SLR: Why Greens Object

HEREFORD & South Herefordshire Green Party strongly opposes the plan for a Southern Link Road for the following reasons. We have included detailed Notes but you don’t need to read this unless you want this detail.

1. THE ROAD WILL PASS THROUGH AND DESTROY PART OF GRAFTON WOOD, DESIGNATED AS ANCIENT WOODLAND. 

Four of the route options originally considered for the SLR were deemed not feasible because they affected another ancient woodland – Newton Coppice. It is inconsistent for this application to propose that Grafton Wood can be damaged but not Newton Coppice, when both have the same protected status (1).

National Planning Policy Framework requires that planning permission is refused where ancient woodland is lost or damaged, unless the benefits of the proposed development clearly outweigh the loss.

Notes:
(1) Transport Assessment Part 8 of the application explains how the route for the Southern Link Road was chosen, stating on page 4:

“In total eight options were initially developed.
 As further detailed work and appraisal has been undertaken on these options, four routes have been identified as affecting the ancient woodland of Newton Coppice. National policy now considers ancient woodland as an irreplaceable habitat which is unlikely to be fully mitigated. These options are therefore not feasible.”

(2) National Planning Policy Framework:

118. When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: 

(…) 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;

(3) Planning Inspectorate decision regarding an ancient wood:

1) Northside Copse (Lake House), Fernhurst (Ancient Woodland) (Appeal decision 2013)

The case involved a proposal for a single very large dwelling which would have been built in part within ancient woodland, and also within the South Downs National Park (SDNP). The decision took into account a number of issues which make it an important case study.

The Inspector noted that the NPPF has stronger wording for ancient woodland than PPS9:

‘…whilst NPPF… cancels the advice in PPS9, the test in respect of Ancient Woodland is very similar in NPPF paragraph 118 to that in PPS9 paragraph 10 save for the fact that there is now a more onerous requirement on developers to show that “the need for, and benefits of, the development in that location clearly outweigh” as opposed to simply “outweigh” the loss.

Considering whether the need for a development outweighs the loss of ancient woodland, the inspector upholds that small incursions into ancient woodland are unacceptable.

Impacts on the Ancient Woodland caused by the proposal would include the direct loss of flora and irreplaceable ancient soils and a substantial change in the character of the woodland arising from the development and its ancillary services. Whilst the Appellants have suggested that this would be only a small proportion of the woodland identified as AW, NPPF considers any loss to be unacceptable.’

2.  THE PROPOSED DEVELOPMENT WILL CONTRIBUTE ADVERSELY TO CLIMATE CHANGE AND AIR POLLUTION

The application acknowledges that the Southern Link Road will “have an adverse impact on the environment, including increasing traffic noise, reducing air quality, and impacts to the landscape and heritage assets”. Whilst not specifically commenting on how it affects CO2 emissions, elsewhere the application claims that it will slow the growth in carbon emissions, implying that carbon emissions will increase as a result of traffic on the SLR.

This is contrary to adopted Local Plan policy SS7 ‘Addressing Climate Change’.

Notes:

1. Local Plan Policy SS7 Addressing climate change

Development proposals will be required to include measures which will mitigate their impact on climate change. At a strategic level, this will include […] delivering development that seeks to reduce the need to travel by private car and which encourages sustainable travel options including walking, cycling and public transport’

3. THE PROPOSED DEVELOPMENT WILL ENCOURAGE CAR USE

The aim of the road is stated to be to reduce congestion and journey times. Unless modal shift to non-car use is actually achieved through other measures – which are not a part of this application – the result will be more car use. This is contrary to adopted Local Plan policy S6 Transport.

Notes:
1. Policy S6 Transport – The safe, efficient and sustainable movement of people and goods will be promoted within the context of reducing the need to travel by:
(2). encouraging alternatives to the motor vehicle which through reducing energy consumption and pollution have less environmental impact

4. THE PROPOSED DEVELOPMENT WILL CONTRIBUTE TO FASTER GROWTH IN ROAD TRAFFIC. ITS FORECAST IMPACTS ON ROAD CONGESTION, JOURNEY TIMES, AIR QUALITY AND THE ENVIRONMENT ARE UNRELIABLE

The application claims that because the development is a link road it will not generate traffic. This assertion is behind the traffic modelling used to forecast vehicle movements in the surrounding network in 2017 and 2032. There is considerable and widely accepted evidence that building roads of this type does generate traffic – the induced traffic effect.

Induced traffic tends to increase environmental damage and tends to reduce the calculated benefit-cost ratio of a road improvement, because the period of relief from congestion will be shorter than planned; also because the benefit to the marginal extra travellers is less; and because assuming the extra traffic is not induced makes the ‘without’ case artificially worse than it really would be.

Notes:
1. The application Transport Assessment states:

7.1.1  Unlike residential or employment development proposals, which are trip origins or destinations in their own right, the application development will not in itself generate traffic. The purpose of the traffic impact assessment in the TA is therefore to understand how traffic is likely to re-route from existing roads when the SLR and Clehonger Link are opened, and the degree to which this is considered likely to occur.

2. In 1994 SACTRA, the Standing Advisory Committee on Trunk Road Assessment, published its best-known report, on what it renamed ‘induced’ traffic. The average traffic flow on 151 improved roads was 10.4% higher than forecasts that omitted induced traffic and 16.4% higher than forecast on 85 alternative routes that improvements had been intended to relieve. In a dozen more detailed case studies the measured increase in traffic ranged from 9% to 44% in the short run and 20% to 178% in the longer run. This fitted in with other evidence on elasticities and aggregate data.

