Is it necessary to build on green belt in Trafford (or elsewhere in GM)?  The short answer is NO!

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 encouragedand 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.

What was promised for Carrington, Partington and Sale West in previous Trafford Local Plans and Strategies?

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.

Furthermore, the 2012 Core Strategy refers to Government Guidance.

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.

Charging – the lazy, unsustainable, ineffective way to reduce air pollution!

There are alternatives to the planned GM Clean Air Zone!


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


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

We won’t cover the what and the why in relation to Air Pollution here.  You all know it is very harmful to our health (from the cradle to the grave), that there are a number of dangerous (killer) pollutants that you cannot see in the air and that there are a range of sources, including road traffic – click on the graphic for more info.

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

Yet, only one solution has been proposed

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

So, what about the alternatives???

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

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

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

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

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

Yep, you got it!  NONE/ZERO/NADA!

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

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

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

Do the decision-makers understand the problems?

It doesn’t seem so! 

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

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

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

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

People are also asking, what happens to all that money that will be collected, where will it go, what will it fund?  Perhaps a new section should be added to the Clean Air GM website to explain!

We don’t think so – NO!

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

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

What is the answer?

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

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

They ARE your key stakeholders!!!

And finally, in relation to Air Pollution!

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

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

Betrayal of the North – an opportunity for change?

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

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

Blah, Blah, Blah

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

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

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

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

Cutting out local people

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

The report states that:

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

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

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

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

Community groups feel the same

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

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

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

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

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

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

More importantly, will it make any difference?  

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

Links:

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

Will GM’s planned new developments impede their carbon emissions target?

Well, the answer is ……………………

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

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

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

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

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

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

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

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

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

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

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

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

For more information, Mark can be contacted here.

Steady State Manchester’s work can be found here.

You can watch a recording of the meeting here.

Join our Walk for Wildlife

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Presenting our petition to Trafford Council

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

Anna Chopping:

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

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

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

1. We are asking for more consultation,

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

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

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

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

So, what about alternative options?

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

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

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

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

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

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

After all, where else in Trafford can we

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

Thank you.

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

What does Trafford’s latest report about the Carrington Relief Road (CRR) mean for affected residents?

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

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

3. Route Options

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

5.3 Option F Risks

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

Extract from Natural England response 22nd March 2021

What are we seeking?

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

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

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

What is so wrong with this latest report?

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

In short, our key concerns about the Appraisal are:

Our other issues with this report include:

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

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

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

Public engagement should also meet the requirements of Trafford’s Statement of Community Involvement and should be carried out in line with the Gunning Principles (very helpfully summarised by the Local Government Association in the graphic to the right – click to see full screen).  These Principles have formed a strong legal foundation from which the legitimacy of public consultations is assessed and they are frequently referred to as a legal basis for judicial review decisions.

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

The decision does seem to be predetermined.  

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

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

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

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

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

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

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

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

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

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

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

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

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

Endorsements in the petition against roads being constructed across Carrington Moss

Do the future travel options follow Policy?

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

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

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

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

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

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

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

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

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

What about the health and wellbeing of Trafford residents?

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

The World Health Organisation has announced (22nd September 2021) that it is reducing the maximum safe levels of key pollutants with PM2.5: reduced from 10 µg/m3 to 5 µg/m3 (NB the legal limit is 20 µg/m3) and NO2: reduced from 40 µg/m3 to 10 µg/m3 (NB the legal limit is 40 µg/m3). These levels will be phased towards the 2030 target date but this is clearly something that should be considered.

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

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

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

What about the losers?

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

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

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

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

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

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

Is Places for Everyone/GMSF2021 the right plan for Trafford and GM?

Open Letter to All Trafford Councillors

Dear Councillor

Before you vote on the Places for Everyone (P4E) Spatial Plan for Greater Manchester (previously known as the Greater Manchester Spatial Framework – GMSF), we’d like you to consider the following significant concerns about its acceptability as the spatial plan for GM for the next 16 years:

