THE COUNTY OF HEREFORDSHIRE DISTRICT COUNCIL HIGHWAYS ACT 1980 ACQUISITION OF LAND ACT 1981 THE HIGHWAYS (INQUIRIES PROCEDURE) RULES 1994

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1 THE COUNTY OF HEREFORDSHIRE DISTRICT COUNCIL HIGHWAYS ACT 1980 ACQUISITION OF LAND ACT 1981 THE HIGHWAYS (INQUIRIES PROCEDURE) RULES 1994 THE COUNTY OF HEREFORDSHIRE DISTRICT COUNCIL (SOUTH WYE TRANSPORT PACKAGE A4194 SOUTHERN LINK ROAD) COMPULSORY PURCHASE ORDER 2018 THE COUNTY OF HEREFORDSHIRE DISTRICT COUNCIL (SOUTH WYE TRANSPORT PACKAGE A4194 SOUTHERN LINK ROAD) CLASSIFIED ROAD SIDE ROADS ORDER ACQUIRING AUTHORITY RESPONSE TO GARETH DAVIES FOR HEREFORDSHIRE TRANSPORT ALLIANCE OBJECTOR NO Department of Transport Ref: NATTRAN/WM/LAO/ October 2018

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3 1. INTRODUCTION 2. ISSUES RAISED BY OBJECTORS 3. RESPONSE 4. CONCLUSIONS CONTENTS

4 1 INTRODUCTION 1.1 This is the County of Herefordshire District Council s response, as the relevant Acquiring Authority in these proceedings to Gareth Davies representing the Herefordshire Transport Alliance (Objector Ref: OBJ-12) ( the Objector ) following submission of their formal representations to the Inquiry. 1.2 The Objector is a Non-Statutory objector to the County of Herefordshire District Council (South Wye Transport Package - A4194 Southern Link Road) Compulsory Purchase Order 2018 ( the Order ) being promoted by the Acquiring Authority ( the Council ). 1.3 A Non-Statutory Objector is an individual or body whose landholding or livelihood although not directly impacted by the Order still wishes to object to it. 1.4 The Objector originally objected to the Order in April The Council have taken due consideration of all correspondence received from the Objector to date. The Objector submitted a Proof of Evidence to the inquiry. 1.5 The purpose of this response is to update and/or expand upon the objection responses detailed in Appendix 1 of the Council s Statement of Case [CD 52], the Council s main Proofs of Evidence and following consideration of the issues identified in the Objector s Proof of Evidence. 1.6 In this response, the Council have not sought to provide a comprehensive response to the Objector s evidence but have instead sought to focus on those points where the Council consider the Inspector may find it helpful to have a written response in advance of the public inquiry. In most instances the Council is content that it can provide a response in oral evidence if required by the Objector. 1.7 This response is to be read in conjunction with the Council s main Proofs of Evidence and Appendix 1 of the Statement of Case submitted to the inquiry by the Council. 2 ISSUES RAISED BY OBJECTOR 2.1 Taking into account all the representations submitted by this Objector the issues raised may be summarised as follows: (i) (ii) (iii) The case for the SLR is premature in the context of the development of the Hereford Transport Package; The past analysis for the SLR is flawed in that it has been undertaken in isolation of an overall transport plan for the city; and The SWTP analysis pays scant attention to alternative transport.

5 3 RESPONSE 3.1 The case for the SLR is premature in the context of the development of the Hereford Transport Package The case for the SLR is not premature. This is a matter that is addressed within the Transport Benefits Proof of Evidence of Martyn Brooks at paras to 5.22 and paras to 6.19 and within Appendix 1 to the Statement of Case In addition, the planning history and context of the development of a relief road for Hereford is set out in the Proof of Evidence of Amy Hallam. This culminated ultimately in the Herefordshire Local Plan Core Strategy which then was reflected within the Council s Local Transport Plan The Objector and the HTA clearly do not endorse the approach adopted in the SWTP and are seeking a wholly alternative solution. This solution would however be contrary to established Council policy which formed the basis for the consideration of the successful planning application for the SLR The Council considers the Inspector would not be assisted by the repetition of the evidence referred to above and that nothing new has arisen in this regard out of the Objector s latest representations to the inquiry which requires further response. 3.2 The past analysis for the SLR is flawed in that it has been undertaken in isolation of an overall transport plan for the city This is a matter that is addressed within the Proof of Evidence of Martyn Brooks in respect of the preferred route stage at para 6.1 and within the Proof of Evidence of Amy Hallam at para. 4.9 and It is also addressed within Appendix 1 to the Statement of Case [CD52] The Council considers however that the Inspector would be assisted by additional comment on this point The Herefordshire Local Transport Plan comprises countywide policy and transport strategy covering maintenance, safety, traffic management, sustainable and active travel. It covers the period aligning with the period covered by the Core Strategy. It was taken to General Overview and Scrutiny committee in January 2016, amended in the light of comments, taken to Cabinet in April 2016, and adopted in May The Herefordshire Local Transport Plan comprises two parts policy and strategy. The policy document outlines the authority s approach on fourteen transport-related topics. The Strategy document includes a section entitled Our strategy for Hereford. This outlines challenges, opportunities, the strategy elements and key schemes and projects. The SWTP is identified in the schedule of key schemes and projects.

