Here is Manchester Friends of the Earth comprehensive and technical submission with an overall emphasis in the AQ Directive non compliance
We wish to register our objections to the A6 to Manchester Airport Relief Road, planning application designation 13/4355M.
Our objections are based on the premise that the proposal is not compatible with the principles expressed in statutory local and national planning documents.
The report submitted by the Director of Economic Growth and Prosperity to the CEC Cabinet on 15 October 2013, agenda item 8, quoted the business case for the scheme set out in an earlier paper, stating its objectives as being to:
ñIncrease employment and generate economic growth: -provide efficient surface access and improved connectivity to, from and between Manchester Airport, local, town and district centres, and key areas of development and regeneration (e.g. Manchester Airport Enterprise Zone);
ñBoost business integration and productivity: – improve the efficiency and reliability of the highway network, reduce the conflict between local and strategic traffic, and provide an improved route for freight and business travel;
ñPromote fairness through job creation and the regeneration of local communities: – reduce severance and improve accessibility to, from and between key centres of economic and social activity;
ñReduce the impact of traffic congestion on local businesses and communities;
ñImprove the safety of road users, pedestrians and cyclists: reduce the volume of through-traffic from residential areas and retail centres; and
ñSupport lower carbon travel: reallocate road space and seek other opportunities to provide improved facilities for pedestrians, cyclists and public transport.
We would like to point out that such benefits are by no means certain. Has it been considered, for example, that any growth at the Airport will draw employment and retail spend etc. away from neighbourhood centres in the area? This is likely to result in little overall growth but increase the need for employees to travel greater distances. The CEC Local Transport Plan Final Strategy stated (para. 2.19):
Current planning policy encourages new development in sustainable locations, so as to minimise the need to travel to that destination by private vehicle. Where a greater range of attractive travel opportunities exist, more people will have the ability to choose sustainable travel modes such as public transport, walking and cycling. There is also a balance to be struck regarding the future vitality of rural towns and villages whereby new development and population increase may support jobs and services.
To concentrate employment at the airport and on a new road flies in the face of this strategy. The SACTRA report (1), accepted by the Government at the time, pointed out that in a mature economy, such as the UK, there is no automatic connection between major transport infrastructure and economic growth.
The suggested traffic advantages in reducing congestion and improving road safety are equally uncertain. Although the SEMMMS team responded that “mitigation measures are proposed for the A6 through High Lane and Disley that will manage traffic flow, support the local centres and improve non-motorised user facilities”, it is not yet clear what these will be, nor whether they will be sufficient to counteract the effects of a heavy new traffic flow joining the A6 eastbound at that point.
And as for supporting “lower carbon travel”, the very opposite will be effected. There will be longer journeys on a route where most people will have no alternative but to use their cars. It would be very different if the public transport aspects of the SEMMMS strategy were to be implemented.
The South East Manchester Multi Modal Study (SEMMMS) listed its aims as follows:
ñto improve public transport;
ñto improve use of road space;
ñto encourage transport change;
ñto encourage urban regeneration;
ñto improve highways.
The recommendations include:
ñenhancements to the fixed track network, including Metrolink extensions to Stockport and Marple;
ñan eastern rail link to the Airport and provision of new rail stations on the existing heavy rail network;
ña Relief Road be built to improve access, ease congestion and therefore assist in the regeneration of several areas of the Borough.
A key element of the SEMMMS strategy was that, to achieve its aims, it should be implemented as a whole.
We note that building of the relief road is the last of these recommendations. However, we note that this is the only one of these recommendations being planned for the near future, despite appearing to be against the key element of the SEMMMS strategy, implementation as a whole.
It has long been established that the provision of new roads induces extra journeys which impact on surrounding roads. Modelling has been carried out to predict the extra traffic that will be generated in the network by the proposed new road. The accuracy of this modelling has been questioned, but even using it the SEMMMS team have conceded that there will be increased traffic on various existing roads.
Of particular concern is the A6 in Disley and High Lane. In response the SEMMMS team state ‘there is ongoing discussion ….. on what the most appropriate form of measures would be on the A6 corridor where an increase in traffic level is forecast…. There is a commitment as part of the scheme that mitigation measures will be implemented, however the detail is still to be determined.
Objection 1. Despite the Relief Road being included in SEMMMS, its proposed construction at this time is in contradiction to the SEMMMS recommendations, given the onus on implementing these as a whole.
