CPRE Cheshire response to initial Trafford Local Plan consultation

We have submitted a detailed response to Trafford Council’s initial (regulation 18 stage) consultation. We want to see the borough become a better place to live and for nature to be protected and supported.

We support many of the proposed policies as they stand. There are many more we would be able to support with some improvement.

Overall, we are relieved that no further loss of Green Belt is proposed (following the losses in the Greater Manchester Places for Everyone Spatial Framework).

However, the Plan is incomplete in multiple areas and does not acknowledge the importance of the Carrington and Warburton peat mosslands.

Many of the points we make about the environment are supported by the Scoping Report prepared for Trafford Council by TEP, the Environment Partnership.

We also have concerns about the likelihood of robust monitoring, accurate data collection and the willingness/ability to enforce policies, especially in view of Trafford’s budget gaps and its need to tackle a deficit exceeding £12m.

Climate change and environment

Climate change

The Plan needs to respond more strongly to climate change. It should call for specific reductions in carbon emissions and footprints and integrate climate change considerations into relevant policies.

For example, policies should ensure that new homes are low carbon, promote investment in the green economy, and state that that the council will ensure businesses adhere to climate change regulations and standards.

Further serious climate change issues include the plans to build on peatland.

Green infrastructure and natural environment

The plan includes a strategic objective to protect and improve the natural environment plus multiple related policies. However, many of these words ring hollow in the context of the allocation for development of large areas of previously unbuilt land including valuable parts of the Manchester Mosses peatlands.

Land allocated for development includes 558 acres at Davenport Green and a significant part of the New Carrington site. Outside of the former petrochemical site, New Carrington encompasses peatland, a site of special scientific interest (Brookheys Covert) and eight sites of biological interest, plus another four sites on the periphery. It is also home to some seven birds listed as ‘red’/endangered.

One specific recommendation we make is that the objective to ‘Achieve biodiversity net gain’ (during developments) should be expanded by adding: ‘…ideally in the same areas where biodiversity is lost, in line with priorities set out in the Greater Manchester Local Nature Recovery Strategy and ideally in areas affected by new development’.

Air and water quality

Too many parts of Trafford suffer from poor air quality, due in part to major roadways. This harms both people’s health and the natural environment. The Plan does not cover this, and should. Neither does the Plan cover water quality. The Mersey Valley policy, for example, focuses on improving access and says nothing about improving water quality in the river.

Renewable energy generation

The Plan needs a policy on where and when large scale renewable energy generation will be supported. This policy should promote rooftop solar, making use of industrial and commercial roof spaces as well as homes. In making decisions about renewable energy infrastructure, we recommend an approach that gives a stronger voice to local people.

Water, flooding and drainage

We ask whether the Council is doing enough to manage flood risk. For example, there is no requirement for new developments to avoid flood zones, and Carrington Moss is not listed as a flood storage area when it should be.

We are also concerned about water supply and sewage capacity for the projected number of new houses.

Policies should also include support for retrofitting water efficiency measures.

Built environment, economy and development

Brownfield land

The objective to ‘Prioritise brownfield development by encouraging the reuse and redevelopment of derelict land’ should be more specific. The term ‘derelict’ is not defined in the NPPF.

We suggest replacing ‘derelict’ with ‘previously developed’ and adding ‘and the re-purposing of under-used or empty office and retail buildings and employment sites for housing where appropriate’.

We have previously presented evidence to show that Trafford’s brownfield register needs updating. We urge the Council to do this as soon as possible so it can focus as much development as possible on brownfield/previously-used land.

Housing

We support the emphasis on the use of brownfield land and on delivering high density housing in the most suitable locations, but not the level of building proposed. We accept however that the figure for new homes is imposed by central government. We continue to question the calculation methods and campaign for a more realistic approach.

Failing parts of town centres should be assessed for conversion to housing and, where suitable, included in the Council’s brownfield register.

We support the Plan’s policies around social and affordable homes, homes for older people, lifetime homes, and homes for children.

We do not support the self-build policy because it specifically endorses building on the two major peatland sites, to which we are fundamentally opposed.

Built environment

Proposed Built Environment policies need improving. For example, the Council should require new large buildings to meet specific sustainability standards. Accessibility requirements and the policy for adverts and signs both need strengthening – the latter to include mention of measures to stop the growth in large adverts alongside the M56/M60.

We note also that the Council’s Local List of non-designated heritage assets should be updated to ensure assets of merit are not lost, and we advise of measures to apply considerate construction approaches to wildlife as well as people.

Economy and jobs

We do not support most of the policies relating to development for the economy.

We presented evidence to the Greater Manchester spatial framework examination that the need for employment land had been significantly overestimated in the previous two decades. This was before the increase in home working prompted by the COVID pandemic. Yet these proposed allocations have been carried through to the local plan.

