There are alternatives to the planned GM Clean Air Zone!

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A new facebook page has attracted over 35,000 members in less than a month, over 10,000 people
joined in the last week alone, and the site generated over 1,000 new posts on just one day.

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So, in facing the fall out from the extensive opposition to the introduction of the GM Clean Air Charge, GM’s Mayor Andy Burnham and the Region’s Air Quality Lead, Andrew Western (also Leader of Trafford Council) issued a statement yesterday. Does it help?  In a word – NO!

The Government requires GM to meet the legal limits for Air Pollution.  The introduction of the scheme to achieve that aim is for Local Authorities and the Mayor of GM to determine.

Yet, only one solution has been proposed

– the GM Clean Air Zone, which will see a number of users charged to use local roads, a Clean Air Zone with a number of flaws!

So, what about the alternatives???

What GM should be implementing is a GM Transport Strategy that incorporates the introduction of genuinely sustainable passenger and freight transport options that will actually reduce the number of vehicles using our roads.

That means affordable, reliable and frequent public transport that covers all corners of the GM landscape, alternatives to the ever-increasing numbers of HGVs on our local roads and prioritising active travel users.

Yet, having led the development of the Greater Manchester Spatial Framework since 2017, Mayor Burnham has not insisted on sustainable transport being at the core of the proposals. 

Look at New Carrington as an example.  The plan is to build 5,000 homes, 350,000 m² employment space (all industrial and warehousing) and to construct 4 major new roads, all on, across and/or around a peat moss, wetland, woodland and grade 2 agricultural land. 

And to support all this development, what sustainable passenger and freight transport options are being proposed – NONE/ZERO/NADA!

Yep, you got it!  NONE/ZERO/NADA!

No passenger or freight trains, despite former railway lines running right through the site.

No passenger or freight water transport, despite the location being right next to the Manchester Ship Canal.

No additional bus services (we’ve checked via an FOI request), despite the recognition in the 2006 UDP and the 2012 Core Strategy that improving public transport is essential to the regeneration of the area (and since those plans were published, our bus services have actually reduced)!

Do the decision-makers understand the problems?

It doesn’t seem so! 

The commentary on that new facebook page identifies the key concerns of residents and businesses. 

Many small businesses, already impacted by the pandemic, say they will not survive, or will have to make staffing cuts, causing real hardship to local families.

And, even if businesses can survive the introduction of these charges, they will be passed on to the consumer, at a time when it is recognised that the most vulnerable in our society are already suffering from increased prices of food, energy and other essential goods and services.

Businesses are also reporting that the financial support scheme is not fit for purpose but, even if it was, supply chain issues mean the vehicles are not available to buy or lease!

So, the term Clean Air Zone sounds good but will it achieve its aim of reducing nitrogen dioxide air pollution at the roadside to levels within legal limits? 

We don’t think so – NO!

Why?  Because all the vehicles paying the charge will still be emitting the pollution (and, crucially, the charge does not result in fewer vehicles being on the road)!

Neither will the charge result in transformational modal change, which should, of course, have been the primary objective of a solution to the air pollution problem (remember, other Air Pollutant Limits are being breached too).

What is the answer?

Clearly a major revision of the GM Transport Strategy is needed but in the meantime ……………………..

Get your residents around the table, Mayor Burnham.  Listen to their ideas, listen to how your plans will impact them and listen to what is important to them. 

They ARE your key stakeholders!!!

And finally, in relation to Air Pollution!

The Community Planning Alliance (an umbrella organisation for over 550 community groups all campaigning against inappropriate development) ran the first of a series of workshops last month to engage communities more actively in the air pollution/air quality debate.  If you missed it, you can see the recording at this link.

Their next session (8^th February) will focus on local measuring and monitoring of air pollution.  Click on the graphic below to register. All are welcome.

The HS2 Integrated Rail Plan (IRP) for the North and Midlands has rightfully resulted in a furious backlash from Northern politicians, of all colours, for many reasons, most of which will be the subject of countless commentary over the coming weeks.  There’ll be analyses on the relative spend between the “North” and the “South”, the broken promises, how this decision fits with the “levelling up” agenda and much, much more.

