Category Archives: P4E

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

The Greater Manchester Green Belt Lie!

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There has been lots of commentary about Stockport’s withdrawal from the Greater Manchester Spatial Plan (Places for Everyone, or PfE) since they made the decision in 2020, especially about the consequential risk that being out of the plan will lead to more Green Belt release and speculative development.  The same threats are being made to those who, more recently, want to remove Oldham from PfE, with some Councillors suggesting the arguments in favour of withdrawal are misleading residents and that this approach “would lead to further developments on the greenbelt”.

Breaking News!

It doesn’t matter whether you are in or out of PfE that risk is still there.  Trafford’s rejection of a Battery Energy Storage System (BESS) on retained Green Belt has been approved on appeal by the Planning Inspectorate, despite participation in PfE that supposedly gave protection to that land!

Given the £millions of public money spent on Places for Everyone over the more than 10 years it took to bring the plan to fruition, why hasn’t the media picked up on this issue and who is auditing this failure to achieve even the basic aims of the plan?

Places for Everyone is supposed to be a brownfield first plan, it is supposed to protect retained Green Belt from development, it is supposed to help resolve the housing crisis in Greater Manchester. 

It does none of those things!

Green Belt allocations are coming forward across the region (much reported in local press and the MEN) and are being approved in advance of all the swathes of brownfield land available for development (despite huge amounts of public money being made available to regenerate that previously developed land).

Retained Green Belt is not protected by participation in the PfE plan. In the particular case mentioned above, the Planning Inspector used the Government’s ‘Grey Belt’ rules to assert that it is appropriate development.  There were no concerns raised about the number of fires that have occurred on such developments, including the BESS fire in Liverpool that burned for 59 hours, or more recent fires in Essex and Aberdeen.  At least there will be plenty of water available from the River Mersey should a fire break out, but All Saints Catholic Primary school is just down-wind of the site, so alarms should be raised to alert the school and local residents if a fire or the associated toxic fumes are released.  Nothing was mentioned about this by the Planning Inspectorate, which seems to be blindly allowing as much development as possible to support the Government’s war on nature and communities.

There are many ways to resolve the housing crisis, none of which require the release of Green Belt.  These are outlined in the Community Planning Alliance Homes for Everyone Report. 

The Government and Greater Manchester’s leadership are explicitly ignoring the data that shows:

  • There is sufficient brownfield land available to deliver at least 1.2m homes nationwide
  • There are 1.55m empty homes across England and Wales (including 70,000 homes owned by councils and housing associations)
  • There are an estimated 165,000 empty commercial properties that could be turned into houses and/or flats
  • More innovative solutions could also be looked at, such as promoting the 26m empty bedrooms in the UK that could provide income for the householder and a place to live for someone on a waiting list.

Shockingly, there are many sites which have been granted planning permission but have not been developed that could provide over 1m new homes – yet there is no impetus from the Government to ensure these sites are brought forward BEFORE any Green Belt is released.

Finally, the biggest issue with the housing crisis is the lack of genuinely affordable homes (social or Council housing).  This is an issue that has been disregarded for many years and the current Government has not even set a target to ensure Councils increase the number of these homes to address the huge and growing waiting lists.  Places for Everyone should have been renamed ‘Places for those who can afford to buy’ because the target for all affordable housing was removed from policy during the modifications process and the target for social housing was removed from the plan altogether!

We have frequently highlighted the impact on nature’s recovery, climate mitigation and our future food security when Places for Everyone was adopted by the Greater Manchester leadership in March 2024.  The consequence of the loss of environmentally and ecologically rich Green Belt land which provides all these benefits, along with the other issues set out above, shows the extent of the betrayal of future generations that is now becoming increasingly obvious.

The Planning and Infrastructure Bill (published by the Government on 11th March 2025) intensifies the Government’s war on nature and communities by reducing democracy and weakening protections for flora and fauna.  It introduces Spatial Development Strategies, similar to Places for Everyone, but without the consultation previously required.  We’ll say more about this in a future blog, but it appears to be yet another Developer’s Charter, as someone else succinctly put it – another Government initiative providing

Developer Net Gain!

New Carrington Transport Strategy

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Lorraine Eagling looks at what the Strategy means to residents given today’s traffic volumes!

