Herefordshire Council Local Plan – Core Strategy (Draft) Questionnaire
4th March 2013 – 22nd April 2013
Response from Here for Hereford
‘Here for Hereford’ is a group of concerned residents based in and around Hereford. Its mission statement, agreed in the autumn of 2010, is as follows:-
Here for: Our People; our Transport; our Countryside; our Hereford!
We are a non-political group, committed to the core values of our
beloved county and city. We encourage challenging debate and action.
1a. What is your opinion regarding policy SS1: Sustainable Development? (page no. 28)
Agree
Partly Agree
Disagree
No Opinion
1b. Please provide any comments you wish to make in support of your answers above.
This Policy needs to be re-drafted (i) to include the words ‘objectively assessed’ in line 4 before the word ‘proposals’ and (ii) include the section at the end of line 13 which starts ‘- taking into account … [with the sub clauses (a) and (b)], and ending on ‘…restricted.’ so that this section appears at the end of line 10, as well. Or re-draft, elaborating the expression ‘material considerations’ so that it applies to all types of planning applications, not just those that accord with ‘policies in this Core Strategy.’
As currently drafted, this Policy does not reflect the wording used in the NPPF.
2a. What is your opinion regarding policy SS2: Housing Distribution? (page no. 8)
Agree
Partly Agree
Disagree
No Opinion
2b. Please provide any comments you wish to make in support of your answers above.
(i) Taking into account the approximately 3,000 homes already identified as being committed and in the plan, there is little explanation of how an additional 13,555 could be ‘market-driven’ to completion, with the obligation also to fund affordable housing during these times of ongoing economic hardship;
(ii) there is no satisfactory explanation of why a reasonable proportion of brownfield sites cannot come forward in this plan period. Hereford has more housing allocated through windfall sites than through the strategic sites. Most of this is available (according to the Herefordshire Strategic Housing Land Availability Assessment 2nd Review, March 2012) on greenfield sites (often of high grade agricultural land) surrounding the city limits, rather than on brownfield sites such as the urban village, Whitecross High School, etc. If these brownfield sites were included the County would have a 5 year housing land supply and a margin for error.
(iii) Information in the background papers which it was intended, according to the Council (see, inter alia, Minutes of Council meeting 8th March 2013), to be sufficient for the purposes of completing this questionnaire, is inadequate – for example, the most recently published Joint Strategic Needs Assessment is for the year 2011, and in it there is no reference to population growth health and wellbeing trends arising out of the proposed addition of 16,500 dwellings to the housing stock of the County by the year 2031. There are attempts elsewhere in the background papers to specify the rate and amount of population growth as far as the year 2031, but the data presented is not always consistent – for example, in the Local Housing Requirements Study Update 2012 the population increase estimated for Hereford over the plan period is 15.2% but the figure used in the Herefordshire Local Plan – Core Strategy Infrastructure Delivery Plan, March 2013, is 13.3% . The recently published ONS 2011-based projections indicate a smaller population growth in the West Midlands (only 6.8% to 2021) than has been used in the Draft Core Strategy projections, and therefore the CS population projections need to be revised downwards. This will have an impact on the entire spatial strategy and, without the necessary adjustments, there will be a further likelihood of the Draft Core Strategy failing a soundness test.
(v) The City of Hereford could only sustain a further 3,800 dwellings without an adverse impact on the SAC River Wye water supply and on the water treatment plants, according to Council data presented during the Revised Preferred Option consultation stage of autumn 2011. The Nutrient Management Plan (offered by Natural England and the Environment Agency) aspires to handle these problems of growth but in effect it can do no more than promise improvements by the year 2027, and it cannot ‘screen out’ the consequences of damaging the SAC, the County’s greatest asset.
3a. What is your opinion regarding policy SS3: Release of housing land? (page no. 44)
Agree
Partly Agree
Disagree
No Opinion
3b. Please provide any comments you wish to make in support of your answers above.
