4.53 The 'exceptional circumstances' that North Hertfordshire District Council find itself in such that it needs to remove Green Belt protection from large areas of prime arable land, with a significant impact on the local setting and countryside is entirely self manufactured. By refusing to do any planning whatsoever for new settlements in North Hertfordshire it has created a manufactured urgency where the district is left without a Local Plan or a 5 year land use plan and councillors and residents are forced to accept a plan that many consider flawed. This sets a terrible precedent nationally for other district councils to follow whereby difficult decisions about reusing industrial land, creating new settlements or increasing density within larger settlements can be kicked down the road and large areas of easy to develop Green Belt can be rezoned under the 'exceptional circumstance' of local housing need. For this reason alone this rezoning should be objected to and scaled back. However, it is also ambitious and highly risky for a district council with low competency maturity for delivering large developments in partnership with commercial developers (for example the Church Gate development in Hitchin or the chaotic development of Great Ashby) to assume simply rezoning a large area and leaving it to developers will result in an effective plan. Whereas other options such as creating new settlements and/or spreading the development out more evenly with more nuanced changes to the Green Belt seem much less risky, easier for the district and county council to deliver and much more realistic. Furthermore, the Plan assumes that the particular area north of Baldock will result in large amounts of affordable housing, but ignores that its previous Green Belt status has prevented an area very close to a train station with a fast (34 minutes) link to central London from being developed in the past and that releasing it will simply create a pool of extremely high value housing that will not meet local housing need and may in fact drive up house prices in the area - they haven't fully considered what rezoning a large area of green belt means and what the implications of such as action might be - in other words they have not thought it through. But this can be mitigated by scaling down the development, separating it from Baldock and the train station (and preferably from Bygrave also), and then looking to make up the short fall in other areas of the district (perhaps by looking at areas considered in previous iterations of this plan) and by a commitment to establish (zone and build the first homes of) 2 new settlements in the district within the plan period (not in the next plan period, when the district council planners can once again kick the can down the road and manufacture the urgency requiring yet more large scale growth around one of the existing towns).

4.55 the assertion that Green Belt releases can be offset by additional Green Belt elsewhere is frankly ridiculous. What is more there is absolutely no need to cover the whole of the south of the district with Green Belt, stifling growth of villages and cutting off options for new settlements in the area - the existing Green Belt zones are sufficient - they have done their job until now and there is no evidence that they need to be strengthened. Encroachment from London, Stevenage and Luton as been sufficiently curtailed by the existing zones and they should be left largely unchanged.

The blanketing of the southern half of North Hertfordshire in Green Belt is unnecessary and counter productive. Where Green Belt has been released for development there are a number of additional policies which should be put in place to enhance the rural character of these communities and to encourage participation with the countryside.

Finally, it is important that there is sufficient tree planting in the development of newly release Green Belt, which will start as bare farmland.

This Local Plan includes a mass redrawing of the Green Belt in North Hertfordshire (although separated out into a separate document). The vast majority of North Hertfordshire (outside of its main towns) is undeveloped and facing challenges in terms of high property prices and under occupation. This plan covers these areas with Green Belt and creates additional developmental barriers whilst removing Green Belt protection from very large areas of highly productive and attractive land around the existing towns - particularly to the north of Letchworth and most notably all around Baldock. (It should be noted that District Council has recently been refusing development plans in villages on the grounds of impact to the country side, e.g. at Whitwell, whilst encouraging destruction of countryside around towns in this plan - this demonstrates the need for the to the plan to clearly and actively encourage rather than discourage development of the villages and hamlets of North Hertfordshire, otherwise the trend to underdevelopment, high cost of living and under-occupancy in these areas will continue.) I object strongly to the blanketing of all the the southern half of North Hertfordshire in Green Belt - the existing Green Belt zones provide sufficient protection against encroachment from Stevenage, Luton and London. It will also unnecessarily exclude (or make it more difficult to consider) these sites as possible sites for a new Garden Village - it could be seen as a cynical attempt to entrench a bias toward over development of existing towns and continued underdevelopment of other areas of the district.
Furthermore, the Green Belt review has removed Green Belt protection for very large areas around Baldock (and surrounding towns such as Ashwell) and north of Letchworth. 13.16 states the town boundary as being that shown on the proposal maps, but this is the boundary after the Green Belt review, which I understand forms part of this Local Plan. The sites BA1 and BA3 were previously greenbelt and this status has clearly been removed in order to facilitate development. It would be of considerable benefit to the areas adjacent to the sites (both developed and non-developed/farming) if their recent greenbelt status was recognised in the plan and additional policies put in place. It represents a significant unbanisation of these adjacent areas, particularly Clothall Common, which is currently bounded on 3 sides with open farmland, but instead will become bounded on 3 sides with urban areas - without mitigation this would reduce access to the countryside, deteriorate surroundings and have a negative impact on health and well being (for example, through diminished countryside access/activities, like jogging, walking, cycle riding, dog walking, etc.) - in short, without specific policies it would make these developments unsustainable. A review of Green Belt around these areas, particularly in light of housing need in the district is to be expected - that such huge areas of protection should be removed against the wishes of the residents of North Hertfordshire as expressed in such large numbers in the responses to the Preferred Options Plan, is astonishing. However, given the housing need (and lack of other options explored by the district council creating a 'manufactured urgency') I accept that these areas will need some development - it is vital that the Local Plan accepts the recent Green Belt status of these areas and identifies them for additional policies and protections. It is entirely possible to maintain the rural feel of these recently Green Belt areas, to encourage interaction and participation with the countryside, and to limit the impact of development in these areas to the countryside, and to do so without affecting the deliverability of development at these sites, or indeed by altering the actual number of homes delivered at these sites very much. For example, 'green lanes' or strips of actual green belt could be inserted between existing boundaries and the newly released areas of development; Also housing density could be limited in these zones and additional planning requirements in terms of 'rural' character of development and consistency with local historical architectural styles could be applied to these zones; Additional requirements for open areas, playing fields and recreational spaces could be placed on these zones; And to ensure continued access and participation with the countryside, green lanes linking existing countryside access points to the new access points at the new boundary could be required, as well as requiring a review of all permanent farm tracks in the adjacent countryside with the aim of upgrading them to footpaths and bridal paths to encourage greater participation in the countryside (to be carried out before development commences to ensure it is not simply ignored by the planning and development process, assuming it would be swift and cheap to complete - a 'quick win') - this would mean that development of these areas actually enhances the rural character of the developed areas and ensures the sustainability of these sites.
Finally, from reading the document, I don't think the policies are specific enough about the need for tree planting in the newly released areas of Green Belt - arable farm land will be starting very bare and for developments (particularly around Baldock and especially around Clothall Common) to be consistent with the character of existing developments and the local townscape, significant tree planting will be required. These policies need to be strengthened, and the sites themselves should give mention of this requirement.