It’s without question that a transport strategy is desperately needed by the residents of Carrington, Partington, Sale West, Warburton and Ashton on Mersey even before the plans for New Carrington get underway, so it was encouraging when Trafford Council published The New Carrington Transport Strategy but very disappointing that no residents had been involved in its development.   

The residents of these isolated and poorly served towns have long been promised and waited for a plan that provides the transport solutions they deserve, that are sustainable and will provide long term options for existing residents and for future generations.

The Strategy describes all the sustainable options (scenario 3) that would provide residents with regular and reliable connectivity to the rest of Manchester.  Solutions that would provide the residents with access to trains and trams and reduce traffic on local roads.   The Strategy goes on to explain, however, that these long-awaited public transport services are not an option because they are too expensive to implement and the only affordable option is a relief road, now expected to cost a minimum of £76.5m (and that is before any resident requirements such as additional junctions, crossings and traffic calming measures, for example are included in the design). Reminiscent of Bullseye’s infamous phrase ‘look at what you could have won!’, residents have once again been let down. 

The proposed relief road will run along the existing A1 Road, which starts opposite the Saica paper factory, to Isherwood Road.  From here a new road will be constructed adjacent to the peat moss and across the farmland to meet the Carrington Spur Road at the junction with Carrington Lane in Sale West.  The new section of the road will have massive implications to the environment. More details about the impact of the CRR can be found at this link, where you can look at our many previous blogs about the Carrington Relief Road by scrolling down the web page.

It’s a very disappointing outcome and it is questionable when the following is taken into consideration:

  • There is no mention of HGV traffic anywhere in the report.  As we know, the huge number of HGVs is the main concern for residents in Carrington Village and beyond.
  • The traffic data used in the report is taken from TfGM 2017 base year, which is outdated and pre-covid.  Considering the implications of this Strategy, the data should be current.  It is not clear whether any actual traffic monitoring has been done at key locations in order to access what road interventions would have the greatest benefit.
  • In addition to the outdated TfGM data, the Strategy interpreted daily travel modes from evidence of what it describes as ‘comparable brownfield’ development sites in South Gloucestershire, including areas of Stoke Gifford, Bradley Stoke, Patchway and Filton, on the northern edge of Bristol.  These sites have their own train stations and are home to industries such as aerospace and hi-tech engineering.  This is hardly comparable to New Carrington, Partington, Warburton and Sale West, where there are no train stations and the main industry is HGV intensive warehousing and logistics.   Also, New Carrington is not just brownfield, it is green belt, comprising peatmoss, woodlands, wetlands and grade 2 agricultural land.

What about the traffic data?

We have been collecting our own traffic data at key junctions in Carrington and Sale West for several years, but to verify the figures in the report, we collected some specific data in February and March 2024.   The results of our survey are as follows:

Cars and Vans

Table 1 shows the average number of cars per hour, during peak times, at the junction of the Carrington Spur and Carrington Lane in Sale West.  The red data was recorded during school term time and the blue data was recorded during school holidays.

As expected, the number of cars increases around this junction during term time.  The data shows during term time there are almost four times as many cars travelling from the M60 to Sale West.  Also, the number of cars travelling from Carrington to Sale West is more than double during term time and the number of cars travelling from Sale West to Carrington is more than tripled.    

On average, a total of 2,728 cars pass through this junction during peak times.   During term time, 48% of the car traffic from the M60 is heading towards Sale West and 43% of the traffic heading towards the M60 is from Sale West.  Additionally, 39% of the traffic from Carrington is heading towards Sale West and 47% of the traffic from Sale West is heading towards Carrington.

Other observations at this junction are:

  • Traffic queuing along the Carrington Spur Road from the M60.
  • Traffic queuing along Carrington Lane towards the M60.
  • Other routes were flowing freely.
  • 2 buses maximum during the survey period.

Table 2 shows the average number of cars per hour during peak times at the junction of the A6144, Flixton Road and Isherwood Road in Carrington.  The red data was recorded during school term time and the blue data was recorded during school holidays.

