Wye Ruin It?

Wye Ruin It?

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Campaign to Stop Hereford Bypass

Campaign to Stop Hereford Bypass

 20 January 2018

Dear Householders

We are writing to you on behalf of the recently formed Action Group called Wye Ruin It?

This group was formed to stop the Hereford Bypass because it will have long term detrimental effects on our countryside, the City, its inhabitant’s health for generations. How can we stop it?

It is unfunded

The proposed developments are unfunded and funding will be sought based on social and economic needs, economic improvements and traffic modelling. The County Council has stated that the housing developers will contribute to the road building capital costs along with two quasi government organisations, Midlands Connect and The Marches Local Enterprise Partnership. However it is most likely the capital costs will be so high it will also need a substantial sum from Highways England. In order to apply for this funding the County Council plans to de-trunk the A49 through the city and divert it west. We encourage our supporters to write to these funding organisations on National Issues.

The traffic implications are horrendous

The A49 traffic volume and pollution will likely increase in the longer term by at least X3 and Heavy Goods traffic could increase X5 and that creates most of the airborne diesel particulate pollution. Highways England is looking to reduce M5/M6 congestion by developing utilising alternate routes. The Welsh Government is building its dual carriageways to connect through to the West Midlands markets and is supportive of the proposal. We encourage our supporters to write to the Department of Transport (Jesse Norman is Minister for roads), Highways England and the Welsh Government.

Increased pollution threatens human health

The road location will result in a plume of particulates through the new estates and city centre increasing detrimental health effects for the population for generations. It is reported on a Government website that 29,000 people die every year from fine particulate emissions and many more suffer ill health. We encourage our supporters to write to the government Minister for Health Michael Gove, , Chris Grayling MP at the department of Transport and Highways England

Herefordshire County Council Core Strategy is evolving

We are learning that the due process of civic planning, budgeting and development is a very slow one. We have the contacts, with your help, to challenge every decision and question every motion on technical and financial issues through the consultation process, which is currently poorly attended by the public. The Herefordshire County Council’s proposals to develop infrastructure West and North of Hereford will severely impact the environment and quality of life of householders from Belmont Rural through Breinton across the Kings Acre Road and up through Three Elms to St Mary’s Estate and surrounds. However these detrimental effects are local issues and dismissed as NIMBY arguments by MP’s and local councillors.

Our Campaign to Stop Hereford Bypass is therefore focused on Three National Issues

1. Road congestion increasing not decreasing with new roads
2. Pollution is increasing and its ill effects on human health are better understood
3. Lack of cost effectiveness of new infrastructure in rural agricultural areas

Herefordshire County Council is misleading the public describing the development as a relief road when it will only result in more congestion with a 26% increase in Herefordshire households and a potential trebling of A49 traffic. No detailed traffic modelling accompanies the public consultations so the current information is grossly misleading.

The Council’s consultants Balfour Beatty designed a scheme that will envelope thousands of new houses on a flood plain with fine particulate emissions. They work on a cost plus contract costing the County Council £2m-£3m a month and are responsible for collating the public consultation results. Talk about letting the fox run the chicken coop!

The Environment Agency has been tasked with reducing flood damage and resulting vast insurance costs. Despite the £90m spent on diverting flows of the Yazor brook, no work has been done to model the run off from the proposed new developments and the effects downstream in Hereford City and the recently adopted strategic flood management plan pays no attention to this proposed new development.

The two biggest employers who draw water from the aquifers west of the city both object to the over-developments given the likely hood of aquifer pollution and the end of their free water source. In fact the aquifers are only 7m-8m below surface on the Eastern edge of Three Elms. Heineken have requested detailed baseline studies on the water resources and Cargills is expanding production elsewhere to close specialist lines at this site.

Highways England is supposed to reduce its carbon footprint and vehicle emissions but this proposed scheme will increase them. It must consider the financial merits of the proposal prior to funding and the case for construction will be very hard to justify when the project is fully costed. The original £132m estimate in 2010 was based on a single carriage way but if the A49 is de-trunked and the road and bridge will need to be dual carriage ways. To justify the circa £500m development will require substantial HGV traffic flows and economies of scale not in any original calculations.

If you would like to protect your environment for future generations we would like to meet you. We aim to stop the road development and force the County Council to rethink its core strategy to develop the Yazor flood plain as a vast housing estate with a new industrial complex. We were formed as a voluntary action group to protect the community and environment of Breinton Parish and soon realised that the implications of this proposed infrastructure development are much, much wider.

We are looking for community leaders, new supporters and volunteers to take the actions required to slow and stop the development. We launched our efforts at the Hereford County Fair in August and have since gathered a group of 200 people who are supportive of our aims and raised funds for printed materials and hiring venues for meetings.  The Hereford Councils proposals are for 6,500 new houses and a bypass west of Hereford. Much more detail can be found on the Herefordshire County Council website using links from our website which is called www.wyeruinit.org and Facebook @wyeruinit.

Please take some time to visit our website and consider what skills you may like to bring to the newly formed group. This is an urgent campaign, the decisions will be taken in the next few months and we have until the Spring of 2019 to stop it or elect a new enlightened County Council. We look forward to meeting you in the near future.

We have prepared some questions for you to ask during the consultation process. Please use the detail to express your concerns. This is best communicated by you as individuals to avoid the Council accounting for us as just one petitioner.

Yours sincerely 

The Wye Ruin It? Team

www.wyeruinit.org          info@wyeruinit.org

 

QUESTIONS FOR HEREFORDSHIRE COUNTY COUNCIL

Section 1

1.       CABINET MEETING 18th 2pm, 2018, Council announces routes of proposed Hereford Western Relief Road.

1.1.   How can the proposal to accept unquantified motorway relief traffic (from the M5/M6) along the unsuitable A49, and along a city bypass upwind of proposed housing estates, be considered sustainable development?

