Communities are delighted that the Conservative Party continues to pledge to retain the Green Belt, despite Sir Keir Starmer’s recent vow to concrete it over!
But …….
That pledge does not secure actual protection for our Green Belt.
Despite the National Planning Policy Framework (NPPF) paragraphs 140 and 141 suggesting that ONLY WHEN “exceptional circumstances” are “fully evidenced and justified”, together with a demonstration that “all other reasonable options” have been considered, can Green Belt boundaries be amended, frequent approvals of Green Belt developments occur (including in our region).
Clearly those “exceptional circumstances” are not a hard test to meet!
Many communities nationwide are campaigning to protect Green Belt sites which comprise irreplaceable habitats (peat moss), Grade 1, 2 or 3 agricultural land, woodlands and wetland habitats. Our politicians are unnecessarily putting them under threat of development and the current environmental protections are just not robust enough, with the requirement to make “as much use as possible of suitable brownfield sites and underutilised land” (paragraph 141) a mythical aspiration rather than an objective of the NPPF!
Just one example of those poor environmental protections is the risk to Greater Manchester’s peat mosses (many of which are allocated for significant development in the Places for Everyone Plan).
The Government is taking a very slow pathway to protect peatland soils, despite the increasing recognition of the ecosystem services peat provides. Since 2009, there has been a commitment to Safeguarding our Soils, recognising that soils play a huge role in the fight against climate change (and helping us manage its impacts). In the 2011 Defra Natural Environment White Paper, the Government recognised the natural capital asset of soils. The 25 Year Environment Plan (published in 2018) restates the aspiration to manage our soils sustainably by 2030, including improving soil health and restoring and protecting our peatlands. More recently, the England Peat Action Plan (2021) sets out the Government’s vision to reverse the decline of our peatmosses. The aim is to prevent further loss of peatland habitats, to restore more peatland landscapes and the document recognises that rewetting peatland areas and returning them to their natural state could make a significant contribution to achieving our targets for reducing carbon emissions, as well as having other benefits for water quality, nature and flood mitigation.
Yet, there is still no moratorium on builds on peat mosses and no commitment to change in the recent NPPF consultation.
There have been many interventions from Natural England (which have been summarily dismissed by the GMCA). Yet, even though there is no actual NEED to build on these precious, irreplaceable habitats and despite every district declaring a climate emergency, some of Greater Manchester’s most important natural capital assets are at risk of destruction!
What about Sir Keir Starmer’s commentary?
The Labour Party position is not a surprise to those of us based in Greater Manchester. The Save Greater Manchester’s Green Belt Group wrote to Sir Keir in January 2023, copying members of his Shadow Cabinet, GM’s Labour Mayor and Labour MPs (you can read our letter at this link). To date, we have received no acknowledgement nor a reply from any of the recipients.
Clearly engagement with communities is not a priority for them.
In fact, as a member of a recent Question Time panel (27th April), Lisa Nandy confirmed (in a discussion about housing), that the Labour Party are working with developers, investors, Councils and planning authorities. She made no mention of working with communities.
In this Times article Sir Keir says “Labour would give councils and residents more power to build on green belt land to meet local housing need”. He continues “It’s important for local areas to have the power to decide where housing is going to be”.
In fact, as mentioned above, Local Authorities are already able to make changes to, or build on, land designated as Green Belt. Conversely, residents have NO power within the planning ecosystem!
Research by CPRE highlights that only 1 in 10 homes on the Green Belt are classed as affordable (using the current NPPF definition). The same report suggests that the density of homes built on the Green Belt land has remained at just 14 dwellings per hectare. This is a quarter the density of developments outside of the Green Belt.
In Labour controlled Greater Manchester, 27,000 residents opposed Green Belt development in the first consultation for the spatial plan in 2016. What is now the somewhat disingenuously named Places for Everyone is currently being examined by Planning Inspectors and aims to release 2,430 hectares of Green Belt.
Residents still oppose it but our Labour Councils, the Labour Mayor and Labour MPs are not listening!
As mentioned above, and, as outlined in our letter to Sir Keir, there is no actual NEED to build on the Green Belt, not just here in Greater Manchester but the nationwide picture reflects a similar story.
Communities are confused by the commentary from politicians and others in relation to land use. The assertion that there is a backlog of 4.3 million homes is typical, yet the facts do not bear out misleading statements such as this. Political rhetoric repeats these fictional assertions, yet as the following infographic shows, there is not only a surplus of market homes, brownfield is not being prioritised, homes are allowed to remain empty, despite over 1.2m people on the housing waiting list and developers are allowed to hold on to land with planning permissions without building the approved developments.
Let’s look at that “rigorous site selection process”!
Given the very recognisable challenges and the extensive harms to be caused by development here (see our previous blog), how was New Carrington chosen?
Well, we would suggest the P4E Site Selection methodology was flawed. For a kick off, it ONLY looked at Green Belt sites (despite the supposed focus on brownfield preference), it did not consider ecology or biodiversity issues until Stage 3 of the process, once most of the sites had been filtered out (and, even then, it did not provide any assessment data) and it did not consider natural capital value at all (despite the Government’s recent devolution deal describing Greater Manchester as a “trailblazer” in that area – see paragraph 226).
Site Suitability
The graphic below shows how the New Carrington parcels comply with the Site Suitability Criteria and clearly demonstrates that the area is not suitable for development! In fact, Criterion 5 on the table below should be coloured red too, given the lack of available school places and poor access to health services in the area (the assessment was based on the site’s proximity to facilities, not the capacity of those facilities to support additional residents).
Criteria 4 and 7 have been assessed based on current land use. So, it is not a surprise that Criterion 4 (Health and Wellbeing) is green. The area is heavily used for walking, cycling, horse riding and other outdoor activities, including formal sports. If the development is approved, this criterion will no longer be green because people will find it unpleasant, unhealthy and unsafe to walk, cycle and horse ride next to the planned four major new roads. These roads will fracture existing public rights of way (and ecological corridors) and will hugely (and negatively) change the experience of those active travel trips (people will no longer be breathing fresh air, or listening to bird song, for example).
Criterion 7 (air quality) will significantly deteriorate as a consequence of the planned development too.
Site Selection
Turning to the site selection criteria, it is incongruous that there were no criteria which considered the P4E Strategic Objectives for improving the quality of the natural environment/green spaces (Strategic Objective 8) or for ensuring access to physical and social infrastructure (Strategic Objective 9). When compared to the first 7 Strategic Objectives, the graphic below demonstrates the total lack of weight given to these two critical Strategic Objectives (and Strategic Objective 10, Health, does not fare much better, with just one site selection criterion being applicable).
The National Planning Policy Framework (NPPF) suggests (paragraph 8) that, to achieve sustainable development, three overarching objectives need to be considered:
a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being
c) an environmental objective – to protect and enhance our natural, built and historic environment; including making effective use of land, improving biodiversity, using natural resources prudently, minimising waste and pollution, and mitigating and adapting to climate change, including moving to a low carbon economy.
The site selection criteria are clearly not consistent with that NPPF requirement.
Furthermore, treating the huge area covered by the New Carrington Allocation (1,153 hectares) as one site means that the site selection criteria are considered attained even if much of the location does not meet those criteria. We set this out in the table below:
Criterion 1 – Land which has been previously developed and/or land which is well served by public transport
We know no part of New Carrington is well served by public transport and only Carrington itself has some previously developed land but despite the Allocation boundary stretching to cover Partington, Sale West and Warburton, the whole site is considered to meet this criterion.
Criterion 2 – Land that is able to take advantage of the key assets and opportunities that genuinely distinguish Greater Manchester from its competitors
In New Carrington’s case, this relates to Port Salford, which is, of course, only close to the Carrington part of New Carrington as the crow flies. There are no direct links. Despite this, Trafford consider the site to meet this criterion.
Criterion 3 – Land that can maximise existing economic opportunities which have significant capacity to deliver transformational change and / or boost the competitiveness and connectivity of Greater Manchester and genuinely deliver inclusive growth
Given that much of the employment land (74%) is brownfield, economic opportunities can be maximised at New Carrington without releasing Green Belt. Trafford suggests the Carrington Relief Road will be transformational for Partington, but this is not the case. There are few, if any, benefits for Partington, Sale West or Warburton residents (and only minimal benefits for Carrington residents). What would bring huge benefits to the Allocation area would be the reopening of the railway line – but Trafford is not even considering this.
Criterion 4 – Land within 800 metres of a main town centre boundary or 800m from the other town centres’ centroids
No part of New Carrington meets Criterion 4.
Criterion 5 – Land which would have a direct significant impact on delivering urban regeneration
As with Criterion 3, given the amount of brownfield land (74% of the employment land and 23% of the residential), urban regeneration can be achieved without releasing Green Belt. In fact, urban regeneration in Trafford, and beyond, could be impacted by releasing so much Green Belt here (as developers will focus on greenfield sites rather than bringing brownfield back into use).
Criterion 6 – Land where transport investment (by the developer) and the creation of significant new demand (through appropriate development densities), would support the delivery of long-term viable sustainable travel options and delivers significant wider community benefits.
The Viability Assessment suggests the Total Developer Contributions are only £66.7m, a paltry sum for such a huge development. This figure includes developer contributions to education and affordable housing. As we highlighted in our previous blog, the “necessary” transport interventions for New Carrington will cost a minimum of £400m, so it cannot be considered that this site meets Criterion 6. In addition, there are no sustainable freight transport options on the transport interventions list and it is hard to understand why the existing population (circa 30,000) is not considered to create sufficient demand to support the delivery of long-term viable sustainable passenger travel options. Community benefits from this allocation are minimal to non-existent!
Criterion 7 – Delivers significant local benefits by addressing a major local problem/issue.
The major local problem/issue for the New Carrington area is the number of HGVs on our roads. There is no plan to address this with sustainable freight transport. We do not consider this criterion to have been met.