As expected, car traffic increases during term time, with the exception of those vehicles headed towards Isherwood Road.  During term time the car traffic from Carrington to Flixton increases by almost five times.  62% of the car traffic from Carrington is headed towards Flixton.  It is also interesting to see that 36% of the traffic headed towards the M60 is from Flixton.

Other observations at this junction are:

  • All traffic was flowing and there was no queuing at any junction.
  • Some traffic was travelling at excessive speeds, including HGVs.
  • 3 buses maximum during the survey period.

According to the data in the Transport Strategy, 875 cars travel from Partington and Carrington to Urmston (the report does not mention Flixton) on a daily basis.  We recorded 678 in one hour during one peak time and 282 and hour during non-peak time.  It suggests that the data in the report is an underestimation for traffic moving in this direction.

The data in the transport strategy is not as specific as the data we collected but assuming the traffic from Carrington and Partington heading to ‘Sale West’ and ‘10km inside GM’ is the traffic headed towards M60, then their data suggests there are 10,587 cars per day travelling along the A6144 between Isherwood Road and the Carrington Spur Road.  Our data shows 663 cars during peak time and 502 cars during non-peak time per hour.  Assuming two peak times and 10 hours of non-peak traffic, that is a total of 6,346 cars travelling along this route.  This time, the data in the report seems an over-estimation for cars travelling along this section of the A6144. 

We will repeat our traffic count in the coming months, to test the validity of this result.

HGV Traffic

The data shows that during peak times there are approximately 152 heavy goods vehicles at the Carrington Spur junction and 213 at the Isherwood Road junction per hour.   At non-peak times, there are 208 and 206 respectively.  This suggests that HGV traffic is consistent irrespective of peak or non-peak times and is in excess of 2,000 per day. This figure will increase significantly as the proposed new warehousing is built.

Conclusions

Our data shows that:

  • The A6144 Carrington Lane in Sale West has as much car traffic as the A6144 in the direction of Carrington, as 48% of the traffic from the M60 turns towards Sale West during peak times.
  • The A6144 between Isherwood Road and the Carrington Spur has less car traffic than that suggested in the report.
  • There was no queuing traffic at the junction of the A6144 and Flixton Road during peak time. There was, however, significant queuing on the Carrington Spur and on Carrington Lane.
  • There is a massive increase in car traffic during term time indicating that there is insufficient public transport for students to get to school and a large proportion of students are travelling to schools from either outside the catchment area or from outside the borough.

Considering the findings of this data, how will the relief road reduce the traffic issues highlighted?

The biggest issue for the residents of Carrington Village has always been the large number of heavy goods vehicles that pass their front door every day.  The existing A1 Road could be opened immediately to redirect HGVs away from the village.  This would be a quick win (if the businesses in Carrington are willing to use that road).

Partington is experiencing housing development on a huge scale.  The new developments on Lock Lane, Hall Lane, Oak Road, Heath Farm Lane and the Greyhound will create another 1,291 dwellings.  Despite these developments increasing the number of houses in Partington by 38%, the routes in and out of Partington will remain the same.  Only after the cars and buses have contended with the congestion in Partington itself, can they access the proposed relief road further along the A6144.

For residents in Sale West and Ashton on Mersey to benefit from the proposed relief road to Carrington, they will have to access it from Carrington Lane which is already heavily congested even before the new relief road joins this junction. 

In essence, residents in Carrington Village will only benefit if HGV traffic moves onto the existing A1 Road.  Residents in Partington, Sale West and Ashton on Mersey will have to queue in traffic in their towns before they can access the relief road.  The new relief road, which will cost at least £76 million offers no relief to these residents who will see the population in their area increase significantly as a result of the Places for Everyone Plan.  There will be an additional 2,260 houses in Partington and Warburton, 1,443 in Sale West (in addition to the 263 already with planning permission) and 603 in Carrington Village. 

So how can this Transport Strategy justify such significant expenditure on a road that offers no solution to traffic issues that already exist? 

There are other considerations here too: 

  • Why hasn’t the A1 Road already been opened to HGV traffic to resolve the issues in Carrington Village? 
  • Why are so many students being driven to school? 
  • Do the school admissions policies in Trafford need reforming?
  • Does the Education authority or TfGM need to look at providing school buses? 

