Author Archives: friendsofcarringtonmossgmailcom

Presenting our petition to Trafford Council

On 13th October 2021, our Secretary, Anna Chopping, stepped right out of her comfort zone to present our petition against the Council constructing roads across Carrington Moss. We have set out her presentation in this blog, along with a link to the short debate held by Trafford Council.

Anna Chopping:

I’d like to begin by explaining that I am actually going to be reading my five minute presentation because I am here, not for my skills or natural talent for public speaking I’m afraid, but as a Mum of three, as the Secretary for the Friends of Carrington Moss, and as a resident of Carrington Village

I am here to speak on behalf of many other residents and families who have signed this petition (1,632 in fact). We are local people, and these signatures represent a community that is feeling voiceless and overwhelmed by this tidal wave of development in our area; it’s challenging just keeping up with the sheer number of planning applications, and it feels hard to be heard above the noise and scale of development – so I thank you firstly for this opportunity to present our petition today.

I would like to draw your attention to three main points that we are asking for your understanding and consideration in the debate;

1. We are asking for more consultation,

2. We are asking for genuine alternative options to the building of roads across Carrington Moss, and

3. We are asking for more consideration of the environmental impact of this road proposal in the wake of our climate emergency

So firstly, we are asking for a seat at the table, we actually want involvement in the design stage of plans for our locality. Local people feel powerless, fearful, and angry that planning and development feels to be carried out DESPITE rather than FOR community members.

Thus far, there has been no consultation with the community regarding the strategic agenda for the Carrington Relief Road. Our village is desperately seeking a STOP to the huge number of HGVs on the road through our village, but this proposal for the CRR does not promise to deliver any benefits or ‘relief’ to residents suffering with this daily hammering of HGVs on their houses and stress levels. The Scheme Objectives for this road are not about prioritising the improvement of health, wellbeing or basic safety of local residents and even schoolchildren who will be impacted… the key objective is about increasing capacity to deliver growth – more construction, more industrial warehousing, more housing and crucially – MORE traffic; including induced traffic.

So, what about alternative options?

There appears to be no discussion or prospect of any tram connections, no option or prospect of any train connections with New Carrington or Partington – even when there are existing tracks in place?!  How are we to be making safer more sustainable transport choices that allow us to get out of our cars, when the focus is entirely on building more roads, with no actual commitment to improving public transport.

We want more cost-effective, safer, alternative solutions that work for everybody, not this ‘quick-fix’ ‘panic-built’ approach driven by developers. We understand that there is time-limited external funding for the road which is at risk if the scheme is not pushed through to planning now – but this ‘rushed-job’ could end up costing far more in permanent damage… to irreplaceable habitats, to the red-listed birds, endangered wildlife, and to the carbon-capturing scope of Carrington Moss.

The Friends of Carrington Moss have always driven a positive campaign – one that is fuelled by a heartfelt desire to value, protect and, where possible, improve our shared landscape and green space of Carrington Moss, our green-lung.

We are NOT ANTI-DEVELOPMENT, on the contrary; we are passionate about engendering progressive change; we want to regenerate as well as protect these natural assets of Carrington Moss’ – we want to CONSERVE not concrete-over the value of what is on our doorstep.

Our local environment is valued not only by our local community, but also by professional organisations such as the CPRE, Natural England and the Cheshire and Lancashire Wildlife Trusts – and their reviews of the PfE proposals for Carrington are damning. Please read them.

In conclusion we ask you to please allow us a seat at the table, allow us to be involved in shaping and improving our locality by finding alternative options to these proposed roads across our greenbelt.

After all, where else in Trafford can we

  • restore peat to more effectively capture carbon, so our children and grandchildren 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 the populations of red listed birds and endangered wildlife, so we can help nature’s recovery, increase biodiversity and mitigate the impact of climate change?

Thank you.

You can hear the responses of the Councillors here (fast forward to 13 minutes 55 seconds).

What does Trafford’s latest report about the Carrington Relief Road (CRR) mean for affected residents?

Apologies for this long blog but it is a sad day when residents believe their Local Authority’s process is so grossly flawed that they need to take expert advice! The CRR report for Trafford’s Executive Committee (Monday 27th September 2021) is yet another example of a biased report relating to this subject!

Natural England had some strong words for Trafford in their response to the information sharing exercise that took place earlier this year – yet these somehow didn’t find their way into this latest report:

3. Route Options

We note that the full Environmental Scoping Report is not yet available but the Options Appraisal Report states that a desktop assessment has been carried out. We are disappointed that the findings of the environmental desktop study are not fully reflected in the appraisal of the route options. Appendix D contains slightly more information on the environmental constraints but is not an accurate representation.

5.3 Option F Risks

The environmental risks have not been included in this section although they were included in Chapter 5.2 (Option A Risks). We think this presents an inaccurate and unbalanced view of the environmental constraints and it is Natural England’s view that Option F would be considerably more damaging than Option A.

Extract from Natural England response 22nd March 2021

What are we seeking?

We’d like to see the scheme paused until all stakeholders have been appropriately consulted and their views are able to be properly included in the options appraisal

We’d like to see our carbon footprint and the climate emergency taking a more meaningful part of the option appraisal

We’d like to see the options reviewed to allow for less expensive, less environmentally intrusive alternatives to be considered (with entirely separate active travel routes).

What is so wrong with this latest report?

We’ve raised a number of issues below but in summary, what we have looked at is whether two reasonable options have been proposed and whether a fair comparison has been made between those two options.

In short, our key concerns about the Appraisal are:

Our other issues with this report include:

  • Creating active travel infrastructure right next to a road which will see huge numbers of HGVs an hour thundering past, will not only be unhealthy, it will be downright dangerous
  • Trafford’s suggestion that the road may need to be dualled in the future does not accord with the strategic transport aims for GM
  • There is no record that any assessment has been made of the Natural Capital Value of the two routes
  • We believe a detailed review of the costings is needed to ensure this proposal offers good value to tax payers
  • The contingency figure proposed should particularly be reviewed (especially given the recently reported problems with the supply of construction materials), we understand that a considerable number of road schemes are found to run significantly over-budget.

Residents views? 
Actually, we have not been asked which option we’d prefer!

Let’s start with the Engagement process, which has been extremely poor.  Direction is provided in the Department for Transport’s Transport Analysis Guidance, which does not appear to have been followed.

Public engagement should also meet the requirements of Trafford’s Statement of Community Involvement and should be carried out in line with the Gunning Principles (very helpfully summarised by the Local Government Association in the graphic to the right – click to see full screen).  These Principles have formed a strong legal foundation from which the legitimacy of public consultations is assessed and they are frequently referred to as a legal basis for judicial review decisions.

We don’t believe the approach to date has followed these Principles! 

The decision does seem to be predetermined.  

FOCM worked with local Parish Councils to develop a response to the information sharing exercise that took place earlier this year.  We requested several workshops – our requests have been ignored! We raised a number of questions – we have not had any answers!  We were given 4 weeks to respond – we are still waiting for Trafford to come back to us!

What is clear is that Trafford does not consider residents to be key stakeholders nor are they interested in giving ‘conscientious consideration’ to our ideas.  One of the questions we raised in that information sharing exercise (which Trafford has chosen not to include in the document) was as follows

Residents believe improvements can be made to the design of Option A, how can these be fed into the process?  Our ideas for improvement would reduce the impact of land ownership issues and will significantly reduce traffic disruption during construction.

This was our polite way of suggesting that Option A was not reasonable as articulated but that we did have ideas about how this could be addressed. 

Of course, if the aim is to culminate in a decision to choose Option F, it is no surprise that, despite chasing frequently, we have had no feedback from Trafford, so have not had the opportunity to discuss or share our ideas.  As a consequence, the inclusion of Option A remains a tick box exercise!

With this in mind, it is really enlightening that the report suggests (as part of the recommendations) that the Corporate Director of Place be able to:  “authorise community engagement and consultations where the Corporate Director deems it necessary or advantageous.  

Advantageous to whom?  Why isn’t it as simple as saying “we will follow the Gunning Principles in engaging and consulting with residents”?.

It should be noted that the “engagement” exercise held earlier this year was not a consultation.  It was merely an information sharing opportunity, which Trafford suggested would be the “first” event and that a Frequently Asked Questions and Answers document would be made available on the Council’s website in the week after completion of the engagement period, which would then be regularly updated.  This has not happened!

As part of this exercise, some information was made available to residents and they were asked to raise any questions they had about it.  They were not asked to give a view about which option they preferred.  It is, therefore, unreasonable to suggest that residents did not express a preference. 

The document incorrectly suggests that we placed a template on our website, we did not.  We shared the questions that we (and the local Parish Councils) had raised with Trafford’s project team.  Our document did not select a preferred option because we were told this was not the purpose of the exercise.  You can find the document and see the full list of our questions on our website here.

It should be noted that, when they have had the opportunity, residents have repeatedly expressed their preference against this road being constructed across Carrington Moss, not only in the previous GMSF responses but also in our survey, which has been completed by 790 local residents, of whom just 4% support Trafford’s plans and 95% support the FOCM aims.

We also have a petition, signed by over 1,500 local residents against the construction of this road across the Moss which we would like to present to Full Council in October.

In addition to resident signatures, the petition has been endorsed by the following organisations:

Endorsements in the petition against roads being constructed across Carrington Moss

Do the future travel options follow Policy?