See above, section 2 b. The Policy SS3 is disingenuous. The implication is that housing land sufficient for 16,500 new homes will be released over the plan period, yet elsewhere in the draft Core Strategy documents, severe reservations are expressed about this possibility. The Council needs to reduce its housing ambitions so that it can deliver what it promises along with fit for purpose infrastructure, rather than pursue overly ambitious plans. Repeated assurances from the Council have confirmed that the Council does not want to be in a position to release housing land outside of an agreed Local Plan / Core Strategy and yet if the current draft Local Plan is not scaled down in ambition it will be undeliverable. The consequences of this are that developers will invoke the NPPF and demand the development rights that the NPPF can allow in the absence of a Local Plan.
4a. What is your opinion regarding policy SS4: Movement and transportation? (p. 48)
Agree
Partly Agree
Disagree
No Opinion
4b. Please provide any comments you wish to make in support of your answers above.
(i) Here for Hereford welcomes the support for Sustainable Transport Measures mentioned in the first three paragraphs of SS4, but it strongly disagrees with the proposals for a Western Relief Road.
(ii) We endorse Natural England’s position of not supporting the relief road proposal and we endorse their position that transport investment should focus on managing demand and prioritising environmentally sustainable, low carbon modes and technologies.
(iii) The modelling used to persuade the Council to adopt the WRR proposal as policy is out of date – the 2008 base year used has yet to be ‘refreshed’.
(iv) There is no proper analysis of the reasonable alternative ‘No Road’ Option which NPPF Guidance indicates should be undertaken. A sustainable travel road study (see http://www.hereforhereford.co.uk/wp-content/uploads/2011/09/MTRU-2011-Sustainable-travel-for-Hereford.pdf), offering a proper analysis of the No Road Option, has not been pursued by the Council. The most recent examination of traffic options in the Interim Forecasting Report Addendum Reduced Housing and Employment Option Nov. 2012 (Amey for Herefordshire Council) provides no separate ‘No Road’ option study across all aspects of appraisal: there is no environmental appraisal of a ‘No Road’ option, no value for money appraisal of a ‘No Road’ option, and no suggestion of what else might be done by way of traffic management measures, for example to increase junction capacities, which would support the sustainable transport package as a separate standalone ‘No Road’ option. The statement in Figure 3.2 of the Core Strategy (Draft) that ‘No relief road’ has been considered as an alternative is inaccurate – the Council’s studies, subsequent to the Multi-Modal Model (2009), did not challenge the findings of the 2009 model but its methodology was flawed.
(v) Some of the predictions in this same November 2012 Report Addendum reveal discrepancies compared with national trends, (e.g. traffic reductions under-estimated, despite using the new version of TEMPRO national forecasting) and discrepancies within the Report itself, e.g. anomalies between the Report’s traffic forecasts and those of junction capacity, and between the vehicle km forecast increases and those in CO2 emissions, and, most glaringly, between vehicle km forecasts themselves and the variable demand modelling.
(v) The Highways Agency still doubt the evidence base used to justify the inclusion of the HRR in the Local Plan proposals. They require further assessments, and a greater level of detail, before considering whether or not to have confidence in the Local Plan proposals regarding the A49(T) as an outer distributor road.
(vi) The Council’s modelling has not included HGV usage and yet part of the Council’s argument for an HRR is that it would take HGV and other long-distance journeys away from the current A49(T) through Hereford.
(vii) There is no up-to-date Habitats Regulations Assessment of the proposed Relief Road (including Appropriate Assessment) in the current package of evidence base documents. English Heritage has already pointed out that any new road infrastructure must be robustly appraised as to potential impacts on the historic environment. Natural England expressed concern that ‘in combination’ effects were not fully considered in the HRA Note August 2011, yet the Council’s updated HRA Report (March 2013) still argues that the ‘in combination’ effects of the proposed Relief Road can be left to the Hereford Area Plan stage. Natural England considers that the HRA process needs to be completed early enough for its conclusions to shape and inform the Core Strategy and that this ‘shaping’ has to go beyond simple alterations to policy wording. The failure to provide an up-to-date assessment of the proposed Western Relief Road, at this Core Strategy consultation stage, risks the Local Plan still being found to be unsound.
