Communities are delighted that the Conservative Party continues to pledge to retain the Green Belt, despite Sir Keir Starmer’s recent vow to concrete it over!
But …….
That pledge does not secure actual protection for our Green Belt.
Despite the National Planning Policy Framework (NPPF) paragraphs 140 and 141 suggesting that ONLY WHEN “exceptional circumstances” are “fully evidenced and justified”, together with a demonstration that “all other reasonable options” have been considered, can Green Belt boundaries be amended, frequent approvals of Green Belt developments occur (including in our region).
Clearly those “exceptional circumstances” are not a hard test to meet!
Many communities nationwide are campaigning to protect Green Belt sites which comprise irreplaceable habitats (peat moss), Grade 1, 2 or 3 agricultural land, woodlands and wetland habitats. Our politicians are unnecessarily putting them under threat of development and the current environmental protections are just not robust enough, with the requirement to make “as much use as possible of suitable brownfield sites and underutilised land” (paragraph 141) a mythical aspiration rather than an objective of the NPPF!
Just one example of those poor environmental protections is the risk to Greater Manchester’s peat mosses (many of which are allocated for significant development in the Places for Everyone Plan).
The Government is taking a very slow pathway to protect peatland soils, despite the increasing recognition of the ecosystem services peat provides. Since 2009, there has been a commitment to Safeguarding our Soils, recognising that soils play a huge role in the fight against climate change (and helping us manage its impacts). In the 2011 Defra Natural Environment White Paper, the Government recognised the natural capital asset of soils. The 25 Year Environment Plan (published in 2018) restates the aspiration to manage our soils sustainably by 2030, including improving soil health and restoring and protecting our peatlands. More recently, the England Peat Action Plan (2021) sets out the Government’s vision to reverse the decline of our peatmosses. The aim is to prevent further loss of peatland habitats, to restore more peatland landscapes and the document recognises that rewetting peatland areas and returning them to their natural state could make a significant contribution to achieving our targets for reducing carbon emissions, as well as having other benefits for water quality, nature and flood mitigation.
Yet, there is still no moratorium on builds on peat mosses and no commitment to change in the recent NPPF consultation.
There have been many interventions from Natural England (which have been summarily dismissed by the GMCA). Yet, even though there is no actual NEED to build on these precious, irreplaceable habitats and despite every district declaring a climate emergency, some of Greater Manchester’s most important natural capital assets are at risk of destruction!
What about Sir Keir Starmer’s commentary?
The Labour Party position is not a surprise to those of us based in Greater Manchester. The Save Greater Manchester’s Green Belt Group wrote to Sir Keir in January 2023, copying members of his Shadow Cabinet, GM’s Labour Mayor and Labour MPs (you can read our letter at this link). To date, we have received no acknowledgement nor a reply from any of the recipients.
Clearly engagement with communities is not a priority for them.
In fact, as a member of a recent Question Time panel (27th April), Lisa Nandy confirmed (in a discussion about housing), that the Labour Party are working with developers, investors, Councils and planning authorities. She made no mention of working with communities.
In this Times article Sir Keir says “Labour would give councils and residents more power to build on green belt land to meet local housing need”. He continues “It’s important for local areas to have the power to decide where housing is going to be”.
In fact, as mentioned above, Local Authorities are already able to make changes to, or build on, land designated as Green Belt. Conversely, residents have NO power within the planning ecosystem!
Research by CPRE highlights that only 1 in 10 homes on the Green Belt are classed as affordable (using the current NPPF definition). The same report suggests that the density of homes built on the Green Belt land has remained at just 14 dwellings per hectare. This is a quarter the density of developments outside of the Green Belt.
In Labour controlled Greater Manchester, 27,000 residents opposed Green Belt development in the first consultation for the spatial plan in 2016. What is now the somewhat disingenuously named Places for Everyone is currently being examined by Planning Inspectors and aims to release 2,430 hectares of Green Belt.
Residents still oppose it but our Labour Councils, the Labour Mayor and Labour MPs are not listening!
As mentioned above, and, as outlined in our letter to Sir Keir, there is no actual NEED to build on the Green Belt, not just here in Greater Manchester but the nationwide picture reflects a similar story.
Communities are confused by the commentary from politicians and others in relation to land use. The assertion that there is a backlog of 4.3 million homes is typical, yet the facts do not bear out misleading statements such as this. Political rhetoric repeats these fictional assertions, yet as the following infographic shows, there is not only a surplus of market homes, brownfield is not being prioritised, homes are allowed to remain empty, despite over 1.2m people on the housing waiting list and developers are allowed to hold on to land with planning permissions without building the approved developments.
Let’s look at that “rigorous site selection process”!
Given the very recognisable challenges and the extensive harms to be caused by development here (see our previous blog), how was New Carrington chosen?
Well, we would suggest the P4E Site Selection methodology was flawed. For a kick off, it ONLY looked at Green Belt sites (despite the supposed focus on brownfield preference), it did not consider ecology or biodiversity issues until Stage 3 of the process, once most of the sites had been filtered out (and, even then, it did not provide any assessment data) and it did not consider natural capital value at all (despite the Government’s recent devolution deal describing Greater Manchester as a “trailblazer” in that area – see paragraph 226).
Site Suitability
The graphic below shows how the New Carrington parcels comply with the Site Suitability Criteria and clearly demonstrates that the area is not suitable for development! In fact, Criterion 5 on the table below should be coloured red too, given the lack of available school places and poor access to health services in the area (the assessment was based on the site’s proximity to facilities, not the capacity of those facilities to support additional residents).
