with the vast majority of the development parcels now only needing to agree to 5% Affordable), despite what Trafford described as the acute need for such housing in the borough.  

So, the plan to release Green Belt here will not help those who are most in need of a home.

We believe the benefits to be accrued by releasing Green Belt to deliver homes should be weighted as “Low” because it is clear that the needs of the most vulnerable residents will not be addressed and existing land supply can meet market housing need.

Employment

Employment land provision is also vastly over-stated in P4E.  Green Belt release results in a totally unjustifiable 75% buffer, with the GMCA’s own expert advisor highlighting that P4E has an Industrial and Warehousing supply margin that “falls well outside the bounds of what has been generally used elsewhere”.

In New Carrington, 74% of the employment land is on brownfield sites, so the release of Green Belt will not provide any benefit in relation to the jobs created there.  Building more warehousing, on what is currently Green Belt land, will bring many disadvantages, including adding to the substantial issues with HGV traffic in the area. In addition, the only employment being proposed is warehousing (which is neither highly paid, nor does it support high staffing numbers).  There are no sites for technology, digital, green jobs, creatives, etc.  The impact on the rural economy and rural jobs (farming, stabling, and their supply chains) has not been assessed, despite the current use of the Green Belt land here.

GM does have alternatives to building on Green Belt, but these appear to have been disregarded, including the potential to convert the 1.3million m² of excess office floorspace, much of which is in sustainable locations, appears to have been ignored.  This is a huge, missed opportunity. 

It should also be remembered that the market is changing.  Amazon, for example, recently announced that it will be closing 3 warehouses and several delivery stations.  It cannot be considered appropriate to release Green Belt to provide warehousing at a time of such uncertainty.

With these points in mind, we believe the benefits to be accrued by releasing Green Belt to deliver employment land should be weighted as “Low” because New Carrington can achieve high levels of warehousing growth on the existing brownfield land.

Infrastructure (Transport, Schools, Health Services)

The aim of GM’s Transport Strategy is to ensure there will be “zero net growth in motor vehicle traffic in Greater Manchester between 2017 and 2040”, an admirable aspiration.  On freight, the ambition is to achieve modal shift to water and rail.  For people, the intention is that, by 2040,50% of all journeys in Greater Manchester will be made by public transport or active travel, supporting a reduction in car use to no more than 50% of daily trips.

Yet GM’s plans do not prioritise sustainable freight and passenger transport, despite the disproportionate focus on warehousing development and the current poor public transport provision in areas highlighted for development.  In fact, P4E proposes to build housing and employment in 34 unsustainable locations, on what is currently Green Belt land, including here in New Carrington. 

As an example of the inappropriate proposals, Trafford’s only transport commitment for New Carrington is to construct the Carrington Relief Road (CRR), which will lead to very high car dependency and further HGV dominance on local roads.  It will also bring very limited benefits to existing residents, particularly given the increased housing and employment traffic that the New Carrington development alone will generate, and for the 26% of households in the Bucklow St Martin’s Ward that do not have a car, no benefits at all!

There is also insufficient focus on health services (which are already overstretched across the sub-region).  There is no land proposed for a new hospital to serve those 400,000 additional residents, for example.  School places are currently a strategic red risk in some Authorities, including Trafford, and bring many challenges for existing residents, with parents being forced to drive their children to schools outside of their locality.  The New Carrington graphics do not show land set aside for any new schools, but the scheme will result in over 2,000 additional students across all age groups.  That is a lot of pupils to accommodate and yet more competition for Grammar/Academy school places.

The NPPF (paragraph 95) states that it “is important that a sufficient choice of school places is available to meet the needs of existing and new communities”.  This choice is not available for parents today, never mind when there are an additional 5,000 (“primarily family”) homes to consider. 

