Trafford’s own assessment suggests it is not!

Let’s look at that “rigorous site selection process”!

Given the very recognisable challenges and the extensive harms to be caused by development here (see our previous blog), how was New Carrington chosen? 

Well, we would suggest the P4E Site Selection methodology was flawed.  For a kick off, it ONLY looked at Green Belt sites (despite the supposed focus on brownfield preference), it did not consider ecology or biodiversity issues until Stage 3 of the process, once most of the sites had been filtered out (and, even then, it did not provide any assessment data) and it did not consider natural capital value at all (despite the Government’s recent devolution deal describing Greater Manchester as a “trailblazer” in that area – see paragraph 226).

Site Suitability

The graphic below shows how the New Carrington parcels comply with the Site Suitability Criteria and clearly demonstrates that the area is not suitable for development!  In fact, Criterion 5 on the table below should be coloured red too, given the lack of available school places and poor access to health services in the area (the assessment was based on the site’s proximity to facilities, not the capacity of those facilities to support additional residents).

Criteria 4 and 7 have been assessed based on current land use.  So, it is not a surprise that Criterion 4 (Health and Wellbeing) is green.  The area is heavily used for walking, cycling, horse riding and other outdoor activities, including formal sports.  If the development is approved, this criterion will no longer be green because people will find it unpleasant, unhealthy and unsafe to walk, cycle and horse ride next to the planned four major new roads.  These roads will fracture existing public rights of way (and ecological corridors) and will hugely (and negatively) change the experience of those active travel trips (people will no longer be breathing fresh air, or listening to bird song, for example).

Criterion 7 (air quality) will significantly deteriorate as a consequence of the planned development too.

Site Selection

Turning to the site selection criteria, it is incongruous that there were no criteria which considered the P4E Strategic Objectives for improving the quality of the natural environment/green spaces (Strategic Objective 8) or for ensuring access to physical and social infrastructure (Strategic Objective 9).  When compared to the first 7 Strategic Objectives, the graphic below demonstrates the total lack of weight given to these two critical Strategic Objectives (and Strategic Objective 10, Health, does not fare much better, with just one site selection criterion being applicable).

The National Planning Policy Framework (NPPF) suggests (paragraph 8) that, to achieve sustainable development, three overarching objectives need to be considered:

a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure

b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being

c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.

The site selection criteria are clearly not consistent with that NPPF requirement.

Furthermore, treating the huge area covered by the New Carrington Allocation (1,153 hectares) as one site means that the site selection criteria are considered attained even if much of the location does not meet those criteria.  We set this out in the table below:

Criterion 1 – Land which has been previously developed and/or land which is well served by public transport	We know no part of New Carrington is well served by public transport and only Carrington itself has some previously developed land but despite the Allocation boundary stretching to cover Partington, Sale West and Warburton, the whole site is considered to meet this criterion.
Criterion 2 – Land that is able to take advantage of the key assets and opportunities that genuinely distinguish Greater Manchester from its competitors	In New Carrington’s case, this relates to Port Salford, which is, of course, only close to the Carrington part of New Carrington as the crow flies.  There are no direct links.  Despite this, Trafford consider the site to meet this criterion.
Criterion 3 – Land that can maximise existing economic opportunities which have significant capacity to deliver transformational change and / or boost the competitiveness and connectivity of Greater Manchester and genuinely deliver inclusive growth	Given that much of the employment land (74%) is brownfield, economic opportunities can be maximised at New Carrington without releasing Green Belt.  Trafford suggests the Carrington Relief Road will be transformational for Partington, but this is not the case.  There are few, if any, benefits for Partington, Sale West or Warburton residents (and only minimal benefits for Carrington residents).  What would bring huge benefits to the Allocation area would be the reopening of the railway line – but Trafford is not even considering this.
Criterion 4 – Land within 800 metres of a main town centre boundary or 800m from the other town centres’ centroids	No part of New Carrington meets Criterion 4.
Criterion 5 – Land which would have a direct significant impact on delivering urban regeneration	As with Criterion 3, given the amount of brownfield land (74% of the employment land and 23% of the residential), urban regeneration can be achieved without releasing Green Belt.  In fact, urban regeneration in Trafford, and beyond, could be impacted by releasing so much Green Belt here (as developers will focus on greenfield sites rather than bringing brownfield back into use).
Criterion 6 – Land where transport investment (by the developer) and the creation of significant new demand (through appropriate development densities), would support the delivery of long-term viable sustainable travel options and delivers significant wider community benefits.	The Viability Assessment suggests the Total Developer Contributions are only £66.7m, a paltry sum for such a huge development.  This figure includes developer contributions to education and affordable housing.  As we highlighted in our previous blog, the “necessary” transport interventions for New Carrington will cost a minimum of £400m, so it cannot be considered that this site meets Criterion 6.  In addition, there are no sustainable freight transport options on the transport interventions list and it is hard to understand why the existing population (circa 30,000) is not considered to create sufficient demand to support the delivery of long-term viable sustainable passenger travel options.  Community benefits from this allocation are minimal to non-existent!
Criterion 7 – Delivers significant local benefits by addressing a major local problem/issue.	The major local problem/issue for the New Carrington area is the number of HGVs on our roads.  There is no plan to address this with sustainable freight transport.  We do not consider this criterion to have been met.

The way to test our assertion that much of the site does not meet any of the criteria would be to split the Allocation into smaller areas (Carrington, Partington, Sale West and Warburton) and to consider whether each development parcel meets any of the site selection criteria.  If they do not, those parcels should be withdrawn from the Plan. 

Finally, in relation to site selection, Trafford chose to remove some sites that were previously Allocations within the GMSF.  We cannot find any evidence in the P4E documentation which shows how and why sites were chosen for removal or to remain. 

Given all the above, the Public Interest Test in relation to site selection cannot be considered to have been met.  We believe this demonstrates that the site selection process is unsound and that New Carrington should be withdrawn from the Places for Everyone Plan.