4.62 the Sustainability Appraisal in fact lists many negative effects of releasing Green Belt. However, in comparing two options - development around existing towns or development of new Settlements - the Sustainability Appraisal makes three flawed assumptions which have had a drastic impact on the plan.
Firstly, it assumes that development of land north of Baldock will help to meet local housing need, however, it takes no account of the fact that the land is right next to the train station which has a direct fast (34 minutes) link to central London - the impact of this is that a large strip of this development (the area within 20 minutes walk of the station) will go toward London housing need and so will be strongly affected by house prices in the London Housing Market and will leave local housing need unmet and it may well act to drive up local house prices. The reason, I think, that this has been ignored is because it has been assumed that the Stevenage Housing Market will apply to this development - but that assumption is based on normal organic growth, where existing high value locations (for example close to fast connections to London) have previously been developed - however this is not the case for this site because this land was previously protected by the Green Belt allocation. The Sustainability Appraisal has failed to consider properly the impact of releasing so much previously Green Belt land so close to the train station. As mentioned elsewhere, this omission can be mitigated by separating the new development from Baldock so that very little of it is less than 20 minutes walk of the station, or by developing this strip only when the rest of the site has been developed.
Secondly, the Sustainability Review assumes that existing facilities of existing towns can be efficiently leveraged by building onto those town, but takes no account of the fact that (in Baldock at least) existing facilities and resources are severely overstretched. For example, schools are very over subscribed, the GP surgery is a capacity, open space and leisure facilities are far below national averages and target values (from tables within Sustainability Appraisal documents themsleves) - so extending existing towns is actually starting from a deficit of local facilities and resources. However, it is clear the development creates opportunities to address this deficit and it is vital that the plan takes positive action to do so. It must recognise the poor starting point and deliberately set out to improve the overall situation as a result of any large scale development (for example the large site north of Baldock, or the cluster of sites surround Clothall Common, to the east of Baldock).
Thirdly, it assumes that the District Council and County Council have the competency maturity to develop large sites quickly. Recent experiences, (for example, Great Ashby or the Church Gate development in Hitchin) point to this not being the case, and the largest sites should be scaled back and development distributed more evenly around the district.
I also feel strongly that establishing (starting) 2 new garden villages by the end of the plan, will help create new options and facilitate an effective and achievable increase in the amount of housing and employment in the district - it will also set up options for continued sustainable development in the following planning period (rather than creating another cliff edge, like-it-or-lump situation of manufactured urgency).

Sustainability Appraisal does not consider the release of so much Green Belt close to Baldock train station (with a fast link to London) as exceptional and instead assumes Stevenage HMA house prices will apply - it will in fact encourage migration from London and there needs to be a mitigation against this. It also assumes the district and county councils can deliver large developments quickly, against recent experience. Without these flawed assumptions the option of new settlements would have risen above the option of extending existing towns, or a least a blend of both approaches.

With regard to point 4.62 there are flaw in the Sustainability Appraisal.
The sustainability assessment is comprised of multiple documents concatenated together. I have only had time to skim this document. I do not have a planning background and I apologise if my comments misuse jargon or repeat things.
> Page 89 approx., points out that BA1, BA10, BA4, BA3 and BA2 all lie in open countryside on the northern and eastern edge of Baldock. 2(b) points to a requirement to provide access to green spaces and Maintain existing rights of way. It is highlighted that the distance to open countryside from existing housing will be increased.
Policies mentioned in these documents don't seem to match up with the latest version of this plan - perhaps they relate to earlier versions? It states policy D1 will ensure through-routes are incorporated in new development, but that must be a different policy. The location of these sites to the north and east of Baldock and of all the major sites of employment and entertainment is a major flaw with these sites that hasn't been considered properly.
> Page 90 approx., states that Baldock BA1, BA10, BA4, BA3 and BA2 all lie in areas of high or moderate sensitivity. 3(b) states there will be residual landscape impact.
In seeking to develop up to 'defensible' boundaries, it is important to respect the impact on the landscape.
> Page 96 approx., reduced access to open countryside, potential negative effects on human health - highlights Baldock, Royston and Great Ashby.
Steps must be incorporated into the plan to increase access to open countryside and not simply accept this as a negative consequence of development at these sites!
> Page 103 approx., Table 35: Residual significant sustainability effects of the Plan. States reduced access to the countryside. Sites this as being of high probability.
Again, vital to take steps against this, or indeed to reverse this.
> Page 104 approx., Reduction in quality of landscape and townscape character. For Baldock (and other sites) this is sited as of high probability, permanent and irreversible.
It is vital that the character of the landscape and townscape is respected as much as possible - I believe, separating the development to the north of Baldock, from Baldock will help to preserve the townscape character and will also preserve the character of the countryside around that location (rather than converting Baldock from a small town to a large town with the consequent impact).