1.2.   Council has been asked on numerous occasions what level of motorway relief traffic would use the Hereford bypass, and responded saying it would be modelled as the project is developed. Data is available so why has this modelling not been done?

1.3.   In the route options report by Amey it was noted that between 300 and 600 houses would be affected by adverse noise from the proposed routes. Parsons Brinckerhoff report July 2011 page 11 para 2.4.11. states that pollution alongside the selected route in relation to residential properties should be considered to be of only minor significance. Can the Council assure residents that it will make a full and updated assessment of the housing numbers and of the air quality and pollution haloes that would result from the increase in HGV usage as motorway relief traffic levels rise, and provide projections for these impacts?

1.4.   Will the public receive a full analysis of the environmental impact of the proposed new road on the proposed new housing estates, with reference to the threats to human health from fine particulate pollution based on a traffic model updated for motorway relief traffic?

1.5.   Technical Consultants Amey repeatedly stated in its Stage 1 assessment and its Options Study reports that there was insufficient traffic data available to make a quantative assessment of impacts. How will the Council reassure the public that motorway relief traffic and new housing traffic impacts will be professionally assessed when it failed to monitor existing traffic levels for the last ten years?

1.6.   We note that the SATURN traffic models produced in 2009 for the main corridors were not utilised in the Amey Options Study. Will the analysis of potential increase traffic from a 26% increase in city households and the M5/M6 Motorway relief be incorporated into the existing SATURN traffic models and published as part of a professional analysis?

 

1.7.   What baseline air-quality and water-quality studies have been done and over what period in the two flood plains where development is proposed first over the Wye Valley Flood Zone and second over the Yazor Brook Flood Zone?

1.8.   Will the proposed bridge crossing the River Wye SSSI/SAC on the western relief road have any footings in the 300m flood plain or will they be, on higher ground away from the flood plain?

1.9.   Given that during the initial Stage 1 analysis and reporting Council’s consultants failed to identify the importance of Hereford’s underground aquifers to its major industries before the Core Strategy was developed can the Council now provide a map of all the Source Protection Zones (SPZ) for all abstraction points within and adjacent to the Strategic Core Development sites of roads and houses?  

1.10.                     Will the Contractors or the Council need a Flood Plain Exception Test to build the bridge crossing over the River Wye SSSI/SAC site?

1.11.                     How can the public make an informed decision on routes when you have not provided a full picture of the proposed development’s impact on traffic, pollution, human health and its cost-benefits?

1.12.                     Is the Council concerned to understand the hydrogeology in relation to the decisions on housing development sites and route options for the proposed road, and that Cargill, Heineken and other employers may leave Hereford due to water supply issues?

1.13.                     What consideration was given to the location of roads west of proposed and existing dense urban conurbations, given the prevailing wind direction, and to the growing scientific evidence of the impact of fine particulate emissions on life expectancy, physical and mental health?

1.14.                     The Council has lost the confidence of the public over inadequate capital cost controls and poorly executed developments. Why would the proposed bypass be any different in terms of budget controls, a design fit for purpose and the Council’s ability to deliver this project on budget?

1.15.                     Reams of data produced by the SATURN traffic modelling are used to justify the introduction and timing of the road development plan but none have any mass transit solutions incorporated to reduce the single purpose journeys like school trips and commuters. Why not?

1.16.                     Public mass transit systems for cities are required to meet certain investment returns to justify construction but rarely do so for medium sized towns. Often the required investment capital does not generate enough financial benefit when analysed under the current planning rules. Why then are roads being constructed without including the full environmental costs associated including healthcare, loss of habitat and biodiversity, CO2 emissions and climate change, absent from many sustainable mass transit options?

1.17.                     It is stated on page 26 para 5.2 of the Hereford Transport Strategy Phasing Study that the western section of the bypass is primarily designed to make the Three Elms housing site more attractive to investors. Is there any limit to the capital that will be allocated from government funds to enable the inappropriate development on a flood zone, and over an important aquifer in a Special Protection Zone?

1.18.                     The value for money criteria base on CO2 analysis is inadequate when the full impact of M5 and M6 motorway relief traffic over the long term is excluded from the data modelled. Can the council confirm that the increase in motorway relief traffic using the A49 and the resultant pollution will be included in all future TUBA analysis?

1.19.                     The reliability tests for the proposed road on contribution towards journey time reliability and capacity of transport links, analysis using the Hereford Saturn model has indicated journey time will increase 8% by 2032. This SATURN model clearly excludes effects of the Motorway relief traffic and is therefore inaccurate and misleading. How does the Council propose to address this misleading analysis?

1.20.                     Must the public accept the misleading traffic user benefit analysis (TUBA) results based on inaccurate traffic modelling and inadequate financial tools just because it is generated in accord with planning policy and current guidelines, or will the Council have the good sense to question these results using informed and independent analysis?

 

 

 

Section 2

QUESTIONS FOR HEREFORDSHIRE COUNTY COUNCIL DURING THE CONSULTATION PROCESS

2.       General Questions

2.1.   How can the Council’s planners propose bypass routes that will devastate high grade farmland, destroy important collections of rare apple trees cultivars, pollute in historic organic orchards of cultural importance, open up sensitive biodiverse areas for housing development over commercially important aquifers without even trying to demonstrate how non-polluting mass transit systems will solve Hereford city congestion.

2.2.   What kind of Local Government planning process allows development of roads at any cost without a professional analysis of new transport options that are cheaper, more efficient and less polluting that building roads?

2.3.   When will this Council accept that a conflict of interest exists between the shareholders of its consultants and the public in its constituency? This Council has repeatedly claimed that no conflicts of interest exist when the public can plainly see a profit driven global infrastructure company is planning and advising the Council to build roads at any cost instead of designing pollution free modern mass transit solutions.

2.4.   What document is used to justify the proposal for a bypass at the expense of our National Heritage farmland assets instead of examining designing and building a modern non-polluting and sustainable mass transit option.