But let’s not talk about the Government’s fixation with journey times, nor about the routes that will (or will not) be delivered, or whether guidance from experts has been ignored. 

Blah, Blah, Blah

Let’s talk about how they feel, those Northern leaders, who are, justifiably, very, very angry, about this “betrayal of the North³”!

Like the brochures produced to justify unsustainable development, there is lots of blah, blah, blah in the IRP about the benefits to commuters and communities of the Government’s “woefully inadequate¹” plan.

Transport for the North (TfN) have asserted that the leaders of the North, from across the party-political divide, “have worked hard to come up with an evidence-led plan to help reverse the chasm of under investment¹”.  

Many campaigners have done that too, putting lots of effort into developing evidence-based Alternative Strategies for our areas (one example from the Friends of Carrington Moss can be found at this link), and many of us have had those inputs, that are created in our own time, with our own money, totally ignored.

Cutting out local people

But the slashed route plans are not all.  My reading of the document suggests that the Government plans to exclude the Northern leadership from decision making and programme direction.  

The report states that:

“One key lesson from other projects of this scale is the vital importance of leadership, clear accountabilities and simple client relationships. Splitting these roles in delivery risks failure. TfN is also a relatively small and young organisation with no experience of clienting a project of this scale through detailed development or delivery, and little or no ability to bear financial risk”.²

A stark stigmatisation of the capability of TfN, something residents from the vast talent pool involved in the planning ecosystem face regularly from a range of commentators who do not value contributions from citizens, whatever expertise they may have.

The document goes on to say the HS2 delivery partners will be managed by a single team, answerable to the Secretary of State, to whom Northern leaders will continue to have “direct and regular access”! ² 

A huge blow for those who feel (quite rightly) that Northern leaders should be driving the initiative in their area.  They are, though, still considered to be a sponsor, albeit with very little power and, seemingly, no influence.

Community groups feel the same

We, who don’t even have a seat at the table in local discussions, totally understand their frustration.  In our areas, we are the ones with local knowledge, we are the ones who fully comprehend the impact (both environmentally and economically) and we are the ones who will be most affected by the plans. 

Yet some politicians have repeatedly denied we are key stakeholders, have refused to engage with residents in a genuine and meaningful way, denying us the opportunity to input to plan-shaping and relegating our role to reading and reviewing copious documents, filled with jargon, misleading information and missing data. We are lucky to even get a response to our emails and our pleas to be involved are continuously ignored.

Comments from politicians of all Parties confirm how “bitterly disappointed³” they are, how “completely shortchanged³” they feel.  With academics also suggesting the revised plans leave the North with “the worst of all worlds³”, the echoes of our own protests are bellowed back at us in remonstration.  Greater Manchester’s Mayor stated “what about the people’s grandchildren and great grandchildren⁴”.  What indeed?  The Save Greater Manchester’s Green Belt group has been asking exactly that question given his plans to unnecessarily release over 2,430 hectares of green belt in the region.

Absolute Power – it isn’t just a northern problem!

So, it is clear, we within the Community Planning Alliance, comprising more than 530 community groups, all campaigning against inappropriate development, can fully empathise with the emotions of these enraged politicians.

But, will the experience of this, the opposite of localism, help THEM recognise the trauma and torment we feel every single day, exhausted by the lack of power, influence and voice citizens have within the planning ecosystem?

More importantly, will it make any difference?  

The Community Planning Alliance hopes they are listening and will continue to lobby for change!

Links:

1. Councillor Louise Gittins, Interim Chair of Transport for the North (TfN newsletter 19/11/21)
2. Integrated Rail Plan for the North and Midlands page 150
3. Guardian article 18^th November 2021 Betrayal of the North
4. BBC article 19th November 2021 HS2: New plan a betrayal of the North, say critics

Well, the answer is ……………………

GM does not know!  Neither the GMCA nor the Local Authorities themselves have calculated the impact of the change of land use and their documents seem to be focused on how carbon neutral the construction of new buildings is!

Of course, that is important, but it is not the whole story. 

