Feedback from the Executive Discussion about P4E

Some very interesting points arose at the Executive meeting (held on 25^th September) which approved the Places for Everyone Modifications Consultation

Councillor Patel, for example, suggested that Green Belt campaigners have taken a “narrow view of how future development can be accommodated”.  This is utterly untrue, totally uninformed and highly insulting.  Green Belt campaigners have used their own time, their own money and their own, and independent, expertise / advice to consider ALL aspects of the Plan.  The Chair of the Friends of Carrington Moss was one of the very few people to attend ALL of the Examination Hearings about the thematic policies.  To describe the work of this and other Green Belt groups as narrow demonstrates the complete lack of engagement the ruling elite has had with the community, and their unwillingness to conscientiously consider the feedback we have been giving (contrary to the Gunning Principles).  

The same is true of our concerns about the lack of evidence that has been provided. 

Let’s be clear, a development of 5,000 homes is a new town and should have been subject to much more detailed scrutiny.  Partington currently has around 3,500 households.  It will be dwarfed by the proposed new town and the requirements of the new community.  The New Carrington development is the largest in the Places for Everyone Plan, representing 25% of Trafford’s housing requirement, the vast majority of which will be built in just one Trafford Ward!

The main report, which can be found in the papers for the Executive Committee at this link, sets out a series of implications of the Places for Everyone Plan.  It is a very misleading set of indicators. 

Indeed, Councillor Coggins raised the greenwashing in the report, particularly in relation to the carbon emissions.  Councillor Patel felt that it would be difficult to summarise in a short paragraph but it is important that such momentous decisions (this is a 17 year plan), that will have a huge impact on current and future communities should be based on an honest and transparent assessment of the implications. There is more information about the carbon emissions implications in the analysis below.

Councillor Coggins raised a number of questions on behalf of the Friends of Carrington Moss, to which Councillor Patel suggested that FOCM should put their questions to the Executive so they can make a detailed response.  We would be delighted to do so, but other emails sent to Councillors have resulted in no response from the Executive. 

The recording of the Executive Committee can be found at this link.  The item about Places for Everyone starts at 4:57 and the discussion lasts for around 40 minutes.

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Read on for a more detailed analysis of the content of the Executive meeting.

Councillor Patel’s opening presentation, sadly, focused on the spin, suggesting that:

The plan is “the best route for a sustainable future for Trafford”	Incorrect given Trafford is proposing development on a peat moss, Grade 2 agricultural land, woodland and wetland habitats, without committed funding for public transport and/or sustainable freight.
There is “huge public interest in the plan’s adoption”	There is huge public interest in removing the Green Belt allocations. There were, for example, 27,000 responses objecting to the release of Green Belt in 2016, these objections have not subsided.
Implementation of the plan represents: “sustainable regional growth” “better future for communities” “tackles the housing crisis” investment “in skills, jobs and productivity” a “robust strategic framework of environmental protections, including nature’s restoration and significant enhancements to biodiversity across GM”	Sustainable! – when the growth is the equivalent of creating two new boroughs in GM? Communities will suffer from the impact of increased air, noise, light, vibration and water pollution! The housing crisis is the lack of social housing – the affordable housing target has been removed from policy! The investment in jobs in New Carrington is limited to warehousing! A robust framework that proposes development on a peat moss, Grades 1, 2 and 3 agricultural land, woodland and wetland habitats! There is not one single allocated site in the whole of Places for Everyone with a purpose of enhancing nature’s recovery!
The plan will “maintain a new and defensible Green Belt which will endure beyond the plan period”	Local Authorities can release more Green Belt in their Local Plans – the previous commitment preventing this was not included in P4E Policy.
P4E “will support GM’s plan to be carbon neutral”	Incorrect – see this analysis of the carbon implications of P4E, which shows that the 2038 carbon neutrality objective is unlikely to be met, something which has been recognised in the GMCA’s own progress report and in their Overview and Scrutiny Committee report
The “Inspectors have rejected a number of the proposed new additions to the Green Belt”	An interesting way of phrasing the situation, which has led to an increase in Green Belt release.  The legal issue that required Green Belt Additions to be removed from the plan was raised by Peel in their regulation 19 consultation response.  The GMCA initially categorised the response as “No Change Considered Necessary” but in March 2023, the GMCA confirmed that 32 of the 49 Green Belt Additions did not meet the exceptional circumstances test required.
The “removal of an overarching GM affordable housing target” has “been replaced with site specific allocations reflective of local needs and viability”	Again, an odd way to phrase the removal of this key principle in the plan.  The site specific allocations always had an affordable housing target. In fact, the New Carrington affordable housing target was previously 30% but has now been reduced to 15% (the Planning Inspector refused to allow Trafford to remove it altogether, although this was proposed). Later in the meeting Councillor Patel suggested that the Inspectors had requested the Affordable Housing target be removed from policy but this is incorrect, this modification was proposed by the GMCA.
Green Belt has dominated the debate and has been detrimental to the overall understanding of the plan	It has not been detrimental to the understanding of the overall plan for those us who have been fully absorbed in it over the last several years.  Given that 27,000 residents objected to the release of Green Belt in 2016, it should be no surprise that a plan that persists in unnecessarily demanding the loss of nature/biodiversity-rich sites continues to be challenged.
Brownfield and urban development will play the most significant part in land identified for development	Of the warehousing developments (for which GM has added a 75% buffer/contingency to their requirements), 49% will be built on unsustainable Green Belt locations. For housing, there is sufficient existing brownfield land supply to build a number of homes that is the equivalent of creating 2 new boroughs in Greater Manchester. Green Belt release is unnecessary and unsustainable!
“in order for the right mix of homes and jobs to be built in the future, some Green Belt release is necessary”	So, a plan that only focuses on market housing and warehousing is the right mix of homes and jobs?  That is not the view of many in the community.  No targets for social housing, no identification of land to support gypsy/traveller/student communities and no aspirations for the rural economy (despite rural areas comprising almost 50% of Greater Manchester’s land).
This Administration considers this is an acceptable ask of the Green Belt in order to provide the land supply needed to address the housing crisis	How many homes for social rent (which is the housing crisis given that considerably more market houses have been built than households formed) are planned for the Green Belt?  This will be monitored but we believe it will be NONE! If tackling the housing crisis is the key consideration, why is Green Belt land being sacrificed for warehouses?

