4.88 The Plan concludes that sensible expansion of towns and villages is the best way of delivering growth needed, whilst protecting the rural character of the District - however, the massive development to the north of Baldock is not a sensible expansion, it is too large and too fast for the district and county councils to manage and will destroy the rural character of that area and Baldock as a whole. Furthermore, the conclusion that expansion of existing towns is the best option is based on a Sustainability Assessment which is flawed in a number of ways. Firstly it assumes that homes delivered by town expansion would be covered by the local housing market which is the Stevenage HMA, however, the massive site north of Baldock is land, being released from Green Belt, that is very close to the train station with a direct fast (34 minutes) link to central London - any part of this development within 20 minutes walk of the station will be affected by London house prices and more over will go to meet London housing need and not to meet North Hertfordshire housing need. This is easily mitigated by maintaining a strip of Green Belt between the new development and Baldock, or by developing this strip only when the rest of the site has been developed. Secondly the Sustainability Review appears to make no regard for how overstretched existing facilities and infrastructure are in the existing towns and whether they can in fact be sustainably increased as part of expansion of the town - in Baldock for example the road layout with narrow roads at pinch points and the position of listed buildings hundred of years old along key roads and junctions, makes it almost impossible for it to accommodate much increase in traffic, but this has not been considered. Finally, it makes no regard for whether several small extensions are as achievable as a single large one - I believe, based on recent experiences at Great Ashby and the Church Gate fiasco that the district and county council may have the ambitions but do not have the capability to deliver single large developments, and that smaller, more evenly spread developments would be more achievable. Furthermore, the plan as it currently stands appears to stifle development of villages of all sizes (by restricting development and trying to cover large new areas with Green Belt needlessly).

Re: Point 4.90 There are several sites that surround Clothall Common on the east of Baldock. Although they are separate sites, they are almost adjacent and are all adjacent to Clothall Common. The total number of homes delivered by these sites is greater than the 500 level set in this plan as the requirement for a strategic plan, and given the dramatic effect these sites will have on Clothall Common and that they are all planned to be developed first and rapidly in order to facilitate the development to the north of Baldock, then these sites should be covered by their own strategic plan. It seems that a lot of the initial conversations about schools and roads have already happened in regard of these sites (from comments made by councillors at information meetings), so creating a strategic plan would not delay implementation, but would ensure that effects and benefits of the sites are considered in combination - for example, do they create a need for more open space, playing fields, sporting facilities, leisure facilities, community facilities, local shops, bus routes, tree planing, etc.
It is clear that a large part of the site (BA1) north of Baldock, within 20 minutes walk of the train station with a direct fast (34 minutes) link to central London, will go to meet London housing need and will leave North Hertfordshire housing need unmet, whilst increasing the load on local facilities and infrastructure and driving up house prices. It is also clear the the district council has failed to make progress on establishing new settlements over the existing period and I see no reason to expect that they will do so over the new period - leading to an even greater housing need at the end of the period of the Plan. The solution is ensure building of new settlements has begun (even if it is only a few homes!) by the end of the period of this plan and that this commitment is included in this plan.
4.100 should have an additional sentence. "This plan commits to the establishment of 2 new settlements, including at least the very first stages of development, that will be able to grow into Garden Villages and then Garden Towns in the future. This is the best way of creating sustainable options for development in the future."
4.101, the first sentence should be changed to The Council is committed to fully exploring settlement options in the District and to establishing at least 2 new such settlements over the period of the Plan.
4.103 is conjecture - it is correct that there are constraints, but whether additional sites can meet future need is unknown, but starting on them will certainly create new options. 4.103 should be changed to "If a new settlement is pursued, it might not meet all future need and there might still remain a need to identify additional sites".
4.109 Self-build is an excellent way to increase the plurality of delivery methods of new development in the plan. I believe that there has been a resurgence in self build across the country (based on perceptions from media reporting and from anecdotal evidence - a close friend is looking at self build as the only way to provide his family with an affordable home). Self build also provides affordable housing and tight knit communities, with varied, interesting and characteristic housing stock. The target for self build should be increased, 1 % is too low.
A another strategic housing site or masterplan requirement should be added, comprising the sites surrounding Clothall Common on the east of Baldock - almost adjacent to each other and dramatically affecting Clothall Common. Together these sites deliver well over the 500 homes minimum that the Plan says will require a housing strategy/masterplan, and are intended to be delivered at the same time and rapidly in order to help facilitate the development of the site to the north of Baldock (BA1 Blackhorse Farm). However, if they are delivered as a set of separate developments, even with the planning that has already been done, there is a risk that matters such as open space, leisure facilities, shopping, transport and infrastructure requirements will be considered separately rather than in aggregate resulting in insufficient facilities and infrastructure being created as a result of the developments. In other words, by developing so many sites, so close to each other, around an existing community, but doing so separately it looks as if the Plan deliberately attempts to separate out the considerations of the requirement for new facilities and infrastructure and deliberately sets out to result in under-supply - or at least to allow this to be possible without contradicting the plan. Since planning for these developments appears to be well under way (since these sites are intended to be developed first and rapidly, and from comments made by district and county councillors at Local Plan information meetings) then the creation of a master plan/strategic proposal for these sites should be possible with little or no impact to the schedule and deliverability of the plan, but with significant improvement on the sustainability of the resulting development of Clothall Common.