Dear Ms Gibbons

Planning application – P162920/F Land at Three Elms, Hereford*Application* – Outline Planning Application with all matters reserved, except access, for the demolition of existing agricultural buildings and an urban extension comprising up to 1,200 homes (Use Class C3); employment development (comprising Use Classes B1/B2/B8); a neighbourhood centre comprising a mix of retail (Use Classes A1/2/3/5), health provision (Use Class D1) and leisure uses (Use Class D2); a new one form entry primary school; park & choose interchanges; together with open and play space, landscaping, highways, infrastructure and associated works.

Breinton Parish Councillors considered this application at their meeting on 14th October and were extremely disappointed to find that, despite a further four years of intensive and no doubt expensive work, the applicants and their agents have given so little attention to the Parish Council’s lengthy representations dated 3rd November 2016 and 27th March 2017.

Never the less we welcome the opportunity to make further representations despite the need to read 27 new documents (@2900 pages) and 23 new drawings, many of which are repetitious.  Many of our previous points remain valid, some the more-so with the passage of time, and we urge you to re-read them again.

However; rather than repeat the full representations again we will simply summarise and update them in the pages that follow as well as provide cross references. Underlining adds our emphasis to any external sources we have used. Major quotations from background documents have been italicised

  • General Comments

Prior to our detailed comments, we wish to make two over-riding points.

  • a) The application still does not provide sufficient attention to the rural areas bordering the site to the north, west or south, including Breinton. This is wrong as the implications of this development will be felt by these areas and their residents just as much as in the suburbs of Hereford city to the east. A particular concern being that regarding the Phase 2 traffic modelling now required by Highways England but at a later date. The development is still focussed on benefits for the developer and the eventual residents
  • b) The applicants do not appear to have fully recognised that the policy context has fundamentally changed in the last four years at both the strategic and local levels. The proposal as master planned and covered by the four parameter plans is unambitious especially where housing, development, design and transport are concerned. The whole application describes a development that could have been built at any time since the 1980’s. It manifestly runs the risk of repeating all the mistakes so evident in the Belmont developments of previous decades south of the river and on more recent developments along the Roman Road.

In particular, but not exclusively there have been the following changes to the policy context;

The Church of England’s General Synod of February 2020 committed the Church to becoming carbon net zero by 2030

Herefordshire Council has declared its recognition of the climate emergency. It has identified positive actions to reduce carbon emissions that arise specifically from travel-to-work and travel-to-school by private cars within and across the city and to implement schemes that make possible more green travel, public transport, cycling and walking.

In these connections and particularly as this is an application by the Church Commissioners, it is very disappointing to note that they have ignored the ambition of the Church of England expressed in General Synod February 2020 that the church is to become Carbon net Zero by 2030. The Church of England passed a resolution worded as follows:

“That this Synod, recognising that the global climate emergency is a crisis for God’s creation, and a fundamental injustice, and following the call of the Anglican Communion in ACC Resolutions A17.05 and A17.06;
(a) call upon all parts of the Church of England, including parishes, BMOs [Bishop Mission Orders], education institutions, dioceses, cathedrals, and the NCIs [National Church Institutions], to work to achieve year-on-year reductions in emissions and urgently examine what would be required to reach net zero emissions by 2030 in order that a plan of action can be drawn up to achieve that target;”

Breinton Parish Council whole heartedly supports this resolution of the Synod and would welcome the Church Commissioners working to deliver this ambition of the Church of England.

While other policy changes include:-

Department for Transport Local Transport Note 1/20 on cycle infrastructure design (dated July 2020) which does not appear to have informed this application – see our section 2 below

Herefordshire Council is not actively progressing the Southern Link Road (although Highways England appear to think it is actually under construction) although the planning approval remains valid.

Herefordshire appear to be in the process of abandoning the Hereford Relief Road upon which Phase 2 (at least) of this development is contingent according to Core Strategy Appendix 5 – Necessary Infrastructure for Strategic Sites)

Breinton’s Neighbourhood Development Plan has been approved and along with those of other neighbouring parishes to the development like Credenhill, Burghill, Holmer and Stretton Sugwas, form part of the local development framework

A tree preservation order now covers the historic avenue of lime trees along Kings Acre Road

Access (See also the Highways section 3/11/2016)

We still maintain that approval of access to the development as far as Kings Acre Road (KAR) is concerned is premature and should not be determined until the future of the proposed Hereford Relief Road (HRR) is known and appropriate traffic modelling completed as required by Highways England. The KAR access is not need anyway until Phase 2 of the development. As the Report to Inform an Appropriate Assessment notes at the time of the original application (2016) the anticipated start date was 2019 with a 12 year completion period. Four years on and assuming outline permission is granted, using the same timing/phasing (as the Transport Assessment Addendum part 2 appears to do) gives a start in 2023 with a build out to 2035. Phase 2 will not commence until 2028 at the earliest. Why set in a tablet of stone something that events of the next decade may alter? There is no immediate need to decide this access now via a parameter plan, indeed there are reasons not to.