The way to test our assertion that much of the site does not meet any of the criteria would be to split the Allocation into smaller areas (Carrington, Partington, Sale West and Warburton) and to consider whether each development parcel meets any of the site selection criteria. If they do not, those parcels should be withdrawn from the Plan.
Finally, in relation to site selection, Trafford chose to remove some sites that were previously Allocations within the GMSF. We cannot find any evidence in the P4E documentation which shows how and why sites were chosen for removal or to remain.
Given all the above, the Public Interest Test in relation to site selection cannot be considered to have been met. We believe this demonstrates that the site selection process is unsound and that New Carrington should be withdrawn from the Places for Everyone Plan.
An appraisal of the New Carrington plan shows that development here will NOT meet the Public Interest Test!
Some words we have heard frequently during the Places for Everyone (P4E) Hearings is that the Plan is “Reasonable”, that, with the “Planning Balance” in mind, the Allocations should be approved and that the proposals meet the “Public Interest Test”.
At the very heart of considering these issues is an assessment of the benefits of a proposed development and the relative harm it would cause, looking at the advantages and disadvantages, analysing information, which should be available for both sides of the scale, and considering the long-term impact of the scheme. The overall outcome being an understanding of whether the Public Interest Test has been met by proposals in the Plan.
So, what about Places for Everyone and the New Carrington Allocation?
Now, we appreciate new homes are needed in Greater Manchester (GM), particularly genuinely affordable homes (social housing). Jobs are vital too, not only for the economy but also to ensure individuals are able to meet their obligations and, hopefully, achieve some of their aspirations. Residents also need access to school places, health services and community facilities.
On the other side of the scale, we also fully understand the importance of our Green Belt and all the natural capital and ecosystem services it delivers. Given the climate emergency, mitigation is essential. We recognise the need to reduce GM’s carbon emissions and to ensure residents are not exposed to high levels of air, noise, light, vibration or water pollution. We must also consider that all development should be demonstrably sustainable (something we discussed in a previous blog).
National planning policy states that “At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs”.
Flooding, for example, not only damages property, it impacts the mental and physical health of both human and wildlife populations. With this in mind, the wetlands at Carrington Moss should be retained to continue to deliver the ecosystem services they have done so well, for so many generations. In addition, the superior carbon capture capabilities of restored mosslands could be achieved here, bringing numerous ecosystem benefits.
In summary, the graphic below highlights that New Carrington does not meet the Public Interest Test, as the levels of harm far outweigh the benefits accrued.
Considerations of the weightings given to the Level of Benefit and the Level of Harm in this graphic are set out in the detailed paragraphs below
Residents, and their views, have been supported throughout the P4E Hearings by a number of MPs, including, for example, Trafford’s Sir Graham Brady (who can be heard here at the New Carrington session) and Salford’s Barbara Keeley MP (who can be heard here). Our MPs raised a number of very important points which highlight that the Public Interest Test has not been met on the sites they are discussing.
These are all very important issues for existing local residents, whose objections to this Plan have been resoundingly ignored. In addition, the GMCA have made substantial changes to the version of P4E that has been consulted upon, weakening a number of Policies and removing over 520 hectares of Green Belt Additions (which were proposed in part as compensation for the extensive Green Belt release) with no notice or scrutiny of the decision.
As we have said before
Given there are no other places in Trafford where we can:
restore peat, to more effectively capture and sequester carbon, so future generations can breathe cleaner air
grow crops and alleviate surface water risks, so our descendants have fresh food, with a low carbon footprint, and residents are not fearful of flooding every time it rains
increase significantly the populations of endangered birds and wildlife, to help nature’s recovery, increase biodiversity and mitigate the impact of climate change
this rich habitat, known as Carrington Moss, with a long history of extensive surface water flooding, should not have been included in the P4E Plan for development, but could have been highlighted for protection.
We, therefore, disagree that the Planning Balance has been achieved in favour of development at New Carrington and strongly believe it would be unreasonable to release the land from Green Belt here.
All in all, the harms extensively outweigh the benefits of this Allocation. So, for the reasons summarised in the graphic above, and set out in more detail in the paragraphs below, an analysis of the New Carrington Allocation resoundingly demonstrates that the site does NOT meet the Public Interest Test.
Read on for more information about those pros and cons:
Housing
This local analysis used Census and ONS data to highlight that more houses are being built in GM than the number of households being formed. Trafford, for example, built almost 3,000 more homes, during the 10-year period, than the number of households created (and that figure excludes the empty homes brought back into use). The data also draws attention to the Government’s defective 2014-based formula, which significantly over-estimates housing need requirements. P4E confirms that GM has sufficient existing housing land supply (without releasing Green Belt) to exceed the Government’s overstated calculation.
GM’s existing land supply is sufficient to meet the needs of an additional population of around 400,000 new residents, the equivalent of two new boroughs in GM, representing huge growth on the projected population increase of 158,200.
In addition, more brownfield land comes forward for development every year. The importance of these windfall sites is demonstrated in the recent CPRE State of Brownfield report, which singles out the North West and Manchester as places with high brownfield capacity. At New Carrington 23% of the land for residential development is on brownfield (so the release of Green Belt is not necessary to achieve the benefits of those developments, they already have planning permission).
Windfall: sites which become available for development unexpectedly and are not included as allocated land in a planning authority’s development plan Brownfield: previously developed land (which is, or was, occupied by a permanent structure) Greenfield: a site that has never been previously developed Affordable (homes): housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and social housing) Viability: an assessment to determine whether a site is financially viable, by looking at whether the value generated by a development is more than the cost of developing it.
Furthermore, despite being labelled ‘Places for Everyone’, we do not believe that this Plan will deliver housing for those GM citizens who need genuinely affordable homes (social housing). GM has c72,000 households on local authority registers, and the Plan estimates that “around 38% of newly forming households are unable to afford to buy or rent a home at lower quartile prices”. Yet during the P4E Examination, the Affordable Housing Policy has been weakened considerably, removing the specific targets from Policy, and relegating it to a mere aspiration.
In New Carrington the number of Affordable Homes (including affordable routes to home ownership) was originally set at 30%, but the scheme was found to be unviable. The number of Affordable Homes was then reduced to 15%, but the scheme was still unviable. Trafford then decided to increase the house prices at New Carrington by 10% (challenging to achieve at this time of financial difficulties). At the recent New Carrington Hearing, Trafford proposed a further reduction in Affordable Homes (with the vast majority of the development parcels now only needing to agree to 5% Affordable), despite what Trafford described as the acute need for such housing in the borough.
So, the plan to release Green Belt here will not help those who are most in need of a home.
We believe the benefits to be accrued by releasing Green Belt to deliver homes should be weighted as “Low” because it is clear that the needs of the most vulnerable residents will not be addressed and existing land supply can meet market housing need.
Employment
Employment land provision is also vastly over-stated in P4E. Green Belt release results in a totally unjustifiable 75% buffer, with the GMCA’s own expert advisor highlighting that P4E has an Industrial and Warehousing supply margin that “falls well outside the bounds of what has been generally used elsewhere”.
In New Carrington, 74% of the employment land is on brownfield sites, so the release of Green Belt will not provide any benefit in relation to the jobs created there. Building more warehousing, on what is currently Green Belt land, will bring many disadvantages, including adding to the substantial issues with HGV traffic in the area. In addition, the only employment being proposed is warehousing (which is neither highly paid, nor does it support high staffing numbers). There are no sites for technology, digital, green jobs, creatives, etc. The impact on the rural economy and rural jobs (farming, stabling, and their supply chains) has not been assessed, despite the current use of the Green Belt land here.
GM does have alternatives to building on Green Belt, but these appear to have been disregarded, including the potential to convert the 1.3million m2 of excess office floorspace, much of which is in sustainable locations, appears to have been ignored. This is a huge, missed opportunity.
It should also be remembered that the market is changing. Amazon, for example, recently announced that it will be closing 3 warehouses and several delivery stations. It cannot be considered appropriate to release Green Belt to provide warehousing at a time of such uncertainty.
With these points in mind, we believe the benefits to be accrued by releasing Green Belt to deliver employment land should be weighted as “Low” because New Carrington can achieve high levels of warehousing growth on the existing brownfield land.
Infrastructure (Transport, Schools, Health Services)
The aim of GM’s Transport Strategy is to ensure there will be “zero net growth in motor vehicle traffic in Greater Manchester between 2017 and 2040”, an admirable aspiration. On freight, the ambition is to achieve modal shift to water and rail. For people, the intention is that, by 2040,50% of all journeys in Greater Manchester will be made by public transport or active travel, supporting a reduction in car use to no more than 50% of daily trips.
Yet GM’s plans do not prioritise sustainable freight and passenger transport, despite the disproportionate focus on warehousing development and the current poor public transport provision in areas highlighted for development. In fact, P4E proposes to build housing and employment in 34 unsustainable locations, on what is currently Green Belt land, including here in New Carrington.
As an example of the inappropriate proposals, Trafford’s only transport commitment for New Carrington is to construct the Carrington Relief Road (CRR), which will lead to very high car dependency and further HGV dominance on local roads. It will also bring very limited benefits to existing residents, particularly given the increased housing and employment traffic that the New Carrington development alone will generate, and for the 26% of households in the Bucklow St Martin’s Ward that do not have a car, no benefits at all!
P4E includes a long list of potential transport options but there is no confirmation that funding is available to deliver any of the identified schemes, including the CRR. It should be noted that there are no options for sustainable freight transport, despite the site’s proximity to the Manchester Ship Canal and the presence of former railway lines, which could be brought back into use.
There is also insufficient focus on health services (which are already overstretched across the sub-region). There is no land proposed for a new hospital to serve those 400,000 additional residents, for example. School places are currently a strategic red risk in some Authorities, including Trafford, and bring many challenges for existing residents, with parents being forced to drive their children to schools outside of their locality. The New Carrington graphics do not show land set aside for any new schools, but the scheme will result in over 2,000 additional students across all age groups. That is a lot of pupils to accommodate and yet more competition for Grammar/Academy school places.