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, it is not going to relieve anyone).  Our response to the initial Options Appraisal (February 2020) detailed our concerns about the 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, along with her response and our subsequent feedback.  We still have not had answers to the questions we raised.

It is interesting that the current document states that the “early public engagement exercise” calibrated and refined the scheme objectives.  It seems that this exercise has resulted in the removal of the objective to provide “Improved public transport and active travel provision to existing areas which are poorly served and to housing and employment growth areas”. 

Feedback from FOCM and the Parish Councils suggested that the number one objective should be protecting the health and wellbeing of existing residents.  Sadly, this has not even made it onto the list! 

The traffic figures in the Transport Locality Assessments (part of the GMSF/P4E documentation) have been challenged in terms of credibility. It was also acknowledged in that information sharing exercise earlier this year that the existing road is only busy during rush hour periods (like every other major road in the Country) and prioritising a new major road above public transport improvements is not compliant with Trafford’s Carbon Neutral Action Plan.

More importantly, any decision to go ahead on the basis of this report could also be challenged on the grounds that Trafford has failed to fully take into account its obligations following its declaration of a climate emergency in November 2018. 

With even the Government admitting it must review its road building policy to take into account climate change, it is odd that this document does not reference Trafford’s declaration at all, nor does it mention how it has assessed that, since that declaration, the construction of a road is still an appropriate option.

The report also does not mention that GM’s Transport Strategy 2040 aims to reduce car traffic by 50% and to move freight onto rail and shipping transport by 2040, less than 20 years away.  So, constructing this road is not in alignment with that Policy, which also suggests that transport investment will follow the Global Street Design Guide hierarchy (it places active travel and public transport first, and people in personal motorised vehicles last). 

Questions should also be asked about why no sustainable options for freight have been considered.  Given Trafford’s approval of overdevelopment in Carrington and the resulting huge number of HGVs on local roads, why has this not been considered a priority? 

Residents have been promised public transport improvements for Carrington, Partington and Sale West since the 2006 UDP (with Trafford reinforcing these promises again in the 2012 Core Strategy). It is, therefore, shameful that, in the largest housing allocation in the whole of GM (as set out within the Places for Everyone documentation), with 6 years’ preparation, there are no sustainable freight options, no plans for trams or trains (even though there is a former railway line running right into Carrington and Partington) and, despite the many disingenuous suggestions in this and other reports, our Freedom of Information Act Request revealed that there are NO commitments to increased bus services for Carrington, Partington or Sale West! 

What about the health and wellbeing of Trafford residents?

There are repeated assertions in the report that the CRR will encourage residents to make healthier life choices and that it will improve the health and wellbeing of Trafford’s residents.  Those people who currently walk, cycle or horse ride on Carrington Moss will have their health and wellbeing severely and negatively impacted by option F.  The professional and amateur athletes that play sports at the Manchester United Training Grounds, the Sale Sharks Training Grounds or the Sale Rugby FC Training Grounds will also be impacted (and sports people themselves have begun to make the connection between air quality and their health https://sustainabilityreport.com/2020/04/23/air-pollution-tackling-sports-invisible-threat/). 

The World Health Organisation has announced (22nd September 2021) that it is reducing the maximum safe levels of key pollutants with PM2.5: reduced from 10 µg/m3 to 5 µg/m3 (NB the legal limit is 20 µg/m3) and NO2: reduced from 40 µg/m3 to 10 µg/m3 (NB the legal limit is 40 µg/m3). These levels will be phased towards the 2030 target date but this is clearly something that should be considered.

The reality is that wherever the huge levels of 24×7 traffic is directed, there will be a significant increase in air, noise and light pollution.  The obvious answer is to prioritise the reduction of the traffic (ie public transport and sustainable freight), not to move the problem from one community to another which is the current plan. 

Whilst it is positive that the long-suffering residents of Carrington will benefit from HGV traffic being removed from Manchester Road (particularly given the terrible vibrations they are suffering every single day – and night), this could be achieved by simply opening up the A1 route.  It has to be recognised that the air, noise and light pollution will still be there though, and a large number of Carrington residents will still be impacted by the huge numbers of HGVs travelling through the area. The document does not commit to removing HGVs from Manchester Road entirely.

The report mentions in several places that the road will benefit the Partington community, suggesting that the “accessibility of Partington will be significantly enhanced by the scheme” and that it will benefit from “improved sustainable transport access, and to embrace new and improved active travel modes linking to the wider area” but that the impact on Partington traffic is expected to be unaffected by the route option choice.  This is rather odd, given the comments about Option A.  We do not know what sustainable transport access the document is referring to because, as mentioned above, there are no commitments to public transport improvements. We are not convinced Partington residents will see any benefits from this road at all, especially given the planned increase in traffic volumes.

What about the losers?

The obvious losers are the red listed birds and endangered wildlife that have made Carrington Moss their home, the local rural businesses (including agriculture, stabling, livery and their supply chains) that will be heavily impacted and, of course, Trafford’s residents in Sale West will suffer the significant rise in air, noise and light pollution that will be caused by the proposed location of this road.  Sale West residents will also suffer the effect of the construction traffic too. 

The other big losers are the younger generation, who will no longer have access to a huge area of grade 2 best and most versatile agricultural land, that could provide future sustainable food sources. 

In addition, it seems there is more work to do to determine whether the route will disturb the peat deposits, and once again, it is the younger generation who will suffer as a consequence of the lack of restoration action. 

Trafford needs to take another look at this initiative to prioritise the actions needed to address the climate emergency!

We’ve set out our high level thoughts on the Appraisal below, but we would encourage you all to look carefully at the information provided. 

Appraisal CriteriaBest Performing Option/Marginal DifferenceKey PointsFOCM Response
Ability to deliver the required network capacityOPTION F  Option F delivers the required network capacity in a less disruptive and more robust manner. It also provides greater network resilience and better access to sites, particularly towards the east of the areaGiven that the Strategy is to reduce car traffic by 50% and move freight onto rail and shipping we believe this needs to be reviewed
The ability to create improvements for public transport and active travelOPTION F  Both options will allow public transport improvements, but Option F allows greater flexibility in routing and will allow for more flexible services and provide better journey time reliability for busesBoth options could provide better journey time reliability for buses.
Carbon Budget MARGINAL  Both schemes have been modelled, each resulting in a similar carbon budgetThe carbon comparisons need to be reviewed, we understand PAS2080 has a carbon reduction hierarchy that does not seem to be reflected here.
Road Safety  OPTION F  The directness of the route, the potential for diverting traffic away from already congested areas, the lower number of junctions and reducing traffic on a road which already has a history of collisions makes Option F the better performing optionThis is interesting – in the information sharing paper the document states “There may be speeding and overtaking issues using the whole A1 route due to its long linear alignment”! 
With our suggested modifications to the proposal Option A would be the safer option.
Environment, Ecology and Heritage  MARGINAL  The analysis indicates that there are potential environmental, ecological and heritage impacts with both options. Any scheme taken forward would be subject to a comprehensive statutory process of environmental impact assessment incorporating a wide range of surveys and studiesSee the response from Natural England at the beginning of this blog. Option F has a much greater impact on the environment and the ecology.
Availability of land  OPTION F  For the offline option (Option F), the developer owns the land required and has committed to making it available for the scheme. In order to widen and improve the A6144 Carrington Lane (Option A), there would be a requirement to acquire property through CPO and demolish buildingsThis is based on the biased version of Option A.  Given that our amendments to create a more sensible Option A have not yet been considered this needs to be reviewed.
Geotechnical Assessment  MARGINAL  From information available to date, there is no basis on which to score either scheme differently. There is already physical site survey data available for Option F and analysis of this concludes no adverse issues from an engineering perspectiveObviously, Option A is yet to be assessed.
Drainage and Flood Risk assessment  OPTION F  Overall, from a drainage and flood risk perspective Option F performs better than Option A, with the exception of the requirement for a greater volume of attenuation required. Option F is therefore considered to perform best in terms of drainage and flood riskIf Option F is chosen what guarantees will Trafford provide to the residents of Sale West that their homes will not be impacted by surface water flooding.
The ability to create new landscape or environmental ImprovementsOPTION F  Option F would be the preferred landscape solution as it provides more potential for landscape treatments, recreational areas, more opportunities for walkers, cyclists and horse riders.At the moment, you can stand on Carrington 1 PROW and see right over to the hills 20 miles away, in the future you will be looking at (and hearing) 200 HGVs an hour thundering down a road directly in front of you.  Not the peaceful place of quiet reflection and birdsong that it is today. 
Construction Phase ImpactOPTION F  If the A6144 was widened, this would require a significantly longer construction period and impact more heavily on the network with a higher number of road closures and temporary traffic restrictionsThis response is based on the biased Option A response rather than on a sensible Option A.  In addition, the construction phase impact of Option F on the residents of Sale West will be more than significant.
Assessment of the impact Statutory Undertakers equipmentOPTION F  The presence of existing Statutory Undertaker services running alongside the existing A6144 would present a significant challenge to the option for widening the carriagewayAgain, based on the biased version of Option A.  This should be reviewed following some listening to residents!
FOCM High Level Commentary on the Appraisal

Is Places for Everyone/GMSF2021 the right plan for Trafford and GM?