(viii) There has been a recent proposal (advocated by local MP, Jesse Norman, and the business community) that an Eastern Spur link road should be built in place of a Western Relief Road. Here for Hereford presumes that this proposal will be given due consideration at this final Core Strategy consultation stage. However, as Parsons Brinckerhoff point out in their Independent Review of Technical Studies (July 2011, 2.4.32 and 2.4.65) both eastern and western inner routes present the possibility not only of SAC conditions being breached, but also damage to the overall Historic Landscape which would render the relief road proposals to be found to be unsound.
(ix) Regarding the ESG Link Road, the Southern Leominster Relief Road, the Park and Ride schemes and other schemes identified in the Infrastructure Delivery Plan, there is insufficient detail in the consultation document to enable Here for Hereford to make a considered response.
(x) Here for Hereford finds it odd that there is only one reference to the Belmont Transport Package (p 82) in the draft CS document, and yet there continue to be meetings about the Southern Link of the proposed Western Relief Road, now with a revised suggested route that has not been incorporated into any consultation documents of whatever date, including this one. The Local Transport Plan is to be enjoined with the Core Strategy and it seems unlikely that the Southern Link can simply be added in to the Core Strategy on this basis. Most of the proposals connected with the Southern Link are deeply damaging to the natural environment and detrimental to sustainable transport measures. Also, without the Southern Link costing, the proposed WRR costs are deflated and misleading.
(xi) When Here for Hereford held a public meeting to discuss the draft CS document, on 23rd March 2013, concern was expressed over the condition of the existing roads, in particular the rural lanes, where potholes are now causing accidents and reducing incentives to visit Herefordshire. Money was urgently needed for a repair programme which had been neglected in the past. This expenditure should take precedence over any new road building. Here for Hereford agrees with Councillor Graham Powell who, speaking at their public meeting on transport on 22nd September 2012, said that the ‘invest to save’ programme, dedicated to ‘front loading’ the necessary and fundamental repairs to the road network, should be undertaken as soon as possible.
5a. What is your opinion regarding policy SS5: Employment provision? (page no. 52)
Agree
Partly Agree
Disagree
No Opinion
5b. Please provide any comments you wish to make in support of your answers above.
There should be an additional Policy statement safeguarding high quality agricultural (including orchards) and horticultural land, recognising that such land supports employment.
6a. What is your opinion regarding policy SS6: Climate change? (page no. 58)
Agree
Partly Agree
Disagree
No Opinion
6b. Please provide any comments you wish to make in support of your answers above.
(i) Here for Hereford welcomes the inclusion of ‘green infrastructure’ in the narrative about ‘Improving environmental quality’ and ‘Addressing climate change’ (pp 58-60) but recommends that this should be given greater prominence in Policy SS6.
(ii) Here for Hereford would welcome a commitment to ‘protect the best agricultural (including orchards) and horticultural land where possible’ in this policy on climate change (and see above, section 5b, regarding the recommendation to add this to Policy SS5 on Employment Provision).
(iii) The policy refers to mitigation and Here for Hereford believes the policy would be improved if a commitment to protect areas of tranquillity which have remained relatively undisturbed by noise were added.
Place Shaping Policies Section
This section sets out strategic policies and proposals for Hereford and each of the market towns, and the approach to development in rural areas. It looks at issues…in different places in the county.
Hereford (pages 65 to 97)
7a. What is your opinion regarding policy HD1: City Centre? (page no. 73)
Agree
Partly Agree
Disagree
No Opinion
7b. Please provide any comments you wish to make in support of your answers above.
Here for Hereford observes that most of the policy in HD1 is already being enacted, so there is little point in disputing it. However, as Parsons Brinckerhoff (July 2011, 3.1.7) point out, the Air Quality of Hereford city centre is a key issue. This HD1 policy endorses the expansion of the road network in the city and the provision of additional housing around the City. Measures to reduce vehicle usage have been welcomed in the Local Transport Plan (2012-15) and they should be put at the heart of the HD1 policy.