  • We understand that Labour Councillors across GM will be whipped on this decision, which is an odd approach if there is confidence that it is the right plan, setting out the right future, with the right balance of economic, social and environmental goals, making the right decisions for the residents of GM, and, in our case, Trafford.  Why is it not possible for Councillors to be persuaded by the evidence that adopting this plan is demonstrably the most appropriate, necessary and commendable option for the P4E Councils?
  • All GM Councils, including Trafford, and the GMCA itself have declared a climate emergency, therefore, all decisions made should reflect this commitment to your current and future residents – we do not believe the plan, as currently articulated, has sufficient focus on tackling climate change
  • Despite there being no evidence that the proposed release of green belt is justified, anywhere in GM (in fact quite the opposite, as explained below), 2,430 hectares of GM’s green belt will be released for development immediately following plan approval (P4E reports a net loss of 1,754 ha as the Plan proposes adding 675 ha of new green belt)
  • Whilst the plan demands that residents must accept a loss of green belt, and the consequent impact to their health and wellbeing, there are no policies that incorporate demands on developers (for example, to build those properties that already have planning permission), there are no policies to prevent developers securing planning permission on what is currently green belt land, yet not delivering against that approval, possibly resulting in yet more green belt land being proposed for release in the future
  • Greater levels of division and inequity will be driven by this plan, not just in terms of access to local green belt but also in access to schools, affordable homes (the New Carrington allocation, for example, will now only provide 15% affordable, due to viability issues) and public transport (New Carrington, for example, with 5,000 homes planned within P4E and a further 1,000 homes in the area with recently granted planning permission, has no trams, no trains and no commitment to new bus services – we have checked this via an FOI request)
  • Residents will suffer the health impacts of increased air, noise and light pollution and constructing 4 major roads across a peat moss will also significantly affect the populations of red listed birds and endangered wildlife that breed and feed in the New Carrington area
  • The New Carrington Masterplan conflicts with many key policies and strategies, not just those set out in P4E but also with the objectives outlined in, for example, the 5 year Environment Plan for GM and the spirit of a number of clauses in the National Planning Policy Framework
  • The GMSF has repeatedly been published with flawed, misleading or disingenuous statements, which should not be necessary if there is confidence in the benefits of the plan
  • There has been an unprecedented volume of responses from residents objecting to the planned builds on green belt across GM in the previous consultations (2016 and 2019), yet the GMCA continue to propose this!

Available Land Supply:

The documents tell us that the P4E plan area has a projected population increase of around 158,200, and housing occupancy rates averaged at 2.38 people per home (according to Census 2011, latest information from ONS puts occupancy levels at 2.4 but as this would reduce the figures further, we have used the Census figure).  This results in a housing need of 66,500 homes for the P4E plan area.  This figure can be compared to an available land supply of over 170,000 homes, as set out in Table 7.1 (excluding green belt allocations).  Given that this figure is over 2.5 times the need for homes, there is sufficient leeway for larger numbers of single occupancy houses, should this become a requirement of future trends.  In fact even without the (20,000) green belt allocations (see Table 7.1), there is more than sufficient land supply (170,000) for every single expected additional member of our population (the increase of 158,200) to have their own home! 

It is clear that there is NO justification for the release of green belt. 

The P4E document itself states that there is sufficient housing land supply to meet the overall identified need in the Government’s formula/algorithm.  The green belt allocations appear to have been made in case developers do not deliver.  We believe this issue should be addressed with policies that make demands of developers, not policies that result in the release of our green belt land.

We have heard the mantra “the Government is making us do it” quoted.  We recognise that there is mixed messaging, which is unhelpful.  The Government has confirmed, including specifically in relation to GM, that the housing need figure is not a target (in both Parliamentary debates and in writing).  The recent MHCLG blog (25th May 2021) seems to be pretty clear:

The Local Housing Need is simply a measure of need and we recognise that not everywhere will be able to meet their housing need in full – for example, where available land is constrained due to the Green Belt and an area therefore has to plan for fewer new homes.”

Given the implications of the climate emergency, Brexit and the pandemic, the GMCA could, and should, have concluded that the sufficiency of housing land supply did not need to be supplemented by a release of green belt at this time.

Green Belt Release:

Yet, despite these numbers, green belt will be released as soon as the plan is approved and P4E proposes a significant loss of green belt across GM – 1,754 hectares in total, equivalent to 2,456 football pitches.  For Trafford, at 269 hectares, our loss of green belt represents over 15% of this figure (the equivalent of 376 football pitches).  Trafford enters this plan with significantly less green belt land (37.6%) than the GM average (46.7%) and will exit it with a much larger (6.7%) net loss of green belt than the GM average (3.27%).  Leaving Trafford residents with even greater inequity of access to local green belt than previously available, with our post plan green belt figure being just 35% of Trafford’s land area against a GM average of 45%.