Open Letter to All Trafford Councillors

Dear Councillor

Before you vote on the Places for Everyone (P4E) Spatial Plan for Greater Manchester (previously known as the Greater Manchester Spatial Framework – GMSF), we’d like you to consider the following significant concerns about its acceptability as the spatial plan for GM for the next 16 years:

  • We understand that Labour Councillors across GM will be whipped on this decision, which is an odd approach if there is confidence that it is the right plan, setting out the right future, with the right balance of economic, social and environmental goals, making the right decisions for the residents of GM, and, in our case, Trafford.  Why is it not possible for Councillors to be persuaded by the evidence that adopting this plan is demonstrably the most appropriate, necessary and commendable option for the P4E Councils?
  • All GM Councils, including Trafford, and the GMCA itself have declared a climate emergency, therefore, all decisions made should reflect this commitment to your current and future residents – we do not believe the plan, as currently articulated, has sufficient focus on tackling climate change
  • Despite there being no evidence that the proposed release of green belt is justified, anywhere in GM (in fact quite the opposite, as explained below), 1,754 hectares of GM’s green belt will be released for development immediately following plan approval
  • Whilst the plan demands that residents must accept a loss of green belt, and the consequent impact to their health and wellbeing, there are no policies that incorporate demands on developers (for example, to build those properties that already have planning permission), there are no policies to prevent developers securing planning permission on what is currently green belt land, yet not delivering against that approval, possibly resulting in yet more green belt land being proposed for release in the future
  • Greater levels of division and inequity will be driven by this plan, not just in terms of access to local green belt but also in access to schools, affordable homes (the New Carrington allocation, for example, will now only provide 15% affordable, due to viability issues) and public transport (New Carrington, for example, with 5,000 homes planned within P4E and a further 1,000 homes in the area with recently granted planning permission, has no trams, no trains and no commitment to new bus services – we have checked this via an FOI request)
  • Residents will suffer the health impacts of increased air and noise pollution and constructing 4 major roads across a peat moss will also significantly affect the populations of red listed birds and endangered wildlife that breed and feed in the New Carrington area
  • The New Carrington Masterplan conflicts with many key policies and strategies, not just those set out in P4E but also with the objectives outlined in, for example, the 5 year Environment Plan for GM and the spirit of a number of clauses in the National Planning Policy Framework
  • The GMSF has repeatedly been published with flawed, misleading or disingenuous statements, which should not be necessary if there is confidence in the benefits of the plan
  • There has been an unprecedented volume of responses from residents objecting to the planned builds on green belt across GM in the previous consultations (2016 and 2019), yet the GMCA continue to propose this!

Available Land Supply:

The documents tell us that the P4E plan area has a projected population increase of around 158,200, and housing occupancy rates averaged at 2.38 people per home (according to Census 2011, latest information from ONS puts occupancy levels at 2.4 but as this would reduce the figures further, we have used the Census figure).  This results in a housing need of 66,500 homes for the P4E plan area.  This figure can be compared to an available land supply of over 170,000 homes, as set out in Table 7.1 (excluding green belt allocations).  Given that this figure is over 2.5 times the need for homes, there is sufficient leeway for larger numbers of single occupancy houses, should this become a requirement of future trends.  In fact even without the (20,000) green belt allocations (see Table 7.1), there is more than sufficient land supply (170,000) for every single expected additional member of our population (the increase of 158,200) to have their own home! 

It is clear that there is NO justification for the release of green belt. 

The P4E document itself states that there is sufficient housing land supply to meet the overall identified need in the Government’s formula/algorithm.  The green belt allocations appear to have been made in case developers do not deliver.  We believe this issue should be addressed with policies that make demands of developers, not policies that result in the release of our green belt land.

We have heard the mantra “the Government is making us do it” quoted.  We recognise that there is mixed messaging, which is unhelpful.  The Government has confirmed, including specifically in relation to GM, that the housing need figure is not a target (in both Parliamentary debates and in writing).  The recent MHCLG blog (25th May 2021) seems to be pretty clear:

The Local Housing Need is simply a measure of need and we recognise that not everywhere will be able to meet their housing need in full – for example, where available land is constrained due to the Green Belt and an area therefore has to plan for fewer new homes.”

Given the implications of the climate emergency, Brexit and the pandemic, the GMCA could, and should, have concluded that the sufficiency of housing land supply did not need to be supplemented by a release of green belt at this time.

Green Belt Release:

Yet, despite these numbers, green belt will be released as soon as the plan is approved and P4E proposes a significant loss of green belt across GM – 1,754 hectares in total, equivalent to 2,456 football pitches.  For Trafford, at 269 hectares, our loss of green belt represents over 15% of this figure (the equivalent of 376 football pitches).  Trafford enters this plan with significantly less green belt land (37.6%) than the GM average (46.7%) and will exit it with a much larger (6.7%) net loss of green belt than the GM average (3.27%).  Leaving Trafford residents with even greater inequity of access to local green belt than previously available, with our post plan green belt figure being just 35% of Trafford’s land area against a GM average of 45%.

There are alternative approaches.  Oldham, for example, proposes (North-East Growth Corridor) that land will be retained in the green belt “until such time that a review of this Plan and / or the Oldham Local Plan can demonstrate that it is necessary”.  All GM Authorities, including Trafford, could adopt similar wording to create a policy that ensures green belt land continues to be protected and is not released whilst brownfield sites are still available for development.

Misleading Statements:

The history of misleading statements that have permeated previous iterations of the GMSF has, disappointingly, continued into P4E, with, for example, the New Carrington Allocation Topic Paper stating (paragraph 12.2) that “Carrington Moss is a former peat bog”.  It then goes on to contradict itself by confirming “initial investigation indicates a maximum thickness of peat of 3m, which thins towards the perimeter”.  That is 9 feet of peat deposits, which are regularly under significant surface water flooding for at least 6 months of the year (see our website page Carrington Lake).  We have requested clarity about this statement from Trafford officers as a recent presentation to residents by the GM Wetlands Project (LIttle Woolden Moss) confirmed that peat can be restored where deposits are as low as 15cm.

The graphic below highlights some of the disingenuous statements included in previous iterations of the plan, along with a summary demonstrating the consistent lack of resident support for the New Carrington Masterplan.  As we are not considered to be major stakeholders (the New Carrington Masterplan defines these as landowners and developers), this plan does not consider the views of local residents.  This is not the approach the Labour administration has taken on strategic plans for other parts of the Borough.  Why are the views of the residents of Carrington, Partington, Sale West and Warburton not considered to be as important as those of Crossford Bridge, Flixton, Stretford and Turn Moss?

There are many other points that we could raise and we will share these over the coming weeks, but for the reasons set out here, and others, we firmly believe the plan will be found to be unsound when examined by Planning Inspectors. 

If you would like to discuss any of these points further, please do not hesitate to contact me.

Kind regards

Marj Powner (Chair)

Friends of Carrington Moss

Understanding Sustainability

When Trafford talks about New Carrington being

into a sustainable location, what does it mean? 

Well, it is interesting, because the plans for New Carrington will take away some inherently sustainable aspects of the area and replace them with some fundamentally unsustainable characteristics. 

Read on, to find out more!        But first……………..

If you look it up, you’ll find various definitions which suggest that being sustainable is about ensuring we avoid wearing out our natural resources as we seek to achieve financial success, whether personally, corporately or globally. 

The National Planning Policy Framework (NPPF), which all development masterplans and planning decisions should follow, says:

This policy links to the UN declaration within Resolution 42/187 of the United Nations General Assembly, which raises concerns about the accelerating deterioration of the human environment and natural resources and the consequences of that deterioration for economic and social development.

The document proposes that sustainable development becomes a central guiding principle of the United Nations, Governments, private institutions, organisations and enterprises

Effectively, this means that plans should not be approved if they are likely to prevent future generations from meeting their needs.  Looking at some very basic examples, their ability to breathe clean air, access healthy, food sources with a low carbon footprint, and have clean water to drink. 

So, at a very high level, it is fair to say that we should not be building on a peat moss, which has the potential to be restored to sequester carbon more effectively, nor should we be building on Grade 2 agricultural land, which future generations may need to grow their food, nor should we be building on wetland which has the ability to reduce flooding and support clean water strategies for the future. 

Many commentators, however, only focus on how sustainable the design and development of construction projects are, how sustainably sourced the materials used will be and how attractive the new neighbourhood will become.  This is certainly true of Trafford’s own considerations within the New Carrington Masterplan, which mentions the word “sustainable” 42 times.  The section on Sustainability (4.9) states that it is “part of a holistic design process that runs throughout all aspects of the scheme, including design and layout of buildings and landscape, the components of the masterplan, transport strategy and phasing”. 

Trafford suggests that delivery of the masterplan will result in sustainable transport, sustainable communities, sustainable society, sustainable economy, sustainable drainage and sustainable movements. 

Yet, there is no mention of what will be lost to future generations.  In fact, the Masterplan describes the area (several times) as “the former Carrington Moss”! 

Excuse us, but ……………

In addition, the language used in the masterplan document does not bode well for future sustainability.  Even in that specific section on Sustainability (page 55), developers are only “encouraged” to use sustainable sources of construction materials and the Government’s forthcoming standards.  Principle 9 (page 31) is another good example “Optimise sustainability This masterplan supports prioritizing Biodiversity Net Gain and, where possible, optimise the wider environmental benefits for a sustainable society and economy.”  So, sustainability will be achieved “where possible”.  Should plans be approved on that basis?  We don’t think so.