2.5.   In the 2011 Options Study, the most recent study of mass transit is dated 2001, surely modern technology has surpassed the inefficiencies of 2001 and if so why is it not a serious consideration before planning new destructive roads?

2.6.   How can the proposal to accept unquantified motorway relief traffic (from the M5/M6) along the unsuitable A49, and along a city bypass upwind of proposed housing estates, be considered sustainable development?

2.7.   How can this destructive unsustainable road building be acceptable under UK Government guidelines in a supposedly developed country when Mexico, Colombia and many other developing nations are building pollution-free mass transit options for their developing cities?

2.8.   If a collective Law Suit was filed against the Council Cabinet and its planners for developing transport and City infrastructure that increased pollution and damaged the health of the city inhabitants, would City tax payers have to pay for their defence?

2.9.   Council has been asked on numerous occasions what level of motorway relief traffic would use the Hereford bypass, and responded saying it would be modelled as the project is developed. Data is available so why has this modelling not been done in order to inform the public?

2.10.                     Road building should be the last resort in solving congestion issues because it is ineffective and increases harmful emissions as traffic volumes rise. The idea that all future road traffic will be non-polluting is not realistic given the vast energy required to replace diesel haulage with electric road haulage.

SECTION 3

3.       Comments following a review of the 2011 Independent Review of Hereford Relief Road Technical Studies Report by Parsons Brinckerhoff are as follows

3.1.   This report is not independent, as stated in the title, because the current consultants to Council, Balfour Beatty, owned Parsons Brinckerhoff when it was produced. If you sense that is was written for the benefit of the infrastructure providers and not the public you may well be correct. Where Council signed the evergreen contract to hire Balfour Beatty in 2013 they were hiring the authors. This conflict of interest continues to impact decisions because the Council is paying the same infrastructure consultant Balfour Beatty to advise and consult on future developments.

3.2.   The report was produced under written instructions from the Council to exclude considerations of detailed engineering OR cost issues, enabling Council to proceed with its core strategy at any cost. This report provided guaranteed ‘blank cheque’ for its future consultants to keep drawing on its cost-plus-contract as designs change and costs escalate. It looks like the global consulting industry, Balfour Beatty, is running rings around the public purse holders. Are you going to let this just continue?

3.3.   In the report it is clearly stated that there was insufficient time to gather or check the environmental data provided by Amey and it was therefore assumed correct. This assumption was shown to be incorrect on the Southern Link Road. The surveys required identifying ancient woodlands, rare habitats and protected species to define the extent and value of its biodiversity were not conducted in time. Key decisions were made on the Southern Link Road without key environmental impact assessments. This practise of decision making with inadequate environmental impact analysis ignoring the detailed planning process has continued.

3.4.   The lack of detailed environmental baseline studies along the proposed routes compared meant that the legacy industrial pollution from toxic waste (Sutton Walls Fort Dump), historic foundry (Special Metals), gravel pits, a cement plant and existing infrastructure including rail lines and HT powerlines was not included in the environmental impact risk assessment. This issue should be cleaned up both in reports and in the Lugg Valley.

3.5.   The report fails to recognise that the road traffic analysis is totally bias towards road building. It fails to recognise the congestion problem is all school and commuter traffic which could be addressed without a bypass and therefore fails to address the key problem with Hereford transport. Wake up to the needs of the current population and get the planners to listen. We need mass transit solutions first and they are not following guidelines.

3.6.   The road capacity and its potential impacts were assessed from the perspective of the City traffic and local commerce, not the future County-wide motorway relief traffic volumes and therefore the traffic modelling needs to be reanalysed using an independent and respected professional body. The results should be explained to the public in plain English.

3.7.   This proposed motorway relief road is clearly not a sustainable development, compared with alternative congestion reducing strategies, when it destroys unique habitat, reduces arable farmlands, results in increasing human health problems plus premature death rates, increases our carbon footprint and diminishes the quality of our lives and our atmosphere by contributing to the rise in global temperatures and oceans. Planning and government box ticking to define this development as sustainable is a disingenuous exercise in public deception.

3.8.   The council needs to better understand the long term costs in terms of human lifestyles, ill-health leading to lower human productivity and loss of productive high quality farmland and natural habitat before proposing such destructive impractical growth plans. This report fails to address the basic elements of its long term high cost to society. 

3.9.   The Hereford 2020 business plan is fundamentally flawed in its proposal of developments over commercially important aquifers, on a flood plain North West and upstream of Hereford City. This bias report fails to justify the Councils flawed Core Strategy. The business plan to justify the infrastructure is still only an outline from a commercial perspective. The Council’s attempts to get its infrastructure funding from housing developers has so far failed.

3.10.                     The road proposed will need Highways Agency approval to become the new trunk route for all A49 traffic. This approval will require a robust business case as the Highways Agency will ask for the strategic, economic, financial, commercial justification and most importantly is the management fit to manage and deliver it?

a.       The strategic case fails because mass transit would better solve city congestion this road will attract motorway relief traffic and increase congestion.

b.       The economic case fails on the poor choice of high cost development sites on a flood plain

c.       The financial case is flawed given the deliberately undisclosed high capital and environmental cost and poor cost-benefits compared with alternative modern transport like trams, buses and electric shuttles.

d.       The commercial justification a no-brainer your taxes fund global infrastructure builders profits. Growth at any cost will be paid for by the next generation.

e.       Can management deliver it?               We think not.

Considering its track record, we do not believe the due diligence was thorough enough to build a business case for development. We consider the capital budgeting and consultancy arrangements in Herefordshire County Council are inadequate and so are the cost controls. We do not believe that the cost-benefits of the proposals are better than the alternatives.

Remember the three National issues when considering questions for Cabinet. First the traffic congestion increasing, second the resultant pollution generating serious health issues and premature deaths and finally the cost issue; it is not going to work and not good value for money.