> Targets for England: hectares per 1000 people, playing fields 1.2, all outdoor sports 1.6, equipped/designated play areas 0.25, other outdoor provision 0.3. Targets for East of England: children's playspace 0.7, outdoor sporting space 1.7, amenity space 0.8 (from Planning Obligations Strategy 2009). Actual for Baldock: outdoor sports facilities 0.41.
This is far below the target values, far below the average for the district and only Royston is lower on the table (which has been the recipient of a lot of recent development and is not a good precedent of the likely effect of development at Baldock). It is vital that development north and east of Baldock results in new open playing fields as well as new sporting facilities (for example tennis courts or new leisure facilities, perhaps tied to a new school). For the north of Baldock site it is possible to imagine that this will be ensured by the strategic plan covering that site, however, the cluster of developments surrounding Clothall Common on the east of Baldock is not covered by a strategic plan - it should be so as to ensure proper consideration of factors like additional facilities (among many other concerns of adding so much housing at one location - even though it is in 4 sites, they are very close to each other around a single part of Baldock).
> It seems from a skim of this Sustainability Assessment that it takes loss of Green Belt into account when considering the impact of a new settlement, but then does not take it into account (certainly gives it a lower consideration) when considering the impact of a large development attached to an existing town.
This is a serious flaw in the analysis - it needs to be acknowledged and remedied as best as possible.
> The Sustainability Assessment appears to assume that house prices will go down with a large development on the edge of an existing town.
However, releasing land for development so close to Baldock train station (with a 34 minute direct link to London) may drive house prices up. This is a significant flaw in the assessment.
> (item 1 and item 5(d) of option (a) continue development of 4 main towns including development of greenbelt). Option C, item 1 and item 5(d) of option (c)
Appear to suffer the same flawed assumption that building large numbers of housing must necessarily improve affordability, without taking into account the possibility of London commuters taking advantage of newly released land close to the train station and so actually driving house prices up and reducing affordability. It is vital mitigations are put in place - for example, leaving a strip of Green Belt near the train station, or ensuring this land can only be developed when the rest of the site (and other site around Baldock) are been developed. This assumption though is correct in the case of Item 1 and item 5(d) for a new settlement, as the only sites available for new settlements will not provide attractive settlement locations for people wishing to commute to London. This option will make housing more affordable across North Hertfordshire. There is no reason that some progress on this option could not be made over the period of the plan. The expectation that sites will be identified and development will commence during the period of the plan should be included in this plan. If progress is made on this option, other aspects of the plan can be reviewed accordingly. In fact, a long list of possible sites could be included in this plan to show good faith toward pursuing this option over the period of the plan. To kick the can down the road until the next plan is to accept unaffordable housing and non-sustainable development, with the hope that new settlements might be included in the next plan - this is why I feel it is vital that this aspect is included in this plan, so we can see progress against it over the period of this plan. Such sites cannot be counted against forecasts of housing to be delivered by this plan, as such sites might not be deliverable during the time-frame of the plan, however, it is vital that progress is made against this option, and it is also possible the development could (in fact should) commence, in part, on new settlements during the period of this plan and this must not be deliberately excluded by this plan.
> page 533 approx., 5(b) of section 2.2 Baldock site BA1, fails to take into account the proximity of the train station in relation to affordability of housing.
> page 535 approx., 2(b) of section 2.2 Baldock site BA3,
I agree that the site provides the potential for new sporting or recreational spaces and at this position in relation to Baldock and the few other areas, this would likely have a big impact on health and well being of residents in Clothall Common, this new site, and this side of Baldock.
> Page 530 approx., Site BA1 mitigation tables
the proximity to the train station with a direct fast link to the centre of London is an important feature of this site and mitigation should be put in place to ensure new housing doesn't simply contribute toward inward migration of people currently living in London and who will continue to work in London (a long and environmentally friendly journey). For example that the land nearest the train station be given a special status, be developed last of other such mitigation.
> Section 1 - HMA housing market areas,
fails to take any account of 'commuter belt' - areas that receive an uplift due to an easy commute into London and the higher salaries that can be obtained there. This is because it assumes organic growth, where locations close to good transport links into London tend to already be occupied and growth will be via in-fill (as has occurred in the centre of Baldock). However, the massive site to the north of Baldock (BA1, Blackhorse farm) is exceptional as it lies very close to the train station and has been left undeveloped due to it's prior greenbelt status which has been removed as part of the review which forms part of this plan. The plan makes no accommodation for the exceptional nature of this site, situated so close to a train station with a fast (34 minutes) link directly into central London (London Kings Cross). It assumes that the normal HMA will apply to these houses, whereas, the strip of this development within a 20 minute walk will not fall into the normal rules of the Stevenage HMA but will instead be influenced by a significant uplift due to inward migration of people currently living in London (who are influenced by a very different and much more expensive HMA in London) and who will continue to work in London, leading to a large uplift on these houses. This seems obvious, so it is extra ordinary that this has not been considered as part of the plan. It is vital that this is considered. Easy mitigations, such as leaving the area closest to the train station undeveloped, or developing this strip last will greatly affect how effective this plan is at meeting local housing need in a deliverable and sustainable manner.