PLANNING IN HEREFORDSHIRE
Herefordshire CPRE volunteers have noticed a steady climb in county planning applications since the NPPF was published in 2012. A number of those have been successful at appeal due to the county’s lack of a five year Housing Land Supply (HLS)
However an application is current that has alarming implications for the landscape of Herefordshire - an application for the Southern Link Road (SLR) is currently available for comment.
Southern Link Road (SLR)
This proposal threatens large swathes of Herefordshire’s green fields and will impact our heritage of historic buildings, from Haywood to Grafton. View the SLR route
Lack of safe walking or cycling routes along the SLR
By excluding the Sustainable Transport package the road on its own does not accord with the existing policies of the UDP or the new policy SS7 from the Core Strategy.
After it was identified in the South Wye Transport Package (SWTP) consultation and reports that there are a lack of safe connected East-West cycle or walking routes, the Council wrote the following:
“There is estimated to be very little demand for a walking (Cycling) routealong the length of the SLR or Clehonger Link andthere are already more direct and convenient walking routes between the urban areas of south-east and south-west Hereford. Onthis basis no footway/cycleway has been included in the design adjacent to the carriageway of the proposed SLR and ClehongerLink.”
This is a direct contradiction of what the SWTP identified; is contrary to Planning policy and there is no reference to evidence to support the statement “estimated to be little demand”.
Additions to plan post consultation
The SLR application also has a spur of road going off to Clehonger, which has been added since the plan was available for consultation – therefore this latter addition has not been consulted upon at all.
So… the SLR threatens ‘just’ the land between Haywood and Grafton?
This is just the next section in the whole scheme. Herefordshire Council’s plan is to have the city ringed with roads.
Some may remember that the Rotherwas Access Road, which HCPRE and many others campaigned against, covers an unique prehistoric pathway.
The next step will be even more green fields under threat and impact to historic houses with the western section of this road plan - route yet to be decided (see map).
The western route cuts though historic parkland at Belmont continuing on to carve through the Breinton landscape that was a favoured spot of Herefordshire painter Brian Hatton.
Herefordshire Council Roads Plan
Western road route
Northern road route
This destruction of Herefordshire countryside and impact to heritage would see alarming amounts of Herefordshire green fields being lost – many of these fields are Grade 1 agricultural land, which could be used for growing food. Herefordshire has amongst the highest proportion of Grade 1 & 2 land (the best for growing food) in the country.
HCPRE has long maintained that the case for this road complex has not been proven. The other concern is that, in order to pay for these roads, housing applications will follow for the 'infill' land. This will obviously lead to more traffic on these roads than is currently planned.
Q.Is this road to relieve traffic congestion or is its purpose to release land for housing development?
All of these new houses will need water and sewerage connections. The current infrastructure is not able to cope with any further demand (phosphate levels are high in the Lugg and are climbing in the Wye)
Water and sewerage
There has been inadequate public consultation about the means by which legally binding water quality targets will be met if the number and location of new dwellings proposed in Policy SS2 go forward.
Numerous critical and necessary items are lacking any cost information. Key uncosted items include the sewage treatment works improvements at Hereford, Rotherwas, Leominster and the rural areas (which are also critical to enabling any Nutrient Management Plan (NMP)and thus meeting Habitats Regulations requirements) and water supply upgrading in Hereford.
Even at the current submission stage, only parts 1 and 2 of the NMP have been issued, while part 3 which is the 'action plan' that will provide the evidence of whether and how the water quality targets can be met is missing.
The actions identified in the NMP will fall to third parties. In the case of sewage discharges, Welsh Water is responsible and the Council has provided no evidence of a binding commitment by the former to provide improved treatment. To quote from the part of the NMP issued so far (para 13.2.1) "The level of confidence in actual environmental outcomes from implementing the measures are relatively low..".
"..the measures considered rely on future technology which at this point is only theoretical and there is a risk that it may not be possible to achieve a level of 0.1mg/L phosphate as assumed in this study."
No figures are given in the May 2014 Infrastructure Delivery Plan for any of the required sewage treatment works upgrades.
Cargill is increasing its poultry processing in the county, as HCPRE has seen with increasing applications for Broiler Units. Part 2 of the NMP has already identified this as significant potential source of agricultural phosphate discharge.
HCPRE full response to the Core Strategy consultation
HCPRE urges County residents to write a brief objection to this application, citing the environmental impact of the SLR and also the lack of a considered consultation
The SLR application was entered on 18th May with the closing date for comment being 18th June. This consultation time is the standard time for comment on a planning application; however, the SLR application consists of 109 separate documents and drawings, of which 20 are larger than 10MB.
Due to this and the County’s traditionally poor broadband services, HCPRE believe that the consultation process should be extended to allow for absorption of so many large documents, leaving aside the issue of being able to download the plans.
HCPRE has concerns over several aspects of this application but 3 areas are of major concern:
1) The consultation process and choice of route
2) Compliance with NPPF sustainable development
3) The environmental and heritage impact
Write your own letter of objection to the SLR – example of Herefordshire CPRE letter below.
A copy of HCPRE's initial objection is available to download here: HCPRE SLR objection
We will be writing a full objection but, given the timeframe, a holding letter was sent to Planning Services. We have been informed that as long as comments are received by 18 June, as a marker, further comments can then be submitted and will be considered.
Please do write a letter in objection to this application. You may use the HCPRE letter as a guide.
Housing Land Supply (HLS) and the Local Plan
The National Planning Policy Framework set out that each Local Authority had to have a 5 year HLS to encompass growth. Failure by Herefordshire Council to identify a 5 year HLS has contributed to many speculative large scale housing proposals and is an important tool used by developers in appeals against Herefordshire Council’s decisions to refuse applications.
This issue is compounded by the fact that Herefordshire currently has no adopted Local Plan. The draft Local Plan 2011-2031 is now 4 years behind schedule and thus the County has no unassailable policy document to guide planning decisions. The majority of Herefordshire's countryside is unprotected by designations such as Green Belt. This situation leaves the county wide open to unchecked development.
The previous plan, the Unitary Development Plan of 2007, is now obsolete although there are some ‘saved’ Policies
NPPF (National Planning Policy Framework) 'The Developer's Charter'
Published in 2012 the NPPF was the largest shake up to national planning policy in decades. This document cites a presumption in favour of ‘sustainable development’, although it does not clearly define the term.
Any county that does not have a Local Plan in place therefore has to bow to the NPPF’s presumption in favour of sustainable development.
This is in effect a developer’s charter. As we have already seen in the county, developers are taking refused cases to appeal, where the application is then passed and costs are awarded to the developer (a further drain on a traditionally poor rural county).
CPRE has long been concerned that this situation could lead to an LA accepting proposals they might otherwise have refused, in order to avoid costs in an appeal.
Planning is one of the most important ways in which we can control and protect our environment. Planning decisions affect us all, yet local people often have very little input. We want planning to be fairer, engage communities and protect the countryside as well as regenerate our towns and villages.
CPRE's Herefordshire’s view on planning
The planning reforms we want to see:
- An open and accessible planning process to encourage more people to engage with the planning system;
- A fair appeals process, to provide fully justified planning decisions;
- Greater weight for the views of local communities in the planning system;
- Locally distinctive communities, where high quality, well designed, energy efficient and appropriately located homes meet local needs and enhance distinctiveness;
- A countryside that is valued and protected.