 

 

 

SECTION 4

4         Questions raised from a review of the 2011 Independent Review of Hereford Relief Road Technical Studies Report by Parsons Brinckerhoff are as follows:

Ref Parsons Brinckerhoff Report entitled: Independent Review of Hereford Relief Road Technical Studies, July 2011

-Balfour Beatty bought Parsons Brinckerhoff in Sept 2009 and disposed of it in Sept 2014.

This report was not an independent review as Parsons Brinckerhoff was owned by Balfour Beatty when it was conducted in 2011 and Council appointed Balfour Beatty in 2013. Now a clear conflict of interests between Balfour Beatty its shareholders and its client and the report.

 

4.1   Ref Parsons Brinckerhoff Report entitled:  Independent Review of Hereford Relief Road Technical Studies, July 2011 The consultant was instructed that no consideration of detailed engineering feasibility or cost issues (Ref page 2 para 1.2.2) were to be included as part of the review? Does this therefore justify Hereford Council’s decision to proceed at any cost?

4.2   Ref Parsons Brinckerhoff Report entitled: Independent Review of Hereford Relief Road Technical Studies, July 2011, Can Cabinet confirm that, as stated in this report (Ref Page 2 para 1.2.5), that the review of Amey’s environmental studies assumed that the data they present were correct and that there was insufficient time for Parsons Brinckerhoff to confirm that Amey’s environmental data was either sufficiently detailed or correct?

4.3   Ref Parsons Brinckerhoff Report entitled: Independent Review of Hereford Relief Road Technical Studies, July 2011. The 2011 review by Parsons Brinckerhoff was instructed to exclude cost issues (Ref page 2 para 1.2.2). Therefore, how could routes be excluded on grounds of high levels of mitigation costs as per the report summary: Ref Page 2 para 1.2.6? Was this a blatant attempt to approve developments at any cost?

Ref Page 2 para 1.2.6 

It is considered at this stage that the exclusion of routes or the preference of one route over another on environmental grounds would largely result from: the presence of ‘show stoppers’ or environmental constraints that have considerable potential for significant impact or that their mitigation to a level that was deemed satisfactory (if indeed that were possible), would have considerable cost and programme implications.

 

Ref Parsons Brinckerhoff Report entitled:

Independent Review of Hereford Relief Road Technical Studies, July 2011

 

Ref page 4 para 1.5.2 from the report as follows:

The basis for the relief road is the need to provide transportation infrastructure to meet with the demand that will be placed on the existing road network from the additional properties that are required for the city.

 

4.4   We note that the 2011 technical review by Parsons Brinckerhoff (Ref page 4 para 1.5.2) did not consider the impact of increasing Motorway traffic relief from the M5/M6 or the Welsh HGV volumes from A465 to the Midlands Via the A49. Can the Council confirm that this will be professionally addressed using independent analysis before any development decisions are made?

4.5   Ref Parsons Brinckerhoff Report entitled:

Independent Review of Hereford Relief Road Technical Studies, July 2011

How is this proposed motorway relief road and housing estate access be considered to be sustainable development (on Page 7 Para 2.2.2) when it involves development on two flood plains, destroys unique habitat in SSSI/SACs, reduces arable farmlands, results in increasing human health problems, increases our carbon footprint and diminishes the quality of our lives and our atmosphere by contributing to the rise in global temperatures and oceans?                                                             When will these ignored environmental and healthcare costs be included in the cost benefit analysis?

4.6   In order to gain approval for road and bridge developments across the River Wye Site of Special Scientific Interest, Special Area of Conservation under the conservation regulations the planners must demonstrate imperative reasons for overriding public interest and that a better alternative does not exist. How does the Council propose to demonstrate that no better alternative exists when its SWTP options analysis excludes and motorway traffic analysis?   

4.7   Can the Council please explain how its outdated study of Southern Wye Transport Options, can be used to demonstrate no other better option exists for construction of a high level single span river crossing over the River Wye SSSI/SAC? (When the report is lacking in full motorway traffic and pollution analysis and excludes any consideration of modern transport (post 2001) other than road-building).

4.8   If the public cannot get satisfactory answers to technical questions from Cabinet members in open meetings, and the written responses are inadequate because they do not provide the requested information or links to any motorway relief traffic analysis, is this a reflection of the lack of information or a lack of understanding by the Cabinet and their technical consultants?

4.9   What level of M5/M6 Motorway Relief traffic would be considered acceptable and viable in the business case for the Western Relief Road and on what basis would it be estimated?

4.10           Is the Council aware that the volume of HGV traffic flowing on the M5/M6 currently is between 12 and 25 times greater than the A49 and any motorway traffic relief of say 15% or 20% will result in a marked increase in fine particulate pollution throughout Herefordshire and why has this not been explained to the residents?

4.11           Ref Parsons Brinckerhoff Report entitled:

Independent Review of Hereford Relief Road Technical Studies, July 2011

On page 8 para 2.3.3 the 2011 Independent Review by Parsons Brinkerhoff report states greater transparency should be provided as to how conclusions were made in the Amey Options Report that the Western Route is preferred. The authors state the decision appeared to be a function of River Wye Special Conservation Area designation but there was no clear statement and no dialog in the report. It was recommended that the choice was explained fully. Has this full explanation ever been given, did it include the industrial legacy pollution on the east from the historic metal foundries, the Sutton Wall Toxic Waste Dump, rail lines, powerlines and cement plants, if so please provide a reference to it?

4.12           Please can the council confirm that the proposed road is intended to replace the A49 trunk road through the city and that it will be designed and assessed subject to a full Environmental Assessment under the Town and Country Planning Act and the Design Manual for Roads and Bridges (DMRB).?