The NPPF (paragraph 95) states that it “is important that a sufficient choice of school places is available to meet the needs of existing and new communities”. This choice is not available for parents today, never mind when there are an additional 5,000 (“primarily family”) homes to consider.
New Carrington will result in 20% of Trafford’s local housing need being sited in one Ward (Bucklow St Martins), increasing the population of that Ward by over 70% (and when existing land supply is included, by over 90%)! This means that some of the most vulnerable people in Trafford are being disproportionately impacted by the lack of infrastructure and services, including losing access to green space. These already disadvantaged members of our community will experience increased inequity as a direct consequence of this Plan.
We believe the benefits to be accrued by delivering infrastructure should be weighted as “Moderate” because delivery is not confirmed and the potential for mitigation of the proposed huge levels of growth has not been addressed.
Adherence to National, Regional and Local Policies
P4E and the New Carrington Allocation should adhere to the policies set out in the NPPF, it should also comply with Climate Change regulations, which commits the UK government, by law, to reduce greenhouse gas emissions. The NPPF specifically mentions compliance with the Climate Change Act 2008. Our response to the Plan consultation (available here) sets out the lack of compliance with local, regional and national policies (page 29).
At a national level, public money has also been spent on a 25 year Environment Plan, an England Peat Action Plan and a range of initiatives relating to nature’s recovery. Whilst these are not explicitly mentioned in the NPPF, Local Plans should not ignore them.
The recently passed Environment Act sets out legally binding targets to protect our environment, clean up our air and rivers and to boost nature’s recovery. These were published in December 2022 and aim to:
Halt the decline in species populations by 2030, and then increase populations by at least 10% to exceed current levels by 2042
Restore precious water bodies to their natural state by cracking down on harmful pollution from sewers and abandoned mines and improving water usage in households
Deliver our net zero ambitions and boost nature recovery by increasing tree and woodland cover to 16.5% of total land area in England by 2050
Halve the waste per person that is sent to residual treatment by 2042
Cut exposure to the most harmful air pollutant to human health – PM2.5
Restore 70% of designated features in our Marine Protected Areas to a favourable condition by 2042, with the rest in a recovering condition.
Given that P4E is a 16 year plan, which will heavily influence the achievement of GM’s proportion of these goals (including the required reduction in carbon emissions), we believe the harms resulting from the release of Green Belt would significantly and demonstrably outweigh the benefits, when assessed against these National policies and ambitions.
At a regional level, in addition to GM’s Transport Strategy, public money has also been spent on a 5-year Environment Plan, a Clean Air Plan and the GM Strategy. Places for Everyone should be fully compatible with all those documents – but it is not! The GM Strategy Summary states, for example, that “Climate change is the single biggest threat that we face”, yet P4E does not have a focus on ensuring that the mitigation of climate issues is prioritised.
The Environment Plan outlines the aim to be carbon neutral by 2038 and articulates the 5 challenges incorporated within the plan (mitigation of climate change, air quality, production and consumption of resources, natural environment, and resilience and adaptation to the impacts of climate change).
Yet the Greater Manchester Combined Authority (GMCA) has not even produced evidence showing the impact of P4E on the carbon emissions. In the absence of any assessment by the GMCA, Steady State Manchester has analysed the data and has produced a report which sets out the Carbon Implications of Places for Everyone, showing that the 2038 carbon neutrality objective is unlikely to be met.
The lack of compliance with local, regional and national policies has caused us to weight this criterion as “Moderate”.
Green Belt Harm
The National Planning Policy Framework (NPPF) states (paragraph 148) that “local planning authorities should ensure that substantial weight is given to any harm to the Green Belt”
National Planning Policy Framework (NPPF): The NPPF sets out the Government’s planning policies for England and how these should be applied (in the preparation of local and neighbourhood plans and to decisions on planning applications). Green Belt Harm: The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping some land permanently open around urban areas. The five purposes set out in the NPPF (paragraph 138) are: – to check the unrestricted sprawl of large built-up areas – to prevent neighbouring towns merging into one another – to assist in safeguarding the countryside from encroachment – to preserve the setting and special character of historic towns – to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
P4E commissioned assessments of the Green Belt land proposed for release, to identify the relative harm that would ensue. The New Carrington Allocation was reviewed for the 2019 and the 2020 planned Green Belt release.
Although this resulted in an assessment of Very High, High and Moderate-High Harm to Green Belt purposes, 169.5 hectares of Green Belt will be released immediately following P4E Plan approval, despite what is supposed to be a focus on delivering brownfield sites first.
In addition, the significant volume of Green Belt land to be released here will undoubtedly impact the appetite for brownfield development. This means that our Green Belt will be decimated whilst brownfield remains wasteland and the amount of available previously developed land increases!
We do not believe the exceptional circumstances required by the NPPF (paragraphs 140 and 141) to release Green Belt have been demonstrated. There is a lack of evidence about the impact of the Plan on the environment, biodiversity and ecology, the GMCA has not fully examined all other reasonable options and there is sufficient brownfield land to meet the Government’s formula (which could be supported by ensuring minimum density standards are enforced across the region).
We believe the cumulative harm from the loss of Green Belt should be weighted as “Very High” given the size and scale of the site.
Loss of Peatland
Developing on Carrington Moss will cause a massive carbon emission event and the destruction of this irreplaceable habitat cannot be offset by any amount of Biodiversity Net Gain.
One of the many advantages of carbon sequestration via peatland is its own negligible carbon footprint. There is no requirement for manufacturing of major technology or equipment and no ongoing use of fossil-fuel based power (although we do recognise that restoration techniques might involve some initial machine-using groundwork and some installation of plastic dams or pipes). Peat mosses require relatively low maintenance, perhaps some weed incursion control, but mostly it is over to the forces of nature and time to deliver the benefits.
Whilst there are no specific protections in the NPPF, the Government has set out its intentions in relation to peat in various documents over the past 10 years (including the 25 year Environment Strategy and the England Peat Action Plan). Even P4E recognises that “lowland raised bog is now one of Western Europe’s rarest and most threatened habitats”, that our peatlands sustain a unique range of wildlife and GM’s 5 year Environment Plan aims to prioritise action to “protect, maintain and enhance our key natural assets”, including restoring “50-75% of our peatlands”. The document sets out responsibilities for Local Authorities, including:
“GMCA and LAs will embed a natural capital approach into strategy and plan development
GMCA and LAs will support peatland restoration approaches and provide a clear framework for approach and delivery as part of a resilience strategy”.
So, a responsible plan should take full account of the natural capital value of peat otherwise it will undermine intended Government and regional policy.
Furthermore, one of the tests of soundness is that there should be a reasonable prospect that the various Plan policies (including the Allocations) are deliverable. Given the, albeit slow, pathway the Government is taking to protect peatland soils and the increasing recognition of the ecosystem services peat provides, specific protection is likely to come. The trajectory for development at New Carrington is spread across the 16-year period of the Plan. Is it, therefore, reasonable to assume that construction on peat will still be allowed at the time planning applications are submitted? We believe it is not!
At the P4E Hearings, the GMCA dismissed the advice of Natural England (NE), the Government’s adviser for the natural environment in England, stating that NE had not raised any issues of soundness. Whilst it is correct that the Planning Inspectors are testing P4E for soundness, we believe it is reckless and negligent to ignore the advice of such national experts.
Examining plans (NPPF paragraph 35) Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development; b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence; c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant.
NE has confirmed that “it takes 1,000 years for 1m of peat to build up”. That seems to be confirmation that Carrington Moss is an irreplaceable habitat. Their advice to the GMCA suggests it is, they say
“The GM Peat Pilot showed the carbon storage within lowland peat within Greater Manchester to be between 1,500 – 2,000 tonnes per hectare Carbon equivalent for 50cm depth of peat. Carrington Moss is significantly deeper than this”.
NE provide guidance about rewetting the peat soils and raising the water table (which is regularly above the surface on Carrington Moss, as can be seen by the information on our website about Carrington Lake). They also advise that
“As a large, continuous peat mass currently under suboptimal management, Carrington Moss provides an ideal opportunity to explore alternative land use scenarios that will assist the City Region in achieving net carbon neutrality by 2038, while providing other ecosystem services through improved ecological function of the peat”.
NE recommends restoration and expansion of the existing relic bog remnants, which would need appropriate buffers and areas of supported associated habitat, to support significant carbon storage. They also agree with our Alternative Transformation Strategy for Carrington Moss, suggesting that there is
“the opportunity to consider and set up a contiguous large area of Carrington Moss as a habitat bank for BNG, and for carbon trading. Natural England strongly supports this approach.”
We consider the loss of this irreplaceable habitat will cause Very High Harm, not just for today but for generations to come.
Harm to our Natural Capital Assets
Natural capital is the way of describing environmental assets (such as land, forests, water, soil, air and minerals) that provide benefits to people (clean air, good health, food and water). A natural capital approach assigns a value to each of those benefits to help us understand their importance and worth to society.
GM has undertaken no assessment of the loss of Natural Capital Assets or the impact on Ecosystem Services as a consequence of the P4E Plan, despite the Trafford Natural Capital Account stating that “a natural capital approach is about everyone understanding the benefits – ensuring the protection and enhancement of natural assets are fully considered in decision making”.
This clearly has not happened with P4E. In fact, FOCM identified a lot of missing evidence in our representation. There is no detail in the Plan relating to carbon emissions, air, noise and light pollution, the rural economy, ecology and biodiversity (including the impact on the SBIs and SSSIs in close proximity), soil resources, or natural capital/ecosystem services.
Our own very conservative natural capital estimates suggest that Carrington Moss accrues over £15m in benefits each year. We understand this benefit is not included in the £71m figure calculated by Trafford. They have decided not to capture all assets but have identified those they believe represent “the most critical in an urban context”. This is consistent with the approach taken by P4E, which completely ignores our rural communities, the rural economy (including the farms, the stables and their supply chains) and rural assets.