Trafford acknowledges that the New Carrington allocation area is not a sustainable location today.  They assert that their vision is “to transform Carrington, Sale West and South Partington into a sustainable and attractive, mixed use residential and employment neighbourhood”.  We will not get hung up in this blog about the fact that these are three separate neighbourhoods, each with their own distinct characteristics. 

It is important to recognise, however, that NONE of these neighbourhoods will become sustainable if the New Carrington Masterplan, as currently documented, is implemented. 

Do keep reading to find out why we think this!

The NPPF has a clear focus on sustainable development.  Paragraph 103, for example, states that “Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.” 

So, what about the area covered by this Masterplan?  With 5,000 new homes, 380,000 m2 employment space and 4 new major roads, it is clearly a significant development.  Yet in New Carrington, there is only one commitment and that is to the new road known as the Carrington Relief Road.  The plan suggests that the strategic roads will “enhance the provision of sustainable transport”.

But …………

There are NO commitments to improve public transport for this, the largest housing development in the Greater Manchester Spatial Framework (now known as Places for Everyone), no trams, no trains and no new bus services (in fact, another bus service has been withdrawn from the area recently).  For more information on this, see our previous blog confirming the revelations from our Freedom of Information Act requests here.

We mentioned the substantial volume of peat that remains on Carrington Moss in another previous blog (When is a Peat Moss Not a Peat Moss).  Peat is an irreplaceable habitat, so a mass extraction event to remove this precious substance cannot be offset by any amount of Biodiversity Net Gain (to say nothing of the huge release of carbon into our local atmosphere).

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. 

In comparison, most new buildings, however sustainably built, do not have the capability to capture carbon, and those that do cannot compete with the carbon sequestration capabilities of our peat mosses.  In fact, such construction will result in a huge increase to carbon emissions locally (more heating, more cars on the road, more waste removal).  Furthermore, as this article suggests – it takes over 50 tonnes of CO2 to build the average UK house

Conversely, in addition to their superior carbon capture capabilities, the restoration of our peatland habitats would bring numerous ecosystem benefits, such as water quality improvements, flood impact reduction, species recovery, biodiversity gains, wellbeing and climate cooling to name just a few.  This wetland environment is a very effective tool which reduces the potential for local flooding (take a look at the Carrington Lake page of our website for more information) and helps to dissipate polluted air, with the large areas of woodland on Carrington Moss also supporting carbon sequestration. 

So, here on Carrington Moss, Trafford will be reducing the highly sustainable peatland area (which could be restored to capture carbon more effectively) and will replace it with housing and employment sites that generate extensive additional carbon emissions and do not have access to sustainable transport options.

But………….. that is not all!

The employment area in Carrington, located alongside the Medieval village, has previously had substantial areas of industrial and warehousing development approved over the years.  This has resulted in huge volumes of HGV traffic on local roads and other pollutants being released from some of the business premises, causing well known, significant and unacceptable, health and wellbeing issues for local residents.

Yet, the New Carrington Masterplan currently proposes to build a further 380,000 square meters of additional industrial and warehousing space (so, no digital, no technology, no green or professional occupations, just industrial and warehousing sites).  This lack of diversity, and the resulting very limited career opportunities, means that many local residents will not have the range of employment options that they would need to find work locally.  In addition, these new employments sites will bring yet more HGV traffic into the area because alternatives, such as rail freight or shipping (given the proximity to the Manchester Ship Canal) have not been proposed.

The brownfield sites in the allocation area have already been granted planning approval.  The remaining land is either green belt (Trafford plan to release 169 hectares) or Protected Open Land.  Where this land is not the peat moss or woodland mentioned above, it is Grade 2 agricultural land, excellent for crop production, supporting existing employment, in farming activities and horse riding/stabling pursuits, both of which sustain Trafford’s local economy.  Much of that existing Grade 2 agricultural land will become housing, industrial or new roads and most of the rest will become extremely polluted as a consequence of all that construction, preventing future generations from being able grow crops here and food growing in the UK is even more important now (because of Brexit), it’s not as easy, or cost effective, to import, given the trade barriers that have been erected.  The plans will decimate the existing agricultural and equine economy and local supply chains will be severely impacted by the loss of these businesses too. 

Furthermore, the development will fracture the wildlife corridor, significantly impacting many red listed birds and endangered wildlife populations.  The active travel routes, that are widely used by large numbers of local residents, will also be extensively affected.  There are, for example, over 1,000 horses stabled in this area, many of which are ridden across Carrington Moss on a regular basis.  Already popular prior to the pandemic, recreational use of the moss by cyclists and walkers has increased dramatically over recent months.  All these healthy, active, outdoor pursuits will be severely constrained by the plans for development.

In researching for this blog, we’ve been talking to some existing employers who are currently based on the Carrington and Warburton Mosses to find out how sustainable they are today.

Carrington Riding Centre, for example, has focused on various environmental improvements, continuously investing in their land, maintaining their fields and recycling their horses’ waste.  They also invested heavily in a bore hole so they can produce their own water. 

Their carbon footprint is low, the Centre purchases their bedding and feed from local farmers, they use environmentally friendly supplies for horse feed and bedding and their café uses recyclable products too, such as paper cups, plates, etc. 

They would like to do more and regularly review potential grant funding to explore opportunities to:

  • introduce renewable energy
  • make the most efficient use of non-renewable resources
  • improve water courses and drainage. 

All of these are very expensive for a small business like theirs to absorb but they are keen to ensure they are as sustainable as possible.

Local farmers also aim to be sustainable and contribute to environmental improvements, such as hedge planting, ditch cleaning, soil quality improvements and they use the least amount of chemicals possible in all their activities.  One farmer told us that, whilst they do use local horse and chicken manure, there are times when they need to use chemical fertilisers.  The farmers deploy GPS and weigh cell technologies to ensure precision application, only dispersing what is needed for that crop, in that location, so the environmental impact is reduced as far as possible.

One of our local farmers hires out straw and hay bales for events.  They then recycle the used bales for their cattle bedding and then further recycle them as fertiliser on the fields.  They are conscious that manufacturers in their supply chain do not always use recyclable packaging, and, whilst this is changing for some products, it is still especially true for the bale wrap. 

Like the Riding Centre, local farmers would consider increasing sustainability, if funding becomes available.  They have also looked at renewable energy, such as solar panels on shed roofs, and improvements to water courses.  They have recently taken up opportunities, through grant funding, to renew fencing, cattle handling facilities, more GPS systems, yield monitoring and livestock monitoring via CCTV, all of which improve the sustainability of their businesses. 

Government funding schemes are evolving, and many are becoming more environmentally focused.  Local farmers are following proposals such as sustainable farming incentives (which will be simple actions most farms can achieve), whole farm plans, crop management, livestock plans, integrated pest management, soil plans, etc.  Local Nature Recovery initiatives, which Greater Manchester is piloting at a Regional level, would involve creating more woodland, wetland, restoring peat mosses, and supporting natural flood management.  The Carrington and Warburton Mosses would be ideal locations for these proposals.

Yet, despite all these Regional and National initiatives, Trafford is willing to sacrifice our essential farmland, this Grade 2 agricultural land, for construction, even though there are urban areas in sustainable locations, that could be used to build homes and employment properties (and it seems the amount of brownfield land is likely to increase post-Covid because of the recognised changes to working practices and personal habits that have become apparent over the past year).

The conclusion of Trafford’s document states that “This masterplan report demonstrates that the New Carrington Allocation site is deliverable and sustainable”.  We do not agree!  The plan to build 5,000 new homes, 380,000 m2 industrial and warehousing employment space, and 4 new major roads on a peat moss and Grade 2 agricultural land is clearly NOT a sustainable strategy. 

Sustainability is more than just a concept.  It is an intrinsic, high value, asset, with features that can and should be measured and monitored.  Furthermore, the assessment of the potential sustainability of this location lacks credibility and this masterplan demonstrates a huge lack of knowledge about the area itself!

That said, when the CPRE tells us that there is “enough brownfield land for 1.3m new homes” and the Local Government Association highlights that “More than a million homes granted planning permission in the past decade have not yet been built” we have to ask why there is a plan to build on green belt at all?  Who will benefit?  Trafford residents?  We think not!

Let’s just remind ourselves again about those words from the NPPF:

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”.

So perhaps what we should be asking ourselves is – are there other places in Trafford where we can:

  • restore peat to more effectively capture carbon, so our children and grandchildren 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 the populations of red listed birds and endangered wildlife, so we can help nature’s recovery, increase biodiversity and mitigate the impact of climate change?

If the answer is “No” to one or more of these questions, we should not be building on Carrington Moss.

When is a Peat Moss NOT a Peat Moss?

Answer:  When someone wants to build on it!

Despite the increased recognition of the importance of our wetlands as priority habitat.

Technically speaking, lowland raised bog always remains a peat bog in terms of the geological formation of the substrate (the bowl in which the bog was first formed).  The physical features of that can never change without massive geological and structural alteration to a whole landscape.  This would have a huge impact on local biodiversity, species survival and the essential work as a flood control mechanism that a peat bog provides!