There are alternative approaches.  Oldham, for example, proposes (North-East Growth Corridor) that land will be retained in the green belt “until such time that a review of this Plan and / or the Oldham Local Plan can demonstrate that it is necessary”.  All GM Authorities, including Trafford, could adopt similar wording to create a policy that ensures green belt land continues to be protected and is not released whilst brownfield sites are still available for development.

Misleading Statements:

The history of misleading statements that have permeated previous iterations of the GMSF has, disappointingly, continued into P4E, with, for example, the New Carrington Allocation Topic Paper stating (paragraph 12.2) that “Carrington Moss is a former peat bog”.  It then goes on to contradict itself by confirming “initial investigation indicates a maximum thickness of peat of 3m, which thins towards the perimeter”.  That is 9 feet of peat deposits, which are regularly under significant surface water flooding for at least 6 months of the year (see our website page Carrington Lake).  We have requested clarity about this statement from Trafford officers as a recent presentation to residents by the GM Wetlands Project (LIttle Woolden Moss) confirmed that peat can be restored where deposits are as low as 15cm.

The graphic below highlights some of the disingenuous statements included in previous iterations of the plan, along with a summary demonstrating the consistent lack of resident support for the New Carrington Masterplan.  As we are not considered to be major stakeholders (the New Carrington Masterplan defines these as landowners and developers), this plan does not consider the views of local residents.  This is not the approach the Labour administration has taken on strategic plans for other parts of the Borough.  Why are the views of the residents of Carrington, Partington, Sale West and Warburton not considered to be as important as those of Crossford Bridge, Flixton, Stretford and Turn Moss?

There are many other points that we could raise and we will share these over the coming weeks, but for the reasons set out here, and others, we firmly believe the plan will be found to be unsound when examined by Planning Inspectors. 

If you would like to discuss any of these points further, please do not hesitate to contact me.

Kind regards

Marj Powner (Chair)

Friends of Carrington Moss

Understanding Sustainability

When Trafford talks about New Carrington being

into a sustainable location, what does it mean? 

Well, it is interesting, because the plans for New Carrington will take away some inherently sustainable aspects of the area and replace them with some fundamentally unsustainable characteristics. 

Read on, to find out more!        But first……………..

If you look it up, you’ll find various definitions which suggest that being sustainable is about ensuring we avoid wearing out our natural resources as we seek to achieve financial success, whether personally, corporately or globally. 

The National Planning Policy Framework (NPPF), which all development masterplans and planning decisions should follow, says:

This policy links to the UN declaration within Resolution 42/187 of the United Nations General Assembly, which raises concerns about the accelerating deterioration of the human environment and natural resources and the consequences of that deterioration for economic and social development.

The document proposes that sustainable development becomes a central guiding principle of the United Nations, Governments, private institutions, organisations and enterprises

Effectively, this means that plans should not be approved if they are likely to prevent future generations from meeting their needs.  Looking at some very basic examples, their ability to breathe clean air, access healthy, food sources with a low carbon footprint, and have clean water to drink. 

So, at a very high level, it is fair to say that we should not be building on a peat moss, which has the potential to be restored to sequester carbon more effectively, nor should we be building on Grade 2 agricultural land, which future generations may need to grow their food, nor should we be building on wetland which has the ability to reduce flooding and support clean water strategies for the future. 

Many commentators, however, only focus on how sustainable the design and development of construction projects are, how sustainably sourced the materials used will be and how attractive the new neighbourhood will become.  This is certainly true of Trafford’s own considerations within the New Carrington Masterplan, which mentions the word “sustainable” 42 times.  The section on Sustainability (4.9) states that it is “part of a holistic design process that runs throughout all aspects of the scheme, including design and layout of buildings and landscape, the components of the masterplan, transport strategy and phasing”. 

Trafford suggests that delivery of the masterplan will result in sustainable transport, sustainable communities, sustainable society, sustainable economy, sustainable drainage and sustainable movements. 

Yet, there is no mention of what will be lost to future generations.  In fact, the Masterplan describes the area (several times) as “the former Carrington Moss”! 

Excuse us, but ……………

In addition, the language used in the masterplan document does not bode well for future sustainability.  Even in that specific section on Sustainability (page 55), developers are only “encouraged” to use sustainable sources of construction materials and the Government’s forthcoming standards.  Principle 9 (page 31) is another good example “Optimise sustainability This masterplan supports prioritizing Biodiversity Net Gain and, where possible, optimise the wider environmental benefits for a sustainable society and economy.”  So, sustainability will be achieved “where possible”.  Should plans be approved on that basis?  We don’t think so.

