The case
Counted in 2016. Warned in 2018. Still unmitigated.
The council’s own documents show the C1098 was left out of the bypass assessment, that the method used could not have found the problem even had it been included, and that the first competent assessment has now found it.
What is being built
Herefordshire Council is constructing Phase One of the Hereford Bypass, formerly the Southern Link Road, under a planning permission granted in July 2016 (ref. P151314/F) and kept alive by a nominal commencement of works in July 2019. The Full Business Case was published in August 2026. Construction is programmed to begin in December 2026, with opening around 2028.
That Full Business Case, and the Compulsory Purchase Order Statement of Reasons, acknowledge for the first time that the scheme will change traffic on rural roads — and the FBC names the C1098 among the roads facing induced traffic.
Six things the record shows
The C1098 was never assessed
The 2015 Transport Assessment defines its study area exhaustively and expressly limits it to the locations on one figure. The C1098 does not appear. It is also absent from the traffic data underpinning the air quality assessment and from the noise assessment data.
Transport Assessment §§7.5.1, 7.5.4; ES Appendices 5.1 and 11.3
The method could not have found the harm
Links forecast to reduce were omitted from further analysis. Increases of 30 PCU/hour or less were categorised as negligible and likewise omitted. And every assessment used unconstrained “demand flows” — traffic that wishes to pass — rather than actual flows constrained by queues. Rat running is a response to congestion; an assignment that ignores what queues do to route choice removes the causal mechanism by construction.
Transport Assessment §§7.3.4, 7.5.2; Briefing Note §§2.4–2.5
Both highway regulators recorded the limitation before consent
The Highways Agency noted in writing that an unconstrained approach was “necessary to allow any valid information to be produced”. The consultants JMP recorded that the long-term model assumes the uncommitted Western Relief Road, and that a constrained run of the link road in isolation would have generated “no useful flow information”. Strip out the second river crossing and the long-term case for Phase One alone cannot be modelled realistically.
Highways Agency letter, 1 December 2014; JMP Technical Note, March 2015 §1.10
The tools to find it existed, and were pointed the other way
The consultants ran a full rat-run analysis — origin-destination select-link work, quantified relief figures, junction-by-junction rerouting — for the corridors south and east of the scheme. Their own tables identify A49 Greyfriars Bridge as an origin and destination for rat-running traffic. The congestion point that drives the C1098 rat run was represented in the modelling and known to drive the behaviour. The analysis was never extended to ask which other routes that pressure diverts traffic onto.
Briefing Note, 30 September 2015, §§3.1, 4, Tables A–D
The scheme already uses traffic orders on existing roads
The traffic case assumed a weight restriction on the A465 Belmont Road, and planning condition 21 requires it before opening. Without it, fewer vehicles would transfer to the new road. Having used that instrument to engineer the traffic distribution it wanted, the council cannot coherently rule the same instrument out where its own Business Case shows the distribution going wrong. A C1098 order serves the identical objective: traffic onto the road built to carry it.
Transport Assessment §7.3.2; planning condition 21
The council has already accepted the road is unsuitable
Its 2018 review records a road 4–7 metres wide, signed “Unsuitable for HGVs”, with residents “almost to a person” seeking limits. Its refusal of a weight restriction rested on one stated reason: the absence of a suitable alternative route. The bypass is that alternative for strategic movements — and with Phase 2, entirely.
ADL Briefing Note ref 3409, January 2018; AD Report §2, April 2018; Record of Officer Decision, 2 May 2018
The 2018 refusal, and why it no longer holds
In 2018 the council refused a 7.5-tonne restriction on the C1098 for a single stated reason: “to avoid increasing the amount of traffic using unsuitable alternatives”. The only other A438–B4352 link is the C1185 over Bredwardine Bridge — 3.7 metres wide, single track, and not considered suitable for heavy vehicles. That made the C1098, in the council’s words, “the only suitable route for HGVs”.
An environmental weight restriction is imposed on routes unsuitable for HGVs where there is a better and equally convenient alternative. The governing test, as stated in the council’s own 2018 briefing
The first limb is already conceded — the council deems the road unsuitable and signs it so. On the second limb, for through cars, which are the bulk of the forecast induced traffic, the suitable alternative is the A-road network those drivers divert to avoid. A prohibition of through traffic therefore faces no obstacle from the 2018 reasoning at all.
There is also a second loading mechanism nobody assessed. With Belmont Road restricted under condition 21, the C1098 becomes the only unrestricted low-standard link between the A465/B4352 side and the A438 side that avoids Hereford entirely.
The ask
That Herefordshire Council commits, in writing, before the final construction contract award or as a condition of resolving objections to the CPO and Side Roads Order:
- Baseline and monitoring Independent automatic traffic counts on the C1098 before construction begins, and at defined intervals post-opening, with classified counts and speeds, published openly.
- Defined triggers Thresholds for flow, HGV proportion and 85th-percentile speed which, if exceeded, oblige the council to implement a pre-agreed package without further gatekeeping.
- The pre-agreed package A prohibition-of-through-traffic order and/or a 7.5-tonne weight restriction except for access; physical measures at the river crossing approaches as required; and a speed limit reduction as a supporting measure.
- Funding from the scheme budget Mirroring the treatment of Belmont Road.
- Disclosure of the 2025 traffic study The council surveyed the roads again in 2025 for the Full Business Case — the only current figures that exist — and has not published the data. Disclose it, with the model outputs for the C1098.