Our peatlands are critical for preserving global biodiversity, providing safe drinking water, minimising flood risk and helping to address climate change.  In many parts of the world, peatlands supply food, fibre and other local products that sustain local economies.  They also preserve important ecological and archaeological information such as pollen records and human artefacts (take a look at this nearby find Lindow Man).

Some comments have been made recently to suggest that Carrington Moss is no longer a peat moss.  Whilst we recognise that, in common with many wetland areas around the world, there has been considerable decline, in both the area and the quality of our mossland habitat, we think these commentators are incorrect. 

They may not be aware of the wetlands survey undertaken, in 1995, by Hall, Wells and Huckerby (results available as a publication by Lancaster Imprints, The Wetlands of Greater Manchester), in which the authors concluded that

a substantial body of peat remains at Carrington Moss”.

The chapter on Carrington Moss gives a short precis of the history of the area including the damage to the moss caused by encroaching industrialisation.  The document describes the central area of the mossland as “deep peat with a nightsoil covering”.  It also confirms that the “total area surveyed of peat more than 0.3m deep is 325 ha”.  Furthermore, the authors found that the peat depths ranged from “2.7m to 0.3m”. 

More recently, documents within the Heath Farm Lane planning application confirmed that peat “is present in thickness of up to c. 2.5m”. 

So, it would appear that the peat is

still here!

It is true that the ecosystem services traditionally provided by wetland habitats have been diminished here on Carrington Moss, but they are certainly not eradicated (yet).  The frequent sightings of globally threatened species, of birds, wildlife and plants, when out and about on the moss demonstrates the value and importance of this essential habitat.  We are so lucky that our local green space is host and home to over 20 red listed birds, for example.  School trips to the moss have seen the skylark, recent visitors have seen the willow tit and you may have your own sightings to share (don’t forget to record them).

This treasure chest of biodiversity brings so many benefits that we should be enhancing, helping these species populations to recover, reintroducing previously abundant flora and fauna and encouraging residents to take advantage of this (almost) pollution-free environment for their regular exercise regimes. 

Our local peatmosses (both Carrington and Warburton) are highly significant to Trafford’s efforts to address climate change.

You may have also seen that Carrington Lake is back and the moss is once again protecting our local area from significant flooding.  This is its job!  We are very concerned that the planned developments will bring a huge risk of local flooding because the amount of water currently amassed on the moss will exceed the capacity of the drainage systems, as has happened elsewhere. Take a look at our video which talks about the impact of flooding on local residents here (click on the image below)

Carrington Moss 21st January 2021

In addition, whilst there has been significant damage to our peatmoss in recent times, and that has undoubtedly resulted in CO2 being released into our local atmosphere, draining or removing the moss for development will result in a further, and much more immense, release of carbon, impacting not only the local environment but the health of local residents. 

The Heath Farm Lane application, for example, asserts that “United Utilities require that all peat is removed from below the invert level of adoptable drainage” and that the local highways authority “would have a preference for removal of peat from the footprint of adoptable highways”.  The peat will also need to be excavated from below all proposed building construction.  This will release CO2 into our atmosphere!

It should also be remembered that over 50,000 tons of peat was removed when the Carrington Spur was built (source: Motorway Archives, Lancashire Archives, Preston). At a very rough estimate (varying dependent on whether the peat was wet or dry) this could have equated, at that time, to a minimum of 12,000 tons of CO2.

We have explored a number of academic studies which assess the impact of that carbon release.  Our researcher, Dr Charlotte Starkey, has reviewed several assertions in detail, including those set out in the New Scientist (1994), Scientific American (2009) and The Guardian (2017).  The results, when applied to Carrington Moss, were quite diverse, ranging from estimates of over 250,000 tonnes of carbon to over 2,200,000 tonnes of carbon.  Charlotte believes there is likely to be around 2,000,000 tonnes of carbon in Carrington Moss today. 

One of our members, Landscape Architect, Paul Beckmann, has reviewed the Why Mosslands Matter approach.  Assuming the area of peat at Carrington Moss is now c.300 ha. (it was 325 ha. in 1995, as mentioned above) and that the average depth is c. 2m (we know in parts it exceeds 3m), Crawford’s calculations suggest the removal of our mossland would result in the release of approximately 2,400,000 tonnes of CO2 into our local atmosphere.  So, an estimate at the upper end of the range.

This is a critical issue and CO2 release is totally incompatible with Trafford Council’s declaration of a climate emergency and its recently published Carbon Neutral Action Plan.

The protection and restoration of our peatlands is vital in the transition towards a carbon neutral economy and should be added as key objective in Trafford’s Carbon Neutral Action Plan.

So, what shall we do?  Well, the Friends of Carrington Moss has been working with partners from the Wildlife Trusts, Trafford Wildlife, the RSPB, the Greater Manchester Ecology Unit, a Rare Plants expert, local bird watchers and other experts to create an alternative transformation strategy for Carrington Moss.  A transformation strategy that results in Carrington Moss becoming a Carbon and Biodiversity Bank

The challenges faced by our local peatland area are not irreversible and, internationally, there is a growing recognition that peatland restoration projects are highly cost-effective when compared to other carbon-reducing technologies or initiatives and there are many other benefits when peat-forming ecosystems are re-established, not least of which is the contribution to Trafford’s (and Greater Manchester’s) Net Zero aims.  Restoring the peat moss will also support the recovery of nature, improve the sustainability of our local soils and will help address the impact of the climate emergency, enabling Trafford to comply with local, regional and national environmental policies.

We’ll be providing more information about our Alternative Transformation Strategy in a future blog and you can find more information about how peatmosses work on the Research page of our website.  We have also shared some information for younger readers in our previous blog “Why is Carrington Moss so important

There is a huge problem with suggesting that the New Carrington development will lead to public transport improvements for this area

Trafford has promised this before and has not delivered

see the Trafford page of our website for links to the Trafford UDP (2006) and Trafford’s Core Strategy (2012)
In Trafford’s Unitary Development Plan of 2006 and in Trafford’s Core Strategy of 2012
Carrington, Partington and Sale West are identified as “priority regeneration areas
with public transport improvements stated as being
core to delivering the regeneration!

So what are they telling us now?

The New Carrington Masterplan recognises concerns raised by residents about the “insufficient public transport service and connections (Bus, Train & Metrolink) available in the area”, yet makes NO commitments for improvements stating that “improving bus accessibility to New Carrington, Altrincham, and Sale should be encouraged”

Transport for Greater Manchester’s Transport Strategy has only one commitment for this area and that is the Carrington Relief Road across our peat moss!!!

There are NO commitments to public transport improvements, and no plans to bring the tram to the largest residential allocation in the whole of Greater Manchester. 

What they say is that “In the next five years, we aim to complete business cases for early delivery of…

New bus services to support the New Carrington and Sale West allocations to serve new development at Carrington with improved public transport links, particularly to and from the Regional Centre”

This has been confirmed in the response to our recent Freedom of Information Act request, in which TfGM state that There are currently no committed schemes to improve public transport in this area.

They go on to say “TfGM and Trafford Council are planning to take forward the development of business cases for two schemes in the area: a busway between Broadheath and Sale West, which could support the 19 service; and a bus priority scheme where the Cat5a route meets the A56 to improve journey times and reliability of buses between Partington and Altrincham”

These two schemes will not address the significant lack of public transport in this area, will do little to reduce isolation and change the current reliance on the car as the main means of transport to and from New Carrington and surrounding areas. 

We have now been waiting for public transport improvements for almost 15 years,
isn’t it time our Council made them a priority?

see our Alternative Transport Strategy
which sets out residents’ priorities, which are traffic calming schemes and public transport improvements

We need a masterplan that is influenced by residents – not by developers!

Why we do not support the GMSF in its current form

We have sent the following feedback about the Greater Manchester Spatial Framework to all Trafford Councillors in advance of their discussion about the GMSF on 30th November.

Summarising the issues!

Whilst we totally support the principle of the GMSF, concur with its ambitions, and recognise the considerable effort that has gone into drafting it, we cannot support the current iteration because it still advocates the unnecessary removal of Green Belt land across Greater Manchester, when there ARE clear alternative approaches. 

The issued documentation declares that Local Authorities are able to make “adequateprovision to meet housing need numbers WITHOUT releasing Green Belt land.  It must also be remembered that, back in 2015, a GMSF Option was considered which required NO use of Green Belt land and a decision was specifically made NOT to take this forward.  This suggests that the decision to release Green Belt in GM is a desire of the leadership, NOT a requirement.  This assertion is further reinforced by the recognition that, whilst a lot of effort has been made to create exceptional circumstances which support the release of Green Belt land, NO attempt has been made to identify exceptional circumstances to reduce the housing need number to ensure all development is focused on brownfield land. 

Given that Local Authorities have identified “adequate” sites to meet housing need numbers, together with the expected changes to working practices post-Covid (which we believe will lead to the availability of windfall sites across GM), the extensive feedback from residents against the release of Green Belt land, and the emphasis of all political parties on nature-led recovery and the climate emergency, the only reasonable approach for the GMSF is NOT to release Green Belt land for development.  The GMSF could have been prepared within that constraint and should, if confidence in developer delivery is low, also have proposed that an extensive post-Covid review be undertaken during the GMSF period to determine whether further analysis is needed.  The current approach is likely to lead to Green Belt being built on, whilst a huge number of windfall (brownfield) sites are left unused.  