Developments proposed locally still mean that there is potential for 4 access points onto Kings Acre Road in the short distance between the Bay Horse pub and Huntington Lane. We understand that there will shortly be an application to develop the large fields east of the Blue Diamond garden centre again that will require access onto KAR.  This would be a fifth junction when it is in all of our interests to keep traffic flowing smoothly as far as is possible including, hopefully, more cyclists and pedestrians. So many junctions on such a very short stretch of road and is surely unacceptable in highways terms.

Concerning the number and type of junctions; the Parish Council considers that even the revised proposals for Three Elms Road are short sighted, are likely to increase accidents and will certainly hinder traffic flows. Two mini-roundabouts are now proposed in the vicinity of Grandstand / Tillington roads but our view remains that a better solution would be to build a single, higher capacity/full sized roundabout at this point to access the development and for Sandown Drive, 3 Elms and the Tillington Roads. Strangely the access parameter plan also has a cycleway and footpath exiting the site at its far NE corner close to the junction with Tillington Road where visibility for motorists is really poor and must surely be substandard by modern criteria.

We note that our previous concern about traffic using Sandown Drive / Grandstand Road as a short cut to the A49 have been recognised with traffic calming measures being proposed. However; vehicles wanting the A49 south will surely head for Whitecross and the Parish Council would support improving the roundabout here early in the development’s life. We note that Table 6.5 of the Transport Assessment Addendum shows the junction close to capacity on the 2022 base assessment and certainly over capacity after Phase 1. In this context and in the likely absence of new roads, we believe that the proposal to reduce its capacity is misconceived and misguided and is not supported. If the junction is to be altered serious consideration should be given to re-locating the electricity substation between Wordsworth and Kings Acre Roads. The lack of sight lines here surely makes the junction sub-standard and as Section 7 explains, historic trees are being removed nearer the proposed development purely to create adequate sight lines.

It is difficult to see how the Transport Assessment concludes that the development can be adequately accommodated within the existing transport infrastructure. This masks the severe impacts that will arise from the current proposals. In 2016 a start on site was anticipated in 2019 with 100 houses being built and a 12 year completion period to 2031. Despite four years of further work – mainly around flooding – and with major new roads not yet started and looking ever more unlikely how possibly can the highways assumptions and scenarios modelled in the Transport Assessment (and repeated in the Addendum) still be considered robust and valid overall?

In particular we note the Highways England response dated 7 October 2020 that includes the following statements

‘…. Phase 2 (up to 620 residential units and employment development) would only be occupied once the Bypass was completed. ……It is set out within the Transport Assessment Addendum that the Hereford Bypass scheme has now been paused and is under review with no certainty as to whether it will continue and in what form………

….Our previous response was based on the provision of the Bypass; however it is now unclear when or if it will be provided.

Junction capacity assessments have so far only been completed for Phase 1 of the development. Those for Phase 2 will be undertaken as part of the reserved matters application. Due to the current uncertainty around Hereford Bypass being delivered as part of Phase 2, we will require re-assessment of capacities for all the impacted SRN junctions without the Hereford Bypass to ensure the traffic impacts of Phase 2 are robustly assessed and suitable mitigation measures provided where necessary’

Accordingly Highways England requires certain conditions be applied to any approval of this application. The Transport Assessment Addendum confirms the reliance of Phase 2 of the development on the Hereford Relief Road and that Phase 2 modelling will be a reserved matter which is why there is not data in the various appendices for this application.

Notwithstanding Highways England misconceptions (i.e. that the Hereford Bypass is in the design and planning stages as well as the Southern Link Road being under construction) the Parish Council believes that this response alone means that all aspects of Phase 2 of the development are premature and should not be approved at this time. We do not believe that conditions to be resolved as reserved matters – potentially without Committee consideration – are sufficient to cover this major, legitimate concern. How can detailed site access arrangements or local housing numbers possibly be approved for instance until the impact on the junctions on the local strategic road (A49) have even been assessed?

