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New Carrington and the Public Interest Test!

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

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

At the very heart of considering these issues is an assessment of the benefits of a proposed development and the relative harm it would cause, looking at the advantages and disadvantages, analysing information, which should be available for both sides of the scale, and considering the long-term impact of the scheme.  The overall outcome being an understanding of whether the Public Interest Test has been met by proposals in the Plan.  

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

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

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

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

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

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

Considerations of the weightings given to the Level of Benefit and the Level of Harm in this graphic are set out in the detailed paragraphs below

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

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

As we have said before

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

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

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

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

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

Read on for more information about those pros and cons:


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

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

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

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

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

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

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

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


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

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

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

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

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

Infrastructure (Transport, Schools, Health Services)

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

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

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

P4E includes a long list of potential transport options but there is no confirmation that funding is available to deliver any of the identified schemes, including the CRR.  It should be noted that there are no options for sustainable freight transport, despite the site’s proximity to the Manchester Ship Canal and the presence of former railway lines, which could be brought back into use.

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

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

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

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

Adherence to National, Regional and Local Policies

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

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

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

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

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

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

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

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

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

Green Belt Harm

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

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

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

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

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

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

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

Loss of Peatland

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Harm to our Natural Capital Assets

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

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

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

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

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

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

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

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

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

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

Prioritising unnecessary growth, rather than the climate emergency!

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

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

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

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

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

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


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

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

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

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

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

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

This is not a reasonable or a sustainable Plan! 

Do the harms significantly outweigh the benefits of the scheme?

Yes they definitely do!

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

Trafford’s Decide, Announce, Defend approach for the CRR continues!

(They say on their website that “Once the initial design plans are completed, we will hold a public consultation“)

Rather than moving to the more appropriate Engage, Deliberate, Decide method, which would fully involve communities in the design.

We were very disappointed to discover, from another organisation, that Trafford is holding workshops to design the logo for a “project relating to people who work, live, and travel within Carrington, Partington and Sale West“, but they are not engaging with the communities who are supposed to be benefiting.

Neither the Parish Councils, nor ourselves, nor other community organisations in the area have been consulted or invited to these workshops.  In fact, we have not heard from the CRR project team since October and have had no information about progress in the plans for the Carrington Relief Road, nor the consultation that was supposed to be happening last year.

This is a very poor approach to communicating with communities.  We were not even informed that the Council’s webpage has been updated, although this is, once again, an opportunity for Trafford to be less than accurate with their information.  We note, for example, that the webpage states that the “Carrington Relief Road is one part of the Places for Everyone Plan” yet the Planning Inspectors at the P4E Hearings were told by a Trafford representative that it is not being considered as part of that Plan!

The website also states that “We continue to have conversations with the local community and others to understand their priorities”.  We have asked our partners in the Parish Councils and other local community groups.  None are aware of any communication.  So, we have asked for information about how the CRR team are engaging with the local community and will send out an update when we receive a response!

Looking at the Council’s webpage, Trafford suggests that the A6144 is heavily congested by both cars and HGVs – this is a direct consequence of the Planning Applications that have been approved by Trafford’s Planning Committee, despite the lack of sustainable passenger or freight transport options proposed for the area. 

Whilst Trafford are proposing to build new roads (4 are planned to be constructed across Carrington Moss), local residents will not see any benefits because of the huge volume of traffic that has been approved.  Air, noise and light pollution (along with carbon emissions) will also increase substantially in this area. 

Trafford has refused to provide information about increased traffic levels, despite our repeated requests, and Carrington Parish Council’s formal Freedom of Information Act request, but we have reviewed recent planning applications and have extracted some information to help us understand the numbers.

These figures will rise significantly if the Places for Everyone proposals are approved by the Planning Inspectors.

In the meantime, Trafford suggests that the Carrington Relief Road will provide:

a new convenient route to encourage HGVs to divert away from the congested A6144but with so many HGVs, almost all going to and from the Carrington Spur, drivers will continue to use the existing road (in fact some businesses have said that they need to use the A6144 through Carrington)
deliver improvements to make travelling by bus easier and saferwe do not believe constructing a new road across Carrington Moss will have any impact at all on bus travel, especially given the number of additional vehicles on local roads
provide new routes to enjoy when travelling by foot, bike and horse.there are no funding commitments for new routes for active travel users and there are currently no plans (and no funding) for crossings for the Carrington Relief Road – this will leave active travel users facing unhealthy, unsafe and unpleasant journeys that will be discouraging due to the lack of circular routes for recreation and the unrealised expectation that active travel commuters can safely use a deserted A6144.

Trafford states that there will be a “combination of travel improvements that will open opportunities to accessing local jobs and new homes. Improving access to both local businesses and new developments in the area” but there are no plans for trams or trains, no additional bus services, and no community transport to employment areas.  What their documents seem to suggest is that local commuters will be encouraged to cycle or walk!

The website continues by confirming that “new routes for walking, cycling and horse riding will be provided”, yet, as mentioned above, there is no confirmed funding for these improvements and construction on a peat moss will be complex and expensive, with developers being required to contribute to the Relief Road, affordable housing, green spaces and school places – so we are sceptical about their ability to fund active travel routes as well.

We will welcome the opportunity to review the results of the surveys and assessments that are being carried out.  Trafford states that they “look forward to sharing more information on how the moss will be cared for in 2023”, yet the moss will be all but destroyed by the volume of development proposed. 

We worked with our partners to create an Alternative Transformation Strategy for Carrington Moss some time ago, see the short video on our you tube channel here.  It is a pity Trafford are not listening to the advice they have had from Natural England, to the information shared by specialist organisations, such as Cheshire and Lancashire Wildlife Trusts, and to the feedback from their local communities.

Trafford state that “Once the initial design plans are completed, we will hold a public consultation”.  This means that they will have spent public money on developing a design using consultants who have not spoken to anyone who lives in the local communities!

Given their plans for extensive development in the area, Trafford should have consulted with residents about the implementation of sustainable passenger and freight transport options, before deciding on a new road (across a peat moss, grade 2 agricultural land, woodland and wetland habitats).

Trafford is progressing the least sustainable of all the options available

The website suggests that our feedback will be “considered and where possible the design will be reviewed and updated where appropriate” but the Council has not conscientiously considered our previous inputs (see our blog about our struggle to secure genuine consultation).  

Finally, Trafford has included a documents library on the webpage.  Do take a look at our previous blogs which analyse those reports in detail.  They are factually incorrect, misleading and biased as we set out in the following:

Trafford ReportFOCM Blog
Scrutiny Committee Report, September 2022
(not on Trafford’s list)  
Has the CRR been fully scrutinised?
Executive report, July 2022  Another biased and misleading report
Scrutiny Committee, January 2022
(not on Trafford’s list)
A biased and misleading Option Appraisal
Our struggle to secure genuine consultation
How many vehicles can we expect on local roads?
Is the CRR the only show in town?
Is it necessary to build on green belt?
What was promised in previous local plans?  
Executive report, September 2021  What does this report mean for residents?
Preferred Option Report, August 2021  Presenting our petition to Full Council
Also see blog above.
Carrington Relief Road Options Report, December 2020  This report specifically related to proposed consultation about the CRR, with the report clearly demonstrating that Trafford are not aware of the meaning of consultation (see graphic below)!
 This did not happen!!!The report suggests that “Once feedback has been collated and categorised, the project team will then host online feedback sessions which tackle individual areas of interest or concern such as traffic congestion, environmental impact, drainage and flooding, and so on”.  
Preliminary Options Appraisal Report, October 2020

Outline Business Case, December 2019  
Discussed on the Carrington Link Road page of our website Much of the information in these early reports was totally inaccurate (see our letter to Trafford’s CEO) and there was no consideration of the more sustainable alternatives set out in our graphic above.  
An engagement presentation on two shortlisted options and transcript  See our comments above and the blog about Our struggle to secure genuine consultation

Sadly, as the Decide, Announce, Defend approach endures, community input looks set to continue to be woeful, which is not how Trafford is addressing change in other parts of the Borough!

P4E Hearings Week 1: How accurate were Trafford’s responses to the Planning Inspector?

We have been working hard over the past few weeks to prepare for the Places for Everyone (P4E) Examination in Public Hearings. 

But ……it is hard to be equipped for Trafford’s responses to the Planning Inspectors’ questions when their answers are blatant inaccuracies! 

