Here for Hereford has been trawling through the thousands of comments on the Core Strategy Questionnaire, posted on the Council’s website as follows: https://beta.herefordshire.gov.uk/planning-and-building-control/planning-policy/core-strategy/psp/. PSP is the acronym for ‘Pre-Submission Publication’. It refers to the documents which will go forward to the Planning Inspectorate some time in the autumn, assuming Council endorse the draft Local Plan / Core Strategy at their meeting on 19th July.
It is important to recognise the policies outlined in the Core Strategy are not popular. See, amongst other documents, the summary of questionnaire responses available at http://councillors.herefordshire.gov.uk/documents/s50012961/GOSC_18-Jun-13_Local%20Development%20Framework%20Process.pdf
It is dispiriting that Councillor Russell B Hamilton, Cabinet member responsible for the Core Strategy (the man who promised to listen and learn from the Consultation) has decided he has ‘no issue with alternative views’ because ‘a healthy opposition is a vital part of any democratic society’ (Hereford Times, 11.7.13). Does this make sense?
Turning to some details (and remember the overall percentages include ‘no opinion’):
44% disagree with Policy SS1, Sustainable Development
57% disagree with Policy SS2, Housing Distribution
51% disagree with Policy HD2, Hereford Movement
In addition to deciding not to take these views into account, (simply stating ‘no change required’ against nearly all the comments that indicate ‘disagree’ in the ‘PSP’ document), the Council also has serious questions to answer, such as, how many errors are in the ‘PSP’ document?
At first, Hereford Futures was quoted as considering the Core Strategy to be ‘totally unsound’ (answer to Q’re #8 Hereford Movement) but, following Here for Hereford’s disclosure, the comment was corrected. Apparently 50 lines had been misaligned. Is it reasonable to ask how many other lines are misaligned in the ‘PSP’ spreadsheets which have not been corrected?
The allocation of ‘agree’ to a comment, when it is clearly not in agreement with the policy expressed in the Council’s Core Strategy Consultation questionnaire, further calls into question the validity of the ‘PSP’ document. For example, in rows 6 to 36 in the answers to Q’re #4, Movement Policy, most of the comments indicate reservations about the ranking ‘agree’, and yet they are recorded as ‘agree’. How much weight should be accorded to this spreadsheet analysis? Would the Council have staff available to go through it again?
There are a number of comments submitted to the Council which were not grouped under the policy headings and therefore prove hard to find. One such comment is that from local MP, Jesse Norman, who considers that the draft Core Strategy lacks ambition; he queries the Council’s economic policies; he recommends more borrowing (!!) and he argues that if the Eastern Link Road were excluded at this stage, it would be unlikely to come forward as a realistic proposal until after 2031.
What of the statutory bodies who have already expressed opposition to the inclusion of a Western Relief Road? English Heritage, Natural England and the National Trust (amongst others) still oppose the road proposal. The Environment Agency has concerns about the environmental constraints and flood risk from the proposed road. Apportioning phosphate discharge into the water table is delaying the Nutrient Management Plan.
The Highways Agency had earlier judged the Core Strategy to be ‘unsound’ because they considered that the evidence base for a relief road was inadequate. The Council now says (‘PSP’ document Q’re #8, row 119) that ‘an agreement has been reached with them that a relief road is required to support the Core Strategy’. This is what the Highways Agency actually said in their submission on the Core Strategy:-.
The Highways Agency is pleased to be involved in the ongoing transport evidence base work… Clearly until this work is complete, we must reserve our position in terms of the acceptability of the proposed level and location of development and required infrastructure improvements.
The HA has also highlighted the need for the Council to establish effective delivery and funding mechanisms for the transport proposals in the Core Strategy.
The Council has spent upwards of £4.5 million on the Core Strategy process since the commencement of its Options stages in 2007. The Council has no ‘Plan B’, no completed transport modelling, no Habitat Regulations Assessment for the Relief Road, no Nutrient Management Plan in place, no costed Infrastructure Delivery Plan, and another round of consultation into the issue of soundness begins, probably, in mid-August.
Here for Hereford asks whether this expenditure has been justified, given that the conclusion to the vexed Core Strategy process still seems to be so far away.