4.13           In the route options report by Amey it was noted that between 300 and 600 houses would be affected by adverse noise from the proposed routes. Parsons Brinckerhoff report July 2011 page 11 para 2.4.11. states that pollution alongside the selected route in relation to residential properties should be considered to be of only minor significance. Can the Council assure residents that it will make a full and updated assessment of the housing numbers and of the air quality and pollution haloes that would result from the increase in HGV usage as motorway relief traffic levels rise, and provide projections for these impacts?

4.14           Will the proposed sites for new housing estates down-wind of the road, such as Three Elms, be added to the Hereford Air Quality Management Areas (AQMAs) before or after the road development decisions are made?

4.15           Will the public receive a full analysis of the environmental impact of the proposed new road on the proposed new housing estates, with reference to the threats to human health from fine particulate pollution based on a traffic model updated for motorway relief traffic?

4.16           Amey repeatedly stated in its Stage 1 assessment and its Options Study reports that there was insufficient traffic data available to make a quantative assessment of impacts. How will the Council reassure the public that motorway relief traffic and new housing traffic impacts will be professionally assessed when it failed to monitor existing traffic levels for the last ten years?

4.17           The lack of detailed studies on baseline environmental aspects, including water quality, air quality is a major concern. If the Council does not recognise the threats to human health from pollution and has no idea how much it will increase from motorway relief, how can it progress the development proposals in close proximity to new proposed housing estates? 

4.18           We note that the SATURN traffic models produced in 2009 for the main corridors were not utilised in the Amey Options Study. Will the analysis of potential increase traffic from a 26% increase in city households and the M5/M6 Motorway relief be incorporated into the existing SATURN traffic models and published as part of a professional analysis?

4.19           What air quality assessments are required for developments on designated sites SSSI/SAC in relation to the proposed bridge over the Wye River flood plain west of Hereford?

4.20           What baseline air-quality and water-quality studies have been done and over what period in the two flood plains where development is proposed first over the Wye Valley Flood Zone and second over the Yazor Brook Flood Zone?

4.21           Will the proposed bridge crossing the River Wye SSSI/SAC on the western relief road have any footings in the 300m flood plain or will they be, on higher ground away from the flood plain?

4.22           Will the proposed bridge crossing the River Wye SSSI/SAC on the western relief road involve significant excavation of Devonian sandstones to illuminate blind summits on the south side of the proposed bridge given the 30m difference in elevation and how will the contractors control earth movements to ensure river quality particularly during salmon migrations?

4.23           Given the threat of pollution posed by construction and then high traffic to surface waters, ground waters and flood risks what steps will the Council take to protect the River Wye SSSI/SAC, residents of Hereford City and the population downstream residing along the banks of the River Wye?

4.24           Given that during the initial Stage 1 analysis and reporting Council’s consultants failed to identify the importance of Hereford’s underground aquifers to its major industries before the Core Strategy was developed can the Council now provide a map of all the Source Protection Zones (SPZ) for all abstraction points within and adjacent to the Strategic Core Development sites of roads and houses?  

4.25           Has the Council obtained Flood Plain Exception tests for the proposed development sites along the Western Relief Road as part of its risk analysis prior to investment or will developers be expected to foot the bill for the road and the Flood Plain Exception Tests?

4.26           Will the Contractors or the Council need a Flood Plain Exception Test to build the bridge crossing over the River Wye SSSI/SAC site?

4.27           Where is the business plan to justify this development and where is the full risk analysis that any good manager if capital assets would require prior to investing in new infra structure?

4.28           How can the public make an informed decision on routes when you have not provided a full picture of the proposed development’s impact on traffic, pollution, human health and its cost-benefits?

4.29           Since all of the proposed routes have the potential to exacerbate flooding risk by reducing the flood plain storage and increasing runoff, which is the worst and what are the likely ranges in cost of mitigation efforts?

4.30           Will the route selection offered for consultation be considered in isolation of the business plans and therefore not in conjunction with the proposed Three Elms Housing and industrial developments that effect flood zones on the transport corridor North east of the City?

4.31           We have seen recent proposed developments refused permission on the basis that the mitigation for loss of habitat could never replicate the rich established biodiversity that would be lost through development. Will the baseline and full environmental impact assessment of the River Wye High Level Crossing area and its surrounds be completed in sufficient detail to satisfy the statutory bodies that habitat loss can be justified?

4.32           The Breinton Spring is a typical emergent ground water source, used for drinking water by residents, flowing into the River Wye SSSI/SAC. Can the Council assure the public that the baseline survey work prior to construction will identified the water tables, perched water tables, perennial springs, aquifers and underground waterways that could be polluted by the proposed developments and future traffic movements?

4.33           Is the Council concerned to understand the hydrogeology in relation to the decisions on housing development sites and route options for the proposed road, and that Cargill, Heineken and other employers may leave Hereford due to water supply issues?

4.34           Conservation Regulation 49 states that a project with an adverse impact on an SAC SSSI would only be able to proceed in the Interests of an Overiding Public Interest (ORPI) were no viable alternative exists.  Give the conflicting interests of Council’s infrastructure consultant how can Council obtain a realistic assessment of any viable alternatives like trams, buses or trains?

4.35           What consideration has been made to protect Cider Heritage assets and how did they influenced the route choices given the organic apple orchards with over 141 different species in a  collection of historic apple trees along the proposed western  relief road?

4.36                                     The accepted aim of the proposed relief road by Council consultants is to stop increases in traffic congestion as the housing developments add 26% more city dwellings, but this was before the Highways Agency identified the need for M5/M6 motorway relief. Is it perhaps misleading to portray empty roads on posters and its website to illustrate the bypass traffic after motorway relief and a 26% increase in housing?     

4.37           What consideration was given to the location of roads west of proposed and existing dense urban conurbations, given the prevailing wind direction, and to the growing scientific evidence of the impact of fine particulate emissions on life expectancy, physical and mental health?

