Send an email to rpryce@herefordshire.gov.uk with the Application Number in the subject line. You can also add “objection” if you want to. In the email you can use the list below to select a few or a lot of reasons to support your objection. Better still write a letter to:
Mr R Pryce, Planning Services, Herefordshire Council, PO Box 230 Blueschool House, Blueschool Street, Hereford HR1 2ZB
Letters pack the file out and physically show how many people are objecting.
IT IS VITALLY IMPORTANT THAT YOU SPEND SOME TIME CHANGING THE WORDING SLIGHTLY, MIXING THE ORDER OF THE REASONS UP, CHANGING THE FONT, THE NUMBERING ETC. EACH LETTER/EMAIL OF OBJECTION MUST LOOK INDIVIDUAL AND NOT MASS PRODUCED.
Application No: DMCE/092576/F
Description: Demolition of existing buildings and construction of new highway, cycleway, drainage landscaping and associated works between the A49(T) Edgar Street and A465 Commercial Road, Hereford, along with a new road link to unclassified road 80332 Blackfriars Street.
Address: Edgar Street to Commercial Road including Barrs Court Road, Blackfriars Street, Canal Road, Newtown Road, Hereford HR4 9JS
I object to the above application for the following reasons:
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This application attempts to disguise the true purpose of this road. It’s primary purpose is not to reduce traffic congestion on the inner ring road/Blueschool Street Newmarket Street. The real reason is to facilitate the ESG development, for which there is little support from Herefordians or from local businesses. The recent petition presented to the council of over 10,000/11,000/9,000/12,000 names shows the strength of feeling in Hereford that this development should not go ahead/proceed.
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The application should not be given permission until it can be proved that the proposed flood alleviation measures are working. Should these fail or only work partially, this elevated road will exacerbate the ESG flooding problem.
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It needs to be proved beyond doubt that this development will not increase the flood risk to the County Hospital.
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The traffic congestion at the junction with Commercial Road (A465) has not been adequately assessed in this application.
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Future rat runs for cars have not been adequately addressed by this application. These will have a detrimental effect on the lives of people living in Southbank Road, Bodenham Road, Central Avenue and St Guthlac Street. All of these roads are residential streets and none of them have been informed about this application and the increase in traffic that they will experience.
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The current Air Quality Management Area (AQMA) on the A49 will be adversely affected by the building of this new road. People living in an AQMA have the right to expect that any application for development that affects the AQMA should reduce existing pollutant levels NOT increase them.
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Planning permission for a road where one of the primary purposes of the road is to open up an area for development should not be given until applications for the developments it serves are also in place. How can the planning authority seriously judge whether the road will adequately fulfil its function if it knows nothing of the future development it will be used for. This application is premature and should be refused.
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How can this road be considered “sustainable development” when it divides the railway station from the city centre with a 5 lane stretch of new road?
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The expected reduction in traffic on the inner ring road that this development is supposed to achieve could easily be achieved by the introduction of sustainable transport methods rather than building a huge and expensive road.
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Herefordshire Council has been promoting the development of ESG vociferously for the past 5years. How can an authority which has in intimate relationship with the applicant, having created ESG Ltd to undertake the development proposed by the political leaders of the council, genuinely be able to take an independent and dispassionate view of this planning application, particularly in the face of so much local opposition? This application should be determined by a planning inspector and not the Planning Committee of Herefordshire Council.
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Where is the independent verification of the information provided by the applicant?
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The assumptions made in the traffic modelling for this application do not stand up to scrutiny. Trip rates are either underestimated or cannot be actually determined because no applications for the development of the rest of site have yet been received. The continual changes to the masterplan for the ESG area means that the Planning authority cannot be certain as to what is being developed where until these are received.
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It is not sufficient to say that this application will have no effect on congestion levels simply because the authority has plans for an outer distributor road and is developing sustainable transport policy. Funding for large road developments is notoriously difficult; indeed Hereford has never managed to attract any. This road should not be given permission until the ODR has been built.