Greater Manchester’s Places for Everyone (PfE) strategy sets 2038 as GM’s target for achieving carbon neutrality, and GM Mayor, Andy Burnham, says he has ambitious plans to decarbonise, including removing 1 million tonnes of carbon over the next three years through retrofitting homes and buildings, smart energy and overhauling the public transport system. 

But, whilst the PfE plan requires new development to be net zero carbon from 2028, there appears to be no information about the carbon emissions that result from the changes to land use set out in any of the documents.  This includes the change in emissions that happens because a location that was agricultural land becomes a housing estate, for example.

With this in mind, residents from across GM joined the Friends of Carrington Moss and Steady State Manchester’s Mark Burton to find out more about how to calculate the carbon emissions that will accrue from the numerous planned new developments set out in the PfE documentation.

Mark said “this is a complex area; we should have clear information from the GMCA and the Authorities themselves but this has not been provided and responses to our Freedom of Information Act requests have not been informative”.

Mark’s presentation used the New Carrington development in Trafford as a case study.  He highlighted the characteristics of the site, the sources of data that can be used to support these assessments, and the limitations of the high level estimate he had undertaken.  For this particular site, he used data from the UK Soil Observatory and the British Geological Survey to understand the scale of the peat on Carrington Moss and to explore what may be under the surface of the land. 

Mark continued “the figures in the P4E documents had huge gaps in the emissions data that should have been considered.  The development of strategic locations should be supporting our journey to carbon neutrality, not increasing emissions or closing the door on sequestration opportunities.”

Paul Beckman, Landscape Architect, was very concerned, “Why have the GM leadership approved this plan if they do not know how it will affect the achievement of the 2038 target?  It is clear that those making the decisions do not fully understand the carbon sources and the lost opportunities for sequestration in these plans”

Attendee Lorraine Eagling from Trafford said, “Carbon emissions have a huge impact on our health and Mark’s presentation was really interesting, I’ll be requesting more data from Trafford about the carbon emissions set out in the Carrington Relief Road options report, which do not make any sense”

Evelyn Frearson from Woodford Neighbourhood Forum said “Mark’s presentation has highlighted the wide range of calculations that need to be made in order to assess the total impact on carbon emissions when changes in land use are proposed”.

Mark confirmed that he has created a toolkit that can be used by others to create high level estimates of the carbon implications of new development.  This will be an invaluable tool for community groups such as ours. You can find links to the toolkit here.

For more information, Mark can be contacted here.

Steady State Manchester’s work can be found here.

You can watch a recording of the meeting here.

And enjoy one of the songs we’ve written to celebrate Carrington Moss

Every decision being made by those who purport to act on our behalf MUST have the climate emergency at heart to ensure we can counter the catastrophic effects that are becoming so frequently reported (wildfires, floods, biodiversity loss – to name but three).

Yet, it is clear from the decisions being taken across GM, and here in Trafford, that the impact of climate change on future generations is NOT the priority and it seems that unnecessary accelerated economic growth takes precedence over the health and wellbeing of existing residents. 

Why unnecessary? Well do remember, GM Authorities state (in the Places for Everyone plan) that they have existing land supply for 170,000 dwellings BEFORE releasing green belt. That is sufficient homes for 400,000 people, against a predicted population increase of 158,200! And these figures do not include an estimate of potential windfall sites (schemes that are currently not known about, but historical trends suggest will come forward). They do not include estimates of permitted development schemes or what may happen to the massive over-supply of office space across the region (over 3.1million m² available against demand for 1.9million m²).

The climate crisis will not be solved if those taking decisions do not prioritise the nature and climate emergency!  Like COP26 participants, our local politicians are making long-lasting choices that will affect our day-to-day lives, where we live and the biodiversity we rely on.  The decline of nature affects us all and threatens the survival of future generations.

So, why have they decided to release green belt sites that are essential for combatting climate change? Land that alleviates air pollution, that soaks up surface water flooding, that is home to red listed birds and endangered wildlife? Here at Carrington Moss, 169 hectares is now under threat because of the decisions made by our Local Authority. An area comprising GM’s best and most versatile grade 2 agricultural land (that could provide locally grown food to meet the needs of local people – sustainable, low carbon footprint, local produce), carbon sequestering woodlands and irreplaceable peat moss/wetland habitats.