Objection 2. A planning application for the A6 to Manchester Airport Relief Road has been submitted despite the lack of specific mitigation measures having been put forward for the A6 in Disley and High Lane, which is predicted to experience a large increase in motor vehicle traffic, and hence in congestion and emission of particulates.
2. NATIONAL PLANNING POLICY FRAMEWORK, dated MARCH 2012
The stated aim of the National Planning Policy Framework (NPPF) is to allow people and communities back into planning. Its introduction and section 196 state that the NPPF is a material consideration in planning decisions.
Section 7 of the NPPF sets out its interpretation of how the roles of the three dimensions of sustainable development, namely economy, society and environment, should be addressed through the planning system.
Section 8 states that these roles should not be taken in isolation and that to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.
The core planning principles listed in section 17 include:
ñsupport the transition to a low carbon economy…..;
ñcontribute to conserving and enhancing the natural environment and reducing pollution;
ñactively manage patterns of growth to make the fullest possible use of public transport…..
ñcontribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework.
Section 75 states ‘Planning policies should protect and enhance public rights of way and access.’
Section 93 states ‘Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions….. and supporting the delivery of renewable and low carbon and associated infrastructure. This is central to the economic, social and environmental dimensions of sustainable developments’.
Section 158. states that ‘Each local planning authority should ensure that the Local Plan is based on
adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.
The Glossary entry for sustainable transport modes is: ‘Any efficient, safe and accessible means of transport with overall low impact on the environment, including walking and
cycling, low and ultra low emission vehicles, car sharing and public transport’.
Objection 3. The proposed relief road is contrary to NPPF principles in that it:
- Does not jointly and simultaneously achieve economic, societal and environmental gains.
- Does not align with several NPPF core planning principles, in particular by:
effectively implementing the least sustainable SEMMMS recommendation before those which are sustainable transport modes;
damaging the natural environment by destroying ancient woodland at Carr Wood (in Stockport MBC);
damaging public amenity by degrading the central section of the Ladybrook Valley Interest Trail at Norbury Hollow and Mill Hill Hollow.
- Does not secure reductions in greenhouse gas emissions
- Is not based on up to date and relevant evidence about the economic, social and environmental characteristics of the area and country.
Note: documents were accessed on Cheshire East Council and UK Government websites on various dates between 12 October and 29 November, 2013.
Transport and the economy:summary report (SACTRA), www.cipra.org/alpknowhow/publications/sactra/sactra1
1.0) The SEMMMS scheme needs to demonstrate that when the road opens air quality is not worsened in areas of poor air quality and that pollution levels are within the limits determined by the EU Air Quality Directive. SEMMMS has reported that air quality will generally improve but they have not used the Directive’s methodology for the assessment.The Directive is a legal requirement.
1.1) The SEMMMS method involves counting the number of houses that see improved or worsening of air quality.
1.2) The other method based on the EU air quality directive identifies representative locations near the source of the pollution and assesses changes at these locations. Many of these locations will be at the roadside or kerbside. As air pollution rises the roadside measurements will reach limit values before the alternative locations further from the road. It follows that even though they use the same limit values the SEMMMS method will always be less sensitive to rises in total air pollution and more people will be affected to a greater degree.
1.3) This leads to contradictory conclusions. In one SEMMMS report the houses flanking the existing A555 road which sees an estimated 100% increase in traffic shows an acceptable air quality whereas another SEMMMS report shows extensive exceedances along the cycle track that runs parallel to the A555 road.
1.4) There are other significant weaknesses in the SEMMMS method. Less than 10% of the total number of houses are assessed and the choice of houses is in practice, arbitrary.
1.5) A modest improvement on the A6 where many small terraces flank the road will over estimate the benefits compared to a significant worsening in Disley with fewer and larger houses leading to an underestimate of worsening air quality.
1.6) In Poynton the SEMMMS method shows a general improvement on Chester Road and London Road North. But London Road South which has at least 4 NO2 sensors and Clifford road which has an estimated doubling of traffic have been excluded from the sample.
1.7) Other anomalies include an improvement on the A34 at Cheadle even though the estimated traffic rises by 2%.
2.0) SEMMMS claim that they have followed the DfT’s interim advice note 175/13 which describes assessment 4m from the road edge and is intended to facilitate an assessment of the risk of being non compliant with the Directive. There is very little evidence that this has been carried out in any meaningful way. In fact FOI requests reveal that no estimate has been made for the existing measurement locations.