We note that the same Transport Assessment Addendum says ‘ ….the scale and nature of the proposed off-site highways works, including the Whitecross Roundabout and the previous Three Elms mini-roundabout, has been determined by the long held expectation that the Southern Link Road will be completed in 2020 and the Hereford Bypass will be completed during the early to mid2020’s in line with the HC Local Plan. On this basis, it has been accepted that HC Officers that the proposed traffic impact of the proposed development at local junctions would not need to be directly mitigated through the delivery of localised junction improvements, as once the bypass had been delivered capacity at local junctions would become available through re-routing of strategic traffic onto the bypass. Instead HC officers requested off-site improvements with a focus towards walking and cycling infrastructure and road safety’.

The Parish Council is amazed at this statement coming as it does in a document dated some 18 months after political control of Herefordshire Council changed and disagrees with both the premise and conclusions of the statement. In practical terms the proposed new roads cannot possibly be built in the timeframe envisaged. In our view the statement shows a significant and ongoing dissonance between Officers of the Council and the aspirations for and emerging direction of the Council’s transport policy. As far as access is concerned there is a real danger of leaving NW Hereford significantly short-changed in the investment needed to mitigate the effects of increased traffic from this development.

Is has been noted earlier in this submission that changes at the Whitecross roundabout should not go ahead as proposed and the entire package of proposals contained in the Access Parameter Plan rejected until they can be reviewed and replaced with more realistically based and practical changes.     

Kings Acre Road junction details. The Parish Council still feels that the design is inadequate for traffic exiting right (west) from the development onto KAR but as previously noted, we do not agree that there is any need for this junction to be approved either at this point either in principle or in the detail currently provided. Should it be approved however we would require a condition that the current network of air quality receptors is extended further west along the Kings Acre Road at the commencement of Phase 1 so that data is captured on the current position and can then be compared with the position should Phase 2 proceed. The design should also provide extra road width so that the filter lane can be accommodated and the lane itself should be of sufficient length to hold a number of vehicles. This will avoid repeating the problems at Kings Acre Halt further to the west where the lane is too short for more than one vehicle to fully enter (being constrained by a well meant but poorly sited pedestrian refuge) and thus westbound traffic is easily blocked as it would be if there was not a filter lane.

  • We can only say that the results of the work done since 2016 by WYG in relation to transport matters and mentioned in Nathaniel Lichfield and Partners response dated 8 February 2017 disappoints us (see our response dated 27/3/2017 point 1)

Sustainable Transport – Cycleways (see also 3/11/2016) and Pedestrians

a)    In the Parish Councils view sustainable transport measures and the Framework Travel Plan still lack ambition despite the applicant’s apparent change of mind on the potential for local bus routes within the development and the adoption of a 400m maximum distance from a bus stop (previously 800m). We remain concerned that buses are not seen as viable initially since a lack of services will do nothing to break entrenched habits and encourage change. As far as the bus stop distances are concerned it is not about what is reasonable or even achievable but what encourages and changes habits.

The ambition is that new residents use of the car for single journeys will reduce from a predicted 67% to 52% with a 2% increase in car sharing (6% – 8%), with 8% by bike increasing to 13%, 16% walking increasing to 19% and public transport increasing from 2% to 7% (no doubt because it will now be available through the site itself). Despite the whole of the City being within half an hour by bike from this site and much of the site just a 10 minute bike ride to the City centre. This remains a car dependent development and will stay so without further design changes that are so common in Europe and have been shown to work over decades. The reliance on a Travel Plan Co-ordinator to influence new residents and absolutely no indication that the design of the new development will learn from international best practices is incredibly short sighted. These are matters for inclusion now since they will have implications for the parameter plans especially land use and access.

As part of the Framework Travel Plan Report (para 2.30), Pell & Frischmann  state “ It is therefore considered that the site is located within a sustainable location and has the potential for a number of trips generated by the site to be made by non-car modes. It is clear that cycling presents the best opportunity to encourage sustainable travel over short journeys (time and distance), which essentially covers all of Hereford as a catchment for this mode. Yet the Travel Assessment still predicts majority car use from this development and fails to take advantage of an opportunity to design a truly ambitious, sustainable development

b) The new application is dated September 2020 yet the Dept for Transport Local Transport Note 1/20 “Cycle Infrastructure Design” July 2020 does not appear to have informed any part of the design for active travel measures nor how the site and its residents will link with other cycle networks in the adjoining areas and form part of a Hereford City cycle network. In this respect many of the transport measures do not conform to the latest guidance. In particular the DfT LTN 1/20 in Chapter 14 reminds planners that: –

14.1.2 Appropriate cycle facilities should be provided within all new and improved highways in accordance with the guidance contained in this document, regardless of whether the scheme is on a designated cycle route, unless there are clearly-defined and suitable alternatives.

