Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2082

Received: 25/11/2016

Respondent: Professor Michael Kirby

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP14 - BA1:
- Not positively prepared
- Not justified
- Not effective
- Not consistent with NPPF
- Healthcare facilities are overstretched
- Highway infrastructure, sustainable/public Transport, increased congestion
- Scale of development
- Natural habitats, wildlife, biodiversity and environments
- Cannot be 'effective use' of land
- Baldock town centre
- Loss of agricultural land
- Infill sites already identified
- Distribution of housing in the district
- Land west of Stevenage
- Drainage and sewage capacity
- Heritage assets
- Delivery of community infrastructure
- Air quality and pollution
- The transport assessment
- Green Space
- Construction traffic
- Flood Risk
- Historic Town

Full text:

I am writing to submit my objection as a resident of the Parish of Bygrave to the proposed draft Local Plan and the designation of Green Belt land to be allocated as housing sites within the parishes of Baldock and Bygrave.
I do not think it has been positively prepared, is justified, or effective and consistent with national policy.
I live in Bygrave and have worked as a doctor in Letchworth for 36 years and also for the same period in the cardiology department at QE2 Hospital. I can vouch for the fact that the current medical services are overstretched and have difficulty filling vacant posts.
I now work at the University of Hertfordshire in the Centre for Research in Primary and Community Care, and travel to continue my medical career in London.
I have seen the quality of life of people who travel down the A1M, and on the trains to London deteriorate due to extreme congestion and overcrowding which will be made much worse by the current housing proposals.
The current strategy does not address the fundamental question of how much development is needed to meet local needs and where these needs are required.
It is simply not fair that Baldock and Bygrave should have 3591 houses from the alleged 12100 required by North Hertfordshire (i.e. 30% of the total allocation)? Thereby, increasing the local population considerably and completely out of proportion.
The Blackhorse Farm site in the plan will be a massive new development, with the need for extensive infrastructure, leading to the destruction of natural habitat and a burden on the existing environment and structures.
This surely, cannot be 'effective use' of land, by re-using land that has been previously developed? The plan contravenes the 'Sustainable Community Strategy' encouraged by the National Planning Policy Framework. The allocated site does not promote and improve the economic, social and environment and will lead to reduced quality of life for all of the current residents and destroy the wildlife.
The plan does nothing to improve Baldock Town centre, which will be destroyed by the building of a new town centre within the planned development with shops and factories? The town centre of Baldock will be grid locked with cars, with no parking and empty of amenities. There is no work locally for all these people who will have to travel on our already overrun roads and railways.
The destruction and reallocation of the Green Belt land contradicts the current Green Belt Policy and the planned reclassification of this area does not mitigate the fact that the plan uses Green Belt land and joins two settlements together. Moreover the destruction of the productive agricultural land will not support 'economic growth' in a rural area nor does it create jobs and prosperity by sustainable development.
The plan does not support sustainable transport. The new road network, major junctions extensions to existing roads and the associated utilities and services required for the Blackhorse site burdens the local area rather than reducing the need for major transport infrastructure.
With careful planning, infill sites already identified would satisfy the requirements whilst also reducing the need for major infrastructure development.
The North Herts housing quota could also be satisfied if there was a fairer proportional allocation applied between the towns of Hitchin, Letchworth and Baldock, together with the site west of Stevenage that is already placed on the reserve list satisfying all the criteria required for development.
Of the RSPB's top ten farmland birds in decline, eight of these have been spotted in our area, namely: grey partridge, skylark, corn bunting, lapwing, yellow wagtail, linnet, yellowhammer and reed bunting. Turtle dove are often in Bygrave and the tree sparrow is making a comeback. All these farmland birds show significant, long term decline - grey partridge down 56% in the last 17 years, skylark down 24% and corn bunting down 39%.
With 3479 houses on Bygrave common, some of the foul water will flow along the Drain ditch to Baldock Sewage pumping station close to Ivel Springs on the right (west), and thence to Letchworth. Likewise the surface water runoff that currently soaks into the green fields, will also flow to the Ivel Springs, into the river Ivel, which will become polluted.
There are almost continuous houses from Hitchin, through Letchworth to the east side of Baldock, with only small green spaces separating them and now Bygrave will be included.
What of impact of Blackhorse Farm site on the Whitehorse Street Junction in Baldock an already problem area? The Railway bridge -causes severe delays already, can it take any more cars/pedestrians?
The town has been described as an hourglass, with the crossroads of A505 and A507 at its centre and the listed buildings at the junction make finding a solution extremely difficult. There are already long tailbacks at this junction during morning and evening peak times and the flow may increase by up to 7000 cars and lorries.
Railway travel at rush-hour is a nightmare, Is there enough capacity for the railway to take a potential doubling of passengers? How will commuters get to the station and where will they park??
Will the railway station itself be developed? Govia are conducting their own consultation about changes to timetabling and new services starting in 2018. Amazingly there had been no communication up until November 2016 between NHDC and Govia about the proposed Local plan or infrastructure
Schools, Doctor surgeries, recreational facilities will all need to be provided and no plans have been provided.
Baldock is located valley, where air pollution can easily develop, there appears to have been little research on this issue. In paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. The Housing and Green Belt Background paper notes that former site 209E (Priory fields in HItchin) was considered unsuitable for a similar reason.
There is section on transport policy SP6 "Sustainable transport". A new link road and some sustainable transport suggestions are made in the SP14 policy for the Blackhorse Farm site. The plan mentions that the site is big enough to support a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road bridge and Whitehorse crossing.
What will be the cost of this and who will pay for it? Railway bridges or tunnels are notoriously expensive.
The transport assessment does not consider north of Baldock, only Baldock with Letchworth in traffic modelling. Local Plan Model Testing 60271338 says in para 2 Baldock and Letchworth have not been tested to date.
A mini roundabout and phased lights planned for A505/507 traffic lights has been suggested.SP14 4.180 says safe access needed to north of Baldock but doesn't say how it will be done.
There is also mention of Southern link road in B3 and B4 but again, no details are provided. SP14 states that a masterplan must be produced prior to any other detailed plans and no detailed plans have been provided.
There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give suitable detailed plans in my opinion.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1site to work.
The mini-roundabout is the only cost included in the plan for Baldock, in-spite of the clear need for major transport projects , such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra traffic away from the Whitehorse Street junction. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives ( Priory Fields) and fails the criteria 4 i.e. it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
There is no mention of providing additional school/doctor services within the current plan for BA2 and BA3.
The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of approximately 900m meaning that the majority of children in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic issues and timing issues for working parents. The proposed housing within these sites will generate another class worth of primary school children with no clear options. It is already significant problem within Baldock without the additional houses.
There is no mention of what % green space will be provided for, no mention of tree planting to improve air quality, nor mention of the provision of parks for children.
All construction traffic for the further development of Clothall Common would need to go through the town to some extent causing air quality, noise and congestion issues which have no obvious remedy.
It is absolutely inequitable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20% and yet Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.
The housing site is on a slope. Baldock town already has issues with flooding when there is heavy rain. Building on this site will reduce or possibly even remove the natural drainage that currently exists, resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings. There is no mention of how the developers plan to resolve the drainage issues caused by building on this site and it is often found in recent years that housing developments rarely provide sufficient drainage given the lack of green space, lack of gardens and high density of housing.
If housing is needed, it would be better to develop a town of the same size away from existing communities in order that the road network and other infrastructure can be developed to be suitable for the needs of the community rather than exacerbating existing infrastructure issues?

A very good example of where this has worked well is Milton Keynes!
I hope my case is well made and I do hope you will pass my comments on to the Planning inspector