The natural capital assets on Carrington Moss include the peat moss itself (albeit degraded), the wetland habitats, the Grade 2 best and most versatile agricultural land, the huge expanse of woodland, areas that have significant levels of regular surface water flooding, and those that are used extensively for social prescribing, sports and recreation, including walking, cycling, horse riding, nature spotting, bird watching and a number of other activities.
The publicly available mapping for GM’s Local Nature Recovery Strategy shows existing habitats and opportunities for enhancement (including for Carrington). Carrington Moss is one of the sites within the GM Wetlands Nature Improvement area. Yet, the current plan is to decimate historic wetland habitats, then to propose restoration and creation of new areas of wetland, this is totally irrational!
Trafford has not made the overall flood risk and drainage strategy for the site available but we recognise it will need to be compelling given the water levels consistently present on the mossland. The Government’s planning guidance has recently been updated and Councils will need to demonstrate developments will be safe from flooding for their lifetime, will not increase flood risk elsewhere, and, where possible, will reduce flood risk overall.
The Allocation will compromise the quality of our natural environment, causing biodiversity loss, and will severely limit access to green spaces. Globally threatened birds/wildlife species will be displaced, their foraging sources diminished, their populations put at further risk. The scenery will be dominated by new roads and warehouses, rather than landscape views stretching for miles, with high levels of traffic noise, rather than birdsong. Carrington Moss will no longer be able to support climate resilience and reduce flood risk, which it does so well today!
How can the Planning Balance be determined when there is only evidence covering one side of the scales? This is important because the fact an Allocation has been made here will be a key influence in decisions about planning applications, despite the lack of evidence at plan-making stage.
We believe the lack of information about our natural capital assets will result in Very High Harm.
Prioritising unnecessary growth, rather than the climate emergency!
Every Local Authority in GM, every Health Authority in GM and the Greater Manchester Combined Authority have all declared a climate emergency (the GMCA has also declared a biodiversity emergency). As mentioned above, the GM Strategy states that “Climate change is the single biggest threat that we face”, yet GM’s Local Authority and Combined Authority leaders are supporting a Plan that will significantly increase carbon emissions, cause a huge surge in air, noise and light pollution, and will expand the number of areas with the potential for localised flooding. Their Plan will destroy irreplaceable habitats (peat mosses), will remove huge amounts of best and most versatile agricultural land (Grades 1, 2 and 3a) and will see thousands of trees felled. None of these actions is compatible with those declarations nor with their carbon neutral goals.
It seems that climate and environmental impacts do not carry the same weight in P4E as the proposed excessive (and unnecessary) growth. In addition, the P4E Plan will significantly impact the health and wellbeing of GM residents as a consequence of increased stress, dirty air and loss of green spaces.
During the P4E Examination, at a time when decarbonisation should be top of the agenda, the GMCA backtracked on published policies (net zero buildings will now be something to be worked towards, rather than mandated, and will be subject to financial viability, the ‘get out of jail card’ used by developers to avoid planning policy obligations). In addition, the weakening of the brownfield first policy could result in more Green Belt release, with the associated increase in carbon emissions, etc.
Given those declarations and the recognition of the future challenges and hazards in the GM Strategy, every plan, every proposal and every decision should be considered through the lens of the climate emergency.
Yet, as mentioned above, the GMCA did not produce any quantitative assessment of the implications of their proposals, and suggested, at the P4E Examination, that it was reasonable for them not to provide such data. Communities highlighted the approach taken in the Greater Cambridge Plan, an Authority which did conduct quantitative modelling of the carbon impact of their different spatial options. This Authority was dismissed as an outlier, rather than heralded as setting a standard that other plans should be following.
P4E cannot be considered to be sustainable when it comes at such a huge price to future generations. The lack of focus on mitigation of the climate emergency will lead to Very High Harm.
Finally
So, with all of the above in mind, is it reasonable to include New Carrington as an Allocation in the Places for Everyone Plan?
We do not believe it is and, in addition to the above, it must be remembered that there is a total lack of community support for this scheme. At a local level, the vast majority of residents object to the Allocation and, although the “major stakeholders” (developers and landowners) have been involved in creating the New Carrington Masterplan, there has been no engagement with local communities, not even the Parish Councils, in the evolution of the Masterplan document.
At a regional level, the scale of opposition to Green Belt loss was huge, with over 27,000 GM constituents objecting to Green Belt release. It seems there is no “public” in the Public Interest Test in relation to P4E!
In summary, P4E has focused on bringing forward sites in the Green Belt, rather than on tackling the blight of brownfield and proposing truly sustainable development. The GMCA has significantly over-inflated the requirement for market priced housing and warehousing, there is insufficient provision of desperately needed genuinely affordable homes, rural communities and the rural economy have been totally disregarded, and insufficient weight has been given to the impact on climate change mitigation opportunities, the environment and nature’s recovery.
Whilst we understand GM’s aspirations, these should be sustainable, balanced by a clear appreciation of the impact on communities and the environment and all decisions should be supported by sufficient information, covering both sides of the Public Interest Test scales.
For New Carrington, Viability is finely balanced too, and we are not clear that all costs have been included in the numbers. This development will not just be expensive in financial terms, it will also bring a high cost in terms of carbon emissions, the further depletion of endangered species and the worsening health and wellbeing of local residents.
This is not a reasonable or a sustainable Plan!
Do the harms significantly outweigh the benefits of the scheme?
Yes they definitely do!
So, for all the reasons set out above, it is resoundingly clear that the New Carrington Allocation does not meet the Public Interest Test.
We have been working hard over the past few weeks to prepare for the Places for Everyone (P4E) Examination in Public Hearings.
But ……it is hard to be equipped for Trafford’s responses to the Planning Inspectors’ questions when their answers are blatant inaccuracies!
In the first week of the Hearings, we discussed legal, procedural and general matters, including the Councils’ adherence to their Statements of Community Involvement (SCI). Sadly, in relation to consultation, this is the only aspect the Planning Inspector can consider. As one of our colleagues from the Save Greater Manchester’s Green Belt Group pinpointed – it is very evident that “there has been a consultation deficit”.
At the session (starting at 5:33:0), the Planning Inspector first asked Trafford about the link between the Carrington Relief Road (CRR) and the Places for Everyone Plan.
As part of their response, Trafford’s representative stated (not once, but twice) that the CRR has been subject to consultation outside of Places for Everyone, including in relation to the Preferred Option.
As you will know, this is factually incorrect. There has, as yet, been NO consultation about the CRR. One only needs to look at Trafford’s consultation portal, and our previous blogs, to confirm that.
Given the importance of these Hearings, it is both shocking and disturbing that Trafford does not expect to be completely accurate in their responses, but there is more!
The Planning Inspector followed up with a question about workshops. The Trafford representative suggested that Covid was the reason for the lack of workshops during the P4E stage of the Plan development.
Some of you will remember that we ran some online workshops during the Covid period, including one on Air Quality, which Trafford attended.
So, it is inappropriate to assign blame to the pandemic for the lack of workshops since 2020.
Their response in relation to earlier phases of the spatial framework was even more objectionable…….. Trafford’s representative stated that workshops WERE held.
Now, remember, this was a discussion about Trafford’s compliance with its Statement of Community Involvement and the question about workshops related to events with the community.
It is clear, Trafford DID run a number of workshops in earlier phases of the Plan. Trafford, landowners, developers and local businesses have mentioned them, including in responses to Planning Inspectors’ written questions.
Trafford call these organisations “major stakeholders” in their New Carrington Masterplan (document 10.09.06 within Places for Everyone). Yet residents, and their potential inputs were totally ignored, despite our requests and what is set out in their SCI.
We did confirm back to the Planning Inspector that community representatives were not invited to any workshops, but the point was avoided by the GMCA’s Kings Counsel.
We were not the only community challenging the Districts’ SCIs and associated issues. The accessibility of the documents in the P4E Plan was raised by more than one group. The 430-page Integrated Assessment, which included pages that are illegible, even when printed on A3 paper, is one such document!
Counsel:
The GMCA’s representation was led by Christopher Katkowski Kings Counsel (KC), a leading planning lawyer and one of the four KCs present at the Hearings this week.
Residents, of course, had no Counsel as it is beyond our funding abilities.
For more information:
You can watch the first set of Hearings at the links below:
The Manchester Evening News has featured Carrington Moss in their recent article about Places for Everyone, which highlighted that the Plan will result in the equivalent of 2 new boroughs in Greater Manchester within the next 16 years.
Government data tells us that since 2013/14 England has lost over 25,110 hectares of green belt – equivalent to over 35,000 football pitches of highly valued land, with various attributes and community benefits, that are now forever lost to future generations.
Here in Greater Manchester, the Places for Everyone (P4E) Spatial Plan Examination in Public has begun, and GM’s leaders are hoping the Planning Inspectors will approve the unnecessary release of 2,430 hectares of our precious green belt (equivalent to over 3,400 football pitches).
We have already argued in our responses to the Plan that GM’s leadership has NOT proven the need for this unwarranted reduction in our green belt but what does the recent publication of Census data provide in the way of justification for their proposals?
Well, actually, quite the opposite. The Census data supports our contention that the exceptional circumstances required to release green belt have not been demonstrated!
Our fellow campaigner, Matthew Broadbent, of the Save Royton Green Belt group, has looked at the Census data in some detail and his analysis reveals that, in terms of Household growth, the 2014 data set (which is used in the Government’s standard methodology for calculating housing need) has significantly over-estimated household growth in Greater Manchester.
Graphic credit: Matthew Broadbent (Save Royton’s Green Belt)
Looking at the figures themselves, it is clear that ALL Districts are impacted by the Government’s standard method (and this is before the Affordability Ratio is added to the calculation). Trafford’s data is particularly shocking given their record on minimal reductions in green belt take in the various iterations of the Plan and Trafford has the highest Affordability Ratio in GM which is added to these erroneous numbers.
What the table below does tell us is that housing need across Greater Manchester has been significantly inflated and that there is clearly no justification to release green belt to supplement the land available in urban areas.
