Category Archives: Masterplan

Developer Contributions Consultation

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Also known as Trafford’s New Carrington Masterplan Funding Mechanism and Delivery Strategy Consultation (closing date 15th October)

What is it? What are the key issues? and Why is it important for residents to respond?

As you know, the proposed developments on and around Carrington Moss are huge!  5,000 houses, 350,000m2 employment space and 4 major new roads, all threatening the 335 hectare peat moss (restorable irreplaceable habitat), the productive Grade 2 agricultural land, the woodlands and the wetlands, and all impacting 15 sites of biological importance and a site of special scientific interest, to say nothing of the populations of numerous red listed birds and endangered wildlife species.

Because of the size and scale of the proposed schemes, in addition to the typical costs that would be incurred when they put forward a planning application, developers will be required to contribute to the strategic requirements (such as roads, buildings to support education and healthcare, and utilities), which Trafford describes as ‘hard’ infrastructure.  These costs would not have been required had the development been focused on previously developed (brownfield) land, rather than on former Green Belt and greenfield land in an isolated, unsustainable location.

The consultation documentation aims to set out the proportionate financial contributions for schemes that have not yet secured planning permission.

The strategy focuses on those so called ‘hard’ infrastructure items and supposedly prioritises the delivery of New Carrington “in a comprehensive and coordinated manner”.  The document confirms (figure 19) that almost half of the identified ‘hard’ infrastructure costs will be funded from developer contributions, and the other half will be funded by the public sector and other sources.

Balanced?  Sadly not!

Developer contributions are limited by government guidance.  This means that, for a scheme to be considered viable, developers must achieve a certain level of profit.  The contributions developers pay cannot be increased to the extent that the scheme would be considered unviable (ie they do not make the necessary level of profit).  So, if there are any excluded or missing costs not incorporated within the calculations (and there are a lot of them), the proportions shown in the graphic above are very misleading. 

The total contributions to be paid by the public sector should be explicitly and transparently shown, rather than covertly hidden in an appendix or not included at all!  It is vital that communities understand the full cost of destroying our essential natural resources to facilitate building in such an unsustainable location.

The biggest issue is the lack of consideration of harms to, or destruction of, natural capital assets.

Given the extensive environmental and ecological harm/destruction to be caused as a consequence of Trafford choosing this location for development, the calculations should include the costs related to the mitigation of, or compensation for, the loss of Green Belt, the cumulative harm to natural capital assets (such as, for example, the peat moss, the woodlands, and the farmland).  These have been explicitly excluded from the costs and subordinated to a future phase of the masterplanning work.

This means that the information provided in the documentation is incomplete and does not reflect the actual costs to be incurred if all the proposed developments go ahead.

Effectively, in omitting what we are calling the ‘Natural Infrastructure’ strategy from these calculations, the harms can be caused but funding may NEVER be available to provide the obligatory mitigation and compensation.

Why are we concerned?

Take a look at our response (here), but, in summary, not only have the natural infrastructure requirements been shelved to some point in the future, but our suggested amendments to the proposals have been summarily dismissed, resulting in unnecessarily inflated costs for the public purse. 

The cost of the road schemes, for example, would be significantly reduced if our alternative proposals were accepted.

The eastern part of the Carrington Relief Road (CRR), across the moss, could be replaced with upgrades to existing active travel routes and improvements to existing roads (A6144 and Sinderland Lane).  This would encourage modal change to walking, cycling and wheeling (it will be far more pleasant, safe and healthy to use active travel modes in a countryside setting, rather than next to a major road, with hundreds of HGVs hurtling along it every hour).  It would also discourage the huge levels of induced traffic that will use this road, travelling between motorways and significantly impacting Partington and Warburton.  The western part of the CRR, the A1 road, should be upgraded and opened to general traffic as planned to relieve the current issues in Carrington Village.  The plan for the A1 should be amended to take HGV traffic away from the homes that have been built on Isherwood Road.  This would require a very short road to run in parallel with Isherwood Road/Ackers Lane, rather than a new road all the way to the Carrington Spur.

The latest information received from the CRR team[1] shows that the current road (A6144) is much safer than an average road of the same type and that there is ZERO capacity to increase traffic on the Carrington Spur.  Trafford should, therefore, not be proposing a new road that will allow traffic to travel at much higher speeds (particularly given the hazardous materials carried by some of the HGVs), or encourage more through traffic into the area.

Because it includes the eastern part of the road, the current CRR proposal unnecessarily inflates the cost of construction and ongoing maintenance (including for the attenuation ponds needed to capture all that water[2] currently stored on the moss), and the costs of the mitigation needed to address air, noise, light, vibration, dust and water pollution, along with other environmental enhancements.  Costs will also increase for the NHS and other emergency services because of increased pollution and traffic accidents/incidents, and there is likely to be an upsurge in the requirement for mental health services due to the stresses caused to local residents because of construction, congestion, the loss of green spaces, and, possibly, future flooding!

Facilitating vehicle access onto Firsway from the new Sale West developments (1,500 homes) will significantly increase traffic and will result in that road becoming a rat run from the M60.  It will require the felling of hundreds of trees, drastically affecting the wildlife and birds and impacting the dark skies in this area.  It will also increase safety concerns on Firsway and, consequentially, the costs to the NHS/emergency services of dealing with any resulting pollution related health conditions and accidents/incidents on the road network.  Limiting access through the Firs Plantation to active travel users only, would not only reduce the costs of constructing the Sale West Link Road, it would also reduce the cost of mitigating or compensating for environmental/ecological harms and the costs to the NHS. 

For all the same reasons, we suggested that the Eastern and Southern Link Roads should not connect with each other, as this will result in huge levels of increased through traffic from the M60 and other motorways, particularly impacting Warburton.  The proposed approach will also cause extensive damage to the very deep peat that will need to be compensated for.  As with the other schemes, it will also significantly increase pollution and will impact the dark skies in this area, with consequential costs for the NHS and other agencies. 

All the current proposals for these roads result in the need for higher contributions from the public purse, whilst our alternative options reduce the cost of constructing, the cost of mitigation/compensation for environmental/ ecological harms and the consequential costs to the healthcare sector and the emergency services.

The Healthcare costs included in the calculations seems to be limited to primary healthcare (which comprises doctors, dentists, pharmacists, and opticians), not mental health provision, not hospital provision (known as secondary healthcare) and not other emergency service provision.  All of which will significantly increase as a result of the proposed developments.  Furthermore, the Council does not recognise the impact on the need for increased social infrastructure because of the employment development (our objection to this is explained in our response).

Sustainable Development

The documentation repeatedly suggests that the ‘hard’ infrastructure is of the utmost importance to the sustainable delivery of New Carrington.  Yet, given the definition of sustainable development this is hugely misleading.

The government’s National Planning Policy Framework (known as the NPPF[3]) defines sustainable development as “meeting the needs of the present without compromising the ability of future generations to meet their own needs”. 

Given the proposed harms to, or destruction of, irreplaceable habitat, food producing cropland, woodland and wetland, it seems ‘sustainable development’ has a much narrower definition in this suite of documents.

With that definition in mind, it is clear that the New Carrington allocation cannot be ‘sustainable’, even with the proposed ‘hard’ infrastructure investment, because development here is dependent on considerable harm to, or the complete loss of, a number of essential natural capital assets that future generations will not be able to reverse. 

And, what is worse, as mentioned above, the costs of mitigating and/or compensating for those cumulative harms is not even included in the calculations set out in this consultation and no information has been provided about how such funding requirements will be addressed, or when!

We would encourage you all to respond to the consultation.  You do not have to go into the detail we have in our response, but it is important that the community voice is heard, particularly given that there will be future consultations related to the masterplan. Send your feedback to newcarrington.masterplan@trafford.gov.uk

What should you be asking for (in your own words)?

The masterplan project priorities should be reviewed to ensure that there is a comprehensive understanding of the costs of all elements of these proposals.  The Natural Infrastructure Strategy should be considered a prerequisite to finalising the contributions scheme.  It should be progressed with urgency, with its evolution including extensive engagement with communities.  The land to be used for environmental and ecological mitigation or compensation should also be identified as a matter of urgency. 

The documentation provided in this consultation should be updated and implemented when the full costs of the impact of development are known.

No environmental or ecological harms/destruction should be allowed to be caused until it is confirmed that funding for the mitigation and compensation for the loss of Green Belt and those extensive cumulative harms to the environment and ecology will become available.  We also need confirmation of where any agreed mitigation or compensation will be located – it is possible that, because of the size and scale of the developments proposed here, enhancements will be implemented elsewhere, which means our local communities suffer all the health, wellbeing and traffic consequences of these plans, and others will benefit from environmental and ecological improvements in their areas!