The data shows that it is school traffic and heavy goods vehicles that create the congestion along the A6144.   These are the issues that need addressing rather than spending £76 million on a scheme that will not solve the transport issues that have plagued this area for decades.  This money could contribute towards the ‘scenario 3’ solution in the Transport Strategy and should be invested in long term, sustainable passenger and freight transport interventions. 

There are several options that could be considered, such as:

  • opening the railway bridge between Irlam and Partington to give residents access to trains
  • opening up the ‘greenway’ and the former railway line from Partington to Altrincham to give residents access to trams
  • revisiting the 2012 Local Plan option to build a bridge from Carrington to Port Salford. 

These are long term sustainable options that will reduce congestion and open up Greater Manchester and the rest of the UK to residents of these local areas.

What we need is a Transport Strategy that meets residents’ requirements, why isn’t Trafford talking to us about it?

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.

Is the New Carrington Allocation Aligned with Trafford’s Corporate Plan Priorities?

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The short answer is NO!

At a recent Trafford Executive Committee meeting (11th December 2023), the leader of the Council introduced their report about performance against the Council’s Corporate Plan, 2023/24.

On the positive side, the Council has a wide range of responsibilities and there are areas for which Officers and Elected Members should be congratulated but ………..

the report highlights (paragraph 1.6) that

“The priorities for 2021-2024 are described as ‘better health, better jobs, greener future’ as outlined below:

Reducing Health Inequalities
Working with people, communities and partners, particularly in deprived areas, to improve the physical and mental health of our residents.
Supporting people out of poverty
Tackling the root causes to prevent people from falling into poverty and raising people out of it.
Addressing our Climate Crisis
Leading the way in our region’s response, reducing our carbon footprint and tackling the impact of climate change”.

So, how does the New Carrington Allocation fit with those priorities?

It contradicts each of them!

Reducing Health Inequalities:

Carrington Moss currently provides deprived communities with a huge area of free to access green space, which will no longer be available due to the proposed development of 5,000 homes, 350,000 m2 warehousing and the plans for 4 major new roads. The moss currently has:

  • almost no traffic, so no air, noise, light, vibration or water pollution – fresh air to breathe (for both humans and wildlife), a peaceful environment for those with anxieties or other wellbeing issues, an area where you can hear and see red listed birds and other endangered wildlife, encouraging outdoor activities and hobbies that improve the health of local people
  • local residents participate in a number of sporting and recreational activities on Carrington Moss, including those professional athletes and children attending the Manchester United or Sale Rugby training grounds, the horse riders who use many of the circular routes (there are over 1,000 horses stabled on or around the moss) and the walkers, cyclists, bird watchers, nature spotters, photographers, artists ….  the list goes on!

Supporting people out of poverty:

  • in the plans for the area, there is only one transport option being funded and prioritised – and that is a new road!  So, those in transport poverty (and there are many in the local area who cannot afford to run a car) will have no benefits from this allocation (Trafford itself describes the area as currently having poor public transport provision)
  • furthermore, the only job opportunities being provided by the allocation are warehousing, which is very limiting in terms of both career choices and wages
  • and those currently working in the rural economy in the area (and their supply chains) will have their job or volunteer opportunities decimated or eliminated entirely!

Addressing the Climate Crisis:

  • the current habitats on Carrington Moss are essential to support the mitigation of climate change and the achievement of Trafford (and the region’s) carbon neutral ambition
  • these habitats include the 335 hectares of peat moss itself (which can be restored to capture and store huge volumes of carbon), Grade 2 agricultural land (which is perfect for growing crops to support the food security of current and future generations), large areas of woodland (which again are a great carbon store and provide shelter and food for the red listed birds and endangered wildlife) and wetlands (which capture and store huge volumes of surface water, that will have to be directed elsewhere when the area is concreted over
  • there are also a number of sites of biological importance and sites of special scientific interest on and around Carrington Moss, these are extremely important for conservation and nature’s recovery.

In addition to all of these benefits, Carrington Moss also has fantastic historical value.  Obviously, the peat has been forming for thousands of years, horses have been ridden over the moss since medieval times, the Victorians used it for dumping night soil and waste (the remnants of the train tracks remain) and, in the Second World War, it was used as a decoy bombing site to save the centre of Manchester.  As typical flat peatland terrain, it also boasts expansive views (you can see the hills over 20 miles away on a clear day).  Imagine the future, with those views changed to HGVs thundering down the planned new road and 22m warehouses blotting out everything else in the landscape!