The conclusion was:

“An average road improvement, for which traffic growth due to all other factors is forecast correctly, will see an additional [i.e. induced] 10% of base traffic in the short term and 20% in the long term.”

The Department of Transport accepted this. The report was updated in a special issue of Transportation in 1996

3. Countryside Agency and CPRE’s 2006 report ‘Beyond Transport Infrastructure’ studied the traffic changes resulting from many by-pass and relief road developments. Three of note:

A27 Polegate bypass – 76% total traffic increase in the Polegate corridor one year after opening – of which up to 27% may be generated traffic. Casualties across the area increased
A34 Newbury bypass – A34 traffic growth far above both predictions and national averagePeak-time congestion in town back to original levelsTraffic relief to old road
is being eroded by development-generated traffic
M65 Blackburn bypass – M65 traffic in excess of predictions, leading to pressure for road wideningTraffic generation by developments omitted from appraisal process

5. ALTERNATIVE SUSTAINABLE TRANSPORT MEASURES HAVE NOT BEEN APPRAISED ADEQUATELY

The application proposes that a package of measures such as behavioural change, cycling and walking promotion, will / may be introduced at some unspecified time in the future to complement the SLR and help achieve the stated aims of improving transport conditions in Hereford south of the Wye. These Sustainable Transport Measures are described in the application but because they have not been implemented there is no evidence of their effectiveness, or their value for money relative to the SLR.

It is very possible that these measures will make a positive contribution to the problem and will provide better value for money than new road building.

The Highways Agency (now Highways England) has commented on the SLR proposal that it would expect to see evidence that sustainable transport measures have been introduced and found to be insufficient before a new road is built.

Notes:

1. Highways Agency letter of 7 August 2014 to Hereford Council said that “under current guidance the building of new road infrastructure could only be justified in policy terms when other avenues such as travel planning and sustainable travel modes had been developed and shown not to address the transport needs and issues identified.”

Serious flaws in Herefordshire Council’s Local Transport Plan consultation

Herefordshire Council is currently consulting residents on its ‘Local Transport Plan 4’ which will have effect from 2016 to 2031. Local authorities are required by the Local Transport Act of 2008 to have a local transport plan.

Hereford Green Party believes that this consultation has been made so complicated and difficult to use that very few people in Herefordshire will be bothered to respond, or will be able to make meaningful comments.

When the Council Overview & Scrutiny Committee discussed an interim report from officers about the consultation on 19 January, they heard that only 154 people had responded since early December.

The Council consultation webpage lists a total of 16 long documents as ‘policy’, ‘evidence’ or ‘related pages’. In total several hundred pages. Poor broadband connections will make it virtually impossible for many people to read these background documents.

The consultation survey asks only 15 questions about the new Policy and six about the Environmental Assessment. The questions in the survey are too narrow, and don’t invite comments or constructive criticism. The big assumptions in the proposed plan – notably the Southern Link Road and the Hereford Relief Road – are not open for discussion.

Completing the survey on-line is unsatisfactory. There is no way to go back to earlier pages, or to save partial input in order to research other materials. There are no links in the survey form to any of the evidence, making it difficult for the respondent to research anything on which questions are being asked.

There should be a clear statement listing what is being changed in LTP4 compared with the previous plan, LTP3. Ordinary members of the public are not going to spend their time comparing two 40 page documents.

It is also very concerning that the on-line survey itself is insecure – it is a simple matter to submit multiple responses. Furthermore, respondents are not required to give their names or where they live.
In contrast, comments on planning applications are not accepted without a name and address. People submitting petitions to the Council have to prove their supporters are real (or at least show they have collected names, signatures and postcodes).

Hereford Greens Spokesperson Rob Palgrave said,” The Council expects to use the results of this consultation exercise to show it has support for its new Transport Plan. The flaws in the on-line system and the poor response levels suggest that any mandate they get will be of very dubious value.”

Southern Link Road to Nowhere

Dubbed the Road to Nowhere, Hereford’s Southern Link Road is appropriately making slow progress. The planning application – with around 500 written objections – was to be decided at a meeting of Council planning committee on 23 November.  Now it’s delayed to sometime in 2016, as planning officers fathom out what to do about the objections raised by Historic England which centre on the harm the road would do to the historic environment surrounding Haywood Lodge.

Late in November, It’s Our County submitted a request to Westminster to have the planning application decided by the Sec. of State on the grounds that Herefordshire Council has a conflict of interest in considering whether to grant itself planning permission – specifically it is likely to benefit financially from land sales were the road to be built.

And planning permission is not the only obstacle – the £27m funding needed to build the road has then to be approved by the Department for Transport. Roads Minister Andrew Jones has confirmed that the Council has to submit a business case once they have got planning permission and have lined up contracts with builders, and it is for him (Andrew Jones) to make the final decision based on value for money. Several of the objectors are already putting aside diary time to unpick and criticise the business case when it is released.

The national and local organisations listed below have objected or commented critically on the SLR plans – this is definitely not just a NIMBY campaign. Objectors see the SLR as a huge waste of public money, which will do nothing to reduce car usage and dependency, and will damage nature and landscapes for ever.

Herefordshire Wildlife Trust (effects on wildlife and vegetation )
Historic England (ancient monuments – effect on the setting of Haywood Lodge)
Hereford Civic Society
Hereford City Council
Here for Hereford
Hereford Transport Forum
Herefordshire Campaign to Protect Rural England (CPRE)
Campaign for Better Transport
Hereford and Worcester Gardens Trust
Clehonger Parish Council
The Tree Council
Woodland Trust
Natural England (critical comments only)
SUSTRANS
Hereford Green Party
Callow & Haywood Parish Council