[1] https://www.youtube.com/watch?v=L3uG5SzmzjA

[2] https://friendsofcarringtonmoss.com/carrington-lake-2/

[3] https://assets.publishing.service.gov.uk/media/67aafe8f3b41f783cca46251/NPPF_December_2024.pdf

What is the point of Local Development Plans?

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In a recent Parliamentary statement, the Minister of State for Housing and Planning (Matthew Pennycook MP), suggested that “Planning is principally a local activity.  It is local plans that set out a vision and a framework for the future development of any given area, addressing needs and opportunities in relation to housing, the economy, community facilities and essential infrastructure – as well as a basis for conserving and enhancing the natural and historic environment, mitigating and adapting to climate change, and achieving well designed places.  Local plans are the best way for communities to shape decisions about how to deliver the housing and wider development that their areas need”.

The theory is that if a local authority doesn’t have a Local Development Plan (LDP), it can leave greenfield (land that has never been built on before) vulnerable to speculative schemes from the big developers.  The converse should, therefore, apply.  Having an LDP should increase the amount of development that is based on local need, rather than on corporate greed.

If only this were true!

An investigation by the Competition and Markets Authority (CMA) recently revealed that around “60% of all houses built in 2021 to 2022 were delivered by speculative private development”, and that “the country’s reliance on this model has seen the gap widen considerably between what the market will deliver and what communities need”.

The CMA also found evidence during the study which indicated some housebuilders may be sharing commercially sensitive information with their competitors, which could be influencing the build-out of sites and the prices of new homes.  The Community Planning Alliance responded to a consultation about this issue, stating that the suggested remedy is so insignificant (in both financial and process terms) that it will not deter similar breaches in the future (from these and other providers).

Currently local development plans are not shaped by citizens; they are manipulated by developers.  Resident input is neither welcomed, nor taken into account, as can be seen by the previous lack of effort to involve Trafford residents in either the LDP or the Places for Everyone (PfE) planning processes, nor to address the feedback they gave. 

Despite analysis confirming that over 80% of those responding to the PfE consultation in 2019 either disagreed or mostly disagreed with the New Carrington proposals, the outcome was not to remove this unnecessary, environmentally destructive allocation or reduce it to just the brownfield land.  No, Trafford continued with the developer proposals to damage or completely destroy a 335 hectare irreplaceable habitat (a restorable deep peat moss), productive Grade 2 agricultural land, woodland and wetland habitats, impacting 15 sites of biological importance and a site of special scientific interest, along with populations of red listed birds and endangered wildlife.

In their letter to the planning inspectors, Natural England confirmed that “the combination of the location and the extent of development proposed for this allocation mean the proposed development could not be accommodated without at least causing the deterioration of this deep peat irreplaceable habitat at the site, if not its loss”. 

These damaging proposals were only adopted with PfE in 2024, yet already its policies are being ignored, and the principles upon which the PfE consultation was based, are not being upheld.

The PfE planning inspectors introduced specific policy criteria for the New Carrington Allocation (now known as JPA30 in the adopted PfE Plan). 

Policy criterion 1 (page 447), for example, states that development of this site will be required to be “in accordance with a masterplan that has been developed in consultation with the local community and approved by the local planning authority”.  The criterion continues “Central to the masterplan shall be the consideration of opportunities to restore habitats, strengthen ecological networks, and manage the carbon and hydrological implications of development, having regard to the presence of peat on parts of the site”.

Policy criterion 24 (page 450), requires that developments “Undertake hydrological and ground investigations as necessary to inform the comprehensive masterplan and use of suitable construction techniques to ensure any loss or deterioration of irreplaceable habitat, and adverse impacts on the hydrology of undeveloped areas, is minimised.  Where loss or deterioration is unavoidable, a suitable compensation strategy should be identified and delivered, including the potential restoration of lowland raised bog and complementary habitats elsewhere within the site”.

It seems that the word ‘requires’ in a planning context should be interpreted as ‘required if the developers or the Council want it to be required’!

When taking the PfE plan through the modifications process, the planning inspectors were very deliberate in their choice of wording, adapting policy criteria as they felt necessary.  Where policy criteria are to be subject to ‘get out clauses’ such as ‘where possible’ or ‘where appropriate’ or even where ‘it is not practicable or financially viable’ they included these terms within the criteria.  In fact, several of the JPA30 policy criteria are subject to these limitations.

Criterion 1 has no such restrictions.  Yet, despite the masterplan NOT being developed, AND a ‘suitable compensation strategy’ NOT being in place Trafford has approved a planning application (115160) on 19.9 hectares of very deep peat!

The approval of this planning application has set a number of dangerous precedents, with the interpretation of policy criteria now subject to the whims of specific schemes.  Dismissing the “be required to” means that other criteria can also be disregarded or interpreted in a way that is contrary to general perceptions, in current and future planning applications.

Furthermore, the consultation for PfE was based on the premise that it would “avoid 10 districts proposing further amendments to the Green Belt in Local Plans” and that PfE would be “the only opportunity to make changes” to the Green Belt (see PfE document 07.01.25 Green Belt Topic Paper and Case for Exceptional Circumstances to amend the Green Belt Boundary).  Despite this, the planning inspectorate has since approved development on Trafford’s retained Green Belt and Trafford consider that incursions into retained Green Belt on Carrington Moss for temporary road building “is an appropriate form of development in the Green Belt”. 

Thus, not only are the policies within the PfE plan ineffective, but the basis on which the consultation was undertaken was flawed, as the GMCA and the participating districts are not in a position meet their stated commitment.  This means that the expenditure incurred on examining the policies is also wasted.

One could ask what was the point of spending huge amounts of public money (multiple millions of pounds), over a 10 year period, to agree a spatial plan with careful policy wording that can just be ignored (unless that abhorrent waste of public funds was simply to enable developers to access 2,400 ha of Green Belt land across Greater Manchester, when there was sufficient brownfield to more than meet housing and employment requirements)!  

Finally, unlike developers, communities cannot appeal a planning decision, even when NPPF and/or LDP policies have not been complied with.  This is a gross inequity within the planning system.  It means that citizens ONLY have the option to request a judicial review (JR).  Not only is this an avenue that the government wishes to curtail, it also requires the communities themselves to fund the action (they cannot use public funds, like a local authority, nor can they use a corporation’s funds, which developers can take advantage of).  Given that communities must request donations from the personal pockets of citizens, there is no such thing as a ‘frivolous’ JR from a community perspective (despite this government’s rhetoric suggesting otherwise)!

All in all, if the policies in the NPPF and an LDP can be cherry-picked to meet the needs of Councils and corporations, they are not providing good value for public money, nor are the associated decisions made in the public interest.  Sadly, what we are seeing demonstrated here is a gross betrayal of current and future generations!

If you’d like more detail, read on!

Quick background for those who are unaware

A Local Development Plan (LDP) comprises all the documents that guide development and land use within a specific local authority area, providing a clear set of planning policies that should determine where and when development can and cannot happen to ensure transparency and consistency.  Once adopted, these documents become statutory, they are supposed to be legally binding and must be taken into account when making planning decisions.

When planning applications are submitted, they are assessed against the policies in the LDP and also against the policies set out in the government’s National Planning Policy Framework (NPPF).

If an LDP is out-of-date, there is a presumption that the Local Planning Authority (LPA) will grant planning permission for sustainable development.  This is called ‘the presumption in favour of sustainable development’ and is set out at paragraph 11 of the current NPPF. 

The term ‘sustainable development’ is not clearly defined (probably deliberately, as successive governments have been keen to ensure developments are approved no matter what harms they cause).  Some authorities, developers and planning inspectors appear to only consider the materials a building or road is constructed with, and do not (for example) take into account whether an irreplaceable habitat will be damaged, whether there is sufficient social and economic infrastructure to support the scheme or whether there will be other environmental impacts (increased air, noise, light, vibration or water pollution, increased carbon emissions, increased risk of flooding, for example).  New Carrington certainly cannot be considered to be a sustainable development but its allocation for development has been approved by the planning inspectorate!

As an aside, there is also Permitted Development, which means that some specific types of development do not need a planning application (such as the conversion of offices and shops to housing).  These schemes could, potentially, override agreed LDP policies.

What about Trafford’s LDP?