6 3.2.5 The Core Strategy [CD8], adopted in October 2015, is intended to shape future development and sets the overall strategic planning framework for the County. The Core Strategy notes in para 1.9 that the document is based on the outcomes of the consultations that have taken place, other council plans, programmes and initiatives and also on the findings of the evidence base that has been prepared to support it In Para the Core Strategy states that: Transport modelling undertaken to understand the extent of existing traffic issues and how the city s growth can be supported in the long-term has indicated that new highway infrastructure supported by a package of sustainable transport improvements are required. Sustainable transport measures on their own, without new highway infrastructure will not accommodate the additional travel demand derived from the planned growth in the Core Strategy In Para the Core Strategy states that: The provision of new road infrastructure, along with a package of sustainable transport measures, is necessary for Hereford to deliver its full housing and economic growth. Sustainable transport measures are also required to assist in creating a development which is less dependent on the private car. New growth areas will be designed to inhibit traffic and encourage more sustainable modes of travel and contribute to new and the enhancement of existing highway and sustainable transport infrastructure The Council does not accept the suggestion that the past analysis for the SLR is flawed as suggested nor has it been undertaken in isolation of an overall transport plan for the city. 3.3 The SWTP analysis pays scant attention to alternative transport This is a matter that is addressed within the evidence of Martyn Brooks on the transport benefits at paras. 5.1, 5.8 to 5.13 and 6.14 to 6.16 and within Appendix 1 to the Statement of Case The Council considers that the Inspector would be assisted by additional comment on this point The analysis has been carried out in accordance with the Department for Transport guidance set out in the suite of documents referred to as WebTAG. An initial sift of possible options was carried out in accordance with Stage 1 Step 6 of the Transport Appraisal Process, a WebTAG document. A range of alternatives, including light rail, were considered. The Transport Appraisal Process notes that a key part of the methodology is to undertake appraisal in a proportionate manner and in a way that enables relative costs, benefits and impacts to be distinguished.

7 3.3.4 This process identified key issues which led to certain options, including light rail, being sifted out whilst others were taken forward to the subsequent stage of the assessment. The issues which influenced the decision on light rail included concerns relating to viability, financial affordability, and financial risks, including revenue support The Objector introduces the suggestion of an entirely different transport solution namely a possible light rail route which would link the HEZ, the new university, South Wye housing and the city centre This alternative has been reviewed for completeness and key issues identified Our consideration of this essentially reintroduces the key issues identified during step 6 of WebTAG and reinforces the view that the light rail option should not progress to a subsequent stage in the assessment process A review of factors influencing successful light rail schemes has also been carried out. The key findings are reported below Para 3.24 of the Department for Transport document entitled Green Light for Light Rail (2011) summarises success factors for light rail schemes. These include serving a major urban conurbation and achieving a high degree of segregation from traffic, with priority at junctions. The Environment, Transport and Regional Affairs Committee report into light rapid transit systems (2000) notes in para. 8 that routes with 2,000 passengers per hour are the most viable candidates for light rail and by implication catchment population is a further consideration. No radial corridors in Hereford are likely to meet this threshold level of demand for travel between key origins and destinations all being in the light rail corridor. The Final Report of the Light Rail & The City Regions Inquiry (2010) highlights that a critical success factor of European light rail systems is the availability of local fundraising powers. These fundraising powers are not available to Herefordshire Council Existing modern tram systems in the UK operate in urban areas which are substantially larger than Hereford. For example, the Nottingham built-up area had a population of 730,000 in 2011 compared with 60,000 for the Hereford built-up area The only ultra-light rail system in operation in the UK connects Stourbridge Station with Stourbridge Town Station using existing rail lines and existing stations. The route is approximately 1km in length. There is a proposal for what is termed very light rail in Coventry (built-up area population 359,000). Committee papers for the West Midlands Combined Authority Investment Board identify that the Coventry system has a target all in cost of 7m/km Some of the key issues arising from the Objector s proposed 10-11km route for Hereford are as follows:

8 - the impact on other road users, including congestion and delay, where the ultra-light rail route follows existing streets (Eign Street, Victoria Street, Newmarket Street, Blueschool Street and Commercial Road); - the impact on other road users, including congestion and delay, where the ultra-light rail route crosses the A49 at the Debenhams Roundabout, Steels Junction and in the Grafton/Bullinghope area, and at the Commercial Road / City Link Road signal crossroads; - the large proportion of Hereford residents who would live some distance from the proposed light rail route. An estimated 73% of Hereford s resident population would live further than 400m from the route; - it would undoubtedly require ongoing subsidy support as patronage failed to meet operating and maintenance costs; - the degree of abstraction which would occur from existing bus services, which could threaten their commercial viability; and - applying the estimated costs per kilometre from the Coventry proposal to the length of the route proposed would result in a scheme cost of between about 70m and 75m The council does not accept that the SWTP analysis pays scant attention to alternative transport options. In addition, for the sake of completeness the Council has assessed the Objector s proposed alternative solution. This confirms that such a proposal is not an acceptable or reasonable alternative to the Council s own approach developed over a considerable period of time and subject to wide public input and professional independent assessment. 4 CONCLUSION 4.1 Considering all the above, the Council submits that this non-statutory objection to the Order should not be upheld and that the Inspector can proceed to recommend to the Secretary of State that the Orders should be confirmed.