Councillors supporting the development also made some rather misleading statements:

Councillor Williams stated that “in unlocking the Carrington site for development we will be able to see one of the largest single brownfield sites in Greater Manchester unleashed for residential housing development”	Incorrect, the brownfield sites already have planning approval, which has been given outside of Places for Everyone (around 1,200 homes in Carrington and at Heath Farm Lane). It is the Green Belt sites that will be “unlocked” by the plan! In addition, the concerns of the Health and Safety Executive could restrict the regeneration of the brownfield employment sites.
Councillor Wright suggested that the people of Partington will have “access to good jobs through the creation of the Carrington Relief Road”	Again this is incorrect.  Only warehousing jobs are being created at Carrington and these are not known for either their quantity or their high pay.  Access to jobs further afield will be impacted by the huge increase in traffic – 5,000 homes and 350,000 m2 warehousing will add a significant number of cars and HGVs to local roads and, as there is no commitment to funding for public transport, challenges with local school places and other council services, residents will continue to have limited choices.  There are no proposals at all for sustainable freight transport options. The existing Partington community, which has a much lower proportion of car ownership than elsewhere in Trafford, will not benefit in any way from the estimated £80m expenditure of the Carrington Relief Road!  Congestion will impact their travel even more in the future than it does today.
Councillor Patel suggested (in response to a question from Councillor Coggins on behalf of the Friends of Carrington Moss) that the Rural Economy was covered in the Examination Hearings and that the Executive do not believe that there is any specific risk to economic activity because of the plan	This is both incorrect and astounding! There is no mention of the Rural Economy in the plan, it was not discussed at the Hearings (other than confirmation that it is subordinated to Local Plans) and no evidence is included in the Examination database about the impact to the Rural Economy as a consequence of the plan.  If Trafford has evidence that there is no specific risks to farming, stabling and other rural businesses (and their supply chains), the data that confirms this should be shared.  Loss of Grade 2 best and most versatile agricultural land, loss of access to stabling, loss of supply chain contracts, etc cannot be achieved without a severe impact to those businesses!
In response to a question from Councillor Butt, Councillor Patel suggested that “the reference to Carrington Moss is not reflective of an extent of large peat reserves right across the site, it fluctuates tremendously and the area of deep peat resides in the centre of the site”	In 1995 an academic study confirmed there were 325 hectares of deep peat at Carrington Moss (I’d say that is reflective of a large extent of deep peat)!  Natural England, the government’s adviser for the natural environment in England, do not agree with the development on the site and confirmed during the Examination that there is an inferred peat extent of 280 hectares on the site.  Whilst it is true that peat thickness does fluctuate, it should also be noted that the Heath Farm Lane Ground Investigations found that the “peat is relatively thick in this area (up to c. 2.5m)”.  This is on the edge of the site, not in the centre!

Councillor Ennis asked how convinced the Executive is that Trafford will get any Affordable Housing out of the plan.  Despite hearing the concerns of Councillor Ennis about the definition of the term “Affordable Housing”, Councillor Patel questioned “why local politicians would somehow object to a housing plan that will deliver such tremendous amounts of Affordable Housing”.  We think it is astonishing that the Executive have such confidence in the amount of Affordable Housing that will be delivered.  It is clear that communities will need to monitor that these and other aspirations are achieved given the Executive appear to believe developer behaviours will change.

Councillors Paul and Duncan from Manor Ward defended the peat moss and raised questions on behalf of Friends of Carrington Moss including a question about the lack of ecological evidence in the plan (given the size and scale of this development, such evidence should have been available prior to site selection).  Councillor Patel advised that she will circulate a detailed note in response to that question.  We hope it will be transparently available to residents.