Paragraph 1.9 of the Council’s report confirms that a “new Corporate Plan is expected for July 2024”.  Given the Places for Everyone Plan significantly reduces the protections brought in by the 2012 Core Strategy, ignores the advice of Natural England and unnecessarily decimates the largest natural capital asset in Trafford, can we expect a similar weakening of Trafford’s future corporate plan priorities? 

Time will tell!

PS The Greater Manchester Combined Authority has published the responses to the Places For Everyone modifications consultation, our friends at Steady State Manchester have included the link in their short blog, available here.

PPS The Friends of Carrington Moss are working with other Greater Manchester groups to determine the next steps in our campaign to prioritise brownfield development across the region (and let’s face it, there is a lot of brownfield land that could be used, and GM has received significant public funding to regenerate it)!  We’ll keep you updated as more information becomes available.

Carrington Moss – once again supports local residents

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Capturing and storing huge volumes of water, reducing the risk of our rivers bursting their banks as frequently as they otherwise would do! 

The ditches are full and Carrington Lake has reappeared, the water is extensive and deep, so take care when you are out and about, especially if visibility is poor.

With flood warnings relating to Storm Henk being issued today, it is useful to remind local residents of the many ecosystem services delivered by Carrington Moss (also known as the Moors to some local people) and the extensive natural capital benefits the area provides.

Trafford’s Natural Capital Account states that “a natural capital approach is about everyone understanding the benefits – ensuring the protection and enhancement of natural assets are fully considered in decision making”.  So, the Places for Everyone (P4E) plan should have taken full account of the natural capital value of peat, for example, incorporating all the ecosystem services it provides, and the plan should have evaluated all the other natural capital benefits and ecosystem services of the Green Belt land to be released if the P4E plan is adopted as currently proposed.

The extensive natural capital assets at New Carrington include its:

  • soil resources (the peat mass and the Grade 2 best and most versatile agricultural land)
  • vegetation, including extensive woodlands, hedgerows and other plants
  • natural flood management and carbon capture capabilities
  • ecological corridors, which sustain the habitats of over 25 red listed birds and a number of endangered/protected wildlife species, insects and reptiles
  • ability to reduce the impact of air, noise, light, vibration and water pollution in the surrounding areas
  • active travel routes, which are used extensively for walking, cycling and horse riding (there are over 1,000 horses stabled on and around Carrington Moss)
  • access to nature-based recreational activities which provide physical and mental health benefits to local communities, including social prescribing
  • access to nature-based volunteering activities and outdoor learning for schools
  • preservation of heritage assets
  • extensive landscape views, which are typical of lowland mossland habitats.

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

The plans for development on Carrington Moss will cause significant harm to its natural capital assets and we do not believe a comprehensive evidence base has been assembled (contrary to the statement in P4E document 07.01.25, paragraph 1.8).  The majority of the natural capital assets within the New Carrington allocation area have not been measured and there are many data omissions in the P4E documentation. 

Our public bodies appear to have no understanding of what will be lost as a result of the unnecessary and unsustainable plan to release our Green Belt.  Trafford’s current plan includes the destruction of historic wetland habitats, then the creation of new areas of wetland.  This is totally irrational, does not make either ecological or financial sense, will require funding from the public purse, and would not represent the best value for public money.

Neither Trafford, nor the GMCA, have undertaken an assessment of the consequential loss of natural capital assets or the impact to ecosystem services that will occur if the P4E plan is adopted as currently proposed.  This is despite GM’s 5 year Environment Plan (5YEP) setting out the responsibilities for Local Authorities, which appear to have been ignored, including:

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

The 5YEP also aims to prioritise action to “protect, maintain and enhance our key natural assets”, including restoring “50-75% of our peatlands” (odd, then, that Trafford plans to destroy a 335 hectare peat moss).  

How local residents can support Carrington Moss

With all the above in mind, please take the time to sign and share our petition asking the Secretary of State to review the Places for Everyone Plan as it does not bring any benefits to local residents and could result in severe consequences, including the increased risk of future local flooding!