In the first week of the Hearings, we discussed legal, procedural and general matters, including the Councils’ adherence to their Statements of Community Involvement (SCI).  Sadly, in relation to consultation, this is the only aspect the Planning Inspector can consider.  As one of our colleagues from the Save Greater Manchester’s Green Belt Group pinpointed – it is very evident that “there has been a consultation deficit”.

At the session (starting at 5:33:0), the Planning Inspector first asked Trafford about the link between the Carrington Relief Road (CRR) and the Places for Everyone Plan. 

As part of their response, Trafford’s representative stated (not once, but twice) that the CRR has been subject to consultation outside of Places for Everyone, including in relation to the Preferred Option. 

As you will know, this is factually incorrect.  There has, as yet, been NO consultation about the CRR.  One only needs to look at Trafford’s consultation portal, and our previous blogs, to confirm that. 

Given the importance of these Hearings, it is both shocking and disturbing that Trafford does not expect to be completely accurate in their responses, but there is more!

The Planning Inspector followed up with a question about workshops.  The Trafford representative suggested that Covid was the reason for the lack of workshops during the P4E stage of the Plan development.

Some of you will remember that we ran some online workshops during the Covid period, including one on Air Quality, which Trafford attended. 

So, it is inappropriate to assign blame to the pandemic for the lack of workshops since 2020.

Their response in relation to earlier phases of the spatial framework was even more objectionable……..  Trafford’s representative stated that workshops WERE held. 

Now, remember, this was a discussion about Trafford’s compliance with its Statement of Community Involvement and the question about workshops related to events with the community. 

It is clear, Trafford DID run a number of workshops in earlier phases of the Plan.  Trafford, landowners, developers and local businesses have mentioned them, including in responses to Planning Inspectors’ written questions.

Trafford call these organisations “major stakeholders” in their New Carrington Masterplan (document 10.09.06 within Places for Everyone).  Yet residents, and their potential inputs were totally ignored, despite our requests and what is set out in their SCI.

We did confirm back to the Planning Inspector that community representatives were not invited to any workshops, but the point was avoided by the GMCA’s Kings Counsel. 

We were not the only community challenging the Districts’ SCIs and associated issues.  The accessibility of the documents in the P4E Plan was raised by more than one group.  The 430-page Integrated Assessment, which included pages that are illegible, even when printed on A3 paper, is one such document!


The GMCA’s representation was led by Christopher Katkowski Kings Counsel (KC), a leading planning lawyer and one of the four KCs present at the Hearings this week. 

Residents, of course, had no Counsel as it is beyond our funding abilities.

For more information:

You can watch the first set of Hearings at the links below:

1st November 2022,   2nd November 2022,   3rd November 2022,   4th November 2022

More details are available at this link  

The Manchester Evening News has featured Carrington Moss in their recent article about Places for Everyone, which highlighted that the Plan will result in the equivalent of 2 new boroughs in Greater Manchester within the next 16 years.

Consultation about the CRR – has it been fully Scrutinised?

The Carrington Relief Road, which IS going to impact irreplaceable habitats and the lives of residents in Carrington, Partington and Sale West, is being pushed ahead at speed.

Don’t be fooled by the spin as Trafford promote their plans for this road.  It is not going to bring benefits to any resident any time soon.  In fact, quite the opposite – read on. 

We would encourage you all to watch the recording of Trafford’s Scrutiny Committee on 21st September (the CRR item starts at 30:04 and only lasts for around 20 minutes).  You will find the papers here (go to page 47 of the pack).

It is interesting that paragraph 4.2 of the report states that, due to its regional significance, community and stakeholders should be as fully involved in the scheme as possible.

If that is the case, why didn’t residents have the opportunity to give our views on which of the options from the Core Strategy 2012 would bring the most benefits?

Given that Trafford totally missed out that first step in the process – why wasn’t there a consultation that gave residents the opportunity to provide their views on the preferred route option? 

At the Scrutiny Committee meeting Councillor Williams confirmed that the response rate for that previous exercise was poor and that the recent meeting between Ward Councillors and the project team was focused on how participation can be increased. 

Councillor Williams expressed his concern that there are a lot of responses from outside the Bucklow St Martins Ward. 

As there has been NO consultation to date, we assume his comments relate to that March 2021 initiative and can confirm that our inputs certainly did include feedback from Bucklow St Martins residents. 

In addition, whilst FOCM membership covers all the above Parishes and Sale West (and includes many residents who live in the Bucklow St Martins Ward), when we met with the project team we invited those Parish Councils to join us, along with Positive Partington and Peak and Northern Footpaths Society.  This has always been our approach and, when we responded to the previous exercise, it was collaborative feedback from all those groups. 

So, has Councillor Williams been misinformed?

In addition, it must be emphasised that Sale West residents will be significantly and negatively impacted by this road.  Bucklow St Martins extends into the Sale West area, so when, as mentioned at the meeting, Councillor Williams goes “door to door” it would be useful for those who live in Sale West to also have a voice.

Let’s look at the reality of previous consultations related to this area!

Trafford does not have an impressive record of engaging with our communities and when residents do provide their views about the CRR or New Carrington, they are studiously ignored (see our previous blog for more information).  This 2 minute video shows how differently local residents are treated when compared to others in Trafford.

The Scrutiny Committee heard, following a question from Councillor Butt, that the overall parameters of the scheme have already been decided, so any future consultation must be clear about what views are actually being sought.

Whilst it is heartening that the Council wish to undertake some specific consultation about the selected route (Councillor Williams suggested this would include giving our views about the vegetation at the side of the road), it seems resident influence will be limited to a few design features.

Scrutiny Committee members raised a number of concerns about the contents of the report.  Councillor Axford, for example, asked how, given residents needed to understand the environmental impact (paragraph 7.2), Trafford would balance those messages (relating to increased pollution and carbon emissions) with the promotion of the road.

Councillor Coggins highlighted that only the positive aspects of the implications (page 2 of the report, page 48 of the pack) have been revealed (just like a sales brochure).  So, no mention of the increased carbon emissions caused by the road, and also no mention of how vulnerable groups will be targeted in the consultation, no mention of how the road will support sustainable development (or not), no mention of the risks to local residents of increased surface water flooding and no mention of the increased air, noise and light pollution that will impact the health and wellbeing of local residents and threatened bird/wildlife species!

Paragraph 1.4 states that the road will bring significant benefits to Carrington and Partington communities.  We disagree!  Trafford’s own documents state that only 60% of the traffic (including HGVs) will use the new road.  Traffic volumes will increase significantly due to Trafford’s plans to approve developments for 5,000 homes and 350,000 m2 warehouses in the area.  This will leave Carrington surrounded by roads (an island in a sea of air, noise and light pollution and, of course, the issues caused by excessive vibrations from HGVs).  We do not perceive any benefits for Partington from this road, especially as a large number of new homes have already been approved, which will result in more traffic on existing routes, a situation that could be exacerbated further by the decision on the increased toll charges for Warburton Bridge, which comes before the Planning Inspector in November.

There is, as always, no mention in the report of the negative impact on Sale West residents of increased air, noise and light pollution and increased risk of significant levels of surface water flooding. 

Given their declaration of a climate emergency, Trafford should be aiming to reduce vehicles on existing roads. There is no justification for building more roads, which will encourage even more traffic.

The Council is keen to emphasise that Partington residents want to see the new road being implemented (paragraph 11.3) but we would encourage all residents in all communities to do their research – there is already a lot of evidence that new roads create new traffic, for example.  The more sustainable solutions we mention above would bring more benefits to residents.  Contact us if you’d like to discuss this further.

Councillor Thompson highlighted that key stakeholder events (including any with Friends of Carrington Moss) were missing from the future timetable (Appendix 2 -Outline Programme for Future Engagement and Consultation Events) and was advised that this is an oversight due to the meetings not yet being scheduled.

Clearly, there is more information to come

And, finally,

whilst the MEN reported on the meeting, there has been no request to FOCM for comment.

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

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

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


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

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

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

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

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

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


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

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

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

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

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

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

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

Are our Councillors happy about the approach to financing? 

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

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

Public Transport:

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

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

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

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

So, another recurring theme of inaccuracies and deceit! 

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

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

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

Compulsory Purchase Orders (CPO)

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

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

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

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

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

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

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


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

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

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

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

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

Health and Wellbeing

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

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

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

Programme Risks:

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

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

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

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

Trafford’s 2012 Core Strategy (CS):

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


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

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

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

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

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

Is Green Belt release in GM premature?  The latest Census data suggests it is!