2.1) IAN175/13 provides a method for deciding whether a scheme is ‘high risk’ or ‘low risk’. A ‘high risk’ assessment only occurs if there is no satisfactory ‘scheme air quality action plan’ proposed. SEMMMS will need to create an action plan to cover the exceedances on the existing A555 caused by the estimated traffic increase to 60,000 vehicles per day.
2.2) SEMMMS intend to take the road through Carr Wood which is protected ancient woodland but they could easily realign the road further up the A6 to avoid the wood at less cost. Contrary to the SEMMMS assessment, the current alignment would adversely affect at least half the area of the wood. The only substantive argument for taking the road through the wood is to maintain the planned alignment up to Bredbury. In fact Mouchel’s have said that the road would not be built if they were not allowed to take the road through Carr Wood. However a successful air quality action plan is unlikely to be able to accommodate the resulting extra traffic from Bredbury and the M60.
3.0) The scheme needs to comply with the Directive or demonstrate that compliance will be achieved over a period of time under the control of an action plan.
3.1) Carr Wood needs to be protected by diverting the road around the wood without reference to the unviable extension to Bredbury.
3.2) The existing A555 should probably been have declared an air quality management area in 2009 due to high measurements taken that year but not continued. This would have identified the air quality problems earlier in the project giving more time to consider the alternatives.
Rt Hon Patrick McLoughlin,
Secretary of State for Transport,
Department of Transport,
National Transport Casework Team,
Newcastle Business Park,
Newcastle Upon Tyne,
NE4 7AR. 30th January, 2014
Dear Mr McLoughlin,
Compulsory Purchase of land for the A555/SEMMMS road Greater Manchester
SMBC are currently applying to compulsory purchase land for the A555/SEMMMS road that includes Carr Wood. Carr Wood is a bluebell wood that straddles the county boundary between Greater Manchester and Cheshire East near Hazel Grove. Carr Wood is included in the Ancient Woodland Inventory and is protected as such in the NPPF. The current plans show that the carriageway, let alone flanking earthworks, overlay the ancient woodland. Experts say that the zone of a road’s influence extends 100s of metres through ancient woodland. Carr Wood is about 300m wide. It is therefore likely that most of the woodland will be adversely affected by the road.
We contend that the Council (SMBC);
- incorrectly identified Carr Wood as an Site of Biological Interest despite MCC correctly identifying it as AW before SMBC took leadership of the project in 2000.
- supplied potential consultees with maps that omitted Carr Wood ancient woodland but which did show other neighboring areas of ancient woodland.
- did not consult recognised experts regarding suitable mitigation
- only produced alternative road alignments that mitigated the impact on the ancient woodland in September 2013 under pressure from NGOs and local residents.
We fear that allowing the ownership of the land to be transferred to the Council might result in damaging preparatory works being carried out before the road alignment and appropriate mitigation has been fully investigated.
We respectfully ask the Secretary of State to make provision to prevent any preparatory works that might adversely affect the ancient woodland before the road receives planning permission and before funding is fully granted. There are many instances of damaging preparatory works preceding cancellations of this road scheme which dates back to the 1930s. In this area alone cottages were demolished following compulsory purchase, just downstream of Carr Wood in the 1990s even though today’s alignment would probably have not required their elimination.
We trust the matter will be given the Secretary of State’s full consideration. Yours Sincerely,
Stephen Houston (Chair. PAULA residents group) 218 Chester Road Poynton Cheshire SK12 1HP (Mob 07929 603534)
Supporting drawings and notes
Council’s 2013 map of Carr Wood showing the their alternative route to the A6. We would contend the route is actually less expensive because it reduces three separate junctions on the A6 to 1 junction because there is more space available than at Simpsons Corner. It also simplifies the crossing of the railway by an overbridge normally preferred by the Network Rail engineers. Furthermore, the A6 residents do not have to endure the A6 traffic being rerouted past their rear gardens. The driving consideration for the Council is maintaining the 1930s alignment for a simplified extension up to the M60 at Bredbury. However the Council are predicting NO2 exceedances on the existing section of the A555 when the road opens caused by the traffic flow rising from 24,000 to 60,000 vehicles per day. A future connection to the M60 would just make this so much worse.