In terms of existing employment land, we should be looking at a flexible approach to ensure such land is best used rather than protecting it for employment use when trends have changed

In addition, the Industrial and Warehousing policy incorporates development on the New Carrington peatland area, and the Office development policy endorses development on Davenport Green/the Timperley Wedge – both of which we are opposed to.

Where new manufacturing and employment land is to be allocated, there should be a requirement for green spaces and landscaping.

The Data and Energy Storage policy needs improvement. It should acknowledge the energy demands of data centres and request developers show what measures will be taken to ensure efficient energy use and mitigate climate change.

We do support the rural economy policy in principle, especially the need to improve access to public transport in rural areas. But we point out again the sustainability issues involved in developing vast areas of previously unbuilt land and reducing green spaces for communities.

Town centres, neighbourhoods and communities

Town centres are usually the most sustainable and accessible locations and should be supported. As well as making provision to enhance and maintain town centres, the Plan should include support for reuse of empty town centre buildings over new out-of-town developments. We recommend also the addition of neighbourhood planning as a theme and that the approach to bolstering town centres be expanded to cover district and local centres.

To inform planning decisions, there should be a commitment to carrying out comprehensive master planning assessments of all the major centres.

We note that taking away important community services/facilities can destroy neighbourhoods and advise that decisions about removing these must be made through personal contact and on-site investigation rather than as desktop exercises.

The proposed policy around new facilities is inadequate because it does not include provisos about traffic, air quality, catering, waste, toilets, light pollution or wildlife impacts.

Travel, transport and parking

Travel and transport

We support most of the travel and transport policies. However, we recommend also investigating the feasibility of reopening the Partington East to Timperley rail link and point out that more could be done to promote the use of the Ship Canal for freight transport.

But we do not support building new roads other than where there is a strong safety case. New roads cause environmental harm, increase exposure to climate change risks and poor air quality, and lead to more traffic.

The Plan should instead adopt a sustainable transport hierarchy as an additional theme, as explained in the CPRE transport policy. This would give greater priority to digital communications, walking, wheeling and cycling.

Parking

We do not support the parking policies.

There is no overall commitment to reduce parking provision in new development or to make explicit provision for people with disabilities. Continuing to promote car parking provision is not sustainable as it is not in line with the need to reduce car use.

The Lorry Parking policy does not mention air quality or the impacts on adjacent local roads or on neighbourhoods.

And research has shown that for various reasons Park and Ride sites are not the environmentally-friendly option they were intended to be. It is far better to have good quality public transport that enables people to do their whole journey without driving.

Culture, tourism and leisure

The strategic objective to support the role of culture, tourism and leisure needs reference to sustainability.

We ask that the policy around new culture, leisure and tourism developments be amended to require the provision of public transport and easy active travel access.

The Plan should also include specific mention of protecting heritage and landscapes.

Infrastructure and planning obligations

Area-specific policies

The Plan splits the borough into a core growth area, inner areas, and southern areas.

Core growth area

We cannot currently support the policy for the core growth area due to major uncertainties around regeneration plans for the area and the possibility of losing rail freight capacity.

Inner area

We are waiting to see the proposed Masterplan. In the meantime, we give qualified support to the inner areas policy.

Southern area

We do not support the southern areas policy, which includes New Carrington and Davenport Green (known as the Timperley Wedge). Development on the New Carrington peat bog would result in the loss of substantial peatland which is crucial for carbon sequestration. We note that Trafford and the other Greater Manchester authorities have adopted a joint policy to protect Holcroft Moss, which is also part of the Manchester Mosses and just over the border with Warrington. All the Manchester Mosses should be protected.

We objected strongly to the loss of Green Belt here during the Greater Manchester Places for Everyone consultation. We also challenged the overall housing figures and presented evidence that the employment land allocations were not justified. Despite this evidence, these allocations have been carried through to the Local Plan.

Trafford Park

We are not convinced that the Trafford Park policy is strong enough to ensure substantial sustainability improvements and deliver a lower carbon footprint and better air quality (both in the main zone and around it).

National Infrastructure Schemes

We object to the proposal to safeguard land for a possible major new rail terminal. The location would be unattractive to travellers, and cause substantial environmental harm and loss of green space, whilst the chosen route presents huge logistical and cost challenges.

A related infrastructure issue is that the plan makes no reference to the motorway service station, hotel, shop and EV charging spaces development between junctions 7 and 8 of the M56 – for which the government has given planning permission. The site is in the same area as the proposed rail terminal. It makes no sense for the plan to feature the rail terminal which is no more than a proposal but not to address the consequences of a new development for which permission has been granted – despite the fact the council opposed the service station and are very aware of the likely problems. Key concerns are that the site – offering high quality food – will become a destination in its own right, resulting in extra traffic and lost business for local food outlets.

More information

Draft Trafford Local Plan

CPRE Cheshire full response to Trafford Local Plan initial consultation

CPRE rooftop solar campaign

CPRE transport policy

Guide to Local Plans