Furthermore, at a local level, whilst we welcome the work that has been undertaken to reduce Green Belt release in New Carrington, Trafford’s overall reduction in Green Belt take is significantly lower than that of other boroughs in GM.  In addition, the plans as documented are NOT plans that are underwritten by local residents.  The New Carrington Masterplan talks about the intensity of discussions with landowners and developers, yet there have been NO workshops about the Trafford allocations with residents or Parish Councils prior to issuing the documentation.  It is certainly a very strange type of democracy that has Local Authorities working on secret plans which significantly impact the local communities they are accountable to, despite a Statement of Community Involvement which suggests, in its introduction, that the Council should be “providing opportunities for active participation and discussions with the community as early in the plan-making and planning application processes as possible.”

With this in mind, the Friends of Carrington Moss are working with local Parish Councils and other community groups to develop alternative proposals for the area.  There is a lot of talent in our communities and a large number of ideas have been proposed.  These alternative options further demonstrate that the release of Green Belt is NOT necessary.

Unnecessary Release of Green Belt Land for Development

We believe that the GMCA is making a deliberate and conscious decision to unnecessarily release Green Belt land for development.  Once this precious resource is released, it is irretrievable for the vital purposes it performs.  In our view, this approach is unsound because it is neither justified (given the confirmation of adequate housing supply) nor sustainable (given the selective implementation of GMSF strategic policies). 

For clarity, the GMSF paragraph 7.12 states that “in numerical terms, the existing supply of potential housing sites identified in the districts’ strategic housing land availability assessments, small sites and empty properties is adequate to meet the overall identified need”.  This means Green Belt land is being released to cover a “buffer”, just in case it is needed.  This is not justifiable and any buffer required should have been covered by a case for exceptional circumstances, as set out below.

The release of Green Belt will have a particularly severe impact on Trafford as we have the lowest proportion of Green Belt land in the whole of Greater Manchester, other than the city areas of Manchester and Salford.  In addition, St Marys Ward has the lowest proportion of Green Space in Trafford, with Bucklow St Martins Ward close behind.  These are the two Wards most affected by the plans for New Carrington.  Many of our residents are not affluent and have valued free access to this local green space more than ever since the pandemic began.  Whilst you may see a corridor coloured green on the New Carrington map, it should be recognised that much of that “green” space is not green and it is not accessible to the public.  This reduced green area will be further diminished if Trafford’s planned roads across the Green Belt go ahead, bringing significant air and noise pollution to residents, sports participants and school pupils.  The community has developed alternative proposals which make these roads and the release of Green Belt unnecessary.

GMSF 2020 could have determined not to release Green Belt and could have proposed a post-Covid review, within the GMSF period, to verify whether developer delivery is on target and, if not, whether sufficient windfall sites are available to meet any shortfall.  Should that review ascertain that Green Belt release could be necessary, this should be considered further and agreed at that time.

Case for Exceptional Circumstances in calculating Housing Need

We believe insufficient effort has been made by the GMCA to present the case for exceptional circumstances to justify a reduction in the housing need numbers calculated using the Government’s National Formula.  This standard method for calculating Housing Need is NOT mandatory.  This has been confirmed, both in writing and verbally, by Ministers, on several occasions over the last few years.  In a recent example, the Hansard transcript for the GMSF and Green Belt Parliamentary Debate of 18 March 2020 confirms the Minister for Housing’s statement that “It is worth noting that the standard method is not mandatory; in exceptional circumstances, an alternative approach can be used, provided that that reflects the current and future demographic trends and market signals. If my hon. Friend the Member for Altrincham and Sale West cares to check paragraph 60 of the NPPF, he will find reassurance in that paragraph” (Hansard: 18/3/20 Parliamentary Debate).

In addition, it has been demonstrated in responses to previous drafts of the GMSF that a 15-year plan would generate sufficient available brownfield land to meet housing need requirements across the Region, totally removing the need to release Green Belt.  A 15-year plan would also allow more flexibility to adapt to the, as yet unforeseen, changes required due to climate change and the current global pandemic (some rethinking of our lifestyles and economy is likely to be required, which will have a direct impact on planning).

So, there are a number of potential exceptional circumstances that do reflect demographic trends and market signals, that could be cited to ensure all development is concentrated on brownfield land.  Some examples include utilising the most up-to-date (2018) ONS figures (to determine more accurate local housing need predictions), limiting the GMSF to a period of 15 years (which is all that is required by the NPPF) and confirming a commitment to the post-Covid review (mentioned above).  In addition, funding of £81m is now available to tackle the more challenging brownfield sites across the Region. 

Addressing the Climate Emergency

We do not believe the plans to release Green Belt in Trafford are consistent with the declaration of a Climate Emergency, made by the Authority in November 2018.  The protection of our Green Belt land is now more important than ever as we experience the increasing impact of climate change.  As an example, large areas of Carrington Moss were extensively flooded between October 2019 and March 2020 (see our website for photographs and videos), including areas now suggested for housing developments. 

The release of Green Belt is also inconsistent with GM’s aim to be “a place at the forefront of action on climate change, with clean air and a flourishing natural environment”.  As part of the preparations for the GMSF, GM commissioned The Environment Partnership (TEP) to assess the current state of the natural environment.  TEP undertook a review to estimate how many Biodiversity Units (BUs) there are in each of GM’s 10 boroughs.  Trafford (at 41k BUs) is the second lowest in the Region, just above Manchester City itself, significantly behind the leading Authority, Oldham (with 139k BUs), and not even comparable to Tameside (95k BUs), which is a similar size in terms of area and population to Trafford. 

Releasing the Green Belt in Trafford will reduce our BUs further.  The local community has developed an alternative strategy for Carrington Moss which would utilise the area as a carbon and biodiversity bank to “sell” carbon and BUs to businesses and urban developers to help them meet their carbon targets and biodiversity net gain figures and to increase Trafford’s BUs at the same time.  Whilst it is impossible to put a price on our green assets, we are seeking to create a viable alternative to the current plans.

All the political parties have a focus on nature-led recovery and the climate emergency.  Labour’s Green Economic Recovery paper, for example, quite rightly, suggests that “Future generations will judge us by the choices we make today”.  How will a decision to unnecessarily release Green Belt be judged by those who no longer have access to nature and green space, who can no longer see the willow tit and the skylark in their local area (because their breeding and feeding grounds have been destroyed), who can no longer see relatives and friends who have succumbed to illnesses caused by increased air pollution. 

That Green Economic Recovery paper also highlights the importance of not only solving the decarbonisation challenge but also in igniting the “broader preservation, enrichment, and protection of the UK’s natural ecosystems and biodiversity”.  The Labour document also mentions the importance of restoring peatlands and we agree that significant action is “needed in order to accelerate the benefits of nature restoration and recovery” and that there is “an abundance of natural restoration projects that could begin right now”.  The plan for New Carrington is NOT an example of how we can achieve these great ambitions, it also directly contradicts many of the environmental policies set out in the GMSF.

In addition, the 2020 GMSF proposes to expand Manchester airport.  It is already a source of considerable air pollution, noise nuisance and contributes to greenhouse gas emissions.  Until green aviation fuel has been developed, which is not likely within GMSF period, there should be no further expansion of the airport or increase to the agreed number of flights (a reduction would be more sensible to align with the GMSF stated aims for carbon neutrality and clean air).  

Other points to consider

Whilst the GMSF incorporates a number of aims and ambitions that are laudable, somewhat summarised in paragraph 1.6, which states that “Our ambitions to be carbon neutral by 2038 have never been more necessary – we need to support the creation of resilient, liveable places where walking and cycling are the obvious choice for shorter journeys, where facilities and services are accessible and close at hand and where the past dependency on the car is superseded by a reliable and responsive public transport system.”, the selective adoption of the policies and strategies encompassing the GMSF means that the desired equality objectives cannot be achieved. 

One equality objective is to “Prioritise development in well-connected locations” and another is to “Deliver an inclusive and accessible transport network”, which will improve air quality across GM.  Paragraph 5.50 states that “The most significant role which the GMSF will play in this respect [improving air quality] is to locate development in the most sustainable locations which reduce the need for car travel, for example by maximising residential densities around transport hubs”.

The New Carrington development is NOT currently a sustainable location and we do not believe it will be transformed to a sustainable residential and industrial location.  Public transport improvements have been promised to Carrington, Partington and Sale West in the 2006 UDP and the 2012 Core Strategy but in fact, bus services have reduced in these areas.  The GMSF does NOT COMMIT to increasing public transport, instead, the Masterplan suggests “improving bus accessibility to New Carrington, Altrincham, and Sale should be encouraged” and the TfGM Transport Delivery Plan 2020-2025 states that “In the next five years, we aim to complete business cases for early delivery of… New bus services to support the New Carrington and Sale West allocations”.   That is not reassuring given residents have been waiting for over 15 years for improvements to public transport.

Furthermore, it is unsustainable to consider the use of Green Belt land for warehouses and industrial with the clear aim of using road transport.  The community has developed an alterative Transport Strategy which proposes a new bridge across the Ship Canal, to provide access to Irlam Wharf and Port Salford for businesses in Carrington.  This approach, which we have discussed with local businesses, would mean HGV traffic can be significantly reduced and that there is no requirement for a Relief Road across Carrington Moss.

