The Strategic Housing Sites, particularly Site BA1, have not been properly considered against all reasonable alternatives (or if they have there is no evidence for it) and have therefore not been shown to be a part of the most appropriate strategy. NHDC appears to have been entirely reactive, considering only sites put forward by landowners, instead of proactively considering all feasible sites and approaching landowners where appropriate.

The largest site, BA1, was not in the Housing Options documents of February 2013. It was first proposed (covering an even larger area) in the Housing Additional Location Options document dated July 2013, leaving relatively little time to evaluate it adequately. Baldock is the smallest of the four towns in the District, with a historic centre on a medieval street layout within a conservation area. With the proposed developments on Site BA1 and the other development sites around the town it will have by far the largest number of new homes, increasing the size of the town by a massive 73% with inevitable and severe negative effects. Road traffic is a constant problem because major traffic routes run through the central conservation area and there is very little scope for providing alternative routes. The nature of the town centre precludes enlarging retail and other infrastructure provision within the central area.

If reasonable alternatives had been properly considered there is a strong probability that site BA1 would have been at least significantly reduced in size, thereby reducing the stress on the town. The following examples, which are not necessarily exhaustive, indicate possible alternative sites. By not using the most sustainable locations the plan fails to meet strategic objective ENV1.

Letchworth Garden City Heritage Foundation has - entirely properly - considered the needs of Letchworth and offered a strategic site, LG1, for 900 homes, However, NHDC does not appear to have considered whether, looking at the needs of the District as a whole, it would have been appropriate ask the Heritage Foundation to make more land available.

The Housing Options February 2013 document included a large strategic site south-west of Hitchin, much of which was owned by a developer who also had options agreed with other landowners, sufficient for between 6000 and 7400 homes. It then disappeared from the Local Plan. The reason may be found in the Housing and Green Belt Background Paper, para. 3.14, that former site 209e, Priory Fields, was excluded because 'There was insufficient certainty that a scheme could be realised here without triggering an objection on air quality grounds.' The Local Plan notes similar air quality problems in the Hitchin Street/Whitehorse Street area of Baldock and these will be exacerbated by development on site BA1, but this site was added to the Local Plan regardless of this problem. Full development of the Hitchin Site would be excessive but using part of it could reduce the pressure on Baldock without having such a large effect on Hitchin.

There is land to the west of Stevenage which it is proposed to safeguard for future development for up to 3100 homes, which could be allocated to meet housing needs now without the adverse impacts associated with site BA1, and which has the advantage of being closer to main centres of employment, retail facilities, and public transport.

Also in the Housing Options February 2013 document there were three sites numbered 15, 014 and 012 to the south of Baldock, together estimated to be sufficient for 468 homes. Site 15 'failed one of the tests' for unspecified reasons, and the other two were rated 'priority 3', with no reasons given. These have disappeared from the 2016 Local Plan document. Although it would not reduce the total number of new homes for Baldock, if some or all of these sites were to be included it would allow a reduction in the number of homes on site BA1, which would have specific advantages, especially for transport. Being to the south of the town, these sites have easy access to the one large supermarket serving the town, at the south end of the High Street. They allow direct access to the south via London Road, to Letchworth and the west via London Road and Letchworth Gate, and to the eastern side of Letchworth (including the retail trading estate on Baldock Road) via Weston Way and the A656. All these routes avoid the congested and historic town centre conservation area.

Identify other potential housing sites, both strategic an non-strategic, and systematically evaluate these and existing sites, initially without considering availability, then open discussions with landowners of suitable sites not previously put forward. The objective should be a more proportionate distribution of planned housing among the four towns that would eliminate or at least reduce the size of Site BA1 and reduce the excessive stress on Baldock.