Criteria 4 and 7 have been assessed based on current land use. So, it is not a surprise that Criterion 4 (Health and Wellbeing) is green. The area is heavily used for walking, cycling, horse riding and other outdoor activities, including formal sports. If the development is approved, this criterion will no longer be green because people will find it unpleasant, unhealthy and unsafe to walk, cycle and horse ride next to the planned four major new roads. These roads will fracture existing public rights of way (and ecological corridors) and will hugely (and negatively) change the experience of those active travel trips (people will no longer be breathing fresh air, or listening to bird song, for example).
Criterion 7 (air quality) will significantly deteriorate as a consequence of the planned development too.
Site Selection
Turning to the site selection criteria, it is incongruous that there were no criteria which considered the P4E Strategic Objectives for improving the quality of the natural environment/green spaces (Strategic Objective 8) or for ensuring access to physical and social infrastructure (Strategic Objective 9). When compared to the first 7 Strategic Objectives, the graphic below demonstrates the total lack of weight given to these two critical Strategic Objectives (and Strategic Objective 10, Health, does not fare much better, with just one site selection criterion being applicable).
The National Planning Policy Framework (NPPF) suggests (paragraph 8) that, to achieve sustainable development, three overarching objectives need to be considered:
a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being
c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.
The site selection criteria are clearly not consistent with that NPPF requirement.
Furthermore, treating the huge area covered by the New Carrington Allocation (1,153 hectares) as one site means that the site selection criteria are considered attained even if much of the location does not meet those criteria. We set this out in the table below:
Criterion 1 – Land which has been previously developed and/or land which is well served by public transport
We know no part of New Carrington is well served by public transport and only Carrington itself has some previously developed land but despite the Allocation boundary stretching to cover Partington, Sale West and Warburton, the whole site is considered to meet this criterion.
Criterion 2 – Land that is able to take advantage of the key assets and opportunities that genuinely distinguish Greater Manchester from its competitors
In New Carrington’s case, this relates to Port Salford, which is, of course, only close to the Carrington part of New Carrington as the crow flies. There are no direct links. Despite this, Trafford consider the site to meet this criterion.
Criterion 3 – Land that can maximise existing economic opportunities which have significant capacity to deliver transformational change and / or boost the competitiveness and connectivity of Greater Manchester and genuinely deliver inclusive growth
Given that much of the employment land (74%) is brownfield, economic opportunities can be maximised at New Carrington without releasing Green Belt. Trafford suggests the Carrington Relief Road will be transformational for Partington, but this is not the case. There are few, if any, benefits for Partington, Sale West or Warburton residents (and only minimal benefits for Carrington residents). What would bring huge benefits to the Allocation area would be the reopening of the railway line – but Trafford is not even considering this.
Criterion 4 – Land within 800 metres of a main town centre boundary or 800m from the other town centres’ centroids
No part of New Carrington meets Criterion 4.
Criterion 5 – Land which would have a direct significant impact on delivering urban regeneration
As with Criterion 3, given the amount of brownfield land (74% of the employment land and 23% of the residential), urban regeneration can be achieved without releasing Green Belt. In fact, urban regeneration in Trafford, and beyond, could be impacted by releasing so much Green Belt here (as developers will focus on greenfield sites rather than bringing brownfield back into use).
Criterion 6 – Land where transport investment (by the developer) and the creation of significant new demand (through appropriate development densities), would support the delivery of long-term viable sustainable travel options and delivers significant wider community benefits.
The Viability Assessment suggests the Total Developer Contributions are only £66.7m, a paltry sum for such a huge development. This figure includes developer contributions to education and affordable housing. As we highlighted in our previous blog, the “necessary” transport interventions for New Carrington will cost a minimum of £400m, so it cannot be considered that this site meets Criterion 6. In addition, there are no sustainable freight transport options on the transport interventions list and it is hard to understand why the existing population (circa 30,000) is not considered to create sufficient demand to support the delivery of long-term viable sustainable passenger travel options. Community benefits from this allocation are minimal to non-existent!
Criterion 7 – Delivers significant local benefits by addressing a major local problem/issue.
The major local problem/issue for the New Carrington area is the number of HGVs on our roads. There is no plan to address this with sustainable freight transport. We do not consider this criterion to have been met.
The way to test our assertion that much of the site does not meet any of the criteria would be to split the Allocation into smaller areas (Carrington, Partington, Sale West and Warburton) and to consider whether each development parcel meets any of the site selection criteria. If they do not, those parcels should be withdrawn from the Plan.
Finally, in relation to site selection, Trafford chose to remove some sites that were previously Allocations within the GMSF. We cannot find any evidence in the P4E documentation which shows how and why sites were chosen for removal or to remain.
Given all the above, the Public Interest Test in relation to site selection cannot be considered to have been met. We believe this demonstrates that the site selection process is unsound and that New Carrington should be withdrawn from the Places for Everyone Plan.
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:
Housing
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
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.
Finally
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.
(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 A6144
but 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 safer
we 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:
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”.
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.
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!
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!
Counsel:
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:
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.
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.
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.
Consultation
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.!
Finance/Funding:
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 detrimentalto 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.
Sustainability
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).
Conclusion
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?
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!
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”.
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.
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!
Friends of Carrington Moss 
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