4.38           The Western Bypass was originally costed at £132m in 2010, before many requirements were changed and the scope of road was increased to include motorway relief traffic. What are the latest estimates for the full capital costs, and how should we expect these to change over the coming years?

 

SECTION 5

Questions for cabinet following a review of its transport phasing study 2014

The Transport Strategic Phasing Study 2014 is used by Council to justify the implementation of the Hereford Western Relief Road but it has some very obvious errors which we should address through public consultation.

 

4    

5    

5.1   The SATURN traffic modelling clearly does not include the motorway relief traffic that would flow as soon as the route was opened it only uses local growth projections. The SATURN model should reflect the duelling of the A465 to Abergavenny by 2020 and increased HGV traffic when fuel costs and travel times are improved from Wales to the Midlands. The National Motorway network is already suffering from M5/M6 congestion so the original predictions that relief is needed by 2030 are already out of date. If the public were presented with the true facts about motorway traffic, how would they feel about Council’s destructive plans to turn the A49 into a motorway for HGVs and the unspoilt countryside around Hereford into a series of giant lay byes and service stations? Ask about the precision and accuracy of Councils traffic modelling it is not an exact science.

5    

5.1    

5.2   The CO2 analysis for environmental benefits is both misleading and unacceptable.

Firstly the financially analysis is total flawed because you cannot reflect a 60 year project value with a present value (PV) model. We know this because we have experience in advising Governments on assets sales at an international level. Governments selling long term assets would not accept this valuation which only reflects 10-15 years out. Using present value analysis is a false representation of the long term impact. Council should be forced to use valuation tools that reflect the long term damage not just the next ten years over a 60 year time frame. It is deliberately misleading the public! Asset valuations for long term projects need to include annual multiples for ratio analysis to reflect strategic values. We have first-hand experience in this. The PV method is both misleading the public and professionally inappropriate.

5.3   Secondly, the assumptions used to generate the data set are clearly wrong omitting any realistic motorway relief traffic volumes, which would generate far more CO2 emissions. Traffic volume on the A49 will increase with increase road capacity. This model is based on false data that any layman with common sense can spot a mile off. The experts must be on cloud nine. If this is following guidelines then guidelines condone misleading the public. So it is an inadequate valuation method on a bad data set.

5.4   Thirdly the analysis excludes emissions from the traded sector and just analyses the non-traded sector. Say a major oil refinery or power generator runs 100’s of HGV deliveries through the bypass from the Welsh refineries to the Midlands power stations. What happens if we exclude their emissions? The Traffic User Benefit Analysis (TUBA) analysis of road traffic pollution is both inaccurate because it excludes the traded sector HGV traffic flowing through the A49 in relief from the M5/M6 and the expected increase in volumes.

5.5   The value for money analysis would not be accepted by any Government or merchant bank for the purpose of asset sales because the input data does not reflect the reality of the costs for the full project nor does it reflect the true costs on the environment and in human healthcare. The private sector would not accept these vague cost assumptions and bogus valuations so why should the public? The costs will be much, much higher on full design to include the numerous expected changes in scope and full mitigation costs. Who benefits most from these misleading financial representations? The infrastructure sector, national housebuilders, Balfour Beatty and its shareholders. Local Government is being led by the nose to slaughter, like a docile sheep. Wake up or your taxes are going way up.

5.6   This development is facing risk of legal proceedings that could likely to lead to substantial delays to the implementation timescale. The consultation with the public is considered to be inadequate given the questionnaires were prepared and collated by interested parties. Council’s answers to public questions do not reflect on past planning mistakes but merely repeat the mantra ITS IN THE CORE STRATEGY. Well that is just not good enough. Ignore mass transit solutions for city congestion for 16 years at your peril. The world is changing and so must the plans for city development. This is not a post war expansion of concrete jungles. Council planners must provide modern solutions to an age-old problem, sustainable measures, and subsidies on sleek new public transport that competes with the car.

5.7   The public distrust In Council management is compounded by their refusal to go back and request professional truly independent un-bias advice in order to answer the public’s simple questions. To make matters worse, Council is claiming ignorance on complex questions and failing to explain its answers in plain English.  For example, what is the probability of motorway traffic doubling or trebling the A49 volumes within 5 years? Council Planners should know and have credible answers. It has happened on so many other road developments the statistics are at hand. Council should be cognisant of the impact of increased pollution on costs, not ignorantly waving arms and claiming its pure speculation. Cabinet must be held to account for the future detrimental effects of their plans, most notably the increase that will come in motorway traffic, healthcare costs and the increase in premature deaths from greater pollution in urban areas. Don’t let them get away with it!

 

Section 6

Questions for Cabinet on the Transport Strategic Phasing Study 2014 by JMP Consultants

 

We have prepared some typical questions below for consideration at the public meetings. We recommend that the more cutting questions be reserved for attendees as their secondary questions to demonstrate the inability of Council Cabinet and its planners to answer simple requests.

 

6    

6.1   How will the Council address the fundamental flaw in the traffic modelling for Hereford detailed in the Transport Strategic Phasing Study 2014 by JMP Consultants Limited in which no account is taken of the M5/M6 motorway relief traffic volumes?

6.2   When the SATURN traffic modelling was last updated for Council, did the inputs ASSUME NO M5 M6 motorway relief traffic would use the A49? We ask because the model outputs show no significant impact despite traffic being X10 greater on the M5/M6.

6.3   According to the Transport Strategic Phasing Study 2014 by JMP Consultants Limited, the Highways Agency’s Route Based Strategy evidence report (February 2014) identifies the A49 link between the A438 and A465 as the 77th most unreliable on the strategic road network in England. The complexity and inefficiency of this road junction was compounded when Council granted permission for a supermarket and fuel station on the junction. This a serious mistake by the planners, will the same strategy be repeated on junctions when the bypass is designed?