The GMSF 2020 places great emphasis on economic growth, appearing to give this a higher priority than the well-being of residents, yet the importance of access to green spaces and nature for physical and mental health is now well documented.  It is recognised that the impact of Covid and economic uncertainty will hit our most vulnerable residents the hardest, yet the GMSF, despite acknowledging the “state of flux”, does not address the inequities that will inevitably follow. 

There is also an equality objective to “Strengthen the competitiveness of north Greater Manchester”, yet the largest residential allocation is in Trafford.  This means that Trafford residents do not have equity of access to Green Belt areas, they have their access to green space further reduced and for residents of North Manchester, growth is not being prioritised as suggested in the GMSF.

Finally, there are issues about the heritage assets in the area (including the peat moss itself, of course), the harm to be caused by the loss of Green Belt (which is acknowledged in the Masterplan) and the loss of income to local businesses (including riding centres and farmers), which of course impacts Trafford’s local economy too.  The New Carrington allocation remains unsound for the many reasons that have been vigorously expressed by local residents in the previous consultation. 

We would be delighted to share our alternative proposals and/or more information about our analysis of the GMSF.

Say no! to detrimental Planning reform

An open letter to Sir Graham Brady about the recent Government Consultations

Dear Graham

I’d like to share with you some of the key points from my responses to the Government’s consultation about Planning Reform and some of my grave concerns about the approach the Government is taking, which appears to drive yet more power into the hands of developers.  I apologise for the length of this letter (and for any repetition that may be in it) but I wanted to get all my points over and to ask you to support my request to halt these reforms until the issues I am raising (as undoubtedly are others) are resolved.  It would also be helpful if you could share this letter with your colleagues, the PM and the Secretary of State (SoS).

Overall, the Planning Reforms are extremely biased against communities and in favour of developers.  Clear and significant inequities are boldly exhibited within the proposals and it certainly is not clear how the dominance of large companies has been addressed.  I have set out some examples in the paragraphs below, which are focused on issues relating to housing, but of course, I recognise planning is so much broader than that.

The Government says they “want all communities, families, groups and individuals to have a say in the future of the places where they live”.  Yet the White Paper does not give us that.  In fact, it reduces democracy and citizen input, with residents being excluded from parts of the process or ‘allowed’ to participate at the whim of the Local Authority or the Planning Inspector.  The SoS says “These proposals will help us to build the homes our country needs”, so where is the focus on social housing?  Just stating that the Government supports “inclusive and mixed communities” is not enough.  The White Paper does not demonstrate that it meets the requirements of the Public Sector Equality Duty.  It does not appear to address the needs of the most vulnerable in our society, including those who share protected characteristics, those who are homeless and those care-leavers who need specific support, ie those who are actually suffering as a consequence of the current housing crisis!  The proposals do nothing for those who will NEVER be able to buy their own home (whatever ‘affordable’ housing schemes are considered).  

Having openly acknowledged (White Paper para 5.17) that the current key beneficiaries of planning gain are developers and landowners, the Government suggests that they be offered even more benefits through these reforms.  There is a proposal, for example, that Local Authorities refund application fees to developers if they do not achieve the new timetable (which will be a real challenge because there appears to be a massive overestimate of the benefits of zoning and a significant underestimate of the administrative burden the Government is planning to impose), yet there is NO charge or penalty to developers if they secure planning permission but don’t ever build any houses.  

The Local Government Association reported, earlier this year, that there are over 1m homes with planning permission that have not yet been built.  It is, therefore, not justifiable to claim that the planning system has failed, as suggested in the PM’s foreword (or blame the newts, as he suggested in his speech of 30th June) and whoever wrote the statement that “too often excellence in planning is the exception rather than the rule” is mixing up planning with development.  A big issue throughout the document but understandable, because we actually have a development system, in which providers have so much influence that the needs of citizens and communities can be ignored, leaving the most vulnerable in our society in crisis and artificially increasing both house prices and land values. 

Despite acknowledging (paragraph 40, Changes to the Current Planning System) that “Not all homes that are planned for are built” (rather an understatement), there is not a single proposal to ‘encourage’ developers to build those outstanding homes and accelerate availability of housing.  An impartial review of current issues would have resulted in such suggestions.  It would be very reasonable to make developers accountable for building outstanding schemes and, in adopting such an approach, there would be NO need for Local Authority targets to meet market housing requirements.  Why hasn’t the Government considered this?

Options for such ‘encouragement’ could include removal of planning permission (thereby reducing the value of the land), compulsory purchase and asking SME builders to take forward approved schemes (addressing another commitment in the White Paper), charging developers a fee for each home with planning permission that has not been built (perhaps equivalent to the Council Tax that would have been incurred had the homes been built to a reasonable timetable).

The SoS says ‘We are cutting red tape, but not standards’ – I beg to differ!  The proposed expansion of Permitted Development Rights to larger schemes is outrageous, given the scandal of the “rooms with no windows”  (and the recently reported flats the size of car parking spaces).  This demonstrates that those same organisations, who are failing to deliver approved developments, cannot be trusted to work without mandated standards in all aspects of a scheme.  Who will benefit from those cuts to red tape?  Oh yes, the developers! 

The proposal that communities have only 14 days to provide their representations on these large schemes is contemptible and is NOT compliant with the Government’s own guidelines on consultation.  Who will benefit from the reduction in the time allowed for public comment?  Oh yes, the developers, once again!

The SoS says the proposals will “recreate an ownership society” – where is the evidence that we need to do this (renting can be a lifestyle choice) and why is this the priority?  The people who would like to buy a property may have challenges but are not typically in crisis!  If the Government is honest about its “levelling up” agenda, it will recognise that the mandated targets for market housing should be agreed with developers in relation to those permissions already given.  The ambition to deliver 300,000 dwellings per annum should be reviewed to determine its appropriateness and updated to require (for the next 5 years as a minimum) that at least 60% of those homes be social housing, supported by a new mandated formula to calculate social housing need for each Local Authority area. 

The House of Commons Research Briefing promises improvements to the planning ecosystem, but the reality, set out in the documents, is somewhat different.  Local communities will ONLY have a voice in the aesthetics of the buildings, not in the what, the where and the when of planning in their area.  This is a huge backwards step from what is set out in today’s Statements of Community Involvement.  The elimination of our democratic right to be involved in planning should not be acceptable to anyone, especially not the Members of Parliament, who represent our communities. 

The Green Belt is not protected, as claimed, it is just subject to the current processes.  Important ecological habitats (including that of the globally threatened newt, and, closer to home, the water vole) will no longer be assured of an Environmental Survey to determine the appropriateness of development.  The Government supposedly have an aim to reverse the decline in nature (not just stop it), yet there is nothing in the documents that suggests support for this aspiration (and promising a further consultation at a later date is not helpful).

The TCPA suggest that “around 90% of applications for planning permission are approved in England”.  Yet there is no mention of this statistic in the very misleading statement that “around a third of planning cases that go to appeal are overturned”.  Of course, whatever the number (presumably around 10% of planning applications), two thirds are not overturned!  The author of this document should be thoroughly ashamed!

The proposal about the simpler national levy seems to be aimed at benefiting developers (again)!  There is nothing in the White Paper that “makes it harder for developers to dodge their obligations” as suggested by the PM.  Local Authorities should influence what is needed in their area, scheme viability should be independently assessed and funding for such an important resource as social housing should be specifically reviewed and consulted upon separately as it is clear registered housing providers cannot meet this need alone.

The White Paper seems to be obsessed with speed and beauty rather than with high quality homes (including provision for those in crisis) and, whilst zero-carbon homes are welcome, the plan to allocate £27b of public money to the construction of (unneeded) new roads should be reviewed.  Both the White Paper and that objective need to be re-written to reflect the post-Covid world. 

Some of the other issues that concern me are the lack of involvement of communities and specialists in the development of these proposals and the lack of opportunity to comment on issues such as costs and the future plans for Environmental Surveys. 

It seems “The Government has welcomed contributions from experts, including Savills and Lichfields” but when organisations such as the Local Government Association, the Royal Town Planning Institute, the Institute of British Architects, the Campaign to Protect Rural England and Shelter are raising serious concerns about the White Paper, it is extremely alarming.  The opportunity to create a ‘Citizens’ Assembly’ to support discussions about these reforms was not even considered.  Is there not an understanding of the importance of stakeholder involvement? (and let’s be clear – Government Advisers are not stakeholder representatives but maybe they do know a lot of developers!).

The White Paper says “we will streamline the opportunity for consultation at the planning application stage, because this adds delay to the process and allows a small minority of voices, some from the local area and often some not, to shape outcomes”.  Yet the Government purports to recognise communities as key stakeholders.  If this is the case, those “voices” would be considered essential and it should be remembered that the “small minority of voices” are very welcome to the communities they live in (especially for those vulnerable residents who may be unable to articulate their concerns themselves).  Citizens should not be losing their democratic rights because developers are not building the homes which HAVE been approved and do not want to justify their new plans to residents!  Who benefits from the removal of those “voices”?  Once again, the developer!

It is clear that the White Paper does not propose any new rights for community participation, despite the promise to “increase access and engagement”.  In fact it appears to reduce both rights and opportunities and, whilst digitisation will undoubtedly be welcome by many residents, there are also some who will be excluded by this approach and there is nothing to show how their involvement will be retained. 