8a. What is your opinion regarding policy HD2: Movement? (page no. 81)
Agree
Partly Agree
Disagree
No Opinion
8b. Please provide any comments you wish to make in support of your answers above.
Please see comments under 4 (b) and 7 (b) above, summarised as follows :
Sustainable transport measures should be fully supported and extended;
the Western Relief Road proposal is not supported by outside statutory bodies;
its evidence base is out of date, both in terms of traffic modelling, and population figures;
the reasonable alternative of a ‘No Road option’ has not been tested;
an up-to-date and complete Habitats Regulation Assessment has not been undertaken;
the existing road network should be fully repaired before incurring major new road costs
9a. What is your opinion regarding policy HD3: Northern urban expansion? (page no. 83)
Agree
Partly Agree
Disagree
No Opinion
9b. Please provide any comments you wish to make in support of your answers above.
Here for Hereford calls on the Council to reduce its housing targets for Hereford back to the 3,800 for which in November 2011 it was agreed that there would be sufficient water supply and water treatment plants, without damaging the River Wye SAC.
10a. What is your opinion regarding policy HD4: Western urban expansion? (p. 87)
Agree
Partly Agree
Disagree
No Opinion
10b. Please provide any comments you wish to make in support of your answers above.
Here for Hereford calls on the Council to reduce its housing targets for Hereford back to the 3,800 for which in November 2011 it was agreed that there would be sufficient water supply and water treatment plants, without damaging the River Wye SAC.
11a. What is your opinion regarding policy HD5: Southern urban expansion? (p. 91)
Agree
Partly Agree
Disagree
No Opinion
11b. Please provide any comments you wish to make in support of your answers above.
i)Here for Hereford finds it curious that it is only in this section of the CS document that there is a reference to the Sustainable Community Strategy (SCS) (January 2010). The CS is supposed to be closely aligned to the SCS and yet the update of the SCS (promised for publication in 2012 ‘when the full impact of external influences are apparent’) is still not available. The decision to use the 2010 SCS as a yardstick and hardly mention it at all in the CS indicates that the Council do not take this strategy sufficiently seriously.
(ii) Here for Hereford calls on the Council to reduce its housing targets for Hereford back to the 3,800 for which in November 2011 it was agreed that there would be sufficient water supply and water treatment plants, without damaging the Wye SAC.
12a. What is your opinion re policy HD6: Hereford employment provision? (p. 96)
Agree
Partly Agree
Disagree
No Opinion
12b. Please provide any comments you wish to make in support of your answers above.
As indicated above, Here for Hereford asks for a reduction in housing targets for Hereford and therefore the proposed strategic sites will be reduced in size. Sites for employment should come forward in a more organic way, and be more widely dispersed, rather than cluster round new residential areas.
Re the following – No Opinion checked due to inability, within the available timeframe, to consult with Here for Hereford supporters on these matters:
Bromyard (pages 97 to 106)
Kington (pages 107 to 111)
Ledbury (pages 112 to 118)
Leominster (pages 119 to 127)
Ross-on-Wye (pages 127 to 136)
22. Rural Areas (pages 136 to 157)
What is your opinion re policy RA1: Rural Housing? (p.139)
Agree
Partly Agree
Disagree
No Opinion
22b. Please provide any comments you wish to make in support of your answers above.
Here for Hereford considers the target of 5,300 new dwellings in rural areas to be overly ambitious and it reminds the Council of Natural England’s concern that the SAC ‘Conservation Objectives’ (reference sewage infrastructure for the receiving watercourse) must be demonstrated as being achievable.