A total lack of understanding!

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Feedback from the Executive Discussion about P4E

Some very interesting points arose at the Executive meeting (held on 25th September) which approved the Places for Everyone Modifications Consultation

Councillor Patel, for example, suggested that Green Belt campaigners have taken a “narrow view of how future development can be accommodated”.  This is utterly untrue, totally uninformed and highly insulting.  Green Belt campaigners have used their own time, their own money and their own, and independent, expertise / advice to consider ALL aspects of the Plan.  The Chair of the Friends of Carrington Moss was one of the very few people to attend ALL of the Examination Hearings about the thematic policies.  To describe the work of this and other Green Belt groups as narrow demonstrates the complete lack of engagement the ruling elite has had with the community, and their unwillingness to conscientiously consider the feedback we have been giving (contrary to the Gunning Principles).  

The same is true of our concerns about the lack of evidence that has been provided. 

Let’s be clear, a development of 5,000 homes is a new town and should have been subject to much more detailed scrutiny.  Partington currently has around 3,500 households.  It will be dwarfed by the proposed new town and the requirements of the new community.  The New Carrington development is the largest in the Places for Everyone Plan, representing 25% of Trafford’s housing requirement, the vast majority of which will be built in just one Trafford Ward!

The main report, which can be found in the papers for the Executive Committee at this link, sets out a series of implications of the Places for Everyone Plan.  It is a very misleading set of indicators. 

Indeed, Councillor Coggins raised the greenwashing in the report, particularly in relation to the carbon emissions.  Councillor Patel felt that it would be difficult to summarise in a short paragraph but it is important that such momentous decisions (this is a 17 year plan), that will have a huge impact on current and future communities should be based on an honest and transparent assessment of the implications. There is more information about the carbon emissions implications in the analysis below.

Councillor Coggins raised a number of questions on behalf of the Friends of Carrington Moss, to which Councillor Patel suggested that FOCM should put their questions to the Executive so they can make a detailed response.  We would be delighted to do so, but other emails sent to Councillors have resulted in no response from the Executive. 

The recording of the Executive Committee can be found at this link.  The item about Places for Everyone starts at 4:57 and the discussion lasts for around 40 minutes.

Read on for a more detailed analysis of the content of the Executive meeting.

Councillor Patel’s opening presentation, sadly, focused on the spin, suggesting that:

The plan is “the best route for a sustainable future for Trafford”Incorrect given Trafford is proposing development on a peat moss, Grade 2 agricultural land, woodland and wetland habitats, without committed funding for public transport and/or sustainable freight.
There is “huge public interest in the plan’s adoption”There is huge public interest in removing the Green Belt allocations. There were, for example, 27,000 responses objecting to the release of Green Belt in 2016, these objections have not subsided.
Implementation of the plan represents:

“sustainable regional growth”

“better future for communities”

“tackles the housing crisis”

investment “in skills, jobs and productivity”