14.2.1 The National Planning Policy Framework (NPPF) 51 sets out the national policy context for land use planning and states that planning policies should:

provide for high quality walking and cycling networks and supporting facilities such as cycle parking (drawing on Local Cycling and Walking Infrastructure Plans)’ (Para 104d).

14.2.2 The NPPF also states that applications for development should: ‘give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas’ (Para 110a).

14.3.6 It is important that the TA does not overestimate motor traffic travel demands, which could make it difficult to provide well-designed cycle infrastructure, particularly at the site access points. Travel demand forecasts should take into account the potential for the increased levels of cycling that will be enabled by high-quality cycle facilities, both on- and off-site.

14.3.7 New developments that have important destinations within them, such as schools and retail centres, should be provided with cycle and pedestrian links to adjacent residential areas and local cycle routes so that residents can cycle to the new facilities. Similarly, large new residential developments should offer external links to adjacent employment, education, administrative, transport interchange and retail destinations.

14.3.12 Cycling facilities should be regarded as an essential component of the site access and any off-site highway improvements that may be necessary. Developments that do not adequately make provision for cycling in their transport proposals should not be approved. This may include some off-site improvements along existing highways that serve the development.

14.3.14 Cycle networks within new developments should generally be made up of the elements listed in Chapter 3, Section 3.4, i.e.:

Dedicated space for cycling within highways (Chapter 6)

Quiet mixed traffic streets (Chapter 7)

Motor traffic free routes (Chapter 8)

Junction treatments and crossings (Chapter 10)

Cycle parking at origins, destinations and interchanges with other modes (Chapter 11).

The spine road through the site fails to be suitable for all members of the community to cycle along and across as it only seeks to provide shared walking/cycleways which is contrary to LTN 1/20 para 14.3.22 “The speed and volume of motor traffic on these routes will often mean that protected space for cycling is required”. It is unclear what speed limit will apply to the spine road since the site exits onto 30mph, 40mph and 60mph roads currently. However it is unlikely to be less than 30mph unless the proposed design of the development is shifted radically now through the master planning exercise and the parameter plans. This should not be left to the approved matters stage. Indeed, the Parish Council would argue that it would be too late at that stage.

We have failed to identify the National Trail through the site that appears in some documents and the Amended Environmental Statement Further Information Report is also incorrect that the ‘site is located adjacent to a comprehensive existing pedestrian and cycling network. The Amended Green Infrastructure Strategy repeats this mistake by showing an existing shared cycleway/footway along its southern frontage (Kings Acre Road). This is actually along its northern frontages – the Roman Road – but this is missed out. Certainly as far as Kings Acre Road is concerned there is no provision for cyclists and the pedestrian path is across the road from the development (south side) meaning new residents would have to cross a busy main road. As such we welcome the intention to provide such an extra facility on the north side. This should be a primary cycle route and not just a secondary one which we understand would simply have space ‘reserved’ on the existing carriageway and enhanced signage/markings.

As we have noted in the section immediately above, the detailed design of movement and access around the development site is not currently available, due to this being an outline application. It should be part of this consideration. Designing out wide scale provision for cars across the site, and limiting car access to the perimeters of the site, would enable a higher ambition of final car use below a base of 67% and a final forecast level of 52%.This would also avoid site visitors (e.g. parents dropping off children at the primary school) from using a car to make these journeys. This would build in active travel from a young age, led by example by staff walking/cycling the last part of their journey. By excluding car movements from much of the site it would improve air quality from this development, enable children to have more space to play and be active in a safe environment, creating a more cohesive community, which is shown to reduce crime and improve health outcomes for all ages.

Flood risk (see also 3/11/2016)

The Parish Council remains concerned that the proposed development will adversely

affect the properties along Kings Acre Road and our previous representations remain valid.. We respectfully point out that the approach to assessing flood risk is incomplete in our view. There is direct hydrological connectivity between this area (which are in SPZ1 and, 2a until the Bay Horse Public House) and the site. Any change in the relationship between soil and water in the rest of the catchment could adversely affect these properties and there are certainly major earth movements being proposed at 3 Elms as part of the developmentAs previously stated, the area immediately south of KAR is actually lower than the proposed development site north of the road and this was confirmed when Balfour Beatty surveyed the area in 2020 after flooding during the winter of 2019/20.