Re the following – No Opinion checked due to inability, within the available timeframe, to consult with Here for Hereford supporters on these matters:
23a. What is your opinion regarding policy RA2: Herefordshire’s villages? (p. 144)
24a. What is your opinion regarding policy RA3: Herefordshire’s countryside? (p 146)
25a. What is your opinion regarding policy RA4: Agricultural, forestry and rural enterprise dwellings? (page no. 150)
26a. What is your opinion regarding policy RA5: Re-use of rural buildings? (p. 151)
27a. What is your opinion regarding policy RA6: Rural economy? (page no. 154)
Housing policies (pages 160 to 167)
28. Policy
H1 (page no. 161) Affordable Housing
Agree
Partly Agree
Disagree
No Opinion
H2 (page no. 163) Rural Exception Sites
Agree
Partly Agree
Disagree
No Opinion
H3 (page no. 164) Ensuring appropriate range and mix of housing
Agree
Partly Agree
Disagree
No Opinion
H4 (page no. 165) Travellers’ Sites
Agree
Partly Agree
Disagree
No Opinion
28b. Please provide any comments you wish to make in support of your answers above.
Social and community facilities (pages 167 to 172)
29. Policy
SC1 (page no. 168) Social and Community Facilities
Agree
Partly Agree
Disagree
No Opinion
29b. Please provide any comments you wish to make in support of your answers above.
Open space, sport and recreation (pages 172 to 174)
30. Policy
OS1 (page no. 173) Requirement for open space, sports and recreation facilities
Agree
Partly Agree
Disagree
No Opinion
OS2 (page no. 173) Meeting open space, sports and recreation needs
Agree
Partly Agree
Disagree
No Opinion
30b. Please provide any comments you wish to make in support of your answers above.
The issue of public health and wellbeing is high on the agenda of the Council’s current concerns – barriers to the provision of recreation should be avoided.
OS3 (page no. 174) Loss of open space, sports or recreation facilities
Agree
Partly Agree
Disagree
No Opinion
30b. Please provide any comments you wish to make in support of your answers above.
Traffic management (pages 175 to 177)
31. Policy
MT1 (page no. 175) Traffic management, highway safety and promoting active travel
Agree
Partly Agree
Disagree
No Opinion
31b. Please provide any comments you wish to make in support of your answers above.
Here for Hereford finds the Policy MT1 to be reasonable, but it has already disagreed with Policy SS4 to which Policy MT1 refers.
Employment policies, tourism and retail (pages 179 to 194)
32. Policy
E1 (page no. 181) Employment provision
Agree
Partly Agree
Disagree
No Opinion
32b. Please provide any comments you wish to make in support of your answers above.
Ref E 1, Here for Hereford asks for a reduction in housing targets for Hereford and therefore the proposed strategic sites will be reduced in size. Sites for employment should come forward in a more organic way, and be more widely dispersed, rather than cluster round new residential areas.
E2 (page no. 183) Re-development of existing employment land and buildings
Agree
Partly Agree
Disagree
No Opinion
E3 (page no. 184) Homeworking
Agree
Partly Agree
Disagree
No Opinion
E4 (page no. 186) Tourism
Agree
Partly Agree
Disagree
No Opinion
32b. Please provide any comments you wish to make in support of your answers above.
Ref E4, Here for Hereford welcomes the intention within the CS document to protect the County’s unique heritage and environmental assets but it does not agree that the historic route where it no longer exists of the Herefordshire and Gloucestershire Canal should be accorded similar protection.
E5 (page no. 189) Town centres
Agree
Partly Agree
Disagree
No Opinion
32b. Please provide any comments you wish to make in support of your answers above.
Ref E 5, Here for Hereford welcomes the intentions expressed in this Policy but comments that had it been enacted at the stage of the consideration of the Edgar Street development that scheme would not have been granted planning approval and Hereford’s City Centre would not be dying on its feet.