Trafford acknowledges that the New Carrington allocation area is not a sustainable location today.  They assert that their vision is “to transform Carrington, Sale West and South Partington into a sustainable and attractive, mixed use residential and employment neighbourhood”.  We will not get hung up in this blog about the fact that these are three separate neighbourhoods, each with their own distinct characteristics. 

It is important to recognise, however, that NONE of these neighbourhoods will become sustainable if the New Carrington Masterplan, as currently documented, is implemented. 

Do keep reading to find out why we think this!

The NPPF has a clear focus on sustainable development.  Paragraph 103, for example, states that “Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.” 

So, what about the area covered by this Masterplan?  With 5,000 new homes, 380,000 m2 employment space and 4 new major roads, it is clearly a significant development.  Yet in New Carrington, there is only one commitment and that is to the new road known as the Carrington Relief Road.  The plan suggests that the strategic roads will “enhance the provision of sustainable transport”.

But …………

There are NO commitments to improve public transport for this, the largest housing development in the Greater Manchester Spatial Framework (now known as Places for Everyone), no trams, no trains and no new bus services (in fact, another bus service has been withdrawn from the area recently).  For more information on this, see our previous blog confirming the revelations from our Freedom of Information Act requests here.

We mentioned the substantial volume of peat that remains on Carrington Moss in another previous blog (When is a Peat Moss Not a Peat Moss).  Peat is an irreplaceable habitat, so a mass extraction event to remove this precious substance cannot be offset by any amount of Biodiversity Net Gain (to say nothing of the huge release of carbon into our local atmosphere).

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. 

In comparison, most new buildings, however sustainably built, do not have the capability to capture carbon, and those that do cannot compete with the carbon sequestration capabilities of our peat mosses.  In fact, such construction will result in a huge increase to carbon emissions locally (more heating, more cars on the road, more waste removal).  Furthermore, as this article suggests – it takes over 50 tonnes of CO2 to build the average UK house

Conversely, in addition to their superior carbon capture capabilities, the restoration of our peatland habitats would bring numerous ecosystem benefits, such as water quality improvements, flood impact reduction, species recovery, biodiversity gains, wellbeing and climate cooling to name just a few.  This wetland environment is a very effective tool which reduces the potential for local flooding (take a look at the Carrington Lake page of our website for more information) and helps to dissipate polluted air, with the large areas of woodland on Carrington Moss also supporting carbon sequestration. 

So, here on Carrington Moss, Trafford will be reducing the highly sustainable peatland area (which could be restored to capture carbon more effectively) and will replace it with housing and employment sites that generate extensive additional carbon emissions and do not have access to sustainable transport options.

But………….. that is not all!

The employment area in Carrington, located alongside the Medieval village, has previously had substantial areas of industrial and warehousing development approved over the years.  This has resulted in huge volumes of HGV traffic on local roads and other pollutants being released from some of the business premises, causing well known, significant and unacceptable, health and wellbeing issues for local residents.

Yet, the New Carrington Masterplan currently proposes to build a further 380,000 square meters of additional industrial and warehousing space (so, no digital, no technology, no green or professional occupations, just industrial and warehousing sites).  This lack of diversity, and the resulting very limited career opportunities, means that many local residents will not have the range of employment options that they would need to find work locally.  In addition, these new employments sites will bring yet more HGV traffic into the area because alternatives, such as rail freight or shipping (given the proximity to the Manchester Ship Canal) have not been proposed.

The brownfield sites in the allocation area have already been granted planning approval.  The remaining land is either green belt (Trafford plan to release 169 hectares) or Protected Open Land.  Where this land is not the peat moss or woodland mentioned above, it is Grade 2 agricultural land, excellent for crop production, supporting existing employment, in farming activities and horse riding/stabling pursuits, both of which sustain Trafford’s local economy.  Much of that existing Grade 2 agricultural land will become housing, industrial or new roads and most of the rest will become extremely polluted as a consequence of all that construction, preventing future generations from being able grow crops here and food growing in the UK is even more important now (because of Brexit), it’s not as easy, or cost effective, to import, given the trade barriers that have been erected.  The plans will decimate the existing agricultural and equine economy and local supply chains will be severely impacted by the loss of these businesses too. 

