Hereford Civic Society response to the

Herefordshire Council Strategic Spatial Options Public Consultation

 

We welcome the opportunity being given to both ourselves and more generally, the residents of Herefordshire to contribute their opinions and vision of Herefordshire in the year 2041.

 

The Vision

Zero carbon, frequent public transport serving Hereford and the Market Towns with regular bus services to “hub” settlements enabling the majority of the County’s population to access services, education and employment with substantially reduced reliance on the private motor vehicle.  We support this aspiration unreservedly.

 

A concern is when do we start to embark on this journey?  In recent months we acknowledge several short-term initiatives including free bus journeys at the weekend. But this is against a background of local bus companies curtailing bus services – reduced frequencies in some areas, abandoning routes in others.  It could be said we are currently heading in the opposite direction. 

 

What is needed is a plan whereby the public purse funds the revenue shortfall for uneconomic services.  A commitment not for twelve months but for twenty plus years.  Only with this assurance will a permanent modal change from the private car to public transport be achieved.

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2021-2041 Housing Target

We challenge the amount of housing growth required.  The Overall Target of 17,000 is too high and ignores the current:

1. moratorium on the construction of new buildings in north Herefordshire because of River Lugg phosphate issues.

2. concerns with phosphate levels in the River Wye.  The Council is making representations to both Westminster and the devolved government in Wales demanding plans to restore water quality to the Wye.  This plan has also to address the issue of discharges into water courses from storm drains, much of which originates from domestic properties.  Limiting the construction of additional dwellings, particularly in rural areas may well form part of this wished for plan.

3. perverse situation in Hereford where construction of housing south of the Wye is restricted, notwithstanding that employment opportunities in Rotherwas are expanding!  The result: increasing numbers of journeys across Greyfriars Bridge as the expansion of housing provision is currently concentrated north of the river.

 

We believe the 17,000 Overall Target in these circumstances is too high.  We recommend a significantly lower figure.  In 2024 or whenever the updated Core Strategy is agreed with Government, if these limitations on development have been removed, the initially set lower overall target could be re-evaluated.

 

Our understanding is that under current planning rules, the Planning Authority is required to demonstrate a five-year supply of building land.  In addition to the anticipated construction of 17,000 dwellings, at the end of the planning period, land for a further 4250 dwellings will need to have been identified.  This consultation does not identify where the five-year supply of building land at the end of the planning period will be located, notwithstanding that such approvals will need to be made during its latter stages. 

 

We understand that if the council cannot demonstrate a five-year housing supply, developers will determine the location of these houses as Herefordshire Council knows only too well from recent experience as it is only latterly, that this five-year supply threshold has been satisfied. 

 

It is our members’ opinion that a commitment to build 17,000 dwellings in the 20 years to 2041 is excessive.

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The consultation document plan does not address the start point.  Where we are today? 

 

Outstanding Housing and Infrastructure Commitments

1.  We recall “Hereford Futures” and the plans and consultations surrounding the Edgar Street Grid.  Construction of the Old Market Shopping Centre was completed as was the Link Road, but where is the Urban Village, the town houses overlooking the canal basin, the Transport Hub besides the station?  Preserving the route of the canal was included in the current Core Strategy, but the route of the Link Road was approved contrary to it.  To what extent will these matters be reflected in the proposed updated plan?

 

2.  There is currently a number of brown field sites in close proximity to Hereford City Centre as a consequence of constructing the Link Road.  According to Government policy, brown field sites should be regarded as “low hanging fruit” ideal for high density town centre development.  We are disappointed with the on-going construction of housing on green field sites north of the Roman Road in Holmer, when alternative sites, within walking distance of services, shops and schools are available in the city centre.

 

3.  The consultation document does not refer to NMITE or the housing for its growing student population, or does it?  Please tell us.

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4.  It would be good to know what Active Transport infrastructure Herefordshire Council are proposing for Hereford.  We have been involved in many past consultations:

• Holme Lacy Road phase 2 (which included re-doing phase 1)

• St. Owen Street cycle contraflow

• South Wye Transport package

• The Hereford Transport plan.

 

The last of these consultations took place in early 2019.  The Consultation’s Option 3 includes 5900 dwellings for Hereford whereas Option 2 includes only 2500.  An understanding of if and when previously consulted infrastructure will be delivered is a key consideration when responding to this consultation and choosing between Options.

 

5.  Absence of a Transport Hub means that Herefordshire’s residents refuse to consider public transport for an end-to-end journey that involve a change of bus or to catch a train.  Hence the current high usage of the private car which has led to Yeomans recently giving up its city bus services.  But then Yeomans thought every passenger’s destination was to/ from Hereford city centre rather than door-to-door.  Maybe to/ from a work place, a Market Town or further afield involving a train journey returning after 6pm when in Ledbury, Leominster and Hereford the last bus has long departed.

 

6.  Conversion of underused town and city centre properties to residential use should be encouraged and a target set for the accommodation that these properties might provide.

 

New Rural Settlement

John Bothamley, who preceded myself as our Society’s chairman proposed a new Herefordshire market town centred on Ewyas Harold in our quarterly magazine (Summer 2015 edition, pages 4-5).  I attach the link untitled (herefordcivicsociety.org.uk).  It makes an identical case to that which this consultation makes in Option 5. 

 

There have been subsequent efforts to open a station at Pontrilas.  Ideally placed half way between Abergavenny and Hereford, a counter balance to Hay-on-Wye at the western end of the Golden Valley.  Also has the advantage of being sufficiently far from other centres of population, thereby limiting commuting to other population centres by private vehicle.