Since 2016 the Environment Agency overland flow flood risk maps have been updated to show increased levels of risk in this area.

As the geological cross sections across both the site and the aquifer produced by the applicants at various points in their supporting documents clearly demonstrate; the fields south of KAR are also part of the Yazor Brook catchment as well as the Ground Water Source Protection Zones (1 and 2a). The hills of Breinton Ridge actually form the southern boundary of the catchment. Water from here eventually percolates underground south east through the catchment including under the proposed development site.

This flood risk was an issue in the granting of permission for development at Breinton Lee (application 123592). Since 2016 a flood attenuation pond has been built providing a measure of protection for Huntsman Drive and the Fayre Oaks caravan park involving Herefordshire Council, Welsh Water, the Environment Agency and the Church Commissioners. In the early part of 2020 homes at Kings Court experienced flooding from the fields to the south after the prolonged, high intensity rainfall from Storms Ciara and Dennis from water ponded up in the fields These examples demonstrate a wider and continuing problem and the impact of climate change and pictures taken at the time(s) can be provided if this will aid an appropriate decision.

The Parish Council fears that the development will exacerbate the drainage issues along KAR and that any changes in the water- table will be detrimental to the surrounding area if not the development itself.  In response to the question on the application form “Will the proposal increase the flood risk elsewhere?” the applicants have stated that it will not.  Breinton Parish Councillors dispute this assertion. We note from various supporting documents that:

  1. the properties at Huntington and along the Roman Road are identified as being particularly sensitive to flooding but there is silence about properties bordering KAR
  2. the development is not supposed to adversely impact on the flood risk to third party land. The Flood Risk Assessment (FRA) is intended to show that ‘the proposed development is safe from flood risk and that flood risk elsewhere in the Yazor Brook catchment does not increase as a result of the development.’ We suggest that the FRA does not do this fully since it is incomplete.

the impact upon water quality of five new properties at 137 KAR (and other developments locally) has been studied but not flood impacts.

The Herefordshire Strategic Flood Risk Assessment indicates ’no incidence of surface water flooding (during high intensity rainfall events such as sheet run off from fields or large hard-paved areas) have been recorded at the site’. However as shown in paragraph 3a above surface water flooding does occur along the sites southern boundary while the applicant has acknowledged that the appropriate flood risk maps actually do show small, specific areas on the south of the site itself to be prone to surface water   

After four more years of intensive study this proposal still ignores the impact on the area to the south and its existing residents. The work to date focusses on the site being flood proof, downstream impacts and satisfying major businesses that their water supplies remain safe. Approval of the parameter plans as currently proposed ignores an opportunity to address overland flooding (some of which is from and affects other Church Commissioners land) in NW Hereford  in a coherent rather than piecemeal way as developments come forward one by one in future years.

We can only say that the results of the work done since 2016 by WYG in relation to flood risk drainage and mentioned in Nathaniel Lichfield and Partners response dated 8 February 2017 disappoints us (see our response dated 27/3/2017 point 1)

Park and choose (see also 3/11/2016)

The Travel Plan mentions Park and Choose sites, commenting that 2 would be provided and both facilities are within walking distance of the residential areas. We remain of the view that  the provision of 75 parking spaces for each phase of development (75 on Kings Acre Road and another 75 on the Roman Road) giving a total of 150 parking places for 1,200 homes is totally inadequate considering the high number of car journeys the Travel Plan forecasts will be made by car. This token provision cannot possibly accommodate sufficient residents, visitors and commuters nor can it make any meaningful reduction in car based journeys into central Hereford or the site

There appears to be no mention of car clubs, which would further help reduce individual car ownership and reduce the space needed for on-site car parking and would make the Park and Choose sites more compatible with the number of housing units proposed. This is important as this site needs to minimise the quantity of hard surfaces due to increasing the risk of flooding both on site, surrounding areas and downstream of the Yazor Brook into the city.

Density (see also 3/11/2016 and 27/3/17 point 8)

We previously said that densities at the margins of the site should reflect what is already there. Nothing has changed with the housing numbers being proposed for phases 1 and 2 remaining the same and no big changes to the land areas included.  The average for Phase 1 is calculated at 28per hectare with Phase 2 – including the area adjacent to KAR – being 35p/h. This completely ignores the low density along the road even the almost continuous ribbon development immediately to the south of the site. The masterplan and appropriate parameter plans should not be approved until this is changed. Our objection remains.