There was no opportunity to comment on the Government’s assertion that the “cost of operating the new planning system should be principally funded by the beneficiaries of planning gain – landowners and developers – rather than the national or local taxpayer”.  What does this do to impartiality in the system?  This approach could introduce significant bias as there would almost certainly be a perceived obligation to find in favour of the funder.  Questions should also be asked about why is a mere supplier of a product the key beneficiary of planning gain?

The White Paper states that “Processes for environmental assessment and mitigation need to be quicker”.  This is one of the most concerning parts of the consultation, yet there were no questions to respond to about the Effective Stewardship and Enhancement of our Natural and Historic Environment.  Given the declarations of a Climate Emergency (nationally, regionally and locally), environmental and biodiversity protection has to be one of the most important considerations within the overall ecosystem and safeguards should not be abandoned, condensed or limited by the quest for process speed!  And who will benefit from this introduction of simpler systems?  Yes, it is the developer (again)! 

Will it speed up delivery of development projects – NO because there are no penalties for developers if they never deliver!  And, what about that promise to our children and grandchildren that these “reforms will leave an inheritance of environmental improvement – with environmental assets protected” etc – not a hope, given the way the documents are currently written!

Whilst the Conservative agenda for private sector innovation and investment is well understood, this should not put developers in an exalted position and does not preclude access to democracy or the benefits of citizen leadership.  What we actually need is to move to a true Planning System, one that is community-led and demonstrates full accountability for action.  The Neighbourhood Plans are a great starting point.  Many people have volunteered huge amounts of their own time in the construction of these documents.  It is offensive that the Government has not explicitly acknowledged and demonstrated the value of these contributions in the White Paper. 

Digitisation is a great idea and I support this, but anyone in the business will tell you that you do not automate a bad process.  Residents do not just want transparency through technology – we want a say in what happens in our locality.  With this in mind, communities should be identifying what is needed for their area, working with ecologists and other specialists to assess the suitability of their local environment to meet their plans and leading the process!  Developers may be the source of some of the investment, but they should not be driving, they should be taken on our journeys.

Given the level of influence developers have today, it will take time to move to this approach, but we can start by ensuring they are not given the ability to further dominate the planning system.  The Government should give real power to communities instead.  Yes, they will need support, yes there will be challenges and yes there will be costs associated with this approach, but our communities are our heritage.  They should not be given away to organisations whose focus is on their bottom line.

In summary, quite frankly, the White Paper is a poorly constructed, repetitive document which does not deliver the promised benefits and the Changes to the Planning System document is completely focused on the wrong targets and the expansion of an already discredited initiative.  How does the Government expect to make progress in addressing the housing crisis when they are whipping their public servants, punishing their communities and giving carrots to those organisations that cause the problem?

Whilst I agree, the current planning system has its faults, and I am all for progress and change that is beneficial, I do not think these proposals are well-thought-out, and they are certainly not an improvement on what there is today!  I have previously written to you (for onward transmission to the SoS) about the appointment of Citizens’ Advocates.  I believe they would accelerate change, bring considerable improvements to the planning ecosystem, and put communities at its heart.

It is very sad that the Government has not taken the opportunity of these reforms to enable planning to have a huge and positive impact on our communities, but this is a White Paper and it can be amended.  In the meantime, let’s push those developers to build all the homes they already have approval for. 

Kind regards

Marj Powner (Chair)

Putting Ecology on the Carrington Moss Map

At our AGM on Wednesday, we had two excellent and very interesting speakers.

We started the meeting with a quick poll in which participants told us whether they had visited Carrington Moss in the last week, how they had travelled, if they had seen any wildlife on the Moss and whether they had recorded it. 

Stuart then talked to us about the importance of recording all our bird and wildlife sightings, he told us a little about the records held by the GMLRC pertaining to Carrington Moss and provided some insights into the protected species found here.  There is a link to the recording site later in this blog.

James talked in a little more detail about the bird species on Carrington Moss, including the, red listed, willow tit.  He described our important habitats as the The Masai Mara of the North and shared a number of links to videos and blogs which may be interesting for our members (the links are embedded in the AGM slide pack – click on the button above).  James also mentioned Greater Manchester’s (virtual) Green Summit, which, this year, will be running from 21st to 24th September.  If you’d like more information, or to receive the links to a Welcome Pack for the GM Green Summit, please subscribe to the Green City Region mailing list.

Stuart and James responded to a number of questions from participants about a wide variety of issues.  More public (virtual) meetings and outdoor recording events (when safe to do so) will be held in the near future, but in the meantime, we’re asking our members to consider contributing to identifying the Carrington Moss Big Five

To support our aim to promote the ecology, the habitats and the wildlife on Carrington Moss, we’d like your help in selecting the species YOU think best represent Carrington Moss

Click here to complete our short survey to help us identify: the big 5 birds, the big 5 mammals, the big 5 insects and the big 5 flora

If you need a reminder about what is out there – take a look at our website at these links:

We’d like as many of you as possible to record your sightings to help confirm just how important the area is to endangered and at-risk species.  You can find out more about the GMLRC by clicking on this logo

If you are not sure which species you have seen, you can use an app such as iNaturalist to look up the species but it is better to record directly on the GMLRC site above.

Following these two outstanding presentations, we elected/re-elected our Committee, huge thanks to Jan for her support in doing this and a huge thank you to both existing and new Committee members for their continuing work on behalf of our communities.

You will find the updated Committee information on our website (click on the graphic to go to our Committee page).

We then briefly reviewed our Annual Report, click on the graphic to go directly to the report, highlighting our work on Air Quality monitoring in the area and providing a summary of progress against our key aims.

Following our finance report, we launched our very important Friends of Carrington Moss 200 Club, (click on the logo for more information).

We recognise that we may need to take legal and/or other specialist advice in the near future and this is expensive, so please do take the opportunity to join our little lottery.  It provides us with much needed funding and you with a chance to win a percentage of our takings.

We closed the meeting with an update on a number of important items, including:

  • Feedback on our Importance of Carrington Moss Survey
  • Our joint work with Carrington Parish Council to create a Balanced, Community Focused Transport Strategy for the area
  • Our next Master Plan workshop, which will focus on Air Quality
  • An update on the Greater Manchester Spatial Framework
  • An outline of the latest Government Consultations about the planning process.

More information about all these items will be included in our September newsletter.

We hope those who came along enjoyed our first online public meeting and will join our future online events.

Two ecology specialists will join our online Annual General Meeting (AGM) on 26th August (7pm)

Many of you are using Carrington Moss as part of your daily exercise routine and, whilst you are out an about, you are highly likely to see lots of birds and other wildlife in this rich, nature-filled environment.  So, we are particularly delighted to announce that we will have two special guests at our online AGM on 26th August.  We will hear firstly from Stuart Fraser, Environmental Records Officer at Greater Manchester’s Local Records Centre (GMLRC), which is part of the GM Ecology Unit.  Stuart will talk to us about recording our bird and wildlife sightings on Carrington Moss and he will tell us a little about the records held by the GMLRC pertaining to Carrington Moss. 

We’d like as many of you as possible to record your sightings to help confirm just how important the area is to endangered and at-risk species.  You can find out more about the GMLRC by clicking on the logo.

James Walsh, aka The Mancunian Birder, will then share some information about the key bird species on Carrington Moss. 

James is an ecologist, a birding expert and the author of “Greater Manchester Birding City Region”, which is available as a free e-book, with colour photos, via Borrowbox (see below).  The Greater Manchester Birding City Region Project (GMBCR) have selected a specific bird species to represent each of the 10 boroughs, with the Northern Lapwing being Trafford’s emblem.   Take a look at the GMBCR Project “Perfect 10” film, including the Northern Lapwing in Trafford – click on the picture to the right

Like Stuart and James, our group aims to connect people with nature and we are really looking forward to hearing their presentations on 26th August.

Click on the picture to the left to go directly to the Borrowbox webpage to borrow this fantastic book. The photographs are wonderful and James mentions how important the Mosses in the Region are. There are also lots of interesting links to other resources at the end of the book.

For information, Borrowbox makes available a wide range of eBooks and eAudiiobooks.  If you don’t have one already, you will need to create an account with Borrowbox either on the Borrowbox website or by downloading the app to your mobile device. You will need your borrower number and PIN to create an account. Click here for more information about Trafford’s online library services.

We will also use our AGM to elect/re-elect our Committee for a further year and to update you on our activities.  If you are interested in being nominated for a role on the Committee please let us know by 31st July by clicking on the button below and completing the contact form. 

For information, Committee members are typically attending between 3 and 5 Carrington Moss related meetings a week (sometimes more), we also spend a lot of time reading and researching and represent the Friends Committee, speaking at public meetings and other events.  New Committee members need to be able to fulfil these activities.  The Friends of Carrington Moss is not politically affiliated and, therefore, it would not be appropriate for elected members of political parties, or those seeking to be elected, to be nominated for positions on the Committee.

If you’d like to join us at our AGM, please click on the link below and complete the contact form, so we can send you the details for the online meeting.  Many people have used various types of virtual meeting over the past few months but if you feel you need help to get connected for our AGM, don’t hesitate to tell us when you click below.

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