6.4   The Council was presented with the facts about the pinch points on the A49 with the A438 and A465 as the 77th most unreliable on the strategic road network in England by Highways England in 2014. Despite this, the Council permitted large commercial developments on the worse junction in Hereford to further compound traffic problems. This has already cost businesses millions in lost time. Why should we trust you and your consultants on the traffic modelling when you have compounded city traffic congestion for years?

6.5   Can the Council confirm if the traffic disruption to flows caused by the recent development of the new supermarket and fuel station at the A49/A465 junction is included in the projections used in its SATURN traffic modelling of Hereford congestion? 

6.6   The proposed Hereford Relief Road construction would result in a minimum of ten years traffic disruption from construction equipment, building access roads and subsequent house building projects. How can the public trust SATURN traffic modelling used to forecast traffic flows when it does not incorporate time losses during construction of roads and housing estates and TUBA analysis excludes potential losses to existing business?

6.7   The Council has lost the confidence of the public over inadequate capital cost controls and poorly executed developments. Why would the proposed bypass be any different in terms of budget controls, a design fit for purpose and the Council’s ability to deliver this project on budget?

6.8   Who advised the Council as lead consults on the ill designed location of the supermarket and fuel station at the A49/A465 junction and would the same consultants be used to advise Council on the Bypass junctions, services and access roads?

6.9   Council informed the public at its last public Cabinet meeting that it will not consider trams or light rail as a mass transit system to reduce city congestion. How can this decision be justified when the last in-depth report commissioned by the Council in now 16 years out of date and the Councillor for infrastructure fails to acknowledge this fact?

6.10           Reams of data produced by the SATURN traffic modelling are used to justify the introduction and timing of the road development plan but none have any mass transit solutions incorporated to reduce the single purpose journeys like school trips and commuters. Why not?

6.11           Public mass transit systems for cities are required to meet certain investment returns to justify construction but rarely do so for medium sized towns. Often the required investment capital does not generate enough financial benefit when analysed under the current planning rules. Why then are roads being constructed without including the full healthcare costs associated with pollution, human mental and physical ill health and documented increased levels premature deaths, absent from a sustainable mass transit system?

6.12           When will the planning regulations relating to the cost estimates for developments in full business plans be required to include the full long-term costs, such as the full healthcare costs associated with pollution, human mental and physical ill health and documented increased levels premature deaths?

6.13           When will the planning regulations relating to the cost estimates for developments in full business plans be required to include the full long-term costs, such as the environmental costs associated with pollution, loss of habitat and loss of biodiversity?

6.14           Public mass transit systems for cities are required to meet certain investment returns to justify construction but rarely do so for medium sized towns. Often the required investment capital does not generate enough financial benefit when analysed under the current planning rules. Why then are roads being constructed without including the full environmental costs associated loss of habitat and biodiversity, CO2 emissions and climate change, absent from many sustainable mass transit options?

6.15           In Hereford’s Transport Strategic Phasing Study 2014 by JMP Consultants concluded the evidence to date indicates an intervention is required by 2027.  It was recommended that the half moon relief road should be in place by 2027 at the latest. Has this date been brought forward to reflect the increased congestion on the A49 A465 junction following developments of a fuel station and a supermarket?

6.16           How will Council’s consultants make the business case for the relief road using Transport Business Case development guidance and other guidance before a full cost analysis is available for the total project?

6.17           What is the expected level of accuracy in the capital cost estimates for the total relief road construction, ie plus or minus 50%, at the current stage of the project and will it be incorporated in contractual terms to include more accurate estimation as the project progresses?

6.18           It was proposed that the value for money assessment be based on an outlined Benefit /Cost Ratio based on TUBA analysis and that more detailed analysis will be required to develop the economic case within the Outline Business Case.

6.18.1      Will this still be the case and when will the analysis and the traffic models be made available for public scrutiny?

6.18.2      Will it be based on the same misleading  model of traffic flows?

6.19           Did the Western Relief Road corridor assessment include in-depth environmental analysis or was it managed like the environmental surveys for the Southern link Road?

6.20           Will the Council’s consultants be using the proposed TUBA transport economic appraisal software based on the inadequate SATURN traffic modelling data to generate another bias result for each section of the road?

6.21           Will the transport economic appraisal system used to evaluate the value for money of the relief road proposed be updated to include the increased cost of healthcare from road pollution for the inhabitants of the proposed new estates evidenced, by higher levels of premature death and increased incidence of ill health adjacent to busy roads?

6.22           Will the current Cabinet be accountable for the decision to build new roads close to and upwind of new housing estates when the increased cost of healthcare from road pollution, evidenced by higher levels of premature death and increased incidence of ill health adjacent to busy roads is finally incorporated into the planning process?

6.23           Did the risk workshop attended by Council and its key consultants to understand risk to deliverance cover issues of rising healthcare cost and elevated premature death rates related to  airborne and waterborne road and motorway traffic pollution or just mitigation issues to reduce the range of fall out?

6.24           It is stated on page 26 para 5.2 of the Hereford Transport Strategy Phasing Study that the western section of the bypass is primarily designed to make the Three Elms housing site more attractive to investors. Is there any limit to the capital that will be allocated from government funds to enable the inappropriate development on a flood zone, and over an important aquifer in a Special Protection Zone?

6.25           The value for money criteria base on CO2 analysis is inadequate when the full impact of M5 and M6 motorway relief traffic over the long term is excluded from the data modelled. Can the council confirm that the increase in motorway relief traffic using the A49 and the resultant pollution will be included in all future TUBA analysis?

6.26           The monetary value (in present value) for greenhouse gases has been produced through TUBA analysis undertaken for the Wye link. This is the net present value of the change in CO2 emissions from road based fuel consumption that is in the non-traded sector. What does the analysis of the traded sector look like and would it negate development when motorway relief traffic is included?

6.27           If the value for money calculation of CO2 emissions included the loss of trees and the increase in motorway traffic over the life of the road would it still result in a positive value? Did Council ask its consultants to address this question?