Government data tells us that since 2013/14 England has lost over 25,110 hectares of green belt – equivalent to over 35,000 football pitches of highly valued land, with various attributes and community benefits, that are now forever lost to future generations.

Here in Greater Manchester, the Places for Everyone (P4E) Spatial Plan Examination in Public has begun, and GM’s leaders are hoping the Planning Inspectors will approve the unnecessary release of 2,430 hectares of our precious green belt (equivalent to over 3,400 football pitches).

We have already argued in our responses to the Plan that GM’s leadership has NOT proven the need for this unwarranted reduction in our green belt but what does the recent publication of Census data provide in the way of justification for their proposals?

Well, actually, quite the opposite.  The Census data supports our contention that the exceptional circumstances required to release green belt have not been demonstrated!

Our fellow campaigner, Matthew Broadbent, of the Save Royton Green Belt group, has looked at the Census data in some detail and his analysis reveals that, in terms of Household growth, the 2014 data set (which is used in the Government’s standard methodology for calculating housing need) has significantly over-estimated household growth in Greater Manchester.

Graphic credit: Matthew Broadbent (Save Royton’s Green Belt)

Looking at the figures themselves, it is clear that ALL Districts are impacted by the Government’s standard method (and this is before the Affordability Ratio is added to the calculation).  Trafford’s data is particularly shocking given their record on minimal reductions in green belt take in the various iterations of the Plan and Trafford has the highest Affordability Ratio in GM which is added to these erroneous numbers.

What the table below does tell us is that housing need across Greater Manchester has been significantly inflated and that there is clearly no justification to release green belt to supplement the land available in urban areas. 

The 2014 data, calculated by the Ministry of Housing, Communities and Local Government, projected significantly higher levels of household growth than has actually been the case.  The latest data available in the Census demonstrates what has been shown in previous ONS data – population projections have been noticeably reducing over the last decade.

Graphic credit: Matthew Broadbent (Save Royton’s Green Belt)

Over the coming months the Office for National Statistics will use the Census data to re-calibrate their Household Projections and hopefully this information will lead to a long-awaited change to the source data required by the Government’s standard methodology, which is clearly resulting in Local Authorities sacrificing vital green belt land that the Government suggests it attaches “great importance to” (National Planning Policy Framework, paragraph 137)!

As mentioned above, it is clear from this data that growth for Greater Manchester CAN be achieved WITHOUT releasing green belt. 

This is endorsed further in P4E itself, which reports that the Government’s standard methodology for calculating housing need creates a requirement to build 164,880 homes within the Plan area (Housing Topic Paper, page 18) and the 9 Districts are able to provide land supply that exceeds that figure (170,000 homes – Housing Topic Paper, page 20). GM’s population in the Plan area is projected to increase by 158,194 between 2021 and 2037 (paragraph 7.14).  This equates to a need for around 66,500 homes, which demonstrates that there is clearly sufficient flexibility and choice within existing urban areas to meet GM’s housing needs (and there are various brownfield land funds that can be applied for).

What should also be considered is how the number of Net Additional Dwellings over the past 10 years (ONS reports that over 73,000 net additional homes were constructed in the Plan area during that period), compares to the Census data (which shows that only 45,000 households have formed in the Plan area).  The graphic below highlights that each District in GM has built more houses than the number of households formed!

Again, the figure for Trafford is astounding, with the construction of dwellings being more than two and a half times the number of new households!  This means that it is not under-provision that is holding back household formation.  If data about vacant housing stock (empty homes) is added to the above numbers, the over-provision figures are increased even further, but let’s keep it simple. 

The Census identifies a household as a property where there is “at least one usual resident”, so do the figures above suggest that a large proportion of the dwellings being built in GM are second homes? investment properties?  More investigation is needed but these figures certainly leave our friends at the GMCA and in our Local Authorities with a number of questions to answer in relation to their plans to unnecessarily reduce our green belt (see our previous blog for more information).

Whose Plan is it anyway?

Given the Examination in Public has already begun, we hope the Planning Inspectors seriously consider our inputs and arguments, but we are aware citizens have very little influence in the Planning Ecosystem and that developers have submitted responses proposing that more green belt is released! 

A Plan that unnecessarily releases green belt, preventing future generations from accessing its recreational value, seeing its landscape views, benefiting from the best and most versatile agricultural land, the abundance of species, the carbon capture capabilities, the flood water storage areas, the woodlands, the wetlands and the irreplaceable habitats, is NOT our plan!

Friends of Carrington Moss

Carrington Moss – Climate Solution or Council Sacrifice?

I watched this short video from Trafford Council’s leader out of curiosity.  It is only 2 minutes long so do have a listen.  Concern is expressed about the climate crisis, the recognition that it will cost billions if not addressed, the acknowledgement of the extreme weather events that we are already seeing EVERY year. 

It is interesting that Councillor Western focused on issues such as flooding, air pollution and the amount of carbon in our atmosphere.  Yet, Trafford plans to decimate Carrington Moss, an area which generates a natural capital value of over £15m per annum (based on GM’s Natural Capital Account, figure 1, 2019 Natural Environment Topic Paper). 

It plans to significantly increase air pollution and the risk of flooding for local residents here, and, of course, the loss of our peat moss will result in a massive carbon release event.

The climate change page on Trafford’s website provides links to examples of collaborative work “to reduce and mitigate carbon emissions as well as adapting to a changing climate”.  One of these is labelled Nature and Biodiversity.  Click on that link and you are taken to a Lancashire Wildlife Trust article (December 2020) announcing that “Nature is on the road to recovery in Greater Manchester”.

Councillor Western is quoted in the article stating that “The funding will help deliver some of the essential work being undertaken to safeguard wildlife habitats, develop natural flood management projects and peatland carbon stores, and teach families and young children about the natural world on our doorsteps”.

But he doesn’t mean here on Carrington Moss, where he is planning to unnecessarily release 169 hectares of green belt to build housing and employment space that could be located elsewhere in Trafford (or even elsewhere in GM, as residents keep being told we must consider the regional strategy, known as Places for Everyone, as a whole). 

The article states “The aim is to fund natural flood management projects and peatland restoration transforming areas into carbon stores”. 

But not here on Carrington Moss, which has 325 hectares of peat, that Trafford states is 3m deep

Despite the huge numbers of additional residents and employees who will be travelling into and out of the area, there are NO plans for any sustainable passenger or freight transport options.  Instead, Trafford plans to construct a road across the Grade 2 agricultural land, woodland, wetland and peatland habitats. 

Stockport’s leadership appears to understand the issues as they rejected their controversial bypass.  Council leader Elise Wilson said a new road that would “destroy wildlife and natural habitats” was an “old world solution“.

But Trafford is sticking with their “old world solution”! 

Residents have ideas for alternatives to constructing a road across the Moss, but Trafford is not interested in even hearing about them, never mind exploring their potential!

Despite their declaration of a climate emergency in November 2018, and the creation of a Carbon Neutral Action Plan in December 2020 (a plan that does not even mention that Trafford has, not one, but two, peat mosses), Trafford appears confused about what sustainability actually means.  Maybe they should take a look at our previous blog!

We have also recently produced our latest Carrington Lake video which, once again, shows just how much water is captured and retained by Carrington Moss.  It’s less than 5 minutes long and highlights the level of hypocrisy we are facing from both GM and Trafford’s leadership.  We’d love to hear just how many attenuation ponds you think we’ll need to capture all that water that is currently being contained by our irreplaceable mossland.

Nationwide, it is acknowledged that the UK is one of the most nature depleted countries in the world.  The Government has an aim to leave the environment in a better state than they found it, setting targets to halt the decline in species, to improve air and water quality and increase our woodland cover.  There is a recognition that we need to use our natural resources more sustainably and that it is critical to build up resilience against the impacts of a changing climate, to enhance our natural capital to support our food security, health and wellbeing, and economic prosperity.

Yet, here in Trafford, there is a plan to further diminish the already threatened populations of red listed birds and endangered wildlife that breed and feed on Carrington Moss and to sacrifice our best and most versatile agricultural land, that future generations may need to provide locally sourced produce to survive! 

Trafford will be spending public money decimating existing nature-rich wetland habitats and will then spend more public money creating new, man-made, habitats, which will take decades to generate the same level of ecosystem benefits.

It is now clear that the biodiversity and climate emergencies are comprehensively interconnected and that there are compelling reasons why both should be considered together to create solutions that reduce the risks to all populations (both human and wildlife).