LPAs should develop their LDPs in consultation with their local communities, to ensure the plan reflects local needs and aspirations.  Back in May 2025, FOCM responded to Trafford’s latest consultation on its new Local Plan.  A quick review will show that we made lots of comments.  We await the next iteration to see if any of them have actually been taken into account. 

We certainly do not feel that our previous inputs were taken seriously.  It is clear that Trafford’s proposals for New Carrington were fixed and firm BEFORE the public consultation.  Whilst there has been some reduction in scale, this was not at the same level as in other districts.  Given that Natural England also objected to the harms proposed to what they describe as a 335 hectare restorable and irreplaceable deep peat moss, it is astounding that the development was not restricted to brownfield land (there is plenty of it in the area).

The consultation process for PfE was abysmal.  Residents were not made aware of the environmental and ecological harms proposed, nor of the size and scale of the proposals (which were originally 16,000 houses and 7m m2 employment space).  In the 2019 consultation, there were over 150 documents (comprising over 14,000 pages) to review.  These documents were full of factually incorrect and/or disingenuous statements.  The Friends of Carrington Moss was actually constituted following the introduction of signage on the public rights of way that stated ‘Trespassers will be prosecuted’.  A clear indication that the developer considered the allocation to be a done deal!

What actually happens?

Well, there is an immediate ‘get out’ clause in the government’s guidance, which states that there is “a requirement set in law that planning decisions must be taken in line with the development plan unless material considerations indicate otherwise”.

And there’s the rub!

Material planning considerations are the things an LPA must take into account when deciding whether to approve or decline a planning application.  It is assumed that these considerations help to ensure that planning decisions are rational and are based on established policies and evidence.

Can it really be considered rational to:

  • build on an irreplaceable habitat, in an area that hosts 15 sites of biological importance and a site of special scientific interest?
  • develop in an area that hosts significant surface water flooding every year?
  • significantly increase air, noise, light, vibration and water pollution, for populations of humans and endangered wildlife and birds?
  • put even more pressure on local resources (such as schools and health services), especially in an area that Trafford considers to be poorly served by public transport?
  • destroy woodland, wetlands and productive Grade 2 agricultural land when there are a significant number of brownfield sites in Trafford and elsewhere in Great Manchester?

Maybe those who have a short term, increase my wealth agenda, think it is rational?  We disagree!

The planning officers consider what is known as ‘the planning balance’.  This is a process of supposedly weighing the benefits and harms of a proposed development.  In determining whether the potential benefits of a development outweigh the negative impacts, or vice versa, the planners use their ‘judgement’.

In the Officer Report for planning application 115160 (Battery Energy Storage System adjacent to the Shell Pool Reserve and the Flare Stack), Trafford set out which documents represent the LDP:

  • The Places for Everyone Joint Development Plan Document (PfE), adopted on 21st March 2024
  • The Trafford Core Strategy, adopted 25th January 2012
  • The Revised Trafford Unitary Development Plan (UDP), adopted 19th June 2006
  • The Greater Manchester Joint Minerals Plan, adopted 26th April 2013.

Trafford decided that the application should be approved, despite:

  • The ground investigation reports revealing that the land was very deep, restorable peat
  • The application not complying with the LDP policies, including the requirement for a Masterplan and a ‘suitable compensation strategy’ for the harms to be caused to the peat (the lack of a final Peat Management Plan agreed with Natural England)
  • Pitiful compensation (via Biodiversity Net Gain) of just 1.15 hectares
  • The visual impact on nearby residents (especially given the flat mossland landscape)
  • No calculation of the carbon impact of removing or piling the peat (despite Trafford’s Carbon Neutral Action Plan and the Greater Manchester aim to be Carbon Neutral by 2038)
  • The document confirming that this “site is allocated for employment use within the New Carrington Allocation”, yet the development will not result in a single local job being created and using the site for this purpose will reduce the potential for employment opportunities for local residents (its previous use as productive Grade 2 agricultural land did provide jobs for local people), another indication of unsustainable development

That the planning officer suggested the application proposals are unique is bizarre.  There are now 3 BESS within Carrington and a further 2 elsewhere in Trafford.  Another rather surprising conclusion reached by the planning officer is that the Friends of Carrington Moss represents a single household and, due to written objections being limited to just “5 addresses, including Friends of Carrington Moss”, they did not meet Trafford’s threshold (10 addresses) for raising the application with the Planning Committee.

In relation to the New Carrington Masterplan, the planning officer did not consider the need for mitigation of the environmental and ecological harms to be caused, both within the site and across the allocation in general but limited their assessment to whether the scheme would be impacted by one of the 4 proposed new roads!

To date, there has been no consideration of how the harms to, and losses of, natural capital assets will be addressed across the allocation area (either in PfE or through the Masterplan discussions).  So, how does the planning officer know that premature planning applications, such as this one, will not conflict with the eventual requirements.  

In fact, the planning officer states that, in relation to this planning application, “it is considered that the site itself is not needed immediately to contribute to the site-wide green and natural infrastructure strategy”.  Given that this 19.9 ha site comprises deep restorable peat, this suggests that decisions have been made about the natural infrastructure strategy in advance of any collaboration with local residents!

Interestingly, their ‘judgement’ was that there was “no fundamental conflict with the emerging masterplan, that would preclude this development from coming forward ahead of it. Nevertheless, this approach can only be supported if the application makes the appropriate financial contribution set out in the Council’s latest Interim Planning Strategy (IPS) for New Carrington (February 2024)”.  In other words, if the developer pays towards the Carrington Relief Road, approval could be granted, if they didn’t it could not. 

We fundamentally disagree with this premise.  Whilst we believe developers should fully contribute to infrastructure requirements, their contributions should not determine whether a scheme meets other policy needs, including the impact on natural capital assets!  It should be noted, however, that Trafford has recent lost an appeal where they refused a development because the applicant (Peel) did not agree to fund the infrastructure requirements according to Trafford’s formula.

The planning inspectors held a specific hearing during which Natural England confirmed that the 335 hectare peat moss at New Carrington (then JPA33) was irreplaceable and restorable.  Yet, in their final report (paragraph 235), having taken NPPF guidance about irreplaceable habitats into account when considering whether the allocations were ‘sound’, the planning inspectors determined that, despite there being sufficient brownfield land to exceed housing ‘targets’, they were content that the GMCA was entitled to make the judgement that an allocation that could completely destroy a 335 hectare irreplaceable habitat (paragraph 635) met the wholly exceptional reasons test (now NPPF 193c).  This decision was strongly challenged by Natural England at the hearing and local communities also disagree that the public benefit clearly outweighs the loss or deterioration of the habitat given the amount of brownfield land available across the urban areas of Greater Manchester. 

The benefits the planning inspector’s refer to in their decision are also set out at paragraph 635, which suggests that “The allocation would make a very significant contribution to Trafford’s housing and employment needs, as well as contributing to the strategy of sustaining the competitiveness of the southern areas.  It would also involve substantial regeneration of previously developed land, bringing with it associated social and environmental benefits”.

Local communities must monitor that these so called ‘benefits’ are actually achieved (no one else will do that).  If they are not delivered, Trafford has sacrificed our much-used local green space, irreplaceable habitat and other natural capital assets for huge developer profits, with no mitigation or compensation for communities or the many local populations of red listed birds and endangered wildlife!

Public Money (ie YOUR money) wasted as Trafford ignores its own policies!

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By Lorraine Eagling

Trafford Council has approved the development of a Battery Energy Storage System on Carrington Moss (the third in Carrington, with more elsewhere in Trafford). This scheme will not only result in the loss of productive Grade 2 farmland (essential for food security), and the food and foraging corridor of 79 red and amber listed bird species (which the applicant notes are utilising the adjacent site of biological importance), it will also necessitate the removal of up to 192,000 cubic metres of peat moss, which will release tens of thousands of tonnes of carbon into our atmosphere.

The approval is contrary to Places for Everyone (PfE) policy, which specifically states that no development can take place on Carrington Moss until the New Carrington Masterplan is in place.  The PfE plan was only adopted in March 2024, after 10 years in the making. At barely a year old, and despite the millions of pounds of public money spent on its development, its policies are now being disregarded by Trafford Council!

The scheme is also contrary to the brownfield first policies in PfE, which has Strategic Objectives for both housing and employment sites that confirm Greater Manchester WILL “Prioritise the use of brownfield land“.  There are acres of vacant brownfield land adjacent to the site in question, so why isn’t this land being used for this development?