a “robust strategic framework of environmental protections, including nature’s restoration and significant enhancements to biodiversity across GM”		Sustainable! – when the growth is the equivalent of creating two new boroughs in GM?
Communities will suffer from the impact of increased air, noise, light, vibration and water pollution!
The housing crisis is the lack of social housing – the affordable housing target has been removed from policy!
The investment in jobs in New Carrington is limited to warehousing!
A robust framework that proposes development on a peat moss, Grades 1, 2 and 3 agricultural land, woodland and wetland habitats!
There is not one single allocated site in the whole of Places for Everyone with a purpose of enhancing nature’s recovery!
The plan will “maintain a new and defensible Green Belt which will endure beyond the plan period”Local Authorities can release more Green Belt in their Local Plans – the previous commitment preventing this was not included in P4E Policy.
P4E “will support GM’s plan to be carbon neutral”Incorrect – see this analysis of the carbon implications of P4E, which shows that the 2038 carbon neutrality objective is unlikely to be met, something which has been recognised in the GMCA’s own progress report and in their Overview and Scrutiny Committee report
The “Inspectors have rejected a number of the proposed new additions to the Green Belt”An interesting way of phrasing the situation, which has led to an increase in Green Belt release.  The legal issue that required Green Belt Additions to be removed from the plan was raised by Peel in their regulation 19 consultation response.  The GMCA initially categorised the response as “No Change Considered Necessary” but in March 2023, the GMCA confirmed that 32 of the 49 Green Belt Additions did not meet the exceptional circumstances test required.
The “removal of an overarching GM affordable housing target” has “been replaced with site specific allocations reflective of local needs and viability”Again, an odd way to phrase the removal of this key principle in the plan.  The site specific allocations always had an affordable housing target. In fact, the New Carrington affordable housing target was previously 30% but has now been reduced to 15% (the Planning Inspector refused to allow Trafford to remove it altogether, although this was proposed). Later in the meeting Councillor Patel suggested that the Inspectors had requested the Affordable Housing target be removed from policy but this is incorrect, this modification was proposed by the GMCA.
Green Belt has dominated the debate and has been detrimental to the overall understanding of the planIt has not been detrimental to the understanding of the overall plan for those us who have been fully absorbed in it over the last several years.  Given that 27,000 residents objected to the release of Green Belt in 2016, it should be no surprise that a plan that persists in unnecessarily demanding the loss of nature/biodiversity-rich sites continues to be challenged.
Brownfield and urban development will play the most significant part in land identified for developmentOf the warehousing developments (for which GM has added a 75% buffer/contingency to their requirements), 49% will be built on unsustainable Green Belt locations.
For housing, there is sufficient existing brownfield land supply to build a number of homes that is the equivalent of creating 2 new boroughs in Greater Manchester.
Green Belt release is unnecessary and unsustainable!
“in order for the right mix of homes and jobs to be built in the future, some Green Belt release is necessary”So, a plan that only focuses on market housing and warehousing is the right mix of homes and jobs?  That is not the view of many in the community.  No targets for social housing, no identification of land to support gypsy/traveller/student communities and no aspirations for the rural economy (despite rural areas comprising almost 50% of Greater Manchester’s land).
This Administration considers this is an acceptable ask of the Green Belt in order to provide the land supply needed to address the housing crisisHow many homes for social rent (which is the housing crisis given that considerably more market houses have been built than households formed) are planned for the Green Belt? 
This will be monitored but we believe it will be NONE!
If tackling the housing crisis is the key consideration, why is Green Belt land being sacrificed for warehouses?

Councillors supporting the development also made some rather misleading statements:

Councillor Williams stated that “in unlocking the Carrington site for development we will be able to see one of the largest single brownfield sites in Greater Manchester unleashed for residential housing development”Incorrect, the brownfield sites already have planning approval, which has been given outside of Places for Everyone (around 1,200 homes in Carrington and at Heath Farm Lane). It is the Green Belt sites that will be “unlocked” by the plan! In addition, the concerns of the Health and Safety Executive could restrict the regeneration of the brownfield employment sites.
Councillor Wright suggested that the people of Partington will have “access to good jobs through the creation of the Carrington Relief Road”Again this is incorrect.  Only warehousing jobs are being created at Carrington and these are not known for either their quantity or their high pay.  Access to jobs further afield will be impacted by the huge increase in traffic – 5,000 homes and 350,000 m2 warehousing will add a significant number of cars and HGVs to local roads and, as there is no commitment to funding for public transport, challenges with local school places and other council services, residents will continue to have limited choices.  There are no proposals at all for sustainable freight transport options. The existing Partington community, which has a much lower proportion of car ownership than elsewhere in Trafford, will not benefit in any way from the estimated £80m expenditure of the Carrington Relief Road!  Congestion will impact their travel even more in the future than it does today.
Councillor Patel suggested (in response to a question from Councillor Coggins on behalf of the Friends of Carrington Moss) that the Rural Economy was covered in the Examination Hearings and that the Executive do not believe that there is any specific risk to economic activity because of the planThis is both incorrect and astounding!
There is no mention of the Rural Economy in the plan, it was not discussed at the Hearings (other than confirmation that it is subordinated to Local Plans) and no evidence is included in the Examination database about the impact to the Rural Economy as a consequence of the plan. 
If Trafford has evidence that there is no specific risks to farming, stabling and other rural businesses (and their supply chains), the data that confirms this should be shared.  Loss of Grade 2 best and most versatile agricultural land, loss of access to stabling, loss of supply chain contracts, etc cannot be achieved without a severe impact to those businesses!
In response to a question from Councillor Butt, Councillor Patel suggested that “the reference to Carrington Moss is not reflective of an extent of large peat reserves right across the site, it fluctuates tremendously and the area of deep peat resides in the centre of the site”In 1995 an academic study confirmed there were 325 hectares of deep peat at Carrington Moss (I’d say that is reflective of a large extent of deep peat)!  Natural England, the government’s adviser for the natural environment in England, do not agree with the development on the site and confirmed during the Examination that there is an inferred peat extent of 280 hectares on the site.  Whilst it is true that peat thickness does fluctuate, it should also be noted that the Heath Farm Lane Ground Investigations found that the “peat is relatively thick in this area (up to c. 2.5m)”.  This is on the edge of the site, not in the centre!