New Carrington will result in 20% of Trafford’s local housing need being sited in one Ward (Bucklow St Martins), increasing the population of that Ward by over 70% (and when existing land supply is included, by over 90%)!  This means that some of the most vulnerable people in Trafford are being disproportionately impacted by the lack of infrastructure and services, including losing access to green space.  These already disadvantaged members of our community will experience increased inequity as a direct consequence of this Plan.

We believe the benefits to be accrued by delivering infrastructure should be weighted as “Moderate” because delivery is not confirmed and the potential for mitigation of the proposed huge levels of growth has not been addressed.

Adherence to National, Regional and Local Policies

P4E and the New Carrington Allocation should adhere to the policies set out in the NPPF, it should also comply with Climate Change regulations, which commits the UK government, by law, to reduce greenhouse gas emissions.  The NPPF specifically mentions compliance with the Climate Change Act 2008.  Our response to the Plan consultation (available here) sets out the lack of compliance with local, regional and national policies (page 29).

At a national level, public money has also been spent on a 25 year Environment Plan, an England Peat Action Plan and a range of initiatives relating to nature’s recovery.  Whilst these are not explicitly mentioned in the NPPF, Local Plans should not ignore them.

The recently passed Environment Act sets out legally binding targets to protect our environment, clean up our air and rivers and to boost nature’s recovery.  These were published in December 2022 and aim to:

• Halt the decline in species populations by 2030, and then increase populations by at least 10% to exceed current levels by 2042
• Restore precious water bodies to their natural state by cracking down on harmful pollution from sewers and abandoned mines and improving water usage in households
• Deliver our net zero ambitions and boost nature recovery by increasing tree and woodland cover to 16.5% of total land area in England by 2050
• Halve the waste per person that is sent to residual treatment by 2042
• Cut exposure to the most harmful air pollutant to human health – PM2.5
• Restore 70% of designated features in our Marine Protected Areas to a favourable condition by 2042, with the rest in a recovering condition.

Given that P4E is a 16 year plan, which will heavily influence the achievement of GM’s proportion of these goals (including the required reduction in carbon emissions), we believe the harms resulting from the release of Green Belt would significantly and demonstrably outweigh the benefits, when assessed against these National policies and ambitions.

At a regional level, in addition to GM’s Transport Strategy, public money has also been spent on a 5-year Environment Plan, a Clean Air Plan and the GM Strategy.  Places for Everyone should be fully compatible with all those documents – but it is not!  The GM Strategy Summary states, for example, that “Climate change is the single biggest threat that we face”, yet P4E does not have a focus on ensuring that the mitigation of climate issues is prioritised. 

The Environment Plan outlines the aim to be carbon neutral by 2038 and articulates the 5 challenges incorporated within the plan (mitigation of climate change, air quality, production and consumption of resources, natural environment, and resilience and adaptation to the impacts of climate change). 

Yet the Greater Manchester Combined Authority (GMCA) has not even produced evidence showing the impact of P4E on the carbon emissions.  In the absence of any assessment by the GMCA, Steady State Manchester has analysed the data and has produced a report which sets out the Carbon Implications of Places for Everyone, showing that the 2038 carbon neutrality objective is unlikely to be met.

The lack of compliance with local, regional and national policies has caused us to weight this criterion as “Moderate”.

Green Belt Harm

The National Planning Policy Framework (NPPF) states (paragraph 148) that “local planning authorities should ensure that substantial weight is given to any harm to the Green Belt”

National Planning Policy Framework (NPPF): The NPPF sets out the Government’s planning policies for England and how these should be applied (in the preparation of local and neighbourhood plans and to decisions on planning applications). Green Belt Harm: The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping some land permanently open around urban areas.  The five purposes set out in the NPPF (paragraph 138) are: – to check the unrestricted sprawl of large built-up areas – to prevent neighbouring towns merging into one another – to assist in safeguarding the countryside from encroachment – to preserve the setting and special character of historic towns – to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

P4E commissioned assessments of the Green Belt land proposed for release, to identify the relative harm that would ensue.  The New Carrington Allocation was reviewed for the 2019 and the 2020 planned Green Belt release. 