E6 (page no. 192) Primary and secondary shopping frontages
Agree
Partly Agree
Disagree
No Opinion
[32b comments given under relevant sections above]
Local distinctiveness (pages 196 to 203)
33. Policy
LD1 (page no. 196) Local Distinctiveness
Agree
Partly Agree
Disagree
No Opinion
LD2 (page no. 197) Landscape and Townscape
Agree
Partly Agree
Disagree
No Opinion
LD3 (page no. 199) Biodiversity and Geodiversity
Agree
Partly Agree
Disagree
No Opinion
LD4 (page no. 201) Green Infrastructure
Agree
Partly Agree
Disagree
No Opinion
LD5 (page no. 203) Historic Environment and Heritage Assets
Agree
Partly Agree
Disagree
No Opinion
33b. Please provide any comments you wish to make in support of your answers above.
i) Here for Hereford has checked the ‘disagree’ box in every instance of this section because it does not wish its overarching concern about this Policy LD1 to be missed. The NPPF expects a commitment, reference evidence, to be included as follows:
* Protect valued landscapes – possible evidence : strategy and policies to create, protect, enhance and manage networks of biodiversity and green infrastructure – and a policy which seeks to minimise the loss of higher quality agricultural land and give weight to protecting the landscape and scenic beauty of National Parks etc.
* Planning policies should minimise impacts on biodiversity and geodiversity – possible evidence : identification and mapping of local ecological networks and geological conservation interests
* Planning policies should plan for biodiversity at a landscape-scale across Local Authority boundaries – possible evidence : policies to promote the preservation, restoration and re-creation of priority habitats, ecological networks and the recovery of priority species
* Include a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk – possible evidence : a strategy for the historic environment based on a clear understanding of the cultural assets in the plan area, including assets most at risk / a map or register of historic assets / a policy or policies which promote new development that will make a positive contribution to character and distinctiveness.
If the Council cannot show evidence along these lines, there is a risk of the Plan being declared unsound at the EIP stage. Herefordshire’s distinctiveness rests on its historic environment and heritage assets and it would be an irony if the Plan were found to be unsound due to failure to protect these assets in the CS document.
(ii) English Heritage has already recommended that protection of the historic environment in the CS needs to be more robust
(iii) Parsons Brinckerhoff (July 2011, 2.4.52 and 2.4.58-60) discusses environmental assessment and suggests that an impact has to occur on 4 of the 7 criteria set out in WebTAG if it is to be classified as ‘large adverse’. This is an incorrect interpretation of WebTAG. There is a ‘most adverse’ rule in WebTAG which states that the overall impact should be based on the worst performance against any one criterion, not an averaging out. There are grave shortcomings with the Heritage impact assessment, which is apparently solely based on impacts on Scheduled Ancient Monuments.
(iv) Here for Hereford has access to private research into the Council’s earlier studies on proposed Relief Road routes – extracts as follows: ‘In 1996 a report was written by J.D. Hurst (Document 419, Project 1197, c/o County Archaeological Service), ‘Archaeological Assessment of the … Hereford Bypass, Stage 2’. The total number of sites within the routes was 198, of which 43 were identified during the project; whilst 100% of these sites were evaluated on the eastern routes, only 30% were evaluated on the western (Hurst, 1996, p. 19). …There is a further likelihood of underestimate of the environmental impacts from the adoption of the western route, noted by Hyder Consulting in their HRA Note (2011, p.7) regarding the River Wye SAC: ‘Very steep banks at the locations of the proposed western corridors [meant it was not possible] to gain access to much of the bank-side habitat.’
Sustainable design (pages 204 to 215)
34. Policy
SD1 (page no. 205) Sustainable Design and Energy Efficiency
Agree
Partly Agree
Disagree
No Opinion
SD2 (page no. 207) Renewable and Low Carbon Energy
Agree
Partly Agree
Disagree
No Opinion
SD3 (page no. 209) Sustainable water management and water resources
Agree
Partly Agree
Disagree
No Opinion
SD4 (page no. 212) Waste water treatment and river water quality
Agree
Partly Agree
Disagree
No Opinion
34b. Please provide any comments you wish to make in support of your answers above.
Whilst there is much in these SD policies that is uncontentious, Here for Hereford makes the following comments:
(i) The references to ‘exceedence’ of phosphate levels and likely significant effects on an SAC do not make sense.