Greater Manchester’s leaders declared a biodiversity emergency on 25th March, with Mayor Andy Burnham talking about the “habitats being lost, destroyed and becoming less diverse due to the impact of development, climate change, pollution and invasive species”.  Yet, he is presiding over a plan that will see huge levels of biodiversity loss across the region.

Perhaps his suggested “rallying cry” will signal a change of approach to the unnecessary loss and destruction of the region’s precious green belt!!!

Yet, while Carrington Moss is being sacrificed by GM and the local leadership, sustainability is out of the window, the biodiversity and climate emergencies are not being considered, neither is their accountability to future generations! 

Carrington Moss provides a number of ecosystem services, including walking, cycling and horse riding routes, excess water capture (huge amounts of that), Grade 2 agricultural land (capable of growing locally sourced food), woodland, wetland and peat moss habitats, is the breeding and feeding grounds for numerous red listed birds and endangered wildlife species (including the willow tit and the water vole), has historical value, and brings health and wellbeing benefits to local communities and those who visit the area.

Greater Manchester is overspending its carbon budget and Places for Everyone will make it much worse

Guest blog:
by Mark Burton (Steady State Manchester)
and Matthew Broadbent (Save Greater Manchester Green Belt)

We are delighted to link specifically to this blog that has been created by our colleagues in Greater Manchester.

Mark and Matthew have assessed:

  • the carbon budget GM’s Combined Authority commissioned from the Tyndall Centre (University of Manchester)
  • the advice given by the Tyndall Centre about the pathway to reaching net zero
  • the alarming lack of progress that has been reported this month
  • the impact and importance of the separate category of Land Use, Land Use Change and Forestry (LULUCF).

They specifically highlight that the Regional plan, known as Places for Everyone (P4E), will involve significant levels of construction on green spaces.  This means that the Region’s capacity to reduce the impact of additional emissions will decrease significantly, severely affecting GM’s aspiration to be carbon neutral by 2038!

In looking at the scale of planned development set out in P4E, much of which will result in green belt release across the Region, Mark and Matthew emphasise the loss of carbon capturing opportunities, as well as the huge level of carbon emissions generated.

Their findings suggest it is highly likely that, on housing alone, the P4E proposals will be disastrous for the Region’s ambition to be carbon neutral.  Different choices could be made to meet housing need, options that do not rely so heavily on new construction!  Here in Trafford, there are also alternatives to constructing new roads across the green belt too.

It is clear from Mark and Matthew’s research, however, that the GMCA has not fully assessed the carbon implications of the P4E Plan, and they believe that the Strategic Environment Assessment (SEA) has not been conducted to an appropriate standard, especially given the conclusions reached by the Authorities.

The lack of information provided by the GMCA about the carbon implications of their strategic plan is astounding, particularly as there were so many P4E documents (more than 150, with 14,000 pages to review), but, as we pointed out in our own response, some of those pages include evidence that is very dated and some, like the carbon emissions data, is not provided at all. 

Mark and Matthew actually found that other Authorities do provide the data required to robustly assess the carbon emissions.  Their example from the Cambridge Local Plan is enlightening.

We totally agree that one of the most shocking omissions from the SEA is the absence of GM’s key objective, the 2038 target for carbon neutrality.  It must be remembered that it is this P4E strategic plan that must secure that target!

If you are interested in finding out more about the Tyndall Centre’s view of Trafford’s carbon emissions targets, you can find an interesting summary here. You will note that the final paragraph states “We also recommend that the LULUCF sector should be managed to ensure CO2 sequestration where possible. The management of LULUCF could also include action to increase wider social and environmental benefits“. Constructing roads, housing and employment space on a peat moss, grade 2 agricultural land, wetland and woodland will not support the achievement of that recommendation!

A biased and misleading Option Appraisal

At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps. 

A member of the Scrutiny Committee requested a more balanced representation of the facts.  The Carrington Relief Road documentation does seem to be plagued by the sheer volume of misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).

This is the sixth in our series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.

This blog focuses on a review of the CRR Preferred Options Report (dated 7th August, 2021).

In this blog, we’ll review the CRR Preferred Options Report (7th August 2021), which was referred to within the Scrutiny Committee presentation (12th January 2022) and in the report to Trafford’s Executive of 27th September 2021 (Carrington & Partington Transport Infrastructure – Carrington Relief Road Update).  Unless otherwise stated, references to “the document” or “the report” in this blog refers to that CRR Preferred Options Report.

We have reviewed the document in detail and, in common with previous documents about the CRR, it is crammed full of misleading information, inaccuracies, conflicting statements, bias and other issues. 

At the Scrutiny Committee meeting, Trafford’s officer stated that the Preferred Options Report is a “very detailed analysis of the options and the benefits and disbenefits”.  This is not correct.  Some elements of the report are at a very high level and the benefits and disadvantages of the two options have clearly been considered with the aim of ensuring Trafford’s predetermined preference (Option F) was proposed to, and agreed by, the Executive Committee.  As an example, the assessment of route option advantages and disadvantages does not take into consideration environmental impacts (air, noise and light pollution), active travel benefits, loss of grade 2 agricultural land, loss of bird/wildlife habitats, and more!

The level of bias is clear, not just from the content of this report but also from the statements set out in previous Option Appraisal (OA) documents.  The link to the Outline Business Case (OBC) is included in the introduction to this blog.  Click on the graphic below to go to the OA from October 2020.

Scrutiny Committee members rightly highlighted a number of issues with the CRR presentation, including whether the costs of this road can be justified, particularly in terms of the inevitable requirements of climate change and whether bolder alternatives should have been considered. 

What about those Cost Implications?

The document states that, despite the pressure on the public purse, the difference in cost should be considered marginal, not impacting option selection.  We disagree, especially as many of the Option F costs are excluded from the estimate and Option A (currently estimated at 10% less than Option F), if redesigned (see below), is likely to significantly reduce the costs of the route.  The report also suggests that it is a requirement of the Core Strategy that the CRR is provided.  This is highly misleading because the road proposed in the Core Strategy was priced at £3m (a much less intrusive plan than the current proposal).

There is confusion about the current costs though!  The CRR Update report to Trafford’s Executive Committee (27th September 2021) states that the “current budget for the scheme is £29.4m”.  Previous reports have quoted higher capital costs (£34m).  We believe it is highly unlikely that, in the current market conditions, costs have come down and, in any event, this Options Appraisal (OA) suggests the cost of the preferred option would be £36m (albeit that this estimate excludes huge chunks of required expenditure).  It is also unclear whether the costs include or exclude the active travel routes, bus lanes, traffic calming, crossings (both human and wildlife), flood prevention or biodiversity net gain requirements.  In response to the public engagement exercise, we requested more information about these cost estimates.  This request has not been fulfilled.

Whilst this OA does not analyse the cost benefits of the road option, this was done in the OBC (December 2019), which stated “Overall, the scheme produces significant benefits, about £132m over the 60-year appraisal period”.  The OBC explains that the benefits are generated by travel time savings (£126m) and vehicle operating costs (£29m).  This 60-year figure equates to £2.2m per year.  As shown in the graphic above, we have estimated the Natural Capital Value of Carrington Moss, based on the GM Natural Capital Account (GMSF, Jan 2019, Natural Environment Topic Paper, figure 1).  Our calculations suggest Carrington Moss achieves a Natural Capital benefit of around £15m per year.  This certainly should have been considered as part of the decision-making process about the route!

In addition, the journey time saving for Option F is only expected to be “almost one minute”, with such savings possibly being totally eroded as a result of congestion caused by the induced traffic concerns highlighted by Transport for Greater Manchester (TfGM) – see next paragraph.  When compared to the destruction of Grade 2 (best and most versatile) agricultural land, woodland, wetland and peatland, Trafford’s declaration of the climate emergency and the emphasis on nature’s recovery, we believe the benefits of this road scheme have NOT been proven. 

One Scrutiny Committee member raised the issue about the evidence that a new road will alleviate congestion.  In fact, TfGM raised this very issue in their Transport Locality Assessment (TLA), which highlighted their concerns (paragraph 12.3.3) that, as the capacity of the Option F route is increased, it becomes more attractive for road users (ie inducing additional traffic to the route, increasing congestion in the area).  Despite this concern, the Preferred Option report quotes TfGM as suggesting that the CRR will result in lower traffic flows and better services for Partington.  This is misleading given their comments in the TLA and, as the Option F route only serves a small Eastern section of the A6144, residents in Partington are unlikely to see any changes to their journey times!