Design sensitivity (see also 3/11/2016 and 27/3/2017 points 3-7 inclusive)

We remain of the view that this development is not ‘sensitively designed to integrate the site with Kings Acre Road (KAR)’ nor does it ‘respond to local character’ or respond to the site context. Even though local building heights have been reduced to 12.5m this is insufficient certainly still out of keeping with the existing two storey ribbon development housing south of KAR and tree heights as the illustrative sections attached for information to the Submission of Further Information clearly demonstrate.

Even though the three storey blocks appear to have been moved north, slightly further into the development, there is no such density, mass or type of property in existence on the opposite (southern) side of KAR and the clash in character are obvious. The previous Design and Access (D&A) statement included what was supposed to be a local character study but none of the five areas chosen resemble the existing KAR frontage; in the slightest. (Please see also our response dated 27/3/2017 points 9-11 inclusive and the photographs attached at that time)

The Amended Environmental Statement says that there is potential for three storey buildings to be located adjacent to the primary route corridor towards the centre of the site. However this is not what the Amended Masterplan shows – larger blocks immediately north of the Kings Acre Park and Choose site on both sides of the primary route corridor nor, importantly does the amended building height parameter plan which we understand is to be approved as part of the outline planning permission. This shows that the 12.5m zone extending to the southern boundary of the site, east of the route corridor along Kings Acre Road

The relevant parameter plans should be further amended to reflect these points

Land use – Loss of trees on KAR (see also 3/11/2016) and Playing Fields

As we said previously, the avenue of lime trees on both sides of KAR gives one of the most visually attractive entrances to Hereford city and therefore to this site. They provide a link to the horticultural heritage of Kings Acre and is one of the important public views covered by policy B16 of the Breinton Neighbourhood Plan which was approved in 2016 and is thus a material consideration in this decision. As the applicants have noted this avenue is now covered by a Tree Preservation Order.

As we feared in 2016 the number of trees to be removed to provide the spine access road to development has increased (from 1 to 4. These are all Category A trees and the only ones to be removed to make way for this development. Even more are at risk given the various junctions proposed for this stretch of road – see section 1b) earlier. One of those to be removed (T5) is recorded as having high visual amenity in the Updated Arboricultural Impact Assessment. This describes the avenue as being ‘a line of good quality mature lime trees which provide an important visual amenity’ but ignores their heritage. The Assessment also identifies trees 13 and 14 as being at risk from any Hereford Relief Road.  The Parish Council objects to this wholesale removal of local landmarks which risks the integrity of the overall landscape feature.

Hedge 8 facing the main (Kings Acre) road is described as ‘a mature, mainly hawthorn hedge, a locally prominent feature that provides valuable screening and habitats’. While the Open Space Parameter Plan (which we understand will be approved as part of this particular application) says that structural planting will be provided as mitigation for the loss of trees and the Land Use Parameter Plan says that existing trees and hedgerows will be substantially retained; we do not consider the current offer of buffers and enhanced planting is sufficient. The aim should be to significantly improve and extend what exists currently and the appropriate parameter plans should be revised before any approval is given. (Please see also the section on ecology/bio-diversity in our response dated 27/3/2017)

Sport England in their latest response have highlighted that there is no longer a need for a 3G sports pitch and instead playing fields with an alternative surface or grass, could be provided instead. In view of the risk of flooding and the high quality soils on this site, Breinton Parish Council would prefer the provision of grass playing fields improving the absorption of rain and fitting better with the current rural feel of the site and the Historic Huntington settlement, despite the development proposals for this site.

In conclusion

The adopted Herefordshire Core Strategy clearly states that ‘Three Elms will be planned on a comprehensive basis informed by a development brief and master plan prepared through the Hereford Area Plan’. This Plan does not exist which may be one reason why the integration of this development with the surrounding areas and the wider city is so poor. Breinton Parish Council remains of the view that this application is premature certainly in relation to those matters affecting Phase 2 of the development.

Breinton Parish Council does not believe that so many of the crucial elements of this development should be left to reserved matters. They should be addressed now. Three Elms is simply of too much significance, on the fringe of the City and bordering one of the main approaches to Hereford, for this to be allowed.

Breinton Parish Council believes that in view of the above comments this application should be refused as failing to comply with the various government policies listed and being contrary to the applicants own Church of England policy on reducing year-on-year emissions.

Yours sincerely,

Emily Godsall

Clerk, Breinton Parish Council