The 2014 data, calculated by the Ministry of Housing, Communities and Local Government, projected significantly higher levels of household growth than has actually been the case. The latest data available in the Census demonstrates what has been shown in previous ONS data – population projections have been noticeably reducing over the last decade.
Graphic credit: Matthew Broadbent (Save Royton’s Green Belt)
Over the coming months the Office for National Statistics will use the Census data to re-calibrate their Household Projections and hopefully this information will lead to a long-awaited change to the source data required by the Government’s standard methodology, which is clearly resulting in Local Authorities sacrificing vital green belt land that the Government suggests it attaches “great importance to” (National Planning Policy Framework, paragraph 137)!
As mentioned above, it is clear from this data that growth for Greater Manchester CAN be achieved WITHOUT releasing green belt.
This is endorsed further in P4E itself, which reports that the Government’s standard methodology for calculating housing need creates a requirement to build 164,880 homes within the Plan area (Housing Topic Paper, page 18) and the 9 Districts are able to provide land supply that exceeds that figure (170,000 homes – Housing Topic Paper, page 20). GM’s population in the Plan area is projected to increase by 158,194 between 2021 and 2037 (paragraph 7.14). This equates to a need for around 66,500 homes, which demonstrates that there is clearly sufficient flexibility and choice within existing urban areas to meet GM’s housing needs (and there are various brownfield land funds that can be applied for).
What should also be considered is how the number of Net Additional Dwellings over the past 10 years (ONS reports that over 73,000 net additional homes were constructed in the Plan area during that period), compares to the Census data (which shows that only 45,000 households have formed in the Plan area). The graphic below highlights that each District in GM has built more houses than the number of households formed!
Again, the figure for Trafford is astounding, with the construction of dwellings being more than two and a half times the number of new households! This means that it is not under-provision that is holding back household formation. If data about vacant housing stock (empty homes) is added to the above numbers, the over-provision figures are increased even further, but let’s keep it simple.
The Census identifies a household as a property where there is “at least one usual resident”, so do the figures above suggest that a large proportion of the dwellings being built in GM are second homes? investment properties? More investigation is needed but these figures certainly leave our friends at the GMCA and in our Local Authorities with a number of questions to answer in relation to their plans to unnecessarily reduce our green belt (see our previous blog for more information).
Whose Plan is it anyway?
Given the Examination in Public has already begun, we hope the Planning Inspectors seriously consider our inputs and arguments, but we are aware citizens have very little influence in the Planning Ecosystem and that developers have submitted responses proposing that more green belt is released!
A Plan that unnecessarily releases green belt, preventing future generations from accessing its recreational value, seeing its landscape views, benefiting from the best and most versatile agricultural land, the abundance of species, the carbon capture capabilities, the flood water storage areas, the woodlands, the wetlands and the irreplaceable habitats, is NOT our plan!
I watched this short video from Trafford Council’s leader out of curiosity. It is only 2 minutes long so do have a listen. Concern is expressed about the climate crisis, the recognition that it will cost billions if not addressed, the acknowledgement of the extreme weather events that we are already seeing EVERY year.
It is interesting that Councillor Western focused on issues such as flooding, air pollution and the amount of carbon in our atmosphere. Yet, Trafford plans to decimate Carrington Moss, an area which generates a natural capital value of over £15m per annum (based on GM’s Natural Capital Account, figure 1, 2019 Natural Environment Topic Paper).
It plans to significantly increase air pollution and the risk of flooding for local residents here, and, of course, the loss of our peat moss will result in a massive carbon release event.
The climate change page on Trafford’s website provides links to examples of collaborative work “to reduce and mitigate carbon emissions as well as adapting to a changing climate”. One of these is labelled Nature and Biodiversity. Click on that link and you are taken to a Lancashire Wildlife Trust article (December 2020) announcing that “Nature is on the road to recovery in Greater Manchester”.
Councillor Western is quoted in the article stating that “The funding will help deliver some of the essential work being undertaken to safeguard wildlife habitats, develop natural flood management projects and peatland carbon stores, and teach families and young children about the natural world on our doorsteps”.
But he doesn’t mean here on Carrington Moss, where he is planning to unnecessarily release 169 hectares of green belt to build housing and employment space that could be located elsewhere in Trafford (or even elsewhere in GM, as residents keep being told we must consider the regional strategy, known as Places for Everyone, as a whole).
The article states “The aim is to fund natural flood management projects and peatland restoration transforming areas into carbon stores”.
Despite the huge numbers of additional residents and employees who will be travelling into and out of the area, there are NO plans for any sustainable passenger or freight transport options. Instead, Trafford plans to construct a road across the Grade 2 agricultural land, woodland, wetland and peatland habitats.
Stockport’s leadership appears to understand the issues as they rejected their controversial bypass. Council leader Elise Wilson said a new road that would “destroy wildlife and natural habitats” was an “old world solution“.
But Trafford is sticking with their “old world solution”!
Residents have ideas for alternatives to constructing a road across the Moss, but Trafford is not interested in even hearing about them, never mind exploring their potential!
Despite their declaration of a climate emergency in November 2018, and the creation of a Carbon Neutral Action Plan in December 2020 (a plan that does not even mention that Trafford has, not one, but two, peat mosses), Trafford appears confused about what sustainability actually means. Maybe they should take a look at our previous blog!
We have also recently produced our latest Carrington Lake video which, once again, shows just how much water is captured and retained by Carrington Moss. It’s less than 5 minutes long and highlights the level of hypocrisy we are facing from both GM and Trafford’s leadership. We’d love to hear just how many attenuation ponds you think we’ll need to capture all that water that is currently being contained by our irreplaceable mossland.
Nationwide, it is acknowledged that the UK is one of the most nature depleted countries in the world. The Government has an aim to leave the environment in a better state than they found it, setting targets to halt the decline in species, to improve air and water quality and increase our woodland cover. There is a recognition that we need to use our natural resources more sustainably and that it is critical to build up resilience against the impacts of a changing climate, to enhance our natural capital to support our food security, health and wellbeing, and economic prosperity.
Yet, here in Trafford, there is a plan to further diminish the already threatened populations of red listed birds and endangered wildlife that breed and feed on Carrington Moss and to sacrifice our best and most versatile agricultural land, that future generations may need to provide locally sourced produce to survive!
Trafford will be spending public money decimating existing nature-rich wetland habitats and will then spend more public money creating new, man-made, habitats, which will take decades to generate the same level of ecosystem benefits.
It is now clear that the biodiversity and climate emergencies are comprehensively interconnected and that there are compelling reasons why both should be considered together to create solutions that reduce the risks to all populations (both human and wildlife).
Greater Manchester’s leaders declared a biodiversity emergency on 25th March, with Mayor Andy Burnham talking about the “habitats being lost, destroyed and becoming less diverse due to the impact of development, climate change, pollution and invasive species”. Yet, he is presiding over a plan that will see huge levels of biodiversity loss across the region.
Perhaps his suggested “rallying cry” will signal a change of approach to the unnecessary loss and destruction of the region’s precious green belt!!!
Yet, while Carrington Moss is being sacrificed by GM and the local leadership, sustainability is out of the window, the biodiversity and climate emergencies are not being considered, neither is their accountability to future generations!
Carrington Moss provides a number of ecosystem services, including walking, cycling and horse riding routes, excess water capture (huge amounts of that), Grade 2 agricultural land (capable of growing locally sourced food), woodland, wetland and peat moss habitats, is the breeding and feeding grounds for numerous red listed birds and endangered wildlife species (including the willow tit and the water vole), has historical value, and brings health and wellbeing benefits to local communities and those who visit the area.
the carbon budget GM’s Combined Authority commissioned from the Tyndall Centre (University of Manchester)
the advice given by the Tyndall Centre about the pathway to reaching net zero
the alarming lack of progress that has been reported this month
the impact and importance of the separate category of Land Use, Land Use Change and Forestry (LULUCF).
They specifically highlight that the Regional plan, known as Places for Everyone (P4E), will involve significant levels of construction on green spaces. This means that the Region’s capacity to reduce the impact of additional emissions will decrease significantly, severely affecting GM’s aspiration to be carbon neutral by 2038!
In looking at the scale of planned development set out in P4E, much of which will result in green belt release across the Region, Mark and Matthew emphasise the loss of carbon capturing opportunities, as well as the huge level of carbon emissions generated.
Their findings suggest it is highly likely that, on housing alone, the P4E proposals will be disastrous for the Region’s ambition to be carbon neutral. Different choices could be made to meet housing need, options that do not rely so heavily on new construction! Here in Trafford, there are also alternatives to constructing new roads across the green belt too.
It is clear from Mark and Matthew’s research, however, that the GMCA has not fully assessed the carbon implications of the P4E Plan, and they believe that the Strategic Environment Assessment (SEA) has not been conducted to an appropriate standard, especially given the conclusions reached by the Authorities.
The lack of information provided by the GMCA about the carbon implications of their strategic plan is astounding, particularly as there were so many P4E documents (more than 150, with 14,000 pages to review), but, as we pointed out in our own response, some of those pages include evidence that is very dated and some, like the carbon emissions data, is not provided at all.
Mark and Matthew actually found that other Authorities do provide the data required to robustly assess the carbon emissions. Their example from the Cambridge Local Plan is enlightening.
We totally agree that one of the most shocking omissions from the SEA is the absence of GM’s key objective, the 2038 target for carbon neutrality. It must be remembered that it is this P4E strategic plan that must secure that target!
If you are interested in finding out more about the Tyndall Centre’s view of Trafford’s carbon emissions targets, you can find an interesting summary here. You will note that the final paragraph states “We also recommend that the LULUCF sector should be managed to ensure CO2 sequestration where possible. The management of LULUCF could also include action to increase wider social and environmental benefits“. Constructing roads, housing and employment space on a peat moss, grade 2 agricultural land, wetland and woodland will not support the achievement of that recommendation!
At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps.
A member of the Scrutiny Committee requested a more balanced representation of the facts. The Carrington Relief Road documentation does seem to be plagued by the sheer volume of misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).