Although this resulted in an assessment of Very High, High and Moderate-High Harm to Green Belt purposes, 169.5 hectares of Green Belt will be released immediately following P4E Plan approval, despite what is supposed to be a focus on delivering brownfield sites first. 

In addition, the significant volume of Green Belt land to be released here will undoubtedly impact the appetite for brownfield development.  This means that our Green Belt will be decimated whilst brownfield remains wasteland and the amount of available previously developed land increases! 

We do not believe the exceptional circumstances required by the NPPF (paragraphs 140 and 141) to release Green Belt have been demonstrated.  There is a lack of evidence about the impact of the Plan on the environment, biodiversity and ecology, the GMCA has not fully examined all other reasonable options and there is sufficient brownfield land to meet the Government’s formula (which could be supported by ensuring minimum density standards are enforced across the region).

We believe the cumulative harm from the loss of Green Belt should be weighted as “Very High” given the size and scale of the site.

Loss of Peatland

Developing on Carrington Moss will cause a massive carbon emission event and the destruction of this irreplaceable habitat cannot be offset by any amount of Biodiversity Net Gain.

One of the many advantages of carbon sequestration via peatland is its own negligible carbon footprint.  There is no requirement for manufacturing of major technology or equipment and no ongoing use of fossil-fuel based power (although we do recognise that restoration techniques might involve some initial machine-using groundwork and some installation of plastic dams or pipes).  Peat mosses require relatively low maintenance, perhaps some weed incursion control, but mostly it is over to the forces of nature and time to deliver the benefits.

Whilst there are no specific protections in the NPPF, the Government has set out its intentions in relation to peat in various documents over the past 10 years (including the 25 year Environment Strategy and the England Peat Action Plan).  Even P4E recognises that “lowland raised bog is now one of Western Europe’s rarest and most threatened habitats”, that our peatlands sustain a unique range of wildlife and GM’s 5 year Environment Plan aims to prioritise action to “protect, maintain and enhance our key natural assets”, including restoring “50-75% of our peatlands”.  The document sets out responsibilities for Local Authorities, including:

• “GMCA and LAs will embed a natural capital approach into strategy and plan development
• GMCA and LAs will support peatland restoration approaches and provide a clear framework for approach and delivery as part of a resilience strategy”.

So, a responsible plan should take full account of the natural capital value of peat otherwise it will undermine intended Government and regional policy. 

Furthermore, one of the tests of soundness is that there should be a reasonable prospect that the various Plan policies (including the Allocations) are deliverable.  Given the, albeit slow, pathway the Government is taking to protect peatland soils and the increasing recognition of the ecosystem services peat provides, specific protection is likely to come.  The trajectory for development at New Carrington is spread across the 16-year period of the Plan.  Is it, therefore, reasonable to assume that construction on peat will still be allowed at the time planning applications are submitted?  We believe it is not!

At the P4E Hearings, the GMCA dismissed the advice of Natural England (NE), the Government’s adviser for the natural environment in England, stating that NE had not raised any issues of soundness.  Whilst it is correct that the Planning Inspectors are testing P4E for soundness, we believe it is reckless and negligent to ignore the advice of such national experts.

Examining plans (NPPF paragraph 35) Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.

NE has confirmed that “it takes 1,000 years for 1m of peat to build up”.  That seems to be confirmation that Carrington Moss is an irreplaceable habitat.  Their advice to the GMCA suggests it is, they say

“The GM Peat Pilot showed the carbon storage within lowland peat within Greater Manchester to be between 1,500 – 2,000 tonnes per hectare Carbon equivalent for 50cm depth of peat. Carrington Moss is significantly deeper than this”.