6.28           It is a well-known fact that present value analysis fails to capture the value of very long term projects of 30-60 years. In fact, any impact greater than 15 years out shows little value on the bottom line in current money. Why then, do the Council and its planners persist in using inadequate methodology in evaluating the long term effects of CO2 emissions?

6.29           There is something very fishy about a CO2 analysis of road traffic emissions that excludes emissions from the traded sector. The TUBA analysis of road traffic pollution is both inaccurate and disingenuous to the public if it excludes the traded sector HGV traffic flowing through the A49 in relief from the M5/M6. When will the Councillor for Infrastructure understand and address this issue?

6.30           The financial analysis of the CO2 emissions over 60 years is an outright disgrace. It would not be acceptable in a private investment process and is clearly a disingenuous approach to presenting data to the public. Governments, advised by merchant banks used multiple methods to evaluate long term financial returns because the discounted cash flow or present value method fails to capture value beyond 15 years. When will Council address this issue?

6.31           The reliability tests for the proposed road on contribution towards journey time reliability and capacity of transport links, analysis using the Hereford Saturn model has indicated journey time will increase 8% by 2032. This SATURN model clearly excludes effects of the Motorway relief traffic and is therefore inaccurate and misleading. How does the Council propose to address this misleading analysis?

6.32           This development is facing risk of legal proceedings that could likely to lead to substantial delays to the implementation timescales. Please quantify expected extra legal costs and time delays.

6.33           Please can Council explain how it might now gain public acceptance for this scheme given its poor transparency of the technical and financial decision making, inadequate responses to questions, its disastrous planning decision on commercial developments over the A49/A465 junction, Blue School Office cost fiasco has generated a lack of trust in its management?

6.34           The public reports state that the value for money terms this road link provides very high value for money (BCR is greater than 4). How much lower is the value for money BCR if the extra healthcare cost over 60 years for ill health and premature deaths are included in the equation if the full traded pollution and the motorway relief HGV pollution is included in the TUBA analysis?

6.35           How can the Council accept legal responsibility for this decision making when the assumptions are so obviously bias towards roadbuilding by its consultants?

6.36           The consultation with the public is considered to be inadequate given the questionnaires were prepared and collated by interested parties. Conflicts of interest and a poor decision making process have marred the process from the start and remain open to legal challenge. Will the Cabinet personally accept legal responsibility for the increased healthcare costs, environmental destruction and poor returns this scheme will generate when full life of project costs are calculated?

6.37           The capital cost for the Western link are estimated as an outline cost of £42.864 million with a quantified risk estimate of £23.792 million giving a total cost at this stage of £66.656 million. The Wye link is therefore the most expensive individual link within the relief road. This is a result of both its length and the need to bridge the River Wye. May we assume these figures will increase 100% like the Blue School House Refurb or 25% like the City Link Road as the mitigation and legal costs escalate?

6.38           This whole relief road is likely to have a relatively complex build. There is a need to cross the River Wye, a rail line and a former canal. In addition the issue of power lines and high pressure gas pipe is likely to cause issues in terms of the construction plan. This project is an infrastructure consultants dream in terms its earnings potential from changes in scope and mitigation costs. What can the Council do to fix costs? What is the budget for Balfour Beatty’s time spent on it?

6.39           This Council approved planning permission for developments that compounded the congestion on the Greyfriars Bridge when it grant approval for the supermarket and fuel station. How then can it be trusted not to increase A49 congestion with M5 M6 Motorway Relief traffic in National interest while destroying the local environments of Herefordshire and Shropshire?

6.40           If Councils consultants say ‘jump of the bridge’ would Council jump? No? Then why does Council accept inadequate traffic modelling that is clearly lacking in full analysis of both motorway relief traffic and construction delays from both road and house building?

6.41           Must the public accept the misleading traffic user benefit analysis (TUBA) results based on inaccurate traffic modelling and inadequate financial tools just because it is generated in accord with planning policy and current guidelines, or will the Council have the good sense to question these results using informed and independent analysis?

COPY OF Open letter to the Hereford Times

Dear Editor

The Hereford Times printed an anonymous letter on page 40 of its Christmas edition.

The anonymous author will have you believe increasing road capacity will reduce city congestion despite the 26% increase in housing developments. This is incorrect because more than 85% of traffic is local and the bypass could attract X3 more volume on the A49. Recent studies showed increasing road capacity attracts more traffic and most bypasses fail to reduce congestion. County Council is clearly driven by the lobby of transport and road building interests not the public interests. The proposed bypass will not work for Hereford or Herefordshire.

The second misleading opinion expressed in the anonymous letter is that a bypass is the only solution to traffic congestion. It clearly isn’t. Many cities across the world are working to reduce road congestion by introducing modern infrastructure that is non-polluting. The mayors and councils in these cities recognise that pollution from diesel engines cause multiple health problems and premature deaths. The future is pollution free zones and mass transit. This County and its two elected MP’s should embrace and invest in modern transport solutions.

The third misleading opinion which highlights this letter as pure propaganda is the insistence that Government cannot afford to build pollution free transport infrastructure, when it can afford to build roads at the expense of the police services, social care, social housing, public transport, education and public health. Planners should be duty bound to propose solutions that reflect a healthy future. In fact Cities like Leeds have adopted a can-do-attitude in reducing pollution.

Don’t believe this propaganda that states we only seek to protect the beautiful countryside around Hereford. We would like you to understand building bigger roads is not in the interests of Hereford, Herefordshire or indeed the health and wealth of this Nation.

Building bigger roads will attract more traffic increasing pollution and increasing healthcare costs. All of this is affordable under current guidelines because Local Government can ignore the time bomb of rising health costs from road pollution, even in the backyard of the Minister for Roads.

Sincerely

Wye Ruin it?

Patricia Ronan