Despite past reassurances, from Trafford Council’s Strategic Planning and Development Department, that policies will be ‘rigorously’ applied and no development will take place until the Masterplan is in place, the same department did not object to this planning application. 

Even more concerning, this controversial application did not go before the planning committee, which would have allowed local residents to raise their concerns to Councillors. Despite repeated objections, including in relation to the health and safety of residents, and the lack of compliance with policies in the development plan, this planning application was approved by a Council Officer, with needless haste.

I have written to the Council (copy below) requesting an explanation as to why this decision has been made, contrary to policy.  Local Councillors have been copied into the email and I have invited them all to come along for a walk across the moss, so they can see first-hand, the impact this and future developments are going to have to this unique habitat.

Letter to Trafford Council’s Strategic Planning and Development Department:

Thank you for your response. I fully appreciate that this is not a simple or straightforward process.  I too get bogged down with the paperwork and reading.  It is no wonder that very few members of the general public have the time to read the masses of paperwork in order to fully understand the implications of The New Carrington Masterplan. 

I did receive your email of 22nd May with the updated schedule.  My subsequent email was in response to the approval of the BESS, despite it being contrary to criterion 1 of JPA 30 and your reassurances that the council is ‘rigorously applying’ criterion 1.

For the sake of those reading this email trail for the first time, criterion 1 states ‘Development of this site will be required to be in accordance with a masterplan that has been developed in consultation with the local community and approved by the local planning authority. The masterplan must include a phasing and delivery strategy, as required by policy JP-D1. Central to the masterplan shall be the consideration of opportunities to restore habitats, strengthen ecological networks, and manage the carbon and hydrological implications of development, having regard to the presence of peat on parts of the site. It should also have regard to the anticipated Hynet North West Hydrogen pipeline (as relevant). The masterplan will be prepared in partnership with key stakeholders to ensure the whole allocation is planned and delivered in a coordinated and comprehensive manner with proportionate contributions to fund necessary infrastructure‘

I fully support green energy and understand it’s role in achieving net zero, but apart from this approval being contrary to the above policy, the destruction of a peat moss to develop a BESS is illogical. The release of carbon during construction will outweigh the carbon benefit of the facility.  The development will involve the excavation of up to 192,000m3 of peat which will release at least 35,000 tonnes of carbon.

This development is certainly not sustainable, (‘a development that meets the needs of the present without compromising the ability of future generations to meet their own needs’) as it will not only destroy premium agricultural land that provides food security for future generations, but will negate the ability to restore the precious carbon capturing peat that is one of our best defence against climate change.

It should also be noted that of all the boroughs in Greater Manchester (with the exception of Oldham and Rochdale who were unable to provide me with the information) Trafford will lose the most agricultural land (481 hectares) under Places for Everyone.  At no point in the development of this plan, has the livelihood of the tenant farmers been mentioned.

I understand that this decision was made by the planning officer, but I have to express my deep concerns that despite the fact that the Masterplan has not been developed, according to the officer’s report, your Strategic Planning and Development Department made no objection to the application. 

Why didn’t this application go to the Planning Committee when it is such a highly sensitive application?  Also, what was the burning platform that made it impossible for this application to wait for the Masterplan to be agreed?  The Places for Everyone Plan took years to develop at a cost of tens of £millions to the public purse, but within months of its adoption, the policies therein are not adhered to.

This approval calls into question just how ‘robust’ the masterplan will be if applications are already being approved. Once a precedent is set, it is unlikely the plan will able to ‘withstand challenge and scrutiny’.  This is played out in the officer’s statement ‘It is noted that there have been two recent appeal decisions in Trafford for BESS applications where the Battery Energy Storage System compounds were in the Green Belt – Land Off Golf Road APP/Q4245/W/24/3343250 and Land at Wild Fowl Farm, Carrington Lane, APP/Q4245/W/24/3354822. The Inspectors concluded in both cases that Green Belt and any other harm was clearly outweighed by the very significant benefits in supporting the transition to net zero and in helping to secure stability and security in energy supply. Although not directly comparable, these cases are material in terms of the recent approach taken by Inspectors.’

It is hard to understand why the officer has approved this application when they themselves state ‘‘The NPPF, at paragraph 11, introduces ‘the presumption in favour of sustainable development.’ For decision-taking purposes, paragraph 11c explains that ‘the presumption in favour’ means approving development proposals that accord with an up-to-date development plan without delay’.

This application does not accord with the most up to date plan (Places for Everyone) as the Masterplan is not yet in place.

The officer also states ‘Where a planning application conflicts with an up-to-date development plan, planning permission should not normally be granted, paragraph 12 of the NPPF explains. The Places for Everyone Joint Development Plan was adopted on 21 March 2024. As development plan policies in Places for Everyone are very recently adopted, they are up-to-date and should be given full weight in decision making’.

With reference to factors that must be weighed in the balance, the officer’s report states that ‘The supporting documents states that the planning application is located on this land due to its close proximity to the Daines National Grid substation. The Applicant holds a grid connection agreement with NGET to connect the proposed BESS project to this substation’.

Whilst this is true, this site is grade 2 agricultural land that is constantly used for growing crops and is home to land nesting birds.  However, there is 27 hectares of vacant hard standing brownfield land directly North of the site which is equidistant to the Daines National Grid substation and would be suitable.  Why wasn’t this fact weighed in the balance when making the decision, particularly when one of the Government’s Golden Rules is ‘Brownfield First’ and one of the Places for Everyone’s Objectives is to put brownfield first for both housing and employment.

It should also be noted that some of the Officer’s knowledge of the New Carrington Allocation is incorrect as they state that there will be ‘major investment in public transport’.  Sadly, this is not the case.  Even though New Carrington is the largest allocation in Places for Everyone, there is no commitment for investment in public transport infrastructure.  Furthermore, despite the Governments recent announcement of a £2.5 billion funding boost for public transport in Greater Manchester, Carrington, Partington and Sale West have not been earmarked for any of this.

As you appreciate, my main concern is the loss of green and natural infrastructure.  The Officer states ‘Taking all of these factors into account, it is considered that the site itself is not needed immediately to contribute to the site-wide green and natural infrastructure strategy. That strategy and the subsequent JPA 30 compliant masterplan is capable of being produced and implemented without the application site in the first instance, as it will be able to have regard to its longer-term availability.

Here the officer is referring to the long-term plan to restore the peat at this site once the BESS is decommissioned.  This raises two questions that should have been taken into account; a) the removal of 192,000 m3 of peat will limit what can be restored in future, b) why isn’t the peat being restored now to protect future generations, in twenty years time it will be too late?  Another consideration is, if this development does go ahead, who will be responsible and has the expertise to ensure the peat extraction will be in accordance with the Peat Management Plan?

The officer goes on to say ‘However, since the application proposals are not in accordance with Criterion 1 of Policy JPA 30, any approval must robustly secure the compensation, so that it can contribute and link to the site-wide green and natural infrastructure’.

Already, the ability to robustly secure the compensation is compromised, as Manchester United have built a car park on land which is designated as the green corridor in JPA 30.  I await the findings from your planning enforcement officers regarding this car park. 

In the New Carrington Ecological Assessment which was in your last email, the Greater Manchester Ecology Unit states ‘GMEU has not itself carried out large-scale, detailed field-based ecological assessments of the entire allocation. Such a level of survey is regarded as beyond the scope of the assessment, generally carried out at the masterplanning or planning application stage of the land-use planning system’.

Is this large-scale, detailed field-based ecological assessment underway as part of the Masterplan, to ensure any approval will robustly secure the compensation, so that it can contribute and link to the site-wide green and natural infrastructure’?  This is urgently needed to ensure a holistic approach, to not only help in the fight against biodiversity loss and climate change, but to ensure that existing communities are protected from flooding, air pollution, noise pollution and a loss of having access to open green spaces for mental well-being. 

At one of the drop-in events for the Carrington Relief Road, the information boards said, in relation to BNG measures, “the scheme aims to transform what is currently unused land for the better with planting proposed on what is currently a brownfield site”. When questioned where this brownfield is located, the staff at the session pointed to the green belt agricultural land.  When this was highlighted, they admitted that they were not entirely sure where this unused land will be.

In an attempt to clarify where these BNG measures will be, the question was sent directly to the team at Amey in February, together with a number of other questions, including ‘In relation to the attenuation ponds, are these being constructed to mitigate the impact of the road alone or are they expected to also mitigate the impact of other development in the eastern part of New Carrington?