This is the fifth in our series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.
This blog focuses on Trafford’s Statement of Community Involvement and resident perception of the “consultation” process.
One of the most interesting parts of the presentation to the Scrutiny Committee was the discussion about public engagement, which many members of the Committee highlighted as a concern.
One of the aims of the Friends of Carrington Moss is to increase the level of community involvement in decisions related to the future of Carrington Moss, including appropriate levels of timely and genuine community engagement on all planned developments.
Sadly, we have been totally unsuccessful in achieving this goal. In fact, we’d go further and say that, despite all our efforts, we have not made any difference at all to Trafford’s approach, which is summarised below (this is a recommendation in the Carrington Relief Road (CRR) Update report to Trafford’s Executive on 27th September 2021)
“authorise community engagement and consultations where the Corporate Director deems it necessary or advantageous”
Necessary or advantageous to whom? Trafford has a Statement of Community Involvement (SCI). Shouldn’t the community engagement and consultations be consistent with that document and with the Gunning Principles (see below), against which any legal challenge regarding the consultation will be measured?
The words of Councillor Aidan Williams (Extraordinary Council meeting, Warburton Bridge Toll decision, 13th January 2022), resonate strongly. Councillor Williams talked about the “huge amount of effort that has been invested by local people, over a vast period of time, into trying to get MSCC to understand the perspective of local residents regarding the toll bridge. Unfortunately, those efforts have not been rewarded”.
We, and other local groups, have tried to help Trafford to understand the perspective of residents about the New Carrington development, the CRR and the importance of Carrington Moss, without success!
What does the SCI say?
The opening paragraph of Trafford’s current SCI document states that “The planning system in Trafford should be as transparent, accountable and socially inclusive as possible. There should be as many opportunities for successful and meaningful public participation as there can be. Trafford Council wants to have even more effective community involvement, providing opportunities for active participation and discussions with the community as early in the plan-making and planning application processes as possible.”
Well, there is a lot of work to do before Trafford meets this goal. We have lots of examples of non-compliance around the whole of the New Carrington development but sticking to the topic of the CRR, let’s look at what we have experienced.
On 8th March 2021, the Friends of Carrington Moss, representatives from the Parish Councils and a representative from Peak and Northern Footpaths society met with two members of the CRR Project Team, having sent a list of questions in advance of the meeting. None of our questions could be answered but the Project Team did manage to clarify some aspects of the scope of their particular phase of the work.
As part of our feedback, following this “engagement” session, we requested the following:
A specific workshop on traffic modelling covering the anticipated traffic levels (including HGVs) from both residential and employment sites, including current volumes and all planned and expected growth
An active travel workshop at the earliest stage of the WCHAR process
A workshop to discuss the design of the two routes in more detail (we mentioned that we have ideas that will make Option A workable, we said we’d also like to ensure the final report is more balanced and highlights all the environmental issues, the costs and the risks related to both options)
Despite chasing this request with the Amey Project Manager in late March 21, we had no response. We forwarded the request to Trafford’s Director of Growth & Regulatory Services in June 21 and to the Corporate Director of Place in July 21 and we still have had no workshops and no explanation of why such sessions could not be arranged, despite the SCI confirming (paragraph 3.11) that consideration “will be given to requests for Virtual Stakeholder events”.
Among much more guidance for the consultation process, Trafford asserts (in paragraph 3.1) that it will “carry out appropriate consultation during the preparation of plans and supporting documents” and that “Comments will be invited on what these plans should contain, what supporting evidence there should be, what the key issues are and how they can be addressed. Consultation will take place at early stages of the plan-making process and continue throughout. Any comments that are submitted will be considered and taken into account during the next phase of the plan-making process”
These assertions are not what has been experienced by residents in relation to the CRR. We do not believe our comments have been conscientiously considered, nor taken into account. As an example, we raised a specific question in our response to the Public Engagement which took place in Spring 2021:
“Residents believe improvements can be made to the design of Option A. How can these be fed into the process?”
We did not receive any feedback and the decision has now been made by Councillors to move ahead with Option F, despite Officers being fully aware that there could be opportunities to ameliorate Option A (a solution which we believe would result in lower costs for the public purse, be less environmentally damaging and more acceptable to local residents).
This is one of many questions from our response that did not make it into the report to the Executive, discussed later in this blog. We do understand that Officers are working to challenging deadlines, but it is totally unacceptable that our questions and requests have been ignored by both Trafford and Amey. There are NO forums for residents to input into the plans for the area.
The SCI document states (paragraph 1.3) that “The SCI will guide all community involvement on planning matters in Trafford, ensuring that people know when, how and for what reason they will be able to take part in plan-making and planning application processes.”
Yet, there was clearly a disconnect between what was publicised and what Trafford presented to the Scrutiny Committee (which stated that “The early public engagement exercise aimed to assist in the selection of a preferred route option, calibrate scheme objectives, and to inform the subsequent development”). Here, the presentation echoes paragraph 3.4 of the Preferred Option Report (7th August 2021) and the report to Trafford’s Executive (27th Sept 2021).
Scrutiny Committee members expressed their surprise that Trafford’s analysis of the 123 responses revealed that “just 21 respondents expressed a preference between Option A (on-line widening) and Option F (new build)”.
To be clear, residents were specifically told that responses to the public engagement were NOT expected to include preferences about the route option. The exercise was limited (as explained in Trafford’s leaflet, their website and their news article) to raising any questions residents had about the CRR and the Option Appraisal process.
Neither the leaflet, which Trafford confirmed had been sent to 10,000 homes and businesses (despite the spelling error) nor the Trafford news article (produced to accompany the launch of the CRR page on their website) suggested that residents were expected to express a preference in relation to the route options.
Had residents been aware that route option preferences were expected, there would have been a significantly greater number of responses returned!
This public engagement exercise did not provide any questions for residents to respond to, nor was the “event” published on Trafford’s Consultation Portal. Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.3) that “As part of the consultation stage there will be the opportunity for the public to register questions and concerns that will be collated for consideration as part of the next phase of engagement.”
Note: This was NOT a “consultation” stage and there has been no “next phase of engagement”!
The leaflet also mentioned the next phase of engagement, suggesting it would be “a series of more focused sessions which will answer your questions”. There has been a deafening silence since this public engagement event. No information has been forthcoming from Trafford Officers to the community, no frequently asked questions document has been produced and no responses have been received either to our questions or, as mentioned above, to our requests for workshops.
Importantly, none of the public engagement communications to residents suggested that there will be NO statutory consultation on both routes!
Table 5 of the Preferred Option Report (7th August 2021) included the following question:
“Q8. When does consultation period start? More information is required about the next steps in the engagement process, particularly when the Frequently Asked Questions document will become available and when the actual consultation about this road will start? Asked 37 times”. The response to this question was: “Q8. Not applicable to route option selection.”
This is an inappropriate response. This question IS applicable to route option selection. Residents expected to be formally consulted on both routes.
In another question in the same Table, residents asked:
“Q9. How has the decision-making process been conducted to ensure it is as transparent and unbiased as possible? Has an independent review been conducted? Asked 36 times”
The response to this question was “Q9. The decision process for the preferred option is detailed in Section 1.2. of this report. The preferred option will be determined based on the agreed criteria and the reporting and conclusions will be subject to both Amey and Trafford check and sign off procedures.”
Section 1.2 of the report is a summary of the Route Options. There is no information about the decision-making process in the report. This is an important question and the decision-making process should have been transparent to residents and to the Scrutiny Committee.
Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 3.4) that “Once feedback has been collated and categorised, the project team will then host online feedback sessions which tackle individual areas of interest or concern such as traffic congestion, environmental impact, drainage and flooding, and so on.”
Residents have not been invited to any such sessions. There has been no feedback, online or otherwise. In fact, there is rarely any contact with Trafford that is not instigated by residents!
Residents have had no involvement in, or input to, either the creation of the proposals/options or the development of a genuine and robust public engagement approach.
Trafford’s CRR Options Consultation Report (dated 18th December 2020) stated (paragraph 5.1) that “It is recommended that this proposal be accepted to ensure that an open and fair engagement process with the public is carried out and to give the Council the opportunity of further understanding and addressing issues of concern.”
With all the above in mind, along with the points made below, we DO NOT consider that Trafford established
an open and fair engagement process!
Neither has the Council addressed the issues of concern. In fact, in choosing the route across Grade 2 best and most versatile land, woodland, wetland and peatmoss, rather than hear resident suggestions about how Option A could be improved, the huge levels of concern about the environmental issues (highlighted by Trafford’s Officer) have been significantly exacerbated.
Other issues remain ignored. As mentioned in our previous blog, residents have been requesting details of traffic numbers for the area for over 2 years, including as part of this exercise, without success.
Has resident feedback enriched the project?
It is not clear that the engagement exercise itself resulted in any changes to the scheme. There were some surprising anomalies in the resulting Option Appraisal document. Some examples are outlined below.
The presentation (and para 3.4 of the Preferred Option Report) also stated that the “early public engagement exercise” calibrated and refined the scheme objectives. It seems that this exercise has resulted in the removal of the objective to provide “Improved public transport and active travel provision to existing areas which are poorly served and to housing and employment growth areas” which was listed as one of the CRR Objectives in the Engagement Presentation.
Scrutiny Committee members should ask why this change was made and who requested it!
The report to Trafford’s Executive (27th Sept 2021) stated (paragraph 5.1) that “the public engagement process has enabled Trafford Council to enhance and update the required deliverables, having taken on board the issues that have been raised by the community.”
This cannot be correct because the majority of our questions (21 out of 23) were NOT covered by the summary in the Executive report, nor have we had responses to them. Our response can be found here.
Furthermore, Table 8 (Other Criteria Summary) of the Preferred Option Report (7th August 2021), includes the following under “Engagement Feedback”:
“a preferred option has not been identified from the engagement responses”.