Furthermore, the development will fracture the wildlife corridor, significantly impacting many red listed birds and endangered wildlife populations.  The active travel routes, that are widely used by large numbers of local residents, will also be extensively affected.  There are, for example, over 1,000 horses stabled in this area, many of which are ridden across Carrington Moss on a regular basis.  Already popular prior to the pandemic, recreational use of the moss by cyclists and walkers has increased dramatically over recent months.  All these healthy, active, outdoor pursuits will be severely constrained by the plans for development.

In researching for this blog, we’ve been talking to some existing employers who are currently based on the Carrington and Warburton Mosses to find out how sustainable they are today.

Carrington Riding Centre, for example, has focused on various environmental improvements, continuously investing in their land, maintaining their fields and recycling their horses’ waste.  They also invested heavily in a bore hole so they can produce their own water. 

Their carbon footprint is low, the Centre purchases their bedding and feed from local farmers, they use environmentally friendly supplies for horse feed and bedding and their café uses recyclable products too, such as paper cups, plates, etc. 

They would like to do more and regularly review potential grant funding to explore opportunities to:

  • introduce renewable energy
  • make the most efficient use of non-renewable resources
  • improve water courses and drainage. 

All of these are very expensive for a small business like theirs to absorb but they are keen to ensure they are as sustainable as possible.

Local farmers also aim to be sustainable and contribute to environmental improvements, such as hedge planting, ditch cleaning, soil quality improvements and they use the least amount of chemicals possible in all their activities.  One farmer told us that, whilst they do use local horse and chicken manure, there are times when they need to use chemical fertilisers.  The farmers deploy GPS and weigh cell technologies to ensure precision application, only dispersing what is needed for that crop, in that location, so the environmental impact is reduced as far as possible.

One of our local farmers hires out straw and hay bales for events.  They then recycle the used bales for their cattle bedding and then further recycle them as fertiliser on the fields.  They are conscious that manufacturers in their supply chain do not always use recyclable packaging, and, whilst this is changing for some products, it is still especially true for the bale wrap. 

Like the Riding Centre, local farmers would consider increasing sustainability, if funding becomes available.  They have also looked at renewable energy, such as solar panels on shed roofs, and improvements to water courses.  They have recently taken up opportunities, through grant funding, to renew fencing, cattle handling facilities, more GPS systems, yield monitoring and livestock monitoring via CCTV, all of which improve the sustainability of their businesses. 

Government funding schemes are evolving, and many are becoming more environmentally focused.  Local farmers are following proposals such as sustainable farming incentives (which will be simple actions most farms can achieve), whole farm plans, crop management, livestock plans, integrated pest management, soil plans, etc.  Local Nature Recovery initiatives, which Greater Manchester is piloting at a Regional level, would involve creating more woodland, wetland, restoring peat mosses, and supporting natural flood management.  The Carrington and Warburton Mosses would be ideal locations for these proposals.

Yet, despite all these Regional and National initiatives, Trafford is willing to sacrifice our essential farmland, this Grade 2 agricultural land, for construction, even though there are urban areas in sustainable locations, that could be used to build homes and employment properties (and it seems the amount of brownfield land is likely to increase post-Covid because of the recognised changes to working practices and personal habits that have become apparent over the past year).

The conclusion of Trafford’s document states that “This masterplan report demonstrates that the New Carrington Allocation site is deliverable and sustainable”.  We do not agree!  The plan to build 5,000 new homes, 380,000 m2 industrial and warehousing employment space, and 4 new major roads on a peat moss and Grade 2 agricultural land is clearly NOT a sustainable strategy. 

Sustainability is more than just a concept.  It is an intrinsic, high value, asset, with features that can and should be measured and monitored.  Furthermore, the assessment of the potential sustainability of this location lacks credibility and this masterplan demonstrates a huge lack of knowledge about the area itself!

That said, when the CPRE tells us that there is “enough brownfield land for 1.3m new homes” and the Local Government Association highlights that “More than a million homes granted planning permission in the past decade have not yet been built” we have to ask why there is a plan to build on green belt at all?  Who will benefit?  Trafford residents?  We think not!

Let’s just remind ourselves again about those words from the NPPF:

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”.

So perhaps what we should be asking ourselves is – are there other places in Trafford where we can:

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

If the answer is “No” to one or more of these questions, we should not be building on Carrington Moss.

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