NE provide guidance about rewetting the peat soils and raising the water table (which is regularly above the surface on Carrington Moss, as can be seen by the information on our website about Carrington Lake).  They also advise that

“As a large, continuous peat mass currently under suboptimal management, Carrington Moss provides an ideal opportunity to explore alternative land use scenarios that will assist the City Region in achieving net carbon neutrality by 2038, while providing other ecosystem services through improved ecological function of the peat”.

NE recommends restoration and expansion of the existing relic bog remnants, which would need appropriate buffers and areas of supported associated habitat, to support significant carbon storage.  They also agree with our Alternative Transformation Strategy for Carrington Moss, suggesting that there is

“the opportunity to consider and set up a contiguous large area of Carrington Moss as a habitat bank for BNG, and for carbon trading. Natural England strongly supports this approach.”

We consider the loss of this irreplaceable habitat will cause Very High Harm, not just for today but for generations to come.

Harm to our Natural Capital Assets

Natural capital is the way of describing environmental assets (such as land, forests, water, soil, air and minerals) that provide benefits to people (clean air, good health, food and water).  A natural capital approach assigns a value to each of those benefits to help us understand their importance and worth to society.

GM has undertaken no assessment of the loss of Natural Capital Assets or the impact on Ecosystem Services as a consequence of the P4E Plan, despite the Trafford Natural Capital Account stating that “a natural capital approach is about everyone understanding the benefits – ensuring the protection and enhancement of natural assets are fully considered in decision making”.

This clearly has not happened with P4E.  In fact, FOCM identified a lot of missing evidence in our representation.  There is no detail in the Plan relating to carbon emissions, air, noise and light pollution, the rural economy, ecology and biodiversity (including the impact on the SBIs and SSSIs in close proximity), soil resources, or natural capital/ecosystem services. 

Our own very conservative natural capital estimates suggest that Carrington Moss accrues over £15m in benefits each year.  We understand this benefit is not included in the £71m figure calculated by Trafford.  They have decided not to capture all assets but have identified those they believe represent “the most critical in an urban context”.  This is consistent with the approach taken by P4E, which completely ignores our rural communities, the rural economy (including the farms, the stables and their supply chains) and rural assets. 

The natural capital assets on Carrington Moss include the peat moss itself (albeit degraded), the wetland habitats, the Grade 2 best and most versatile agricultural land, the huge expanse of woodland, areas that have significant levels of regular surface water flooding, and those that are used extensively for social prescribing, sports and recreation, including walking, cycling, horse riding, nature spotting, bird watching and a number of other activities.

The publicly available mapping for GM’s Local Nature Recovery Strategy shows existing habitats and opportunities for enhancement (including for Carrington).  Carrington Moss is one of the sites within the GM Wetlands Nature Improvement area.  Yet, the current plan is to decimate historic wetland habitats, then to propose restoration and creation of new areas of wetland, this is totally irrational!

Trafford has not made the overall flood risk and drainage strategy for the site available but we recognise it will need to be compelling given the water levels consistently present on the mossland.  The Government’s planning guidance has recently been updated and Councils will need to demonstrate developments will be safe from flooding for their lifetime, will not increase flood risk elsewhere, and, where possible, will reduce flood risk overall.

The Allocation will compromise the quality of our natural environment, causing biodiversity loss, and will severely limit access to green spaces.  Globally threatened birds/wildlife species will be displaced, their foraging sources diminished, their populations put at further risk.  The scenery will be dominated by new roads and warehouses, rather than landscape views stretching for miles, with high levels of traffic noise, rather than birdsong.  Carrington Moss will no longer be able to support climate resilience and reduce flood risk, which it does so well today!

How can the Planning Balance be determined when there is only evidence covering one side of the scales?  This is important because the fact an Allocation has been made here will be a key influence in decisions about planning applications, despite the lack of evidence at plan-making stage. 

We believe the lack of information about our natural capital assets will result in Very High Harm.

Prioritising unnecessary growth, rather than the climate emergency!