Unfortunately, we had no response from Amey, so a freedom of information request was done to which we had a reply this week.  The response to the BNG question was ‘The brownfield land is the Shell Carrington Estate’.  The response to the attenuation ponds was ‘These are designed based on highway drainage, not relating to developments’.

Clearly describing the brownfield land as the Carrington Estate is very vague, and the response to the attenuation ponds demonstrates the ad-hoc nature of the planning applications for this site.  Without a holistic approach, there is greater risk of flooding and a greater loss of biodiversity. This is why the inspectorate set out criterion 1 and emphasised the need for a Masterplan to be in place before any applications are approved.

It begs the question, how did the officer come to the conclusion that ‘As such there is no fundamental conflict with the emerging masterplan, that would preclude this development from coming forward ahead of it’ when there has been no discussion with stakeholders regarding the natural infrastructure, no evidence that there is any site-wide plan with regards natural infrastructure and that this site may be needed for mitigation and compensation under the masterplan.

All that the community have ever asked for is to be listened to.  For years the communities have put forward sustainable alternatives that would benefit the communities of Partington, Carrington and Sale West, without the need to destroy a peat moss, wetlands, woodlands and agricultural land. Unfortunately, all of the ideas and the advice of other stakeholders, such as Natural England, have been ignored.  So, the promise of stakeholder meetings at which we could discuss the issues that matter the most to us, in particular the green infrastructure, was really appreciated.  At the one meeting so far, which was last July, we did not get the opportunity to raise our concerns and put forward our suggestions.  Instead, we were asked to submit our thoughts with the promise that there would be further stakeholder meetings.  I hope that these will recommence soon, as you suggested in your previous email.

I sincerely apologise for the length of my email.  I appreciate you are working hard on this project, but to be honest, I have lost faith in the whole system.  Who will benefit the most from New Carrington?  Not the communities or future generations.  They will face more traffic, air pollution, no improvement to public transport, social isolation and inequalities, less green space, a loss of biodiversity, flora and fauna essential for well-being, a loss of identity due to urban sprawl, higher risk of flooding, the list goes on.  The winners will be the developers, who’s only objective is to make as much profit as possible irrespective of the costs to humans and nature and the planning system facilitates this.

We have little influence of what happens Nationally and Globally when it comes to the destruction of the natural world.  Here we have an opportunity to do the right thing, to put nature before profit, to look at the alternatives and ensure we leave a legacy that will benefit future generations.  If all decision makers did this, we would not be in the middle of a climate crisis. 

My invitation to you to take a walk across the Moss still stands (although cycling would be best as the site is huge), so that maybe you will understand why we feel so strongly about its destruction.  I welcome Local Councillors along too.

A final thought, ‘Let’s put GDP growth aside and start a fresh with a fundamental question that is what enables human beings to thrive? A world in which every human being can live a life with dignity, opportunity and community and where we can all do this within the means of our life-giving planet’.  Kate Raworth, Senior Teaching Associate at Oxford University.  I believe this is possible, so I will continue to fight to protect Carrington Moss, if only so that in years to come, I can look my children and grandchildren in the eye and say that I tried my best.

Kind regards

Lorraine Eagling

Call for Action 1 – Carrington Relief Road!

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Respond to the Consultation

As the first Carrington Relief Road (CRR) consultation goes live today (20th January 2025), we are issuing our first Call for Action to local communities.  Please take the time to respond and encourage friends and family to participate too.

The consultation period includes some face-to-face sessions, and we hope you will be able to attend one of these.  Just a reminder that the current CRR team are NOT responsible for the decisions made in the past and that they have been directed to give a very limited scope to the consultation, which is only based on the design of the road! 

The inadequacies of this consultation have been determined by Trafford Council, and they have repeatedly rejected our requests for communities to be able to influence the wider aspects of transport solutions for the area – our next Call for Action will address this failure (see below).

This consultation ends on 28th February.  Your inputs are extremely important, so do click on this link to read Trafford’s materials and submit your own response.  We will be discussing this consultation at our next online public meeting on 28th January (6pm), the link to the meeting is here and all are very welcome to join us.

At the meeting, we will highlight some of the key points to consider, which include the following:

  • there are two parts to the Carrington Relief Road (CRR):
    • we are totally supportive of the upgrading of the A1 route in Carrington (this runs through the employment zone from Isherwood Road to the A6144 near Saica Paper), all HGVs should be encouraged to use this road, rather than the A6144 through Carrington Village – this could have come forward years ago without any objections!

    • we are totally against the development of the road across Carrington Moss and have been proposing our alternative to Trafford for the last 4 years, without success – they are only interested in promoting the CRR, despite its escalating costs – it is a commitment to support development – not a solution aimed at benefiting existing communities
  • how the current design ‘benefits’ communities:
    • Carrington residents will only benefit from this new road if through-traffic and HGVs are unable to use the A6144 through the village, with appropriate traffic calming mechanisms put in place (otherwise, residents here will just be surrounded by constant traffic and the associated pollutant impacts)

    • Partington and Warburton residents will, sadly, not benefit from the scheme – Trafford has acknowledged that the road will induce additional traffic, much of which is likely to continue through Partington and Warburton, seeking an alternative route to the motorways, furthermore, given the low levels of car ownership in Partington, a new road will not reduce the isolation of this community (unlike a tram/train connection)

    • Sale West residents will be the most negatively affected by the scheme, they will suffer from huge increases to air, noise, light, vibration and water pollution, a significant, intensified and more frequent risk of local flooding, and the loss of the current safe, healthy and pleasant traffic-free recreational routes – we recognise that the recorded and unrecorded public rights of way will still be there, but, with the road solution, residents will be walking, cycling and horse riding next to the over 40,000 motor vehicles expected to use the road each day (including over 3,000 HGVs) – the number of vehicles will significantly increase from the current traffic numbers due to the proposed developments in the area and the induced traffic using the road as a ‘rat-run’!

    • Urmston residents will not benefit from the scheme either, but they are also likely to see an increase in traffic on their local roads and the risk of local flooding will increase due to the loss of water capture and storage on Carrington Moss (we do not believe the proposed attenuation ponds will be sufficient to replace the capacity lost when the road is built)
  • how the design ‘mitigates and compensates for the impact on the natural environment’:
    • the part of the road that cuts across Carrington Moss will severely impact red listed birds (including, for example, the skylark, which is prevalent along the route of the road) and protected/endangered species – we are very saddened by the thought of yet more roadkill!

    • the road will fracture the corridors used by wildlife and birds to access food and water sources – this will result in further depletion of their species

    • the road will also damage the peat moss (a restorable 335-hectare irreplaceable habitat according to Natural England) and the sites of biological importance/site of special scientific interest, even where these are not directly impacted – this is because of the changes to hydrology that will be required to keep the road water-free

    • it is likely that Trafford will consider that the attenuation ponds will replace the immense water capture and storage functionality of the moss – we think they underestimate the level of water captured here and this could lead to huge risks for local communities

    • Trafford is also likely to assume that these pond areas will create biodiversity gains, but what must be considered is that the losses will be experienced immediately, whereas any gains could take years to deliver, and, in that time, species will be lost to the area forever

    • the road will also impact the potential opportunities to support the Local Nature Recovery Strategy

    • the loss of productive Grade 2 agricultural land will impact future food security as this cannot be replaced elsewhere in Trafford
  • how the design constrains the development of the New Carrington Masterplan which is currently under development and covers the whole allocation area:
    • the CRR will significantly restrict and constrain what is possible in terms of recreational, ecological and natural capital benefits for the Sale West area, considerably increasing the inequities of access to green space for residents

    • the Natural Infrastructure Strategy underpinning the Masterplan has not yet even been discussed – this should determine the approach to mitigation and compensation for environmental and ecological harms to be caused across the allocation area (including the cumulative harms) – such issues should not be addressed as piecemeal solutions for individual developments, including the CRR.

Whilst we are keen for residents to respond as constructively as possible to this consultation, we also need to recognise that Trafford has not given communities the opportunity to influence either:

  • the choice of transport options for this area (why weren’t we asked if we wanted trams or trains, given the size and scale of the developments they are proposing, the number of years this has been under consideration, and the sheer common sense that we should make full use of the former railway lines running through the allocation area and the proximity of the Manchester Ship Canal?), or
  • the route options for the road.

You might want to mention this in the final section of the response questionnaire (headed “Further Comments / Queries), but with these things in mind, there will be a future Call for Action from local communities to address the total lack of previous consultation about the CRR. 

Look out for our next blog for more community action on the Carrington Relief Road Consultation.

