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Manchester Friends of the Earth response to the South East Manchester Multi Modal Study (SEMMMs) Refresh consultation

Stockport Council recently consulted on a ‘Refreshed’ SEMMMs transport strategy.  SEMMMs is supposed to be the South East Manchester Multi-Modal Strategy.

Unfortunately, over the lifespan of SEMMMs most of the focus has been on building new roads or widening existing ones.  Meanwhile, the transport sector in Greater Manchester (and in the UK as a whole) has become the largest sector contributing to climate change emissions and air pollution.

Greater Manchester is required to reduce air pollution to be compliant with legal limits in the ‘shortest time possible’ and also has to urgently reduce climate-wrecking CO2 emissions to meet the Green Summit objective of becoming ‘carbon neutral’ by 2038.

It is disappointing that Stockport Council are seemingly focused on building new roads – which create more traffic via induced demand and often simply move congestion further down the road.

“As a part of a co-ordinated plan, increased highway capacity can also include road building.” (SEMMMs refresh consultation document. Page 73).

“simply increasing highway capacity to meet an ever growing demand for car travel is not sustainable or, indeed, physically or financially practical” (Greater Manchester Transport 2040 Strategy)

We need to be investing in sustainable transport options such as cleaner and affordable public transport services and enabling people to make more of the short, local journeys by walking and cycling.

The full Manchester Friends of the Earth response to the SEMMMs consultation is available (pdf) and the introduction to Stockport Council leader Alex Ganotis is shown below.

Want to help campaign for clean air and sustainable transport in Greater Manchester?  Get involved with the Manchester FoE Healthy Air and Sustainable Transport campaign.

For more information please email  graeme[at]


15th July 2018.

Dear Alex Ganotis

Thank you for inviting people to respond to the South East Manchester Multi Modal Study (SEMMMs) refresh.

Manchester Friends of the Earth is an award-winning environmental group, creatively campaigning on local, national and international issues and actively promote sustainable transport initiatives and solutions for Greater Manchester.

We have encouraged people to respond individually to the SEMMMs refresh and are submitting this more detailed collective response.

Our response is arranged in 6 sections, namely:

1. Climate change
2. Air pollution
3. Building more roads is not a sustainable solution.
4. Priority for Whom? Congestion doesn’t just affect motor vehicles
5. Noise pollution
6. SEMMMS – more multi-modal solutions required.

Manchester Friends of the Earth’s vision for Greater Manchester’s transport system is one in which there has been substantial modal shift away from the private car and towards public transport, walking and cycling. All vehicles have zero tailpipe emissions. Transport provision is affordable and well integrated with easy-to-use journey planning tools and everyone has the services they need within easy access in their district centre so that there is less need to travel.

In this vision, these changes have greatly increased the level of active travel and improved air quality across Greater Manchester. This has seen improvements in the health and wellbeing of the people living and working in the region helping to reduce pressure on the health service. Better spatial planning, focused on improving access and opportunities in district centres across the region, has reduced the need to travel and has resulted in a low carbon footprint for the conurbation’s transport system and a thriving economy.

The Greater Manchester Green Summit highlights that Greater Manchester needs to become carbon neutral by 2038 and that steep reductions in CO2 emissions are needed in the next 5 years.

Given the overwhelming evidence that building more roads leads to increase traffic levels, these proposals for road-building (bypasses and widening schemes) will not help Stockport and Greater Manchester meet this 2038 carbon neutral target. It is alarming that the SEMMMS refresh fails to mention “climate change” at all and provides no assessment of the cumulative CO2 emissions impacts of the transport options being proposed.

One of the ‘next step’ actions from the Green Summit requires Transport for Greater Manchester to revise the 2040 Transport Strategy to be in line with the Mayor’s 2038 carbon neutral target 2038 date and all road building should therefore be considered within this revised context.

Manchester Friends of the Earth makes the following key points:

* The SEMMMs refresh document provides a misleading impression of the original SEMMMS Strategy. It does not reflect the multi-modal transport proposals that have not been delivered.

* Strategic Priority 7 should be reviewed as it is focused on two major highway schemes which would have severe environmental impacts, encourage unsustainable land use development, result in increased congestion elsewhere and take a high proportion of the potential transport funding likely to be available.

* The highway schemes are presented as “concrete proposals” whereas the more sustainable options (bus and rail services) are listed in the section that starts “Our aspirations are”.

* More sustainable options such as bus and rail services should be presented as solid proposals, whereas at the moment they are limited to ‘aspirations’.

* The SEMMMs refresh document asserts that highway congestion is increasing, when data shows that traffic flows have reduced on major local roads and there is evidence that this highlights a longer term change. Modelling should therefore be repeated in light of this changing context.


We would strongly urge Stockport Council to take this opportunity to revise the SEMMMS strategy to be in line with the urgent need to reduce CO2 emissions from the transport sector. Such an approach would also help Stockport Council meet its legal obligations to be compliant with air pollution levels in the shortest time possible.

Building new roads, or widening existing roads, is not a sustainable solution.

We look forward to working with Stockport Council to help achieve our vision.

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