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The timing of the development of the Outer Distributor Road and the sustainable travel plan will inevitably not coincide with the building of this road. With the further development of the ESG site large increases in traffic will occur along the A49 having a detrimental effect on this major roadway which is already badly congested. This increase in traffic will lead to compensation claims against the Highways Agency.
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The application says that congestion will be reduced, but does not give any information about how these conclusions were arrived at. How can we trust them?
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Herefordshire Council is a shareholder of ESG Ltd and as such has a major conflict of interest in determining this application. As such it cannot play an independent role as a planning authority and should pass this application to a higher authority to determine it.
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There is no facility for bus lanes along the proposed road and it is therefore not compliant with the principals laid down in Herefordshire Councils own Local transport Plan.
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Once this road is built, pedestrian access to the railway station will be dreadful, even with the traffic lights in place. This will not promote better access between the station and the city centre.
BELOW IS AN EXAMPLE OF AN EXTREMELY GOOD LETTER THAT HAS ALREADY BEEN SENT IN – DO NOT COPY IT! THEY WILL BOTH BE IGNORED IF YOU DO. IT IS SIMPLY REPRODUCED HERE TO HELP THOSE WHO WANT TO MAKE THE EFFORT TO WRITE SOMETHING MORE COMPREHENSIVE.
Dear Russell,
Application No. DMCE92576/F Edgar Street Grid Link Road
The Edgar Street Grid development proposals, still being modified could, if satisfactory modifications are made, be an asset to Hereford.. Unfortunately the application as submitted does not meet these requirements and is deficient in many other aspects for the reasons set out below.
In addition and in common with the other 16 occupiers of The Point, Aylestone Hill, I am directly affected by the application. I therefore wish to object to the application and consider that Herefordshire Council should reject it. My grounds for objection are set out below. This list has been compiled in the limited time available and so is not necessarily complete. It is sub-divided into:-
1) Basic objections in principle
2) Comments on specific proposals.
Basic objections in principle.
1. Section 5.33 of the Planning Statement of this application says “…the principle of providing a link road, particularly in the context of other aspects of the ESG scheme such as the proposed retail development on the old Livestock market site remains for some a focus of concern” It certainly does and hence this objection.
2. This application is in respect of one part only of a major development of the city and other parts of the ESG development such as the retail and civic quarters are still the subject of negotiation and revision. Consequently this application should not be considered until further information is available from Stanhope and others on these recently proposed revisions.
3. The size of the application document is such that it is not possible for those who wish to examine and comment on it to do so in the time available and consequently there will be a democratic deficit as the Council, when dealing with the application, will not have a properly considered response from the public.
4. There is a very large amount of technical data and opinion included in the application which requires expert and experienced knowledge to assess it. With the present state of technical support available to Herefordshire Council such expertise is unlikely to be available in the proposed timescale and consequently the application cannot be dealt with or recommendations made in a proper manner.
5. Herefordshire Council is a shareholder in ESG (Hereford) Ltd and is therefore an interested party while at the same time having to determine the application. This represents a major conflict of interest.
6. The application sets out some Key Urban Design Principles such as:-Ease of movement and adaptability; unlikely to be achieved when both access to new housing and diversion of a main route are being served by the same road.
- Ease of movement and adaptability; unlikely to be achieved when both access to new housing and diversion of a main route are being served by the same road.
- “A prime function” is to divert traffic away from Blueschool and Newmarket Streets so improving connections between the ESG and the historic city. But no information is given of how and when the alterations to the Inner Ring Road are to take place. Until they are, this “prime function” will not be achieved and consequently the Link Road application should not be considered until more details of the Inner Ring Road changes are available. If this desired and vital improvement is to be made to Blueschool/Newmarket Streets it should be a requirement that it takes place at the same time as the Link Road and the planning application for these works considered alongside the Link Road application.
- “Business relocation is a key off-site enabling provision” but this problem is nowhere near being solved and there is considerable danger that many jobs will be lost. The application is inconsistent regarding the number of employees affected by the project. This will certainly not produce the “benefits to the local economy” claimed.
