At Trafford’s Scrutiny Committee on 12^th 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 7^th August, 2021).

In this blog, we’ll review the CRR Preferred Options Report (7^th August 2021), which was referred to within the Scrutiny Committee presentation (12^th January 2022) and in the report to Trafford’s Executive of 27^th 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 (27^th 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 18^th 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.

At Trafford’s Scrutiny Committee on 12^th 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 27^th 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, 13^th 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 8^th 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 (7^th August 2021) and the report to Trafford’s Executive (27^th 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 18^th 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 18^th 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 18^th 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 (27^th 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:

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 (28^th 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 13^th 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 13^th 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 (27^th 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.