The table concluded that “No Clear Preference” for the Option was stated. An astonishing statement, given that residents were not asked to provide their preference, giving rise to considerable concerns about the bias throughout this Preferred Option Report! This topic will be covered further in a future blog.
The item in the Table goes on to say “This section does however demonstrate the feedback provided has been considered in the overall preferred option selection and there is a requirement for further engagement and consultation prior to submission of the preparation of the planning application.”
Yet another incorrect and misleading statement.
As mentioned above, the majority of our questions do not appear to have been considered, there will be no opportunity for residents to respond to a formal consultation on Option A and a decision has been made about the route without any engagement with residents about their ideas to improve Option A.
It should be noted that giving the option to ask questions (but not get answers) is not engagement. Engagement is getting residents around the table, finding out what OUR key objectives are, listening to our proposed solutions and acting on them or explaining why this is not possible!
One of our questions related to the objectives of the CRR. We asked why protecting the health and wellbeing of existing residents is not the number one objective. Not only did this suggestion not make it to number one on the list of objectives, it did not even make it onto the list itself!
The report to the Executive continues (paragraph 4.8) with the statement “Every comment received has been evaluated in detail and recorded on a response tracker. Many individuals raised a number of points, so their responses were recorded separately in all relevant categories. The team created a list of 11 “standardised questions”, under which response themes could be allocated.”
Not so!
We raised questions about, for example, other (more sustainable) options that could have been considered (such as the bridge across the Manchester Ship Canal), dualling capacity and the costings. We also asked (having recognised that the existing option appraisal is quite basic) when will a more detailed review of both options take place? None of these (and many others) have been included in the report.
In addition, Natural England’s response had some strong words for Trafford – yet these somehow didn’t find their way into either the report or the presentation to the Scrutiny Committee:
Extract from Natural England response 22nd March 2021 (along with Green Claims Code Principles)
Was Trafford only prepared to include information in the Option Appraisal and Committee Reports that supports their predetermined decision to choose the Option F route? Again, this is an example of the bias demonstrated in that Option Appraisal report.
It should be noted that we have been raising issues about Trafford’s reporting on the CRR for the past 2 years. Our letter to Trafford’s CEO (28th February 2020) raised numerous issues, including the lack of engagement with residents. We particularly highlighted the statement that the project “is expected to be managed using PRINCE2 principles” (paragraph 7, Outline Business Case, Executive Summary, December 2019). In its methodology, PRINCE2 has specific requirements relating to stakeholder engagement and, as residents should be considered to be THE KEY STAKEHOLDER, we were (and still are) keen to understand who our representative on the Programme Board is. Once again, we have been unsuccessful in our attempts to solicit responses from Trafford in relation to our questions on this matter.
Up to date evidence?
The SCI mentions (paragraph 2.18) that the “Council’s evidence base contains up to date and regularly monitored information from surveys and evidence gathering exercises. The evidence base helps to inform the preparation of planning policies and the contents of plans. Information contained within the evidence base can also highlight the need to prepare or review a plan. Where appropriate, the Council will seek the involvement of relevant groups and organisations in the development of this evidence base so that it has the most reliable and robust information available.”
The graphic below demonstrates the feedback that has been received to date about the New Carrington allocation, which includes the CRR, and our specific petition against roads being built across Carrington Moss. Residents have consistently disagreed with Trafford’s proposals, yet there has been NO consideration of alternatives, despite the alternative propositions put forward by residents.
And what about our petition?
Councillor Wright mentioned that “you’ve got to bring the communities that already live there on board with all those new homes and all of that change”.
Newsflash! Residents do not feel “on board”!
As our Secretary said to Full Council on 13th October 2021, “Local people feel powerless, fearful, and angry that planning and development feels to be carried out DESPITE rather than FOR community members.”
Councillor Wright mentioned that the majority of the 1,632 signatories of our petition did not live in Carrington or Partington. We believe we could have significantly increased the number of signatures further had we not been in a pandemic. Councillor Wright continued, suggesting that the people who are going to be most affected by the road live in Carrington and Partington.
This is incorrect!
Whilst Carrington residents may benefit from the opening of the A1 route (if the existing road is closed to HGVs and through traffic), we do not believe Partington residents will see any benefit from the construction of this road, especially given the amount of traffic it is expected to induce into the area.
The disputed part of the CRR (the part which runs across Carrington Moss) will affect the residents of Sale West the most, especially those with children at All Saints Catholic Primary School, who will be particularly impacted by
huge increases in air and noise pollution
It is Sale West residents who will be impacted by any flooding caused by concreting over this part of the Trafford’s largest Natural Capital Asset, and they could also be impacted by large scale vermin infestation when the construction commences.
The other populations most impacted by the Option F route are the users of Carrington Moss (including the sports professionals and children who play and train there), the horse riders, cyclists and walkers whose routes across the Moss will be fractured (which could lead to serious accidents) and, again, they will be hugely affected by air and noise pollution. Of course, nature and wildlife will be impacted too, we will cover that in a future blog.
More consultation, we asked for a seat at the table and involvement in the design of the plans for our locality
Genuine and sustainable alternative options to building of roads across Carrington Moss, and
More consideration of the environmental impact of the CRR, especially given Trafford’s declaration of a climate emergency
We have not been offered any of these things, nor have we been told why they cannot be addressed. In fact, we have had no formal response to our petition from Trafford at all.
In summary
Given all the issues mentioned above, perhaps the Scrutiny Committee could recommend that Trafford activates the option in paragraph 5.26 of the SCI, which states that “In certain circumstances the Council may decide to undertake Re-consultation”.
In the report to the Executive (27th September 2021), Carrington & Partington Transport Infrastructure – CRR Update, the paragraph labelled “Consultation” suggests that the report “sets out in detail how the public have been engaged so far.”
It should be noted that there has, as yet, been NO consultation about the CRR.
We are delighted that members of the Scrutiny Committee requested that future consultation proposals are reviewed by Scrutiny Committee in advance of publication. Perhaps that will signal a change in approach?
And Finally
When it comes to consultation, the courts apply a set of rules known as the ‘Gunning Principles’ to decide whether a consultation is lawful. These Gunning Principles are considered to be fair to both Consultor and Consultee and are increasingly being used to measure the legitimacy of consultations in legal cases.
We’ll cover compliance with the Gunning Principles in a future blog. Legal processes are time-consuming and costly for all concerned, even the winners, so let’s hope such action is unnecessary!
What are our asks?
We set out our key asks in our previous blog. Without the information we request, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal.
For more information about our previous analysis relating to the Carrington Relief Road, please check out the Carrington Link Road page on our website.
At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps.
A member of the Scrutiny Committee requested a more balanced representation of the facts. The Carrington Relief Road documentation does seem to be plagued by the sheer volume of misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).
This is the second in our series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.
This blog focuses on the Places for Everyone Plan and the specific New Carrington Allocation.
The presentation given to Scrutiny Committee appeared to suggest that the proposal for the Carrington Relief Road in the 2012 Core Strategy instigated the huge development known as New Carrington. This does not seem plausible because, as noted in our previous blog, the road proposed in the 2012 Core Strategy was clearly much less intrusive than the current scheme and did not intend to decimate local green belt.
The presentation continued with information about the number of homes and employment space to be constructed in the area but failed to mention that 169 hectares of green belt will be released to make way for these plans. That is the equivalent of over 236 football pitches of peatland, wetland, woodland and grade 2 best and most versatile agricultural land that will no longer be available for future generations, not a sustainable solution!
It should be noted that the Places for Everyone proposals have NOT yet been approved, including the New Carrington Allocation, and will be subject to an Examination in Public later in 2022. Given this, questions should be asked about why Trafford are incurring expenditure through the acceleration of a project for a Relief Road, at this time of huge challenges for the public purse, when the primary aim (see GM Transport Strategy 2040) of that project is to support growth plans that have not yet been approved.
The Proposals
Whilst we welcome the reductions made to the New Carrington Allocation by Trafford’s leaders, we believe the development in Carrington, Partington and Sale West remains excessive.
The proposals for this one Ward (Bucklow St Martins) equates to over 20% of Trafford’s planned housing development for the next 16 years!
With a population increase for Partington of almost 72%, this is not a sustainable approach, but before we dig deeper into the plans for New Carrington, let’s look at this Regional Strategy now known as Places for Everyone.
Is the decision to release 2,430 hectares of green belt (the equivalent of 3,403 football pitches) across the Region necessary?
We don’t think so – read on to find out why.
GM’s leaders had the opportunity to choose from a number of spatial options for the Region, some of which did NOT require the release of green belt.
The Region is planning to build homes to meet the needs of an additional 450,000 people against an estimated natural population increase of 158,200. Of course, some growth would be expected but this rapid expansion of GM’s population is disproportionate, damaging and unsustainable.
It should be noted that ONS recently issued the latest population statistics (12th Jan 2022), which confirmed that the downward trend in projected UK population growth since 2016 is continuing. It is no surprise that the 2020-based population growth is, once again, slower than in the previous projections.
The available land supply across the GM Region (without the release of green belt) equates to 170,000 homes (which could meet the needs of over 400,000 people), more than sufficient to provide growth, along with flexibility and choice for both developers and customers. It is also adequate to meet the Government’s mandated housing need figure (without releasing any green belt land).
With these figures in mind, it is clear, there is NO justification to release green belt land anywhere in Greater Manchester.
So, why didn’t our leaders choose a spatial strategy aligned with their declarations of a climate emergency (made by all GM’s public bodies)? Did they fully understand the implications of all the options on the table? The Public Transport Max spatial option is a better fit for GM’s contemporary needs.
What is in the New Carrington Masterplan?
The brownfield land in Carrington already has planning approval, as do the plots shown as PR4A in the graphic above (Heath Farm Lane).
Trafford has continued to commit to overdeveloping the area, granting planning applications despite resident concerns (particularly about the number of HGVs on local roads) and the lack of sustainable transport options.
Trafford acknowledges there is a major problem with HGV traffic in the area, yet, given their very positive approach to growth,
it is hard to understand why Trafford has not, OVER THE PAST 10 YEARS, progressed ANY option for passenger and freight transport other than the Carrington Relief Road.