Unsustainable New Carrington – “Trapped Behind the Wheel”

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by Lorraine Eagling

Where we live and how we get around are key to what shapes our everyday lives.  A recent New Economics Foundation (NEF) report ‘Trapped Behind the Wheel’ found that

“far from moving our economy towards sustainability and improved wellbeing, England’s new homes in recent years have increasingly encouraged car-dependent lifestyles.

One factor in this change has been the outsized share of new homes being built in rural areas, which has risen continually across the country in recent years”.

New Carrington will be one of these car and HGV-dependent developments that will not be sustainable, nor will it deliver improved wellbeing for new and existing residents.  The majority of the housing and warehousing will be located on grade 2 agricultural land and part of a restorable 335 hectare peatmoss! 

Despite the proximity of New Carrington to Partington, Carrington and Sale West, there is currently a lack of adequate public transport and no committed funding for new public transport infrastructure.  In fact, there are no plans to connect New Carrington to the water, rail or tram network, despite the allocation being adjacent to the Manchester Ship Canal, having former railway lines running through the site and it being the largest development in Greater Manchester.

The Council are pushing ahead with this plan regardless of the experience of the past 15 years, which shows us that, without substantial changes and investment into new public transport infrastructure, there is a major risk of locking in increased car and HGV dependency for decades to come.

As a result, Trafford Council and the Government will not be able to deliver priorities such as

Bringing the cost of living down to more manageable levels, reducing spatial inequality and responding adequately to the climate emergency

In most cases, residents in New Carrington will face the higher costs of car dependent living. Their ability to enter paid employment or the training needed to secure a well-paid job is constrained by the availability of local public transport infrastructure.  

Although there are plans to improve bus services as part of the masterplan, Partington, Carrington and Sale West have seen bus services reduce significantly over recent years, so any increase in services provides no net gain overall. 

“A 2021 study demonstrated that in ‘left-behind’ neighbourhoods, which have high deprivation and poor social infrastructure provision, public transport is worse than average (74% have no railway station and bus journeys per capita have declined faster than the national average). Residents are less able to afford to compensate by owning a car (40% of households have no car, compared with 26% across England). These areas of the country typically have worse connectivity than the English average but rely more than other parts of the country on their local bus service”. (Emmet Kiberd, Benedikt Straňák, NEF, November 2024)

So, why is there no commitment to invest in new public transport infrastructure such as reopening the rail line between Irlam and Timperley?  Part of the answer may lie in the following figures.

“The public transport system in wealthier parts of the country, such as London and the south-east, is much more effective and gives residents there far more access to jobs than the equivalents in the north-west, Yorkshire, and parts of the Midlands. Despite this, public investment in transport has tended to overlook the parts of the country where it is most needed. The north of England would have received an additional £51bn in public investment in transport if it had matched the per capita level seen in London from 2014/15 to 2019/20. Similarly, investment in active travel infrastructure between 2016 and 2021 was £24 per person in London but only £10 per person in the rest of England. (Emmet Kiberd, Benedikt Straňák, NEF, November 2024)”

Regardless of the lack in funding in the north for public transport, Trafford Council plan to build a relief road (the name is misleading), with a current cost of £76million, which is very likely to rise! 

Why isn’t this money being used for new public transport infrastructure? If the Government is to deliver on its priorities, when there is a ‘black hole’ in public finances, surely public transport must take priority over road building.

Then, there is another question, why is Trafford pushing ahead with this development when there are other available sites and enough windfall sites over the past four years to provide 40% of the housing target for New Carrington? 

Emmet Kiberd and Benedikt Straňák (NEF, November 2024) suggest the reasons behind these questions are

  • “Favour cheaper greenfield land in a profit-driven housing development system.
  • Relatively lower levels of local political opposition to new developments in more remote areas.
  • A lack of early, integrated planning of transport, housing, and development sites, reinforced by substantial underfunding of public planning departments.

The provision of public transport and active travel for new homes is affected by:

  • The insufficiency of Section 106 funds to cover the public transport needed, together with the lack of negotiating power for councils tends to see transport provision lose out in a trade-off against social housing, community facilities, and other items.
  • The use of large amounts of public funding on expensive road infrastructure alongside new developments, encouraged by a lack of advance transport planning and car-centred approaches.
  • The provision of public transport and active travel for new homes, which is affected by poor public transport and active travel provision in adjacent neighbourhoods, due to congestion and a lack of safe walking and cycling routes”.

Clearly, there is a need for ambitious policies and brave decisions in relation to the New Carrington Masterplan because the second-best solutions that present themselves are unlikely to solve the problems and deliver the priorities that will bring the cost of living down to more manageable levels, reduce spatial inequality and respond adequately to the climate emergency.

Does the New Carrington Outline Transport Strategy address resident priorities?

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We had hoped the collaborative way the New Carrington Masterplan is being managed would prevail for other aspects of development in the area, but sadly, no!  Once again, we have a “strategy” that has been agreed by Trafford’s Executive without any input from the residents who will be severely impacted by its implementation (not only by what is in the “strategy” but also by what is not)!

At a recent Trafford Executive Committee meeting (29th January 2024), the report about Infrastructure and Development in New Carrington was introduced (we note there is a typo in the report date but it was presented in 2024, not 2023).  As part of this report the New Carrington Outline Transport Strategy was presented to the Executive.

On the positive side, the Council has begun an open and transparent process for developing the Masterplan for New Carrington (the details are on their website here).  This is good news, because, it is clear that residents have a lot to bring to the table in relation to what is needed in the area.

The Executive report itself is actually a marked improvement on previous documents created by Trafford about the Carrington Relief Road.  It does acknowledge some of the issues that have arisen (and continue to be identified).  In view of Trafford’s declaration of a climate emergency back in 2018 and its carbon neutral goals, set out in 2020, the accompanying Transport Strategy document, however, remains unambitious and has several major omissions.

Interestingly, that “strategy” document was produced in September 2023 but has been kept under wraps until after the Places for Everyone (P4E) Modifications Consultation was completed, which is rather disingenuous of Trafford’s politicians and officers, given that its contents signal concerns about whether the huge list of “Necessary Transport Interventions” set out at Appendix D (page 708) of the P4E Plan can, or will, be delivered. 

Resident Priorities?

Whilst the production of this “strategy” is to be welcomed, there has been no involvement of the community in determining the Vision, or the aspirations, and there is nothing in the document that suggests that communities will be engaged as the “strategy” evolves in the future!  It is, therefore, not a surprise that it merely continues to promote car/HGV-dependency, leaving a legacy of huge levels of air, noise, light, vibration and water pollution (to say nothing of the carbon emissions), that will result in poorer health outcomes for residents and higher costs to the public purse.  There is a reference to a specific consultation about one initiative, the Carrington Relief Road, but that was supposed to commence in January 2024, so is already behind schedule.

HGV traffic on the A6144 is, by far, the biggest concern for residents, yet there are no figures in this document which identify the size of the issue (either now or in the future), nor does it explain how Trafford proposes to address this problem.  The “strategy” confirms that the new road will be the panacea for freight transport!  Yet, we know that businesses are not in favour of restricting HGV use on the A6144, as was confirmed in a response to a planning application.  There is no indication about how the proposed route changes will be agreed with businesses and implemented so that travel through Carrington Village can be limited to local resident movements.

So, what we have now is a “strategy” which:

  • does not address any of the issues related to the huge number of HGVs that are travelling on local roads, there are no references to sustainable freight transport solutions and no aspirations to even consider them – is this really a strategic document?
  • does not estimate the anticipated induced traffic that will arise from the construction of the proposed new roads (causing more congestion, much higher levels of pollution and increased travel incidents), particularly for Partington, nor does it reveal the ultimate aim, set out in the GM Transport Strategy 2040, to create a link between the M60 and the M62 via Carrington (page 124/125), which will undoubtedly induce immense volumes of motor vehicle traffic through the area
  • does not even mention the importance of local travel routes to horse riders (there are more 1,000 horses stabled in and around the area – source British Horse Society) – this is a huge gap as horse riders need specific surfaces (to reduce the potential for the animals to slip in wet weather, for example, and specific crossing points) – it would be inappropriate to consider active travel routes here without including their considerations.

The background facts are rather selective, there is no reference, for example, noting that Partington has a much lower rate of car ownership (27.2% of households with no cars or vans according to Census 2021) compared to the rest of Trafford (19.3%).  Neither is there any mention of the likely changes arising from the increased charges on the Warburton Toll Bridge.  There are no figures highlighting the difference in traffic volumes during school term times and school holidays (there is a marked variation in numbers which we have observed in our traffic counts that could be addressed through increased school bus services, cycling buses and other initiatives).