Every Local Authority in GM, every Health Authority in GM and the Greater Manchester Combined Authority have all declared a climate emergency (the GMCA has also declared a biodiversity emergency).  As mentioned above, the GM Strategy states that “Climate change is the single biggest threat that we face”, yet GM’s Local Authority and Combined Authority leaders are supporting a Plan that will significantly increase carbon emissions, cause a huge surge in air, noise and light pollution, and will expand the number of areas with the potential for localised flooding.  Their Plan will destroy irreplaceable habitats (peat mosses), will remove huge amounts of best and most versatile agricultural land (Grades 1, 2 and 3a) and will see thousands of trees felled.  None of these actions is compatible with those declarations nor with their carbon neutral goals.

It seems that climate and environmental impacts do not carry the same weight in P4E as the proposed excessive (and unnecessary) growth.  In addition, the P4E Plan will significantly impact the health and wellbeing of GM residents as a consequence of increased stress, dirty air and loss of green spaces.

During the P4E Examination, at a time when decarbonisation should be top of the agenda, the GMCA backtracked on published policies (net zero buildings will now be something to be worked towards, rather than mandated, and will be subject to financial viability, the ‘get out of jail card’ used by developers to avoid planning policy obligations).  In addition, the weakening of the brownfield first policy could result in more Green Belt release, with the associated increase in carbon emissions, etc.

Given those declarations and the recognition of the future challenges and hazards in the GM Strategy, every plan, every proposal and every decision should be considered through the lens of the climate emergency.

Yet, as mentioned above, the GMCA did not produce any quantitative assessment of the implications of their proposals, and suggested, at the P4E Examination, that it was reasonable for them not to provide such data.  Communities highlighted the approach taken in the Greater Cambridge Plan, an Authority which did conduct quantitative modelling of the carbon impact of their different spatial options.  This Authority was dismissed as an outlier, rather than heralded as setting a standard that other plans should be following.

P4E cannot be considered to be sustainable when it comes at such a huge price to future generations.  The lack of focus on mitigation of the climate emergency will lead to Very High Harm.

Finally

So, with all of the above in mind, is it reasonable to include New Carrington as an Allocation in the Places for Everyone Plan? 

We do not believe it is and, in addition to the above, it must be remembered that there is a total lack of community support for this scheme.  At a local level, the vast majority of residents object to the Allocation and, although the “major stakeholders” (developers and landowners) have been involved in creating the New Carrington Masterplan, there has been no engagement with local communities, not even the Parish Councils, in the evolution of the Masterplan document. 

At a regional level, the scale of opposition to Green Belt loss was huge, with over 27,000 GM constituents objecting to Green Belt release.  It seems there is no “public” in the Public Interest Test in relation to P4E!

In summary, P4E has focused on bringing forward sites in the Green Belt, rather than on tackling the blight of brownfield and proposing truly sustainable development.  The GMCA has significantly over-inflated the requirement for market priced housing and warehousing, there is insufficient provision of desperately needed genuinely affordable homes, rural communities and the rural economy have been totally disregarded, and insufficient weight has been given to the impact on climate change mitigation opportunities, the environment and nature’s recovery.  

Whilst we understand GM’s aspirations, these should be sustainable, balanced by a clear appreciation of the impact on communities and the environment and all decisions should be supported by sufficient information, covering both sides of the Public Interest Test scales. 

For New Carrington, Viability is finely balanced too, and we are not clear that all costs have been included in the numbers.  This development will not just be expensive in financial terms, it will also bring a high cost in terms of carbon emissions, the further depletion of endangered species and the worsening health and wellbeing of local residents.

This is not a reasonable or a sustainable Plan! 

Do the harms significantly outweigh the benefits of the scheme?

Yes they definitely do!

So, for all the reasons set out above, it is resoundingly clear that the New Carrington Allocation does not meet the Public Interest Test.