Part of Council’s drawing showing alternative route round Carr Wood (blue and brown notes added by PAULA)
The Council identified Carr Wood in their NATA worksheets (2013) as the most adverse environmental impact anywhere on the scheme but have proposed no mitigation, no other aspect of the scheme is identified as high as ‘Large Adverse’.
The overall assessment score of moderate adverse has been derived due to a number of individual moderate adverse assessment scores. The large adverse assessment score for the loss of a small area of ancient woodland at Norbury Brook Wood is unavoidable as the proposed scheme in this location is not subject to change due to
other physical constraints. As such and in line with WebTAG guidance the overall assessment score is considered to fairly represent the scheme as a whole.
Yet the Woodland Trust would have given the Council specific advice based on extensive research. In particular they advise a buffer zone between 50 and 150m wide separating the road from the woodland. This would have allowed the road to pass south of the wood joining up again with the A6, 300m further up the A6 towards High Lane.
The Trust sent the Council a letter of objection for the first phase of public consultation but the Council made no subsequent attempt to seek the Trust’s advice. The Trust is not included on list of consultees in the current planning application.
24th January 2012 Dear Sir or Madam, Proposal: A6 to Manchester Airport Relief Road
…The Woodland Trust objects to the proposed scheme as it will cause the direct loss to an area of ancient woodland. This site is Norbury Brook, also known as Carr Wood (grid ref: SJ933854) and is an area of Ancient Semi Natural Woodland (ASNW)….
….The protection of woodland in England – legislation and policy. The current mechanisms provide for the general protection of woodland in England and
for the specific protection of ancient woodland sites:….
…We hope that you find these comments of use. If you have any queries relating to the information that we have provided then please do not hesitate to contact us.
Katharine Rist Campaigner Ancient Woodland
In fact the 2010 environmental scoping report produced by the Council’s consultants included maps and supporting text that referred to other areas of ancient woodland nearby but completely omitted the existence of ancient woodland at Carr Wood. The Carr Wood area was simple
identified along with a far more extensive wooded area, as an SBI. At this time the Council’s Solicitor was preparing notes for briefing lawyers for the SEMMMS planning application in which he specifically refers to this ancient woodland. This implies a worrying lack of clarity in the Council’s appreciation of local Geography.
Part of figure 2c from the 2010 Environmental Scoping Report that omitted the ancient woodland (note in black identifying Carr Wood added later by PAULA)
Here is a commentary from Transport for Greater Manchester describing the significance of SBIs;
Sites of Biological Importance (or SBIs) are a nonstatutory designation used locally by the Greater Manchester districts. SBIs have no legal protection, but do receive some protection through different policies and they must be taken into consideration by the local authority when planning applications affect the site. Sites are selected using a
number of attributes that include; habitat type, diversity and rarity of the species present, and the sites naturalness.
compared to the protection of Ancient Woodland in the NPPF, paragraph 118;
..planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss.
Natural England responded to the request to comment, oblivious to the omission of the ancient woodland(19/07/2013);
Dear Mr McMahon
Proposal: A6 to Manchester Airport Relief Road – Phase 2 Consultation
Thank you for your consultation on the which was received by Natural England on 10 June 2013. Natural England is a nondepartmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Natural England has previously commented formally and informally on the EIA Scoping report in 2009 and 2010 and then in January 2013 we responded to a request from Mouchel for comments on scope of the EIA in the light of minor changes to the scheme design. Overall we were satisfied with scope and coverage of environmental issues related to our statutory purpose.
Having considered the information in the Phase 2 consultation, we have no further specific comments.
(Please excuse the abridged content. We would be pleased to send the original documents obtained under FOI and EIA if this would be useful. SH)
A total of 1,043 UK woods have been under threat from development over the last ten years. And with just 2% of the UK’s land area covered in ancient woodland we cannot afford to lose anymore.
The UK’s ancient woodland is one of the few remaining living links to our past. It’s the richest, most valuable habitat for wildlife we have, covering only around 2% of the land area of the UK.
Contrary to popular belief, ancient woodland is not fully protected and threats are relentless.
Loopholes in the planning system, short-term government thinking and careless disregard are putting ancient woods at risk every day. Infrastructure plans – such as HS2, housing, quarrying and roads – and applications for development such as campsites, car parks and even golf courses pose ongoing threats.
Ask the Government to protect all ancient woodland.
Go here for further information:
We have no money, unless it is for new roads, in which case we have plenty.