Because the proposed new road will be constructed adjacent to and beyond Carrington, it is more likely to induce additional traffic into Partington than to relieve traffic for residents there.  Other initiatives are needed to improve transport options for Partington residents, such as community transport and the reopening of the former railway line between Timperley and Irlam.  This latter scheme would be highly beneficial to the people of Partington and would enable sustainable passenger and freight transport to be fully examined.  Given the lack of consideration for this option from Trafford, Partington Parish Council has begun to explore opportunities to raise the funding needed for a feasibility study for the initiative.

What about the funding?

There is very little information in the document about the costs/funding of the overall “strategy”.  There are only figures related to the Carrington Relief Road (£76.5m) and the overall Greater Manchester Transport Strategy 2040 (£1.1b).  Our own very conservative estimate puts the overall cost of the “Necessary Transport Interventions” for the New Carrington development to be over £400m, see Appendix D (page 708) and listed in the graphic above. 

That GM Transport Strategy 2040 aims to reduce car use to no more than 50% of daily trips by 2040 and reduce demand on road space from freight, moving freight traffic onto rail and water-based transport by the same date. The associated Transport Delivery Plan states that “The Right-Mix aim is for 50% of trips to be made by sustainable modes across GM.  This will require zero net growth in motor vehicle traffic between 2017 and 2040, and non-car mode share to increase from 39% of all trips in 2017 to 50% of trips in 2040”.

With the strategic aim to significantly reduce motor vehicle traffic by 2040 (just 16 years away) in mind, along with the requirement for zero net growth in motor vehicle traffic, there is surely no business case for public money to be invested in a new road, that will impact the borough’s and the region’s carbon neutral ambitions, and generate huge levels of air, noise, light, vibration and water pollution.

Given the very marginal viability of the allocation, especially taking into consideration the contamination issues raised at the Executive Committee meeting, we believe that the public purse will be required to pick up the vast majority of these funding requirements and/or local residents will be forced to accept a huge development without the benefit of the Necessary Transport Interventions to make it, not only sustainable, but also tolerable. 

The Committee Report particularly highlights (paragraph 5.9) the long-elapsed time of the funding period for the Carrington Relief Road (a 9-year funding programme).  Consideration should be given to alternative options that may reduce the cost impact for the public purse and make sustainable transport solutions a reality.  This could include upgrading the existing routes (A6144 and the A1 currently private road in Carrington), along with significant enhancements to the public rights of way across Carrington Moss, making them suitable for extensive active travel, horse riding and, possibly, bus services only.  This would be a much more attractive option for encouraging modal shift as walking and cycling next to huge numbers of HGVs and other motor vehicle traffic is unpleasant, unhealthy and unsafe.

At the Executive Committee meeting a number of insightful questions were raised by Councillors, including Councillor Welton, who asked why there is no analysis of the costs of not achieving Scenario 3 (which is the most sustainable option).  As Councillor Welton highlighted, not achieving that scenario will lead to higher costs in terms of carbon emissions, poorer public health outcomes, increased traffic incidents and congestion and higher costs of road maintenance. 

More Missing information – Carbon Emissions!

The Transport Strategy does not include any information about the carbon implications.  There are no calculations that estimate what impact the different scenarios could have on Trafford’s carbon neutral ambitions. 

Interestingly, the “strategy” references the Greater Cambridge Local Plan to support its assertions in relation to compable sites.  In the P4E assessment work we have done with partner organisations, including Steady State Manchester (who produced an excellent document which calculates the carbon emissions resulting from P4E), our responses to the Planning Inspectors included reference to the Greater Cambridge Local Plan.  Their plan, unlike P4E, incorporated a Strategic Environmental Assessment that calculated the projected carbon emissions for each spatial option being considered (and they were comparable to the spatial options set out in P4E).  Cambridge discovered that coupling residential development and public transport leads to approximately 20% lower carbon emissions than a strategy that promotes car-dependent development in the Green Belt!

Given Trafford’s climate emergency declaration and carbon neutral ambitions, the document should be very clear how such a large development, and the associated road infrastructure, will impact both Trafford’s and the region’s carbon neutral goals.  The lack of sustainable freight transport options is a key consideration here because the carbon implications of the huge numbers of HGVs will be significant.

Comparing New Carrington with similar areas?

The “comparable” areas mentioned in the document are not actually analogous with New Carrington.  The benchmark sites (such as Filton, which has the UK’s largest Aerospace Area – BAE Systems, Rolls Royce, Airbus to name a few) are home to a Global Technology Centre and companies such as Filton Systems, Hewlett Packard and Viridor.  These industries are not like those businesses that are currently operating in (or are proposed for) New Carrington, which are predominantly warehousing/logistics units that generate extremely high numbers of HGV journeys.

Additionally, Filton and the surrounding areas of Stoke Gifford, and Patchway each have their own train station, whereas Carrington, Partington, Sale West and Warburton have no train stations and non are proposed in this “strategy”.  Another “comparable” site, Waterbeach, is a new development but, unlike New Carrington, it is getting its own train station.  There are no large warehousing sites proposed for that location.  It will have flexible workspaces and hubs (more cottage industry makers and creators) and, therefore, limited HGV traffic!  It is a real challenge to understand how these sites can be considered to be “comparable” to the New Carrington location!

The Executive Report states (paragraph 9.1) that “New Carrington will be the main growth point in Trafford for the next decade or more” but the New Carrington allocation is not even comparable to Trafford’s other major warehousing location – Trafford Park does have sustainable freight transport solutions!

What about the deep peat deposits on Carrington Moss?

At the P4E Examination in Public, Natural England’s contributions included the following:

  • Natural England (NE) wrote to the planning inspectors in June 2023 (OD42), stating that there is extensive and restorable deep peat within allocation JPA33 (New Carrington), that the deep peat should be considered to be an irreplaceable habitat, and that “the combination of the location and the extent of development proposed by the allocation policy means the proposed development is incompatible with avoiding the deterioration of this irreplaceable habitat”
  • NE’s view, set out in OD23, is that the development will not only prevent future restoration but “will cause irreversible damage to the body of peat directly under the developed land and the wider peat mass, which depends on the continuity of the flow of water”.  They go on to recognise that the degradation of the peat mass will also result in significant greenhouse gas emissions
  • NE confirmed (in OD42) that their position is in line with the England Peat Action Plan, that there should be no development on (restorable) deep peat, and that peat should be kept wet and in the ground.  NE drew attention to their “extensive experience of peatland restoration projects” which provides considerable credibility to their professional judgement in this matter.

So, for Trafford to conclude in the report (paragraph 7.7) that “peat is not considered to be a significant constraint on future infrastructure provision” demonstrates a huge lack of understanding of the impact of hydrology on the main body of peat, which Natural England estimates to be around 335 hectares.  This is not a surprise, as it is recognised that Natural England are the experts, not Trafford, and their advice should be followed.

Even More Omissions from the “Strategy”!

Whilst the 29th January Executive Committee report mentions that the 2006 Unitary Development Plan (UDP) included a safeguarded route for the road and that the 2012 Core Strategy significantly underestimated the cost of such a route, it does not explain why the land that was safeguarded for the Manchester Ship Canal bridge is not included in the Transport Strategy.  This was also a Proposal E15 requirement in the 2006 UDP and one of the Implementation Projects listed in the 2012 Core Strategy (p80).  This initiative would reduce the number of HGVs (and other vehicles) on local roads significantly.  It is clear that the majority of the actions set out in previous local plans have not been delivered in this area and the potential benefits of the most sustainable solutions, particularly for freight, (such as bringing the former railway line back into use and/or transporting goods via the Manchester Ship Canal) have been totally ignored by Trafford for almost two decades.

The Carrington Relief Road appears to be going through a name change to the A1 Link Road.  The recognition that this road will not “relieve” anyone is welcome but we do wonder where the road will link from and to!  The government’s announcement about the funding to be made available as a result of cancelling HS2:states that “more than £500 million in funding will be provided for 2 major road schemes around Manchester. These include a new link road between the M62 and the M60”.  Whilst this initiative is set out in the Greater Manchester 2040 Transport Delivery Plan, and we assume the A1 link road is ultimately being proposed to provide the first stage of this scheme, the “strategy” makes no mention of this longer-term proposal.

More information:

There are many tables full of confusing information throughout the document.  The calculations about the number of trips do not include the current traffic numbers, the HGV movements and there is no estimate about the expected level of induced traffic.  So, effectively, there is no assessment of the expected overall traffic levels on the new road. 