7. Section 5.2.9 of the Planning Statement sets out nearly 40 objections and questions that were raised in the consultations held. The vast majority of these still stand. The answers that were given then were vague and the application does not deal with them satisfactorily. Consequently the consultation was flawed and the application should be rejected.
8. The road is designed as single carriageway, with continual changes from single lane to double lane at junctions and there are five traffic light controlled junctions plus pedestrian crossings along its length. This cannot produce the smoothly flowing traffic that is needed if this road is to be effective.
9. The proposed Park and Ride facility is ignored as there are no bus lanes provided. The application is therefore not in accordance with the Local Traffic Plan
10. It is claimed that the number of junctions operating at “over 85% capacity” and so liable to seize up will not be increased but the objective of this road should be to decrease the number of such junctions considerably. The application does not state how many of these over capacity junctions will deteriorate still further.
11. Annex 3 Fig A.3.1. shows how the Commercial Road/ Link Road junction could be improved by modifying the access to the local business park; as these proposals clearly benefit this already difficult junction why are they are not included as part of the application? Presumably because they are outside the designated ESG area. They should be included.
Comments on specific proposals and sections of the application.
Traffic
1. PPS1 advocates that “new highway infrastructure should form part of a well connected network”. This cannot be said to be true of the Link Road.
2. While the concept of a “Transport Hub” at the station is good the pedestrian access across the Link Road, even with traffic light control is awful. It certainly does not “facilitate better pedestrian and cycle access between the railway station and the city centre”. Section 7.4.39 of the Environmental statement acknowledges that there “will be some severance of N/S movement of pedestrians.
3. Car parking. It is proposed to use the cattle market site to replace parking spaces lost at Merton Meadow during construction but no information is given on how this might affect the construction programme of the presently proposed retail quarter or what car parking will be available once construction starts at the old Cattle Market site.
4. Improvements are claimed for the Commercial Road/Aylestone Hill/Link Road junction. This is already heavily overcapacity and it is difficult to believe that tinkering with traffic light timings will produce the needed extra capacity. Traffic volumes for the top of Aylestone Hill, Folly Lane and Southbank Road are said to be unaffected(6.16) but no account appears to have been taken of the “rat run” effect on Folly Lane and Southbank Road once the short cuts from Ledbury Road to the Link Road come into operation. This directly affects The Point where I live.
5.It is acknowledged, not surprisingly, that there will be an increase in traffic volume at the Link Road/Edgar Street junction. This will make an already highly congested and polluted road even worse than at present; before the application is considered there should be a clear and firm statement from the Highways Agency that they accept these and the other adverse effects of the Link Road on the A49 trunk road.
6. The need to avoid a right turn from Link Road westbound to Edgar Street northbound creates a difficult right turn at Widemarsh street and puts more traffic onto low capacity Newtown Road and the Newtown Road roundabout where minor alterations do not appear sufficient to improve this junction. The other turning restrictions to be imposed at the other junctions can only affect adversely the free flow of traffic.
7. 6.14 gives the performance of various junctions but does not give the changes from the present position
8. There is mention of a bus turning facility at Maylord Orchard; an interesting proposal but no details given to show its practicability or its effect on a modified Blueschool Street.
9. Table 6.5 shows the claimed reduction of traffic on Blueschool/Newmarket Street as 16% and 1% respectively AM and 23% and 24% PM once the Link Road is open in 2013. This is neither “significant” (3.5) or sufficient to give the necessary connectivity between the retail quarter and the city centre. Only when the modifications to these streets are carried out is there an improvement and even then it is only a 26% to 53% reduction. It will not result in the “high quality pedestrian linkage to the historic city centre” claimed in 2.2. This emphasises why these improvements should be constructed in parallel with the Link Road – see above.
10) It should be remembered that traffic forecasting is a notoriously difficult and the satisfactory results claimed for the Link Road proposal only need to be in error by marginal amounts to make the results invalid. The scheme is said to work but even if the figures are accepted it only just works and the margins for error are very slim. For example a far better solution would be for Blueschool/Newmarket Street to be restricted to buses/taxis only but it is acknowledged in Section 5.2.8 of the Environmental Statement that such a restriction would make the Commercial Road/Link Road junction unworkable; this demonstrates how the traffic forecasting data is both finely balanced and susceptible to error.