Trafford’s officer mentioned that it had taken 100 years to become reliant on road transport. Does Trafford plan to take 100 years to start working on some sustainable solutions for the area, or is the aim to force residents to accept the need for a new road because of imprudence and inaction? We’ll examine the Option Appraisal for that new road in a future blog in this series.
Impending decisions are all about building on the 169 hectares of green belt!
As we set out in our open letter to all Trafford Councillors in advance of their decision to approve the Places for Everyone Plan, there are a number of inequities for Trafford residents and particularly for those who live in Carrington, Partington and Sale West, as a direct consequence of agreeing these proposals. Not least of which is the loss of access to green space and, therefore, to nature. There is also (for example) lack of access to affordable homes (only 15% in total for New Carrington), to local schools (where are they?) and to a diverse range of jobs (only industrial and warehousing on this site). And then there are the risks, such as exposure to harm from hazardous businesses, flooding, vermin infestation and increased air, noise and light pollution. We’ll say more about these issues in a future blog.
Given its location, these plans will see Carrington become a traffic island in a sea of air pollution and the current green lungs of the area, Carrington Moss, will no longer be there to help disperse all that polluted air.
During the presentation, Trafford’s officer suggested that the Carrington Relief Road would take traffic away from the very narrow and congested A6144. This is not the case. As was pointed out by one member of the Scrutiny Committee, new roads bring new traffic. This was acknowledged in the P4E documentation in relation to the Carrington Relief Road (Transport Locality Assessment paragraph 11.2.3). Based on what has happened in other locations, it is highly likely additional traffic will be attracted to use both the new road AND the existing A6144!
It should be recognised that there is no dispute about opening up the A1 road (end to end), and that could be explored immediately. HGV and through traffic should be prevented from using the A6144 through Carrington Village but Trafford has NOT committed to this, which means residents will suffer the harmful effects of traffic on both roads. This approach will not achieve the desired aim of improving the reliability of public transport timetables either.
Like most other major roads in Trafford, and beyond, the A6144 is only busy during rush hour. So, instead of introducing sustainable passenger and freight transport solutions, that would benefit the whole community, Trafford are progressing a £30m scheme which will only replace a very short section of the A6144, benefiting some drivers for a very short time (see this video for an explanation of this example of Jevons Paradox in action).
This new section of road is close to the Carrington Spur, so we are at a loss to understand the benefits to Partington residents that Trafford has suggested will be transformational! The road will cause significant air, noise and light pollution to the residents of Sale West, affecting the children at All Saints Catholic Primary School, the users of Carrington Moss and, of course, the red listed birds and endangered wildlife that breed and feed here.
What Trafford’s Masterplan says about Transport in New Carrington
“Carrington and Partington suffer from relative isolation from the wider urban area of Greater Manchester. New Carrington provides the opportunity to make strategic highway interventions, for both the car and bus; significant upgrades to public transport; and enhancements for pedestrians, cyclists and horse riders resulting in a much more sustainable community for established and new residents”.
It might provide “the opportunity” but there are NO planned upgrades to public transport.
The only commitment is to the Carrington Relief Road, despite the promises made in previous Local Plans. No trams, no trains (despite the former railway line running right into Carrington and Partington) and no water-based transport (despite the proximity of the Manchester Ship Canal).
Trafford insist the road is “not the only show in town” but for passenger and freight transport, it certainly is!
In fact, in relation to public transport, what Trafford’s document says is that“improving bus accessibility to New Carrington, Altrincham, and Sale should be encouraged” and the response to our FOI request said:
“There are currently no committed schemes to improve public transport in this area.”
Residents have been waiting for public transport enhancements for 15 years! Isn’t it time our Council did more than “encourage” provision and makes those improvements a priority, and a reality, along with sustainable freight options?
What are our asks?
We set out our key asks in our previous blog. Without the information we request, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal.
For more information about our previous analysis relating to the Carrington Relief Road, please check out the Carrington Link Road page on our website.
At Trafford’s Scrutiny Committee on 12th January 2022, members were given a presentation about the Carrington Relief Road, providing some background to the initiative along with some information about the Option Appraisal for the preferred route, the engagement with the public and the next steps.
A member of the Scrutiny Committee requested a more balanced representation of the facts. The Carrington Relief Road documentation does seem to be plagued by misinformation (see our letter to Trafford’s Chief Executive in February 2020 about the Outline Business Case document).
This is the first in series of blogs which addresses the gaps in the information given at the meeting, providing further details to help members of the Scrutiny Committee and others, when reviewing the proceedings.
This blog focuses on what was said in Trafford’s previous documents about the Carrington Relief Road and the area the proposed preferred option will destroy.
At Scrutiny Committee, members were told that delivering transport improvements in this area has been Council policy for 10 years. It has, in fact, been Council policy since at least the publication of the Unitary Development Plan in 2006. The Council recognised almost 20 years ago that public transport improvements are core to the regeneration of Carrington, Partington and Sale West.
Yet, these promised improvements have NOT been provided.
Sadly, in this part of the Borough, Policy L4.5 has not been delivered at all. Worse still, since the publication of the Core Strategy in 2012, services have reduced even further and have continued to decline over recent years.
Getting the huge volume of HGVs off our roads is a priority for local residents and will be discussed further in another blog in this series. Trafford’s previous documents mentioned opportunities to relieve the traffic in the area by building a bridge across the Manchester Ship Canal between Carrington and Irlam. This would enable local companies to move their goods via Irlam Wharf and the Manchester Ship Canal or via Port Salford, which will also be a rail freight terminal. Very sustainable options.
Yet, where are Trafford’s proposals for the bridge? What work have they done to move this option forward since 2006?
The 2012 Core Strategy said “a Manchester Ship Canal crossing will be subject to further investigation”.
We made an FOI request and only received information back about the community proposal for this option!
Another member of the Scrutiny Committee suggested Trafford’s plans were not bold enough. Whilst recognising there would need to be significant investment, he particularly highlighted reopening the former railway line as a potential sustainable solution.
The lack of consideration for reintroducing rail for passengers and freight in this area has not always been a problem for Trafford.
It seems it is only the current proposition that has removed all the sustainable options from the development plan (other than providing walking and cycling routes next to major roads).
We’ll say more about the traffic numbers in a future blog, in the meantime –
what did that Core Strategy document say about the Carrington Relief Road.
Well, the document does say (SL5.2) that the new road infrastructure would “serve the development area to relieve congestion on the A6144”.
The document also says (para 8.73) that the development area will be “accessible by a choice of transport modes”. There was choice in 2006 and 2012. Not just a less intrusive road, but also consideration of the bridge and rail and a plan for public transport improvements. It was expected that these options would “significantly improve transportation links to the Strategic Road Network, Metrolink and cross conurbation to Salford” and there is a recognition that such measures would be needed to mitigate the impact of the development on both local roads and the motorways.
BUT
There is nothing to suggest the proposed road was expected decimate grade 2 agricultural land, woodland, wetland and peat moss.
In fact, Trafford’s previous documents were insightful. It does seem that there was a recognition of the importance of Carrington Moss, from ecological, biodiversity and heritage aspects.
Carrington Moss is a huge asset to Trafford and should continue to be protected as such.
The ecosystem services it provides are extensive and, in some cases, irreplaceable. More about these in a future blog.
Going back to the meeting, Scrutiny Committee members were told the preferred route would go across the fields.
It needs to be recognised that these “fields” are Grade 2, best and most versatile, agricultural land
(as identified in GM’s land classifications – see Mapping GM, include a layer search for Agricultural Land Classification).
The Council has previously committed to protecting such land, recognising its value to the local economy.
Of course, since Trafford’s declaration of a climate emergency in November 2018, the protection of this land should have been enhanced as it offers the potential for the future provision of local sustainable food sources.
Let’s look at the current National Planning Policy Framework (NPPF) guidance in relation to conserving and enhancing the local environment!
So, in summary, it seems the proposed transport improvements for Carrington, Partington and Sale West have not been taken forward since 2006, yet Trafford’s Planning Committee has repeatedly approved developments that have, and will continue to, significantly increase the traffic on local roads, to the detriment of the health and wellbeing of existing residents.
Whilst Trafford’s Officer said that “the road is not the only show in town”, there are no other proposals on the table. No trains, no trams, no water-based freight or passenger transport and no additional bus services. We have checked this via an FOI request, for which the response was
“There are currently no committed schemes to improve public transport in this area.”
What are our asks?
As we have requested previously, we’d like to see the scheme paused until all stakeholders have been appropriately consulted and their views are able to be properly included in the options appraisal
We’d like to see our carbon footprint and the climate emergency taking a more meaningful part of the option appraisal
We’d like to see the options reviewed to allow for less expensive, less environmentally intrusive alternatives to be considered (with entirely separate active travel routes).
In addition:
Trafford’s declaration of the climate emergency in November 2018 agreed to “consider, systematically, the climate change impact of each area of the Council’s activities”.
We’d like to see the assessment that has been undertaken in relation to this road and the premise under which it is not only continuing but is now considered to need to be a dual carriageway!
Trafford appears to be wedded to an outdated plan to implement a carbon-hungry new road, to the exclusion of all potential opportunities to reduce the number vehicles on our roads.
We would like to see these alternatives fully evaluated alongside the proposals for the road. We recognise that Trafford’s lack of consideration for these options has resulted in a timing issue, but we believe there are ways to alleviate the existing traffic problems, without destroying our green belt.
There are huge gaps in the information needed to determine the most appropriate approach to resolving the traffic issues in the area.
We would like to see a more comprehensive evaluation which includes an assessment of the natural capital assets in the area, the detailed traffic numbers and a review of the carbon implications.
Without the information mentioned above, we do not believe the Scrutiny Committee can undertake an adequate review of the current proposal.
For more information about our previous analysis relating to the Carrington Relief Road, please check out our website.
Friends of Carrington Moss 
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