The “strategy” states (page 18) that “Employment provision in the area should offer a wide range of employment types” and (page 15) that currently 6% of car journeys and 7% of public transport journeys are internal (within Carrington and Partington).  This suggests few residents currently work in the Carrington area, an assertion borne out by our own research.  The current and proposed employment development does not offer a diverse range of job opportunities (despite the assumption on page 38).  It is predominantly warehousing which requires a small, low paid workforce.  There should be more evidence to show how the target of 17% of internal journeys can be achieved.

The current conditions (set out on page 14) focus on Carrington and Partington, without referencing the issues related to Sale West or Warburton, which will be impacted significantly by this “strategy” and, as mentioned above, totally omits any reference to the huge number of HGV movements in the area.

What next?

We have requested a meeting with Trafford to discuss the contents of the “strategy” further and will provide an update to residents as soon as we are clearer about the implications.

Trafford has a website page dedicated to the Carrington Relief Road, you can access it here.

You can find our previous blogs about the Carrington Relief Road by scrolling down at this link.

Residents and local experts deliver added value in Master Plan workshops

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As we mentioned in our previous blog, the Friends of Carrington Moss recently arranged two workshops to provide input to the local Master Plan. 

We’d like to take this opportunity to provide some feedback on the outputs from these workshops.  We’ll give you some information about next steps and we’d love to have your thoughts about some of the key issues, because, of course, the

OUTCOMES

(ie what happens in response to the workshops) are, most importantly, why we spent so much time planning, preparing and hosting these sessions.

The Coronavirus has impacted timescales, so please bear with us and our partners over the coming months as some of the planned activities will not be completed within the same timescales now.

The first deliverable from each workshop was a set of key design principles which were discussed and agreed within the participant groups.  We also received further feedback after the workshops.  The graphic below represents the final output, which has been updated for all comments and responses received.

The core principle for each of the two topics is shown at the centre of the graphics.  We believe these core principles are the overarching imperatives in the Master Planning process for these two themes.  Some suggestions were also made about additional principles, which need further discussion.

The workshops also discussed the key assets we have on the Moss.  This activity was structured in a slightly different way in the two workshops.

In the Ecology and Biodiversity Workshop:

We looked at the quantitative values of the ecology and biodiversity on the Moss and how they can be measured.  Quantitative values can typically be measured numerically in some way, such as by size of the area, the number of creatures supported by that feature, or by using a pre-determined metric established by experts.

To facilitate this discussion, Trafford Wildlife shared their assessment of the wide variety of existing habitats on Carrington Moss and a representative from the Greater Manchester Ecology Unit (GMEU) presented information about the sites of biological importance and the presence of endangered species on Carrington Moss.

The break-out groups then considered the qualitative values, discussing their views about the most important ecological assets on Carrington Moss.  Qualitative values are things that would not necessarily be counted numerically, they can be perceptions and feelings, not just tangible measurements and typically relate to the quality of a feature.

The results of this activity are shown in the graphic below:

As you can see, there was a lot of consistency in the discussions that took place in each break-out group, so it is important that these values are considered in the design and development of the updated Master Plan.

In the Interconnected Traffic-Free Routes across Carrington Moss

We categorised the various routes across Carrington Moss that are used today and also identified potential future traffic-free routes that will be important to consider in the Master Planning process.

Again, there was a lot of consistency between the groups, including in their assessment of potential future routes.  Connectivity with the wider network of walking and cycling routes is considered to be very important.  There was a lot of discussion about the dismantled railway line and it is important to take the number of horse riders using the Moss on a day to day basis into account.  Our friends in the horse riding community tell us that there are over 1,000 horses stabled in the area, no wonder we see someone on horseback almost every time we go onto the Moss.

Finally, the third activity was to identify the key next steps to help progress the Master Plan and ensure community engagement continues as a key part of the discussions.  These have been consolidated because there was so much overlap between the break-out groups and lots of actions were suggested.

Let’s look first at the Quick Wins, these are things we can do in the short term (in the next three to six months), without too much difficulty.  We are already working with our partners to deliver these:

ActionCommentary
Plant wildflower meadows (next to the footpaths, ditches, solar farm, hedgerows)We have already discussed this with HIMOR and hope to sow seed over the coming months
Plant bulbs/understorey in the woodlandsAgain, we are actively planning this with HIMOR
Create a programme of work for schools (including, if possible, on-line resources), arrange school/resident visits onto the MossTwo school visits already arranged, with more to follow, we are also planning some community walks over the coming months
Introduce more way markers and signage to help those using the MossAgain, HIMOR are actively supporting this initiative
Do litter picks on and near the footpathsWe held our first litter pick in February and will be doing more over the coming months
Involve representatives from all communities in discussions about the Master Plan for the area, invite those representatives to the existing forums which are part of the Master Plan processWhilst we feel this must be a quick win, community engagement on Master Planning is not yet in place, but we hope to bring more information on this over the coming weeks.

The workshops also identified things that would take a bit more discussion but we believe can be achieved in the medium term (in the next six to nine months) and also some more challenging actions which may start over the coming weeks but will take much longer to complete (possibly up to a year or longer):

We’d also like to have your inputs into the next steps and with that in mind, we have created a very short survey, which should take less than 5 minutes to complete.  We are keen to secure inputs from as many in the community as possible, so please encourage your family, friends and neighbours to respond too. Click on the button below to access the survey.

Survey: How important is Carrington Moss?

We are now planning our next workshops, the first of which will consider the plans for the Strategic Road Network to be constructed across the Moss, these currently include the Carrington Relief Road, the Sale West Link Road, the Birch Road Link and the Southern Link Road.  We will be seeking to identify quick wins, route options and alternatives to the reduce the need for so much new tarmac!  A further workshop will look Risks and Issues (for example, Air Pollution, Noise Pollution, other impacts of high volume HGV traffic and potential COMAH site topics). More information will follow on these workshops over the coming weeks.  They may, of course, need to be on-line sessions, due to the Coronavirus.

Inputting to the development of the Master Plan for our area

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Trafford is developing a Master Plan for “Future

Carrington” and we are working with Trafford Council’s

Strategic Planning Team to ensure community

representatives are able to input into the design of that

                           Master Plan. 

This is important, because if lots of money is spent developing a plan, it is much harder to effect change in later phases of the process.

With this in mind, the Friends of Carrington Moss recently arranged two workshops to provide input to the local Master Plan. 

The first workshop focused on the Ecology and Biodiversity on Carrington Moss, and the second covered Interconnected Traffic-Free Routes across Carrington Moss.  Participants included landowners, developers, Trafford Council, specialists from local regional and national groups (see the graphic below for a full list), school pupils and representatives from local community groups.

Why is the Master Plan important?

The Master Plan will shape the future of our local landscape.  It will act as a framework for upcoming planning applications and will be a supporting document in the final iteration of the GMSF which is due to be published later this year.  The community are extremely important in this process.  The other people who are involved may not live in the area and may not know its existing features and unique characteristics as local residents do.

In line with their Statement of Community Involvement (available at this link Trafford’s Statement of Community Involvement), Trafford will be seeking to consult and engage with residents and other interested parties throughout all phases of the Master Planning process. 

Trafford Council’s planning officers have confirmed that the new version of the Master Plan for the area will use the HIMOR Master Plan, which is available at this link HIMOR Master Plan March 2019, as its starting point.

As it is a strategic document, the Master Plan will aim to show what the vision, ie the long-term proposition, for the area looks like.  It will include some analysis of the existing site, highlighting the constraints and the opportunities which may arise during the plan period. 

The work of the Friends group will provide some useful baseline information which can be included in the inputs to the Master Plan, including, for example, our monitoring of air quality on and around Carrington Moss.

In addition, the outputs from our recent workshops definitively demonstrate that local residents and specialists can add real value to the Master Planning process.  The design principles for each theme (Ecology/Biodiversity and Interconnected Traffic-Free Routes) were discussed and updated during the workshops and attendees have had the opportunity to comment further during the review of the workshop outputs. 

We are now working with workshop participants to consider the next step actions, particularly focusing initially on the quick wins, which could include, for example, route signage and wildflower planting.

Whilst these workshops aimed to support Master Planning for our own area, this is a great framework which can be adopted by others and is a huge opportunity to enable local communities to be involved in the design phase of the Master Plan.  We are creating a toolkit which can be shared with other groups and we believe this will help change the perception that residents can add little value to the planning process.