Socio-economics and Land Use
1.The Link road proposals have a highly adverse effect on employment and the business economy of the city due to the removal of 18 businesses from the line of the road. While alternative sites have been proposed it is acknowledged that increased rentals will be payable, access will be more difficult; see the problems outlined in Sections 7.4.10, 7.4.12, 7.4.15 and 7.4.17 of the Environmental Statement. The turnover of these businesses makes a major contribution to the economic viability of the city and the application should not be approved until a satisfactory solution has been found and agreed with those affected.
2. Table 4.1 of the Planning Statement shows a total of 156 employees affected but excludes any possible losses at Jewsons. In 7.4.18 it states that that there will be no overall loss of jobs. This cannot be true once the disruption to these businesses is taken into account and the effect must be greater than “moderate adverse”. There are also adverse effects on other existing businesses –see Sections 7.8.5 to 7.8.9 of the Environmental Statement.
3. There is mention of possible alternative solutions to relocating Rockfields and the Post Office. These proposals should be available before the application is considered.
Pollution and Air Quality.
1.There is already an air quality problem along Edgar Street and Victoria Street – hence the Air Quality Management Area. Section 9.2.29 of the Environmental Statement states there will be a potential direct impact on this area in respect of Nitrogen Dioxide and Diagrams 9.3 and 9.4 show the increases.
2.It is then claimed in section 9.9.4 that there will be “no significant adverse impacts” and “in general” concentrations are lower but not in some cases – so this implies there will in fact be an increase in concentrations. Section 7.4.41 also states that there will be an increase in pollution on Edgar Street. The pollution case set out in the application relies on a decrease in emissions over time from lower background pollution and improved vehicle design which is a very uncertain and unproven basis. One can only conclude that the construction of the Link Road will not be beneficial to an already over polluted area of the city.
3. It is acknowledged in the application that air quality modelling is a very inexact science so all air quality predictions must be questionable; common sense would predict that whatever the actual scale of the increase in pollution there will still be an increase, which is not beneficial to the city.
4. Noise. Section 10 of the Environmental Statement states that in the first year of operation there will be 784 premises affected by increased noise. Conveniently, there is no mention of the large increase in affected premises once the Urban Village is constructed.
Flooding.
1. The Flood Risk Assessment shows that the design of the road is deficient. Surely the new Widemarsh Brook culvert should cope with a 1in100 year flood. Similarly why build a road that itself floods in these conditions?
2. Section 5.10 states that surface and sewer flooding will occur with reasonable frequency so there is no apparent improvement to difficult areas such as Newtown Road which would become an important link for northbound traffic off the Link Road.
3. It is stated that the Link Road will not be a strategic emergency route. This is surely wrong; if all the claimed benefits for the road are realised it will surely be used in emergencies.
4. There appears to have been no consideration of groundwater flooding or the future effect of the Urban Village housing and sewers and the resulting increase in run-off and the effect on the new road.
5. There is an apparent risk of flooding from the canal basin.
6. While this section of the application attempts to identify and quantify the flood risk and to demonstrate that the road does not make matters worse, the case made is far from convincing and it is clear that the effect of the construction of the road is not beneficial to the flooding problem.
Bearing all the above in mind it is clear why I am objecting to this application and that your recommendation should be that Herefordshire Council rejects it.
Finally will you please let me know the date of the meeting of the Planning Committee that will consider the application.
Yours sincerely,
The It’s OUR City! campaign underwent a complete re-invigoration this weekend with an incredibly successful Campaign Day in Hightown. Passers-by were treated to the sight of just how BIG the campaign had become with a recreation of what the petition really looked like. At over 10 metres long by two and a half meters high it was an impressive sight.
![Friday13th5[1]](http://www.itsourcity.org/wp/wp-content/uploads/2009/11/Friday13th51.jpg "Friday13th5[1]")