Councillor Ennis asked how convinced the Executive is that Trafford will get any Affordable Housing out of the plan.  Despite hearing the concerns of Councillor Ennis about the definition of the term “Affordable Housing”, Councillor Patel questioned “why local politicians would somehow object to a housing plan that will deliver such tremendous amounts of Affordable Housing”.  We think it is astonishing that the Executive have such confidence in the amount of Affordable Housing that will be delivered.  It is clear that communities will need to monitor that these and other aspirations are achieved given the Executive appear to believe developer behaviours will change.

Councillors Paul and Duncan from Manor Ward defended the peat moss and raised questions on behalf of Friends of Carrington Moss including a question about the lack of ecological evidence in the plan (given the size and scale of this development, such evidence should have been available prior to site selection).  Councillor Patel advised that she will circulate a detailed note in response to that question.  We hope it will be transparently available to residents.

Trafford’s Executive Committee to consider next P4E Consultation

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The next phase of the Places for Everyone Plan is for the GMCA to consult on the multitude of Main Modifications being made to the plan following the Examination in Public, which has just concluded.  The Planning Inspectors have confirmed to the GMCA that they are satisfied that the proposed main modifications (set out in PMM6/GMCA12.3.3) are necessary to make the Plan sound and legally compliant.

The formal process requires the Executive/Cabinet Committees of each participating District to approve the commencement of the consultation.

The Executive/Cabinet Committees are responsible for all key decisions and the strategic management of services in their Authority.  You can find out more about the Trafford Executive here. 

Save Greater Manchester’s Green Belt Group has written an Open Letter to all Councillors in the participating Districts to explain our concerns about the plan, providing factual information about:

  • the District data which shows why Green Belt release is unnecessary anywhere in Greater Manchester
  • why it is a discriminatory plan that has removed the Affordable Housing Targets from policy
  • the huge impact on carbon emissions and climate mitigation opportunities, including the lack of ecological evidence
  • the intention to unnecessarily release Green Belt on the day the plan is approved (meaning Brownfield first is no longer the aim)
  • what the Census 2021 data tells us (really demonstrating that the proposed level of growth is excessive).

The effect on local residents as a consequence of the New Carrington Allocation is exacerbated by the following:

  • no sustainable freight transport options have even been proposed, despite the proximity of the Manchester Ship Canal and a former railway line, this will lead to thousands of additional HGVs on local roads!  
  • no committed funding for sustainable passenger transport in an area that is currently very poorly served
  • the significant surge in air, noise, light, vibration and water pollution caused by the huge increase in traffic, including HGVs
  • the concerns raised by the Health and Safety Executive about the risks related to the COMAH zones in the area
  • the challenges relating to school places (which are already a red risk for Trafford), along with GP and dental surgeries (which are also struggling to meet current demand)
  • the impact for both current and future residents as a consequence of huge levels of surface water flooding that is currently captured by the moss
  • the drainage required for the development (which will impact the whole area, meaning that the 10 current SSSIs/SBIs here could be severely affected – decimating populations of over 25 species of red listed birds and endangered wildlife)
  • the viability of the site is marginal (which means that developers are likely to demand reductions in their contributions and the public purse will need to fund much more of the necessary infrastructure requirements).  

For information, we developed our own assessment of the public interest test relating to this development in our recent blog.

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