The report also suggests Option A will result in a significant increase in traffic volumes at the Isherwood Road junction.  Option F is likely to drive much greater use of this junction, as much more traffic from Flixton/Urmston will use the (supposedly) quieter A6144 between Isherwood Road and Banky Lane (another example of the CRR inducing yet more traffic onto the existing road).

No dispute about the A1 route – let’s get it started!

One common aspect of both route options is the plan to open the A1 route, end to end.  This is something we believe Trafford could have progressed with landowners already, along with the implementation of traffic calming measures through the village of Carrington.  It should be noted, however, that Trafford are NOT planning to close the existing road to HGVs and through traffic (the report states that, for Option A only 60% of the expected traffic will use the A1 route, for Option F only around 64% of the expected traffic will use the A1 route).  This means high numbers of vehicles will continue to use the existing A6144.  The commitment is only to “discourage through traffic from using this route”.  This means that residents will be surrounded by the consequential air, noise and light pollution and bus timetables will continue to be disrupted by slow traffic during rush hour. 

As there is no dispute about the A1 route, we will focus the rest of this blog on the analysis of the Eastern part of the CRR (Option A, using the existing A6144 between Banky Lane and Isherwood Road, and Option F, which constructs a new major road across Carrington Moss).

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 as it is not going to relieve anyone).  Our response to the OBC (December 2019) detailed our concerns about the lack of 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.  We have still not had answers to the questions we raised.

The Spatial Framework has NOT YET BEEN APPROVED!

So, let’s start at the beginning, with the Scheme Objectives.  As we pointed out in our previous blog, we asked why protecting the health and wellbeing of existing residents is not the number one objective.  Not only did this suggestion not make it to number one on the list of objectives, it did not even make it onto the list itself!  Trafford confirms that the design team discussed the proposals with TfGM to determine the current issues and future plans for public transport improvements in the area but there has been no response to our repeated requests for workshops with local communities to determine OUR requirements. 

The primary objective, as confirmed in the GM Transport Delivery Plan, is all about supporting growth.  Yet the spatial framework plans have not yet been approved and the Future Proofing section of the Options Appraisal covers just two proposals: dualling the route and giving access to the new Sale West developments.  Despite these plans for the overdevelopment of this area, there has been no consideration of any alternative opportunities to support future growth, such as sustainable passenger and freight transport options.  The lack of consideration for such solutions is imprudent and does not suggest Trafford is acting in the best interests of its existing and future residents, especially as the area is right next to the Manchester Ship Canal and incorporates two former railway lines which we understand are capable of restoration. 

Given Trafford’s declaration of a climate emergency, and the GM Transport Strategy aims to significantly reduce car traffic and move freight to rail and water-based transport options by 2040 (less than 20 years away), it is astounding that Trafford consider a dual carriageway is a rational or cost-effective solution!

In addition, the document makes it clear that the A1 road cannot be dualled.  It is questionable whether the Carrington Spur can be dualled (it was originally designed as a single lane motorway).  This will lead to significant congestion (and the potential for accidents) at either end of any dual carriageway.

A very biased articulation of Option A!

It is clear that Option A was described in such a way that it could not be progressed.  Back in March 2021, residents asked Trafford how their suggested improvements to the design of Option A could be fed into the process?  There was no response and our requests for workshops were also ignored.

It is noted that, whilst some of the obstacles relating to Option F have been highlighted, they have not been considered a barrier to implementation (with, for example, mitigation being mentioned in relation to the ecology/biodiversity concerns, and an extension to scope being proposed, to address the current gap in active travel provisions along Isherwood Road).  Yet, for Option A, constraints have been considered to be a total barrier to selection, without any consideration of alternatives to ameliorate the issues, despite resident feedback. 

Trafford suggests that Option A is constrained by existing residential properties.  This is not the case. It is impeded ONLY by Trafford’s lack of leadership on sustainable transport options.  Growth is set out in the Places for Everyone Spatial Plan, which covers a 16 year period, starting at the point of approval (as mentioned above, this plan is not yet approved). 

This gives Trafford and TfGM time to develop and implement sustainable passenger and freight transport solutions.  Why isn’t this the priority, rather than focusing on increasing road traffic in the area?

So, given those timescales, the GM Transport Strategy aims and Trafford’s declaration of a climate emergency, there is no requirement for Option A to secure land (via Compulsory Purchase Order or otherwise) or to demolish existing properties. 

In comparing the land needed for Option A and Option F, whilst Trafford emphasises the requirement for CPOs for their current articulation of Option A, they make no mention of the land status of Option F, which is Grade 2 (best and most versatile) agricultural land, wetland, woodland and peatland, all of which should have a measure of protection, according to planning guidance.

Trafford’s officer suggested to the Scrutiny Committee that Option F will provide much safer cycling provision.  This is not the case.  With Option F, existing walking, cycling and horse riding routes will be severely fractured, leaving residents and users unable to travel from one side of the moss to the other without crossing a major road or taking a long detour.  There is nothing in the documentation which suggests there will be crossings, for humans or wildlife.  This could lead to a significant increase in accidents and health related incidents. 

In addition, Trafford suggests that Option A would “compromise the high-quality active travel provision the scheme is required to provide, which is one of the main scheme objectives”.  This is, again, incorrect.  If Option A was chosen, high-quality active travel routes can be provided across Carrington Moss.  Public Rights of Way (PROWs), such as Carrington 1 (which runs in parallel to the existing A6144 between Banky Lane and Isherwood Road) should be upgraded to encourage modal shift.  Trafford also suggests active travel commuters would prefer Option F.  This is, once again, incorrect, as shown by the feedback to the WCHAR exercise.  Active travel commuters would prefer Option A, so they have uninterrupted routes across Carrington Moss (which, as noted in the report, is the shorter route).  This is also true for leisure users, as routes across the moss will be much more pleasant, healthier and safer (rather than walking, cycling and horse riding next to huge volumes of speeding traffic that creates significant levels of air, noise and light pollution).  With this segregated active travel approach, the redesign would mean Option A does NOT require carriage widening.

The document suggests Option F would result in the A6144 becoming a more friendly route for active travel users over its full length, on a quieter, reduced speed road.  This is also incorrect for three reasons.  Firstly the A6144 runs from Sale to Warburton, Option F covers only a very short Eastern stretch. Secondly, the document confirms that only 64% of vehicle traffic is expected to use the new route (furthermore, as mentioned above, the Option F route is likely to induce additional traffic from Flixton/Urmston to the A6144 on this stretch of the road). And, thirdly, the document states that the A6144 is expected to have a design speed of 40mph (discussed below).  All in all, a very misleading suggestion.

Those active travel routes will need to be maintained.  The document suggests that this places a greater burden on Option A but, in fact, the greater burden is on Option F, which will need to provide crossing points and connections between existing PROWs.  These do not appear to be included in the current costings.

The document states (page 6) that both options are expected to have a design speed of 30mph along the existing A1 route and 40mph elsewhere.  This suggests that the A6144 route would be a 40mph road.  We believe this would be dangerous for local residents, particularly because of the high volume of HGVs that will use both routes.  Speed limits on the A6144 should be reduced to 30mph to decrease the risk of collisions, creating less pollution and less congestion.

Know your place! Only disruption for drivers is considered to be an issue!

Whilst we recognise that any work on an existing route (Option A) would be disruptive for vehicle users, if a redesigned Option A is considered, the disruption caused by addressing statutory services and road construction issues will be significantly less than currently estimated. 

The document does NOT consider disruption for anyone other than those driving vehicles.  So, the disruption caused by Option F to users of Carrington Moss, the adults and children who play and train on the sports grounds and the people who live in Sale West, is not even mentioned in the report.  In addition, Trafford’s statement that access and egress for Option F will add minor disruption to Carrington Lane is a massive understatement given that there will be 30% more HGVs for this route option!

The document also suggests that there are minimal receptors to be affected by the noise, vibration and dust nuisance for Option F.  This is also incorrect.  The residents of Sale West will be significantly affected, as will the users of Carrington Moss, including those using the sports grounds.  In addition, there will be a huge environmental impact.  We have significant concerns about the populations of red listed birds and endangered wildlife that breed and feed on the moss.

We also recognise that the current design of Option A results in a preference for Option F from a fluvial flood risk perspective.  It should be noted, however, that if Option A were redesigned in line with the resident views set out above, this would no longer be an issue.  Our proposed Option A would also require fewer materials for construction.  With this in mind, we believe a redesigned Option A would have significantly lower costs for the public purse (and much lower ongoing maintenance costs).