(ii) Conservation objectives need to be fully explained.
(iii) The policy needs to be re-written to state proposals will not be considered if they are not accompanied with information to demonstrate that there will be no likely significant effect on the water quality of a European site.
Natural resources: minerals (pages 215 to 223)
35. Policy
M1 (page no. 217) Minerals safeguarding areas
Agree
Partly Agree
Disagree
No Opinion
M2 (page no. 218) Annual apportionments for aggregate provision
Agree
Partly Agree
Disagree
No Opinion
M3 (page no. 219) Criteria for the assessment of minerals related development
Agree
Partly Agree
Disagree
No Opinion
M4 (page no. 220) Small scale non-aggregate building stone and clay production
Agree
Partly Agree
Disagree
No Opinion
M5 (page no. 221) Secondary (reused and recycled) aggregates
Agree
Partly Agree
Disagree
No Opinion
M6 (page no. 222) Moreton-on-Lugg railhead
Agree
Partly Agree
Disagree
No Opinion
35b. Please provide any comments you wish to make in support of your answers above.
Waste (pages 223 to 231)
36. Policy
W1 (page no. 226) Waste stream and targets
Agree
Partly Agree
Disagree
No Opinion
W2 (page no. 229) Location of new waste management facilities
Agree
Partly Agree
Disagree
No Opinion
W3 (page no. 230) Existing and permitted waste treatment sites
Agree
Partly Agree
Disagree
No Opinion
W4 (page no. 230) Technologies for biological treatment of waste
Agree
Partly Agree
Disagree
No Opinion
W5 (page no. 231) Waste minimisation and management of new developments
Agree
Partly Agree
Disagree
No Opinion
36b. Please provide any comments you wish to make in support of your answers above.
These policy proposals seem uncontentious so long as they are scrupulously enacted, including realistic cost/benefit analyses before approval of any proposal.
Infrastructure delivery (pages 235 to 236)
37. Policy
ID1 (page no. 236) Infrastructure Delivery
Agree
Partly Agree
Disagree
No Opinion
37b. Please provide any comments you wish to make in support of your answers above.
(i) Here for Hereford has grave concerns about policy ID1 because it is unthinkable that everything listed can be funded from development levies.
(ii) It is unlikely that substantial government funding will be available to boost development levy funding and it is misleading to suggest that it will be.
(iii) The policy should be honest about what can be achieved. Its population and economic projections need to be revised downwards.
(iv) Alternatives should be pursued to replace the disproportionately expensive, and environmentally damaging proposal for a Western Relief Road.
(v) Public expressions of support for increased hospital bed capacity must be addressed – Here for Hereford’s recent survey at a public meeting concluded that this was deemed to be the overwhelming requirement to be noted in an Infrastructure Delivery Plan.
(vi) The background document on the Infrastructure Delivery Plan was not available in a timely manner for it to have been properly considered by the General Overview and Scrutiny committee. The details on costings in its Appendix 1 are woefully inadequate. The public should have had the courtesy of comment from a Scrutiny Committee in order to have had some sort of confidence in the document itself. Its ranking labels against some projects seem to have been prepared by Cabinet members with undue haste and indeed the label ‘fundamental’ against the Western Relief Road lacks credibility – the CS document admits that any proposed relief road cannot expect to be funded until near the end of the plan period, and yet the ‘fundamental’ definition is that it is required ‘immediately’.
38. Is there anything else you would like to say about the Core Strategy?
Here for Hereford considers that the consultation process for this last opportunity for people to comment on this most important Forward Planning Strategy has been conducted with a sense of irritation lacking in earlier processes. Intemperate language has been used by certain Cabinet members. The documents presented have been too long, dense and intense; members of the public have been confused and even upset by this; the documents lack the Crystal Mark for Plain English, and, even for those people with access to the Internet, they have been daunting.
COMPLETED ONLINE AT 13.32 on Monday 22nd April 2013