These decisions have been made despite resident opposition, despite alternative options (including those put forward by ourselves and the impacted Parish Councils) and, most importantly, despite the declaration of a climate emergency, which Trafford Council made in November 2018, almost 3 years ago!

The existing ecology and biodiversity will be all but destroyed by the plans to construct 4 major new roads, and build 5,000 houses and 350,000 m² employment space on and around Carrington Moss. The so-called green corridor that remains incorporates over 80 hectares of land that is used by businesses, so is not accessible to the general public and is certainly not going to become alternative wildlife habitats. This local decision means we (and future generations) are facing more frequent and more serious surface water flooding, significant increases to air, noise and light pollution – and do get ready for an invasion of rats and other pests because their nests on the moss will be disturbed once the construction starts. 

Come along on 6th November to show your support for action today not regrets tomorrow!

Along with many other groups, we are taking part in the Global Day of Action on 6^th November 2021, a historic moment in the worldwide campaign for nature and climate justice.

As a Friends group, we have always conducted a very positive campaign, so with that in mind, we have written a number of songs to celebrate Carrington Moss.  We’re sure you will recognise all the tunes. As a starter for 10 (although we have only written 5 songs so far), we have chosen this song to support the Walk for Wildlife (click here for the words and some great photographs taken by various members of our group). Please share it with your friends and families. 

This next video (click here) shows various community members and groups singing a verse of the song, both young and old, local residents and users of the Moss, walkers, cyclists and horse riders.  Look out for the special effects and the outtakes at the end.

If you’d like to download the words to the song, they are available here.

So, please come and join us in this unique opportunity to stand with millions of other people from around the world, to focus on the impact of these decisions at a local level.  It’s YOUR chance to give nature a voice. 

By way of background, COP26 is the annual United Nations climate change conference (COP stands for Conference of the Parties).  It runs from Sunday 31 October 2021 to Friday 12 November 2021.

As has been widely reported, the science shows much more needs to be done to achieve the previously agreed aims.  World leaders need to take robust action because, if we continue as we are, temperatures will carry on rising, bringing even more catastrophic flooding, fires, extreme weather and destruction of species. 

The world needs to halve emissions over the next decade and reach net zero carbon emissions by the middle of the century.

Local politicians need to take action too.  Nature-based solutions, such as the restoration of our peat mosses, would help achieve the Region’s and the district’s carbon goals, efficiently and effectively.  Find out more here.

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

Anna Chopping:

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

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

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

1. We are asking for more consultation,

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

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

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

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

So, what about alternative options?

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

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

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

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

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

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

After all, where else in Trafford can we

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

Thank you.“

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

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

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

3. Route Options

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

5.3 Option F Risks

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

Extract from Natural England response 22^nd March 2021

What are we seeking?

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

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

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

What is so wrong with this latest report?

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

In short, our key concerns about the Appraisal are:

Our other issues with this report include:

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

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

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

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

The decision does seem to be predetermined.  

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

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

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

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

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

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

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

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

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

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

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

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

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

Do the future travel options follow Policy?

The Friends of Carrington Moss (FOCM) has previously raised issues with Trafford about the disingenuous documentation in relation to the plans for this road (which really should have another name, it is not going to relieve anyone).  Our response to the initial Options Appraisal (February 2020) detailed our concerns about the Engagement with residents, the Costings, the Air Pollution, the Strategic Aims for the road and also the Misleading Statements and Factual Errors that permeated the report (as well as other issues).  You can find our letter to Trafford’s CEO here, along with her response and our subsequent feedback.  We still have not had answers to the questions we raised.

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

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

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

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

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

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

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

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

What about the health and wellbeing of Trafford residents?

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

The World Health Organisation has announced (22nd September 2021) that it is reducing the maximum safe levels of key pollutants with PM_2.5: reduced from 10 µg/m³ to 5 µg/m³ (NB the legal limit is 20 µg/m³) and NO₂: reduced from 40 µg/m³ to 10 µg/m³ (NB the legal limit is 40 µg/m³). These levels will be phased towards the 2030 target date but this is clearly something that should be considered.

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

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

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

What about the losers?

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

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

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

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

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

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