Inconsistencies in the Document!

Trafford do get very confused in their document, which has a number of conflicting statements.  They suggest, for example, that, if Option A is progressed, the active travel facilities that could be provided along the A6144 Carrington Lane will be limited due to constraints but if Option F is chosen, the existing road (ie the A6144 Carrington Lane) will be upgraded to provide active travel provision.  Surely, this would not be possible, due to those constraints!  In addition, this would add to the costs. 

Furthermore, Trafford suggest that, for Option F, active travel provision would be fully segregated from the carriageway.  That is not how the images in Trafford documents show the provision (see the New Carrington Masterplan, figure 4.7 and the graphic above).  In addition, the Options Appraisal document states that due to Option A being longer, Option F would be more desirable for active travel users.  Yet, in confirming Option F is the shorter route, this suggests that active travel routes across Carrington Moss would be the most beneficial for such users, making the redesigned Option A the better solution in this category.  In fact, Option F has far less flexibility for active travel users but this is not highlighted anywhere in the report.

Trafford describes Option F as removing “the majority of the through traffic from a long section of the existing A6144”. This is misleading to the extreme.  It is a very short section of the existing A6144 (which runs from Sale to Warburton).  Whilst, indeed, 64% is the majority of the traffic, the document does not highlight that over a third of vehicles will continue to use the existing route.  In addition, the statement that Option F will reduce vehicle-to-vehicle collisions on the existing road is deceptive because there are likely to be collisions on the route across the Moss AND the existing A6144.

Still trying to understand the Carbon figures!

We have requested the detail behind Table 3 (Carbon Emissions Summary) but have not yet been provided with this input document.  Trafford assert that Option F requires 30% more construction journeys, yet the carbon emissions for Option A are higher than those for Option F.  In addition, we do not believe Option A requires the level of vegetation removal suggested by Trafford, which would significantly reduce the loss of sequestration figures (Table 4).  Furthermore, Trafford does not appear to have captured the total loss of sequestration required for Option F. 

Whilst Trafford states they have only found a “thin layer of peat in an isolated trial hole” the Government has a Strategy to restore England’s peat mosses and any drainage in the vicinity of the huge area of remaining peat on Carrington Moss (325ha in 1995, 3m in depth), could impact its ability to be restored, resulting not only in a loss of future sequestration opportunities, but also the loss of a recognised irreplaceable habitat.

We believe the peat moss at Carrington is capable of restoration and as such, should be treated as an area of high conservation priority.  To propose a road option that could result in such restoration not being possible is, once again, imprudent, especially given Trafford’s declaration of a climate emergency.

More about those Environmental Issues!

We were shocked to discover that the ecological/biodiversity risk does not affect the route option selection, with the document asserting that the ecological impact of Option F can be mitigated and offset by careful planning and early engagement of ecologists.  This is incredibly misleading, especially if the route does impact the irreplaceable habitats mentioned above. 

In any event, the first step in the Government’s Planning Guidance relating to the Natural Environment is Avoidance, with the advice stating “Can significant harm to wildlife species and habitats be avoided; for example by locating on an alternative site with less harmful impacts?”

In this case, yes it can!

Furthermore, it is astounding that Natural England’s feedback is not even mentioned, never mind the document highlighting their view that Option F would be “considerably more damaging” than Option A.  Given that they raise such major concerns about the findings of the desk top study not being fully reflected in the Option Appraisal, that there is “not an accurate representation” of the environmental constraints, that the “environmental risks have not been included“, creating an “inaccurate and unbalanced view of the constraints, we believe this should have been highlighted, not only in the report but also to Trafford’s Scrutiny Committee!

Suggesting that both Options impact the green belt but not then providing the scale of that impact is also highly misleading.  Constructing new carriageways across the green belt will result in a considerably higher level of green belt harm than upgrading the existing road.

The other environmental assessments are incomplete, inaccurate and misleading.  There is no assessment, for example, of the air, noise or light pollution impact on the residents of Sale West, nor on the users of Carrington Moss, including those who train and play on the sports grounds and, specifically, there is no assessment of the impact on the ecology, biodiversity, the birds and wildlife, all of which will be considerably affected by the construction of Option F. 

Referring to the ecological surveys, the document asserts “It is difficult to conclude which route option is more favourable until this survey work is completed”, then continues with confirmation that those surveys will be carried out early in the planning application preparation stage, after the route selection has been made.  This appears to suggest that those ecological surveys will only be carried out on Option F! 

There are other environmental issues too.  We have a problem with the way Option A and Option F are described in ecological terms, and the claim that the proposed attenuation ponds and landscaping areas along the Option F route will enhance the ecological habitats in the area, is bizarre.  Are Trafford aware of how much water will need to be captured?  If not, take a look at our video.  How large will these attenuation ponds be? 

The document confirms that Option F requires 2.5 times more water storage than Option A. Unlike parts of the area required by Option F, the existing road (Option A) is typically not regularly under significant water levels. 

The document suggests that mitigation measures could include installation of a ditch to reconnecting water to the current outfalls, further suggesting that Option F has more flexibility and would provide short-term volume storage for the existing overland flow.  Given the existing ditch system does not contain the surface water, we believe this assessment is too simplistic and that Option F poses a considerable risk of future flooding to homes in Sale West.

A quick reminder of those consultation issues

The Public Engagement feedback was considered in detail in our previous blog which mentioned that there has not yet been any formal consultation on this road and the public engagement to date does not meet Trafford’s Statement of Community Involvement nor the Gunning Principles

Furthermore, Trafford has not followed the approach set out in their own CRR Options Consultation Report (dated 18th December 2020), which stated (paragraph 3.4) that “Once feedback has been collated and categorised, the project team will then host online feedback sessions which tackle individual areas of interest or concern such as traffic congestion, environmental impact, drainage and flooding, and so on. There will then follow a period of analysis and design development work on the shortlisted options, which will seek to address issues raised. Following completion of this work a summary report will be produced setting out the recommended next steps.”

Given the information we have provided in this series of blogs, we believe strongly that there should now be a formal, genuine and robust consultation about the requirements and route of this road, which includes accurate, up-to-date, unbiased assessments of the alterative options (including information about the practical timescales for sustainable transport solutions).

In Conclusion

There are sooooooooooooooooo many other examples we could highlight about this Option Appraisal, but we think you will, by now, recognise that it is not a document that is capable of robustly supporting such an important decision, one which will have such wide ranging impacts on current and future generations of both humans and wildlife. 

As has been shown above, there are a variety of contradictions within the Option Appraisal but there are even more when you consider this document against previous reports on the CRR.  As just one small example, the OA talks about the importance of the directness of the route, suggesting this makes Option F the safer solution.  Yet, in the Public Engagement exercise, Trafford highlighted that the long linear alignment of the A1 may result in speeding and over-taking issues.  Surely this would also be the case for the Option F route across Carrington Moss!

Trafford also suggests that Option F provides greater potential for landscape treatments, creating recreational areas and more opportunities for active travel users.  It will actually reduce all three, harming the existing open, rural, landscape features, fracturing routes across the moss and reducing the ability of local people to use the area for recreational purposes (it will not be pleasant, safe or healthy to visit green space next to a heavily trafficked major road, that is creating significant levels of air, noise and light pollution).  And, all the while, having a substantial impact on bird and wildlife habitats and their populations.

This has clearly not been a genuine appraisal exercise.  Option A was deliberately articulated as an impractical route, when this is not the case.  We believe there are less expensive, less environmentally intrusive options that can be considered by Trafford.   At the very least, resident requests to discuss a revised design should have been accommodated prior to the decision to choose Option F being made.

In addition, the document states that Option A has been “ruled out” based on meeting the requirements of the scheme objectives and in terms of feasible deliverability.  Yet, the assessment of the two options against those scheme objectives is fundamentally flawed, fails to acknowledge the induced traffic concerns raised by TfGM, incorrectly assesses the active travel benefits and contains a number of misleading statements such as the one suggesting that “Option F provides relief to the entire A6144 route for a greater distance”.  This is incorrect, Option F provides “relief” to a very short stretch of the A6144 (with the document confirming that Option F is the shorter route). 

In summary, whilst construction of a brand new road will add capacity in the short term, there has long been evidence that such improvements are quickly eroded by induced traffic.  Trafford should be introducing a scheme which is deliverable without impacting the health and wellbeing of existing or future local residents or further harming the populations of red listed birds and endangered wildlife in the area.  Their scheme should be futureproofed via sustainable passenger and freight transport options, NOT by encouraging more and more vehicles onto local roads.