 

 

Other locations for a New Rural Settlement?:

i.  Ashperton, Tarrington, Trumpet;

ii. Wellington, Marden, Morton-on-Lugg

 

We felt both “other locations” to be too close to Hereford and that over time the temptation would be infill between them and Hereford, leading to the creation of one large metropolis.

 

Option ii, Wellington, Marden, Morton-on-Lugg   Train operating companies would likely object to a station located between Hereford and Leominster as the route is used by long distance services to Manchester and Holyhead (going north) and Cardiff and Milford Haven (going south). 

 

Option i,  Ashperton, Tarrington, Trumpet on the Worcester route may find favour as both London and Birmingham trains have Hereford as their final stop.

A new Market Town provides the opportunity to create a community using Active Transport design principles without having to compromise/ or modify existing infrastructure at vast expense. Also represents an opportunity to construct affordable/ social housing at scale.

 

We fully support Option 5.  The ambition of 1500 dwellings by 2041 should in our view be increased to 2,500 with the majority constructed between 2031 and 2041.

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Growth in Hereford and the Market Towns

We favour growth in the New Rural Settlement and proportionately across Hereford and the market towns (as in Option 3 except with fewer potential dwellings in rural areas).  That a quarter of the County’s population is aged over 65 places considerable strain on the provision of medical and the Council’s social services if delivered in a rural setting. 

 

Growth in provision of bespoke dwellings for the over 65 needs to be concentrated in Hereford and the Market Towns, including the New Rural Settlement in due course (probably post 2041).  This is for reasons of proximity to health services including the County Hospital and the susceptibility of this age group experiencing reduced mobility and requiring access to services and community facilities without recourse to personal transport.

 

Kington and Bromyard.  Whilst being remote, both Market Towns have substantial natural capital.  Improved bus services to adjacent market towns and to Hereford (and Worcester in the case of Bromyard) would improve their attractiveness.

 

Ledbury. The Local Plan extends to 2041.  Although the current number of approved dwellings is substantial, most, if not all current planning commitments are likely to be built by the mid-2030s.  Town possesses the advantage of a railway station, access to the M50 and M5 and proximity of employment opportunities to the west of Worcester and Gloucester.

 

Leominster.  Only 13 miles from Hereford, a railways station and at the junction of north/ south and east/ west arterial roads.  Enterprise Park, but somehow doesn’t want to grow.  Perhaps it is the state of the roads in the centre of town?  Funding through designation as a High Street Heritage Action zone will hopefully bring in the investment that will encourage private capital to expand the town’s industrial base.

 

Ross-on-Wye.  Whilst not connected to the rail network, it is strategically placed on the A40 and M50 with access to the Midlands and South Wales.   On the doorstep of the Forest of Dean.

 

 

Current Planning Rules

We suggest an amendment to existing planning rules, enabling the construction of high-density Market Town or Hereford city centre dwellings with either no or only a single parking space.  It is perverse that current regulations for parking provision are the same for rural and town/ city centre dwellings.

 

In many areas of Herefordshire, dwellings have been acquired either as 2nd homes or for short-term rental.  A consequence is high prices, leading to affordability issues for those raised / educated in the county and the difficulties those living in rural areas to find local tradesmen and workers necessary to support the county’s farming community.

 

Herefordshire is not unique in experiencing these problems.  We recommend that Herefordshire Council lobby Central Government for powers to adopt fiscal measures that would discourage 2nd homes/ vacation property for short term let, investing the resulting income in rural community infrastructure.  Such schemes have been introduced to good effect in several areas in Wales.

 

Rural Areas Housing Distribution   

We are of the opinion that housing growth should be outside ANOBs and Conservation Areas.  The background Spatial Options Consultation when setting out the options has not been informed by local Neighbourhood Plans.  This we understand forms part of the Rural Settlement Hierarchy and will be included in the next phase of the consultation process.   Many Neighbourhood Plans have been adopted only very recently and reflect a body of work by local people with an interest in making their community sustainable. Part of this process was the calling for land for future housing.

 

We agree that Rural Housing Distribution should be spread across larger settlements (Options 2 and 3), with emphasis on those settlements that are adjacent to a Herefordshire or neighbouring county Market Towns (e.g.  Hay-on-Wye, Presteigne, Knighton, Ludlow, Tenbury Wells, Malvern, Monmouth which are not acknowledged in the Consultation document) and to which there is a regular bus service.  Outside of these larger settlements, new dwellings should only be approved on an exceptional basis e.g.  for agricultural workers, to facilitate care of relatives, to live adjacent to a place of work.

 

We would first want to review the Rural Settlement Hierarchy Paper Consultation that is due shortly before we feel able to give an opinion on this consultation’s Rural Housing Strategy.  We have difficulty understanding the distinction between “larger settlements” and “rural hubs”. Some examples, or a listing under each heading would have been helpful.

 

Community Land Trust/ Self Build

Small plots of land, especially those sufficient for only 1 -5 dwellings are not an economic proposition for many developers.  They are ideal for self-build projects, which could include affordable starter homes for young families.  A possible mechanism enabling the construction new build social housing in rural settings?

 

The above comments reflect the generality of the view of the Society and do not necessarily reflect the views of all members.

 

Again, thank you for giving the Hereford Civic Society the opportunity to comment,

 

Yours sincerely,

David Fowler

Chairman