The UDP has far-reaching implications for the future of Herefordshire. It sets out both the broad strategic framework for development in the county and all the detailed policies which will govern its implementation at the day-to-day level. Reading and assimilating its 305 pages, together with Supplementary Planning Guidance documents and background papers, was a formidable task but it was at an early stage of our discussions that several members of the group raised the alarm over the Council’s handling of ‘sustainability’. While the document was littered with fine words on the subject it quickly became apparent that the Council’s collective thinking was confused and the net effect on relevant policies was lamentably weak. The group presented this in its formal response as a fundamental area of concern for CPRE Members. The straitjacket pro forma on which responses were required to be submitted did not make it easy to tackle what should have been such an important pervasive thread in a coherent assault: every individual policy in which this issue arose had to be challenged separately.

The guarantee of ‘sustainability’ for the policies in the plan supposedly rested on the accompanying Sustainability Appraisal against which each had been assessed. Scrutiny of this document alone quickly revealed the inadequacy both of the definitions laid down and the methodology adopted. The team enquired more closely into how these views had been arrived at and were horrified to discover that the important groundwork which had been done some years ago, by the then Hereford & Worcester CC, to produce a promising Local Agenda 21 (towards which members of this Branch had contributed) had been entirely lost sight of. It had been superceded by a new document which we had not seen before and which is a very poor shadow of the original joint County LA21. The planning policies of other, comparable counties, were consulted and exemplary models of how LA21 had been integrated into all their policies came to light: particularly notable was that that of Dorset. This provided excellent ammunition for challenging Herefordshire Council’s low expectations of what their policies should set out to achieve.

Greenfield/brownfield development

As most members of CPRE would expect, some of the most vehement of our objections were to the many proposals to build on greenfield sites - houses, industrial and business units, and roads (particularly the 10h of housing land and 13h of employment land earmarked at Holmer, north of Roman Road). We have consistently argued against the target figures for housing and are already opposing the proposals for a Rotherwas Access Road but we now found ourselves also querying the calculations of land needed for ‘employment’ purposes. While the UDP sets out to show how Herefordshire Council is striving to meet government targets for the development of brownfield sites, we were not always convinced that the best use was being envisaged for these. The redevelopment for housing of the 12h brownfield site at Baron’s Cross, for instance, carries with it a caveat regarding increased traffic on Bargates and the eventual need for a new road linking from there to the old Hereford Road B 4361. We have, therefore, objected to this. Other brownfield sites have long been reserved for development for employment purposes: we formed the view that, far from needing to add greenfield sites to these, to increase the ‘portfolio’, a more far-reaching review of employment needs would show that more than enough land is already available for business development and that some might be made available for housing, reducing the pressure on greenfield sites. The crude division of the release of land for housing development into three five-year phases did not seem to us to accord with ‘plan, monitor and manage’, nor were the mechanisms to ensure that 60% of brownfield land was developed before greenfield sites were released sufficiently clear and robust.

Main Villages: outside Hereford and the market towns the UDP limits housing development to designated ‘main villages’. We have objected strongly to the concept, in that it misunderstands the settlement pattern of the county, to the crudity of the selection criteria used and to the claim that the locations chosen are ‘sustainable.’ The chief claim made to ‘sustainability’ is that these villages all currently have a daily bus service. This factor is the lynch-pin of a policy which claims to seek to place housing where there is access to job opportunities. We were not convinced that this is realistic (the background paper was confused) or founded on a sufficiently worthy and distinctive vision for Herefordshire.

Employment: the way the Council assessed ‘employment needs’ lacked coherence. The chapter headed ‘Employment’ dealt only with 3 very specific types of business class use and the thrust of land provision is towards inward investment projects and business expansion. Other chapters, such as Town Centre and Retail, Tourism and Recreation, also have obvious employment implications but these did not form part of this equation (and the background papers on which the policies were based were again generally inadequate). Nor did that most crucial aspect of the county’s economy - farming. Although the Plan set out planning policies governing the reuse or conversion of redundant farm buildings, it offers no convincing evidence that Herefordshire Council understands the needs and potential of contemporary agriculture. It is less than energetic in its policy on renewable energy (or energy conservation). The Plan’s failure to embrace ‘sustainability’ as the central plank of a vision for the county has prompted the Branch Policy Group to continue working on these issues in an effort to raise public consciousness of their urgency

Transport: ‘economic development’ and ‘employment opportunities’ provided a questionable rationale for road-building proposals. The drive towards an eventual bypass for Hereford is clearly discernible (although the two statutory consultees have already told Herefordshire Council that it must remove references to its commitment to an Outer Relief Road on the route - A465/A438 - already turned down at Public Enquiry). We supported policies designed to protect from other forms of development land currently occupied by unused railway facilities, particularly those which would enable more freight to be moved by rail but this is not enough, of course, to make such a shift actually happen. The proposal to move the Livestock Market out of Hereford has already aroused considerable controversy: we expressed particular opposition to that part of it which talks vaguely of redeveloping part of the vacated site as a new ‘public transport interchange’ - its distance from the railway station means that only another bus station is under consideration.

Landscape character assessment

Strong criticisms have and are continuing to be made about the position adopted by the Council on Landscape Character Assessment as it is set out both in specific policies in the UDP (particularly LA2) and in subsequent Supplementary Planning Guidance. The principal cause for concern is the newly-introduced concept of ‘resilience to change’ and the questionable criteria and methodology for evaulating it. We are very anxious to see this misconceived SPG document withdrawn from immediate use as a development control tool for planning officers. Its mechanisms bring to mind the phrase ‘painting by numbers.’

We were generally less than happy with the public consultation process but the way Herefordshire Council handled the production of the Landscape Character Assessment SPG in particular gives us serious cause for concern. It was also published very late and was not available to the public during the period for responses to the UDP. Without it the green and white colouring of the Proposals Maps had little meaning. The Council has indicated that it will accept responses to this late document up to 31st January. Apart from the objections that we will make regarding key concepts and methodology, we shall also protest that CPRE is mentioned as a consultee although no member of the Branch had seen any ongoing work on this document since its very earliest stages some years ago. The lack of public consultation and proper discussion with all interested parties about such a fundamentally important planning issue, which has wide implications, is deplorable.

Many other areas of the Plan were unsatisfactory - notably the chapter on Waste and the lack of an Historic Landscape Characterisation SPG - but there were several aspects to be supported. Among these we particularly applauded the Supplementary Planning Guidance on Design to which several members of the Branch, under the Chairmanship of the Policy Group’s own co-ordinator, Peter Beresford, had made very significant contributions. Their participation provided a model of how consultation can work to beneficial effect. We look forward to playing a full and vigorous part in the statutory period of consultation which precedes redrafting of the UDP.

The UDP and Supplementary Planning Guidance documents are on the Herefordshire Council website www.herefordshire.gov.uk – search for UDP

More information on Landscape Character Assessment can be found on the Countryside Agency website www.countryside.gov.uk/cci/westmidlands/default.htm

The Policy Group would be glad to receive feedback from members: particularly welcome would be examples drawn from local knowledge (e.g. of changes to Settlement Boundaries) that help to support our points. And, of course, we encourage anybody interested to join in the further work required to influence Herefordshire Council’s decisions about the final shape of the UDP. Contact us for details or come along to any of our regular policy meetings.