What are our asks?

We set out our key asks in our previous blog.  Without the information we request, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal. 

For more information about our previous analysis relating to the Carrington Relief Road, please check out the Carrington Link Road page on our website.

Our Struggle to Secure Robust, Genuine Consultation

At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps. 

A member of the Scrutiny Committee requested a more balanced representation of the facts.  The Carrington Relief Road documentation does seem to be plagued by the sheer volume of misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).

This is the fifth in our series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.

This blog focuses on Trafford’s Statement of Community Involvement and resident perception of the “consultation” process.

One of the most interesting parts of the presentation to the Scrutiny Committee was the discussion about public engagement, which many members of the Committee highlighted as a concern. 

One of the aims of the Friends of Carrington Moss is to increase the level of community involvement in decisions related to the future of Carrington Moss, including appropriate levels of timely and genuine community engagement on all planned developments.

Sadly, we have been totally unsuccessful in achieving this goal.  In fact, we’d go further and say that, despite all our efforts, we have not made any difference at all to Trafford’s approach, which is summarised below (this is a recommendation in the Carrington Relief Road (CRR) Update report to Trafford’s Executive on 27th September 2021)

“authorise community engagement and consultations where the Corporate Director deems it necessary or advantageous

Necessary or advantageous to whom?  Trafford has a Statement of Community Involvement (SCI).  Shouldn’t the community engagement and consultations be consistent with that document and with the Gunning Principles (see below), against which any legal challenge regarding the consultation will be measured?

The words of Councillor Aidan Williams (Extraordinary Council meeting, Warburton Bridge Toll decision, 13th January 2022), resonate strongly.  Councillor Williams talked about the “huge amount of effort that has been invested by local people, over a vast period of time, into trying to get MSCC to understand the perspective of local residents regarding the toll bridge.  Unfortunately, those efforts have not been rewarded”.

We, and other local groups, have tried to help Trafford to understand the perspective of residents about the New Carrington development, the CRR and the importance of Carrington Moss, without success!

What does the SCI say?

The opening paragraph of Trafford’s current SCI document states that “The planning system in Trafford should be as transparent, accountable and socially inclusive as possible. There should be as many opportunities for successful and meaningful public participation as there can be. Trafford Council wants to have even more effective community involvement, providing opportunities for active participation and discussions with the community as early in the plan-making and planning application processes as possible.”

Well, there is a lot of work to do before Trafford meets this goal.  We have lots of examples of non-compliance around the whole of the New Carrington development but sticking to the topic of the CRR, let’s look at what we have experienced.

On 8th March 2021, the Friends of Carrington Moss, representatives from the Parish Councils and a representative from Peak and Northern Footpaths society met with two members of the CRR Project Team, having sent a list of questions in advance of the meeting.  None of our questions could be answered but the Project Team did manage to clarify some aspects of the scope of their particular phase of the work.

As part of our feedback, following this “engagement” session, we requested the following:

  • A specific workshop on traffic modelling covering the anticipated traffic levels (including HGVs) from both residential and employment sites, including current volumes and all planned and expected growth
  • An active travel workshop at the earliest stage of the WCHAR process
  • A workshop to discuss the design of the two routes in more detail (we mentioned that we have ideas that will make Option A workable, we said we’d also like to ensure the final report is more balanced and highlights all the environmental issues, the costs and the risks related to both options)

Despite chasing this request with the Amey Project Manager in late March 21, we had no response.  We forwarded the request to Trafford’s Director of Growth & Regulatory Services in June 21 and to the Corporate Director of Place in July 21 and we still have had no workshops and no explanation of why such sessions could not be arranged, despite the SCI confirming (paragraph 3.11) that consideration “will be given to requests for Virtual Stakeholder events”.

Among much more guidance for the consultation process, Trafford asserts (in paragraph 3.1) that it will “carry out appropriate consultation during the preparation of plans and supporting documents” and that “Comments will be invited on what these plans should contain, what supporting evidence there should be, what the key issues are and how they can be addressed. Consultation will take place at early stages of the plan-making process and continue throughout. Any comments that are submitted will be considered and taken into account during the next phase of the plan-making process

These assertions are not what has been experienced by residents in relation to the CRR.  We do not believe our comments have been conscientiously considered, nor taken into account.  As an example, we raised a specific question in our response to the Public Engagement which took place in Spring 2021:

Residents believe improvements can be made to the design of Option A.  How can these be fed into the process?” 

We did not receive any feedback and the decision has now been made by Councillors to move ahead with Option F, despite Officers being fully aware that there could be opportunities to ameliorate Option A (a solution which we believe would result in lower costs for the public purse, be less environmentally damaging and more acceptable to local residents).

This is one of many questions from our response that did not make it into the report to the Executive, discussed later in this blog.  We do understand that Officers are working to challenging deadlines, but it is totally unacceptable that our questions and requests have been ignored by both Trafford and Amey.  There are NO forums for residents to input into the plans for the area.

The SCI document states (paragraph 1.3) that “The SCI will guide all community involvement on planning matters in Trafford, ensuring that people know when, how and for what reason they will be able to take part in plan-making and planning application processes.”

Yet, there was clearly a disconnect between what was publicised and what Trafford presented to the Scrutiny Committee (which stated that “The early public engagement exercise aimed to assist in the selection of a preferred route option, calibrate scheme objectives, and to inform the subsequent development”).  Here, the presentation echoes paragraph 3.4 of the Preferred Option Report (7th August 2021) and the report to Trafford’s Executive (27th Sept 2021).

Scrutiny Committee members expressed their surprise that Trafford’s analysis of the 123 responses revealed that “just 21 respondents expressed a preference between Option A (on-line widening) and Option F (new build)”. 

To be clear, residents were specifically told that responses to the public engagement were NOT expected to include preferences about the route option.  The exercise was limited (as explained in Trafford’s leaflet, their website and their news article) to raising any questions residents had about the CRR and the Option Appraisal process. 

Neither the leaflet, which Trafford confirmed had been sent to 10,000 homes and businesses (despite the spelling error) nor the Trafford news article (produced to accompany the launch of the CRR page on their website) suggested that residents were expected to express a preference in relation to the route options. 

Had residents been aware that route option preferences were expected, there would have been a significantly greater number of responses returned!

This public engagement exercise did not provide any questions for residents to respond to, nor was the “event” published on Trafford’s Consultation Portal.  Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.3) that “As part of the consultation stage there will be the opportunity for the public to register questions and concerns that will be collated for consideration as part of the next phase of engagement.”

Note: This was NOT a “consultation” stage and there has been no “next phase of engagement”! 

The leaflet also mentioned the next phase of engagement, suggesting it would be “a series of more focused sessions which will answer your questions”.  There has been a deafening silence since this public engagement event.  No information has been forthcoming from Trafford Officers to the community, no frequently asked questions document has been produced and no responses have been received either to our questions or, as mentioned above, to our requests for workshops.

Importantly, none of the public engagement communications to residents suggested that there will be NO statutory consultation on both routes!

Table 5 of the Preferred Option Report (7th August 2021) included the following question:

Q8. When does consultation period start? More information is required about the next steps in the engagement process, particularly when the Frequently Asked Questions document will become available and when the actual consultation about this road will start? Asked 37 times”.  The response to this question was: “Q8. Not applicable to route option selection.”

This is an inappropriate response.  This question IS applicable to route option selection.  Residents expected to be formally consulted on both routes. 

In another question in the same Table, residents asked:

“Q9. How has the decision-making process been conducted to ensure it is as transparent and unbiased as possible? Has an independent review been conducted? Asked 36 times”

The response to this question was “Q9. The decision process for the preferred option is detailed in Section 1.2. of this report. The preferred option will be determined based on the agreed criteria and the reporting and conclusions will be subject to both Amey and Trafford check and sign off procedures.”

Section 1.2 of the report is a summary of the Route Options.  There is no information about the decision-making process in the report.  This is an important question and the decision-making process should have been transparent to residents and to the Scrutiny Committee.

Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.4) that “Once feedback has been collated and categorised, the project team will then host online feedback sessions which tackle individual areas of interest or concern such as traffic congestion, environmental impact, drainage and flooding, and so on.”

Residents have not been invited to any such sessions.  There has been no feedback, online or otherwise.  In fact, there is rarely any contact with Trafford that is not instigated by residents! 

Residents have had no involvement in, or input to, either the creation of the proposals/options or the development of a genuine and robust public engagement approach. 

Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 5.1) that “It is recommended that this proposal be accepted to ensure that an open and fair engagement process with the public is carried out and to give the Council the opportunity of further understanding and addressing issues of concern.”

With all the above in mind, along with the points made below, we DO NOT consider that Trafford established

an open and fair engagement process!

Neither has the Council addressed the issues of concern.  In fact, in choosing the route across Grade 2 best and most versatile land, woodland, wetland and peatmoss, rather than hear resident suggestions about how Option A could be improved, the huge levels of concern about the environmental issues (highlighted by Trafford’s Officer) have been significantly exacerbated.

Other issues remain ignored.  As mentioned in our previous blog, residents have been requesting details of traffic numbers for the area for over 2 years, including as part of this exercise, without success.

Has resident feedback enriched the project?

It is not clear that the engagement exercise itself resulted in any changes to the scheme.  There were some surprising anomalies in the resulting Option Appraisal document.  Some examples are outlined below.

The presentation (and para 3.4 of the Preferred Option Report) also stated 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” which was listed as one of the CRR Objectives in the Engagement Presentation. 

Scrutiny Committee members should ask why this change was made and who requested it!

The report to Trafford’s Executive (27th Sept 2021) stated (paragraph 5.1) that “the public engagement process has enabled Trafford Council to enhance and update the required deliverables, having taken on board the issues that have been raised by the community.”

This cannot be correct because the majority of our questions (21 out of 23) were NOT covered by the summary in the Executive report, nor have we had responses to them.  Our response can be found here.

Furthermore, Table 8 (Other Criteria Summary) of the Preferred Option Report (7th August 2021), includes the following under “Engagement Feedback”:

a preferred option has not been identified from the engagement responses”

The table concluded that “No Clear Preference” for the Option was stated.  An astonishing statement, given that residents were not asked to provide their preference, giving rise to considerable concerns about the bias throughout this Preferred Option Report!  This topic will be covered further in a future blog.

The item in the Table goes on to say “This section does however demonstrate the feedback provided has been considered in the overall preferred option selection and there is a requirement for further engagement and consultation prior to submission of the preparation of the planning application.” 

Yet another incorrect and misleading statement. 

As mentioned above, the majority of our questions do not appear to have been considered, there will be no opportunity for residents to respond to a formal consultation on Option A and a decision has been made about the route without any engagement with residents about their ideas to improve Option A. 

It should be noted that giving the option to ask questions (but not get answers) is not engagement.  Engagement is getting residents around the table, finding out what OUR key objectives are, listening to our proposed solutions and acting on them or explaining why this is not possible!

One of our questions related to the objectives of the CRR.  We asked why protecting the health and wellbeing of existing residents is not the number one objective.  Not only did this suggestion not make it to number one on the list of objectives, it did not even make it onto the list itself!

The report to the Executive continues (paragraph 4.8) with the statement “Every comment received has been evaluated in detail and recorded on a response tracker. Many individuals raised a number of points, so their responses were recorded separately in all relevant categories. The team created a list of 11 “standardised questions”, under which response themes could be allocated.”

Not so! 

We raised questions about, for example, other (more sustainable) options that could have been considered (such as the bridge across the Manchester Ship Canal), dualling capacity and the costings.  We also asked (having recognised that the existing option appraisal is quite basic) when will a more detailed review of both options take place?  None of these (and many others) have been included in the report.

In addition, Natural England’s response had some strong words for Trafford – yet these somehow didn’t find their way into either the report or the presentation to the Scrutiny Committee:

Extract from Natural England response 22nd March 2021 (along with Green Claims Code Principles)

Was Trafford only prepared to include information in the Option Appraisal and Committee Reports that supports their predetermined decision to choose the Option F route?  Again, this is an example of the bias demonstrated in that Option Appraisal report.

It should be noted that we have been raising issues about Trafford’s reporting on the CRR for the past 2 years.  Our letter to Trafford’s CEO (28th February 2020) raised numerous issues, including the lack of engagement with residents.  We particularly highlighted the statement that the project “is expected to be managed using PRINCE2 principles” (paragraph 7, Outline Business Case, Executive Summary, December 2019).  In its methodology, PRINCE2 has specific requirements relating to stakeholder engagement and, as residents should be considered to be THE KEY STAKEHOLDER, we were (and still are) keen to understand who our representative on the Programme Board is.  Once again, we have been unsuccessful in our attempts to solicit responses from Trafford in relation to our questions on this matter.

Up to date evidence?

The SCI mentions (paragraph 2.18) that the “Council’s evidence base contains up to date and regularly monitored information from surveys and evidence gathering exercises. The evidence base helps to inform the preparation of planning policies and the contents of plans. Information contained within the evidence base can also highlight the need to prepare or review a plan. Where appropriate, the Council will seek the involvement of relevant groups and organisations in the development of this evidence base so that it has the most reliable and robust information available.”

The graphic below demonstrates the feedback that has been received to date about the New Carrington allocation, which includes the CRR, and our specific petition against roads being built across Carrington Moss.  Residents have consistently disagreed with Trafford’s proposals, yet there has been NO consideration of alternatives, despite the alternative propositions put forward by residents.

And what about our petition?

Councillor Wright mentioned that “you’ve got to bring the communities that already live there on board with all those new homes and all of that change”.  

Newsflash!  Residents do not feel “on board”! 

As our Secretary said to Full Council on 13th October 2021, “Local people feel powerless, fearful, and angry that planning and development feels to be carried out DESPITE rather than FOR community members.”

Councillor Wright mentioned that the majority of the 1,632 signatories of our petition did not live in Carrington or Partington.  We believe we could have significantly increased the number of signatures further had we not been in a pandemic.  Councillor Wright continued, suggesting that the people who are going to be most affected by the road live in Carrington and Partington. 

This is incorrect! 

Whilst Carrington residents may benefit from the opening of the A1 route (if the existing road is closed to HGVs and through traffic), we do not believe Partington residents will see any benefit from the construction of this road, especially given the amount of traffic it is expected to induce into the area.

The disputed part of the CRR (the part which runs across Carrington Moss) will affect the residents of Sale West the most, especially those with children at All Saints Catholic Primary School, who will be particularly impacted by

huge increases in air and noise pollution

It is Sale West residents who will be impacted by any flooding caused by concreting over this part of the Trafford’s largest Natural Capital Asset, and they could also be impacted by large scale vermin infestation when the construction commences.  

The other populations most impacted by the Option F route are the users of Carrington Moss (including the sports professionals and children who play and train there), the horse riders, cyclists and walkers whose routes across the Moss will be fractured (which could lead to serious accidents) and, again, they will be hugely affected by air and noise pollution.  Of course, nature and wildlife will be impacted too, we will cover that in a future blog.

When presenting our petition to Full Council on 13th October 2021, we asked Trafford to consider:

  1. More consultation, we asked for a seat at the table and involvement in the design of the plans for our locality
  2. Genuine and sustainable alternative options to building of roads across Carrington Moss, and
  3. More consideration of the environmental impact of the CRR, especially given Trafford’s declaration of a climate emergency

We have not been offered any of these things, nor have we been told why they cannot be addressed.  In fact, we have had no formal response to our petition from Trafford at all.

In summary

Given all the issues mentioned above, perhaps the Scrutiny Committee could recommend that Trafford activates the option in paragraph 5.26 of the SCI, which states that “In certain circumstances the Council may decide to undertake Re-consultation”.

In the report to the Executive (27th September 2021), Carrington & Partington Transport Infrastructure – CRR Update, the paragraph labelled “Consultation” suggests that the report “sets out in detail how the public have been engaged so far.”

It should be noted that there has, as yet, been NO consultation about the CRR. 

We are delighted that members of the Scrutiny Committee requested that future consultation proposals are reviewed by Scrutiny Committee in advance of publication.  Perhaps that will signal a change in approach?

And Finally

When it comes to consultation, the courts apply a set of rules known as the ‘Gunning Principles’ to decide whether a consultation is lawful.  These Gunning Principles are considered to be fair to both Consultor and Consultee and are increasingly being used to measure the legitimacy of consultations in legal cases.  

We’ll cover compliance with the Gunning Principles in a future blog.  Legal processes are time-consuming and costly for all concerned, even the winners, so let’s hope such action is unnecessary!

What are our asks?

We set out our key asks in our previous blog.  Without the information we request, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal. 

For more information about our previous analysis relating to the Carrington Relief Road, please check out the Carrington Link Road page on our website.

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