Baldock

See attached

We are writing to express our views about the Proposed Submission North Hertfordshire Local Plan 2011-2031.
Baldock is a rural, historic market town, the smallest town in the region, with more listed buildings than any others in the district. It has around 5,000 dwellings. If we get the proposed 3,590 more dwellings that would equate to a massive 80% increase. We feel this is a disproportionate increase that will adversely affect the nature and character of Baldock (see Green Belt section below). Also large settlements on the edge of the town with their facilities and local shops will compete with the existing shops and fragment the town; the heart of Baldock will be lost.
We should be thinking regionally and working co-operatively with others and with our neighbours. Houses do not make a community and a huge settlement of 2,800 as that planned for Blackhorse Farm is not viable. We need to find a suitable site for a new garden city. Baldock should be grown and expanded organically, not exponentially.
We have focussed our objections below on BA1, the Blackhorse Farm development, but many of these should be applied to Baldock in general.
Green Belt
The plots of land around the proposed Blackhorse Farm development (BA1) are all green belt. The NPPF government guidance states that green belt boundaries should only be altered in exceptional circumstances (para 82). There are none in this case. Green spaces around towns are crucial. The North Hertfordshire Green Belt Review states that these particular sites make a 'significant contribution' to the Green Belt purposes. It is short-sighted to simply move them to another area in the region. It is an essential part of the quality and character of the area and a fundamental part of the town's design. It should be protected. It enhances the high quality of life that people in the area currently enjoy.
The Blackhorse Farm site is an area of rolling countryside. A development this size would have significant adverse visible impact on the landscape. Once it has been built on, it is gone for ever. The NPPF states that the essential character of Green Belts are their openness and their permanence. They 'preserve the setting and special character of historic towns'. The development would also have a negative impact on the Ivel Springs local reserve and wildlife site. The sites around Bygrave Road are teeming with birdlife. Since 2012, there has been a large flock of resident starlings as well as house sparrows, finches, linnets, tits, pheasants and sparrowhawks.
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered.
Road network
There are considerable existing congestion issues both locally in Baldock town and also on A1M. The current bypass was built and still there are continuing traffic problems with static traffic jams during peak travel times. With the new roads proposed to take traffic onto the Royston Road there will still be many commuters needing to travel through Baldock. The increase in the weight of traffic will cause further gridlock and put terrific strain on the road network. We already have a dangerous bottle neck under the narrow railway bridge in North Road where two people are unable to pass each other on the pathway and there are road safety concerns at the exit from Bygrave Road onto North Road.
Lorries are still adding to congestion problems by using North Road to access the A505 rather than using the bypass. How many times have lorries struck the railway bridge, despite the 'low bridge' warning? Many times, we have seen lorries inch through and only just clear the bridge. All of this delays traffic, especially if there is a bridge strike.
(In addition, the current weight limit of 7.5t in Bygrave Road would be insufficient for heavy plant vehicles used during construction).
The proposed new development on Blackhorse Farm relies on a new road bridge being built over the railway. We understand that Network Rail have no knowledge of this proposal; an assumption has been made where it is not clear if this is would be possible.
The A1M between junction 6 and 10 is unable to cope with the current capacity travelling during rush hour and changes are being put in place to try to alleviate this problem. But many houses are being built in Royston and more are proposed in the North Herts Local Plan which will all impact on the A1M corridor. It has no capacity to take more traffic.
The NPPF para 32 states that all developments that generate significant amounts of movement should be supported by a transport statement'. The proposed North Herts Local Plan refers to 'travel plans' on page 89 and 'measures to include' on page 61 but there are no details.
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 BA1 site to work.
Transport
The Plan makes no significant points other than the convenience of Baldock's location next to a station. The current train arrangements would not be able to cope with the proposed influx of new commuters not just at Baldock, but also from all along the Royston/Stevenage corridor. We understand that longer trains are proposed for the route, but the platform at Baldock will need to be extended. Where would these new commuters park? There is currently limited parking at the station. This would have an impact on local streets and cause displaced parking. Bringing in parking restrictions is not the solution. The town centre is already struggling due to parking restrictions. Where can the town centre workers park? Station facilities would also need to be improved as currently there are no provisions for those with disabilities or those with pushchairs, buggies etc.
The NPPF para 31 says local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure. NHDC did not consult with Govia the current train provider, during the preparation of the Local Plan. Govia are themselves conducting a consultation about train services from 2018 onwards and were planning to reduce the peak service trains and are still intending to reduce the off-peak service.
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 BA1 site to work.
Employment
It will be impossible to create jobs locally for all the new residents in the town. There aren't enough jobs locally currently. There are plans for some industrial space, but the majority of residents will need to commute out of the area. Residents should be able to live sustainably near their place of work, not have to travel great distances. The NPPF para 34 states that 'plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised'. Policy SP3 in the Local Plan describes the additional employment provision of 19.6ha of land East of Baldock. It also states that the Council will 'promote and support the expansion of the knowledge based economy in the District. Para 4.23 states that 'many higher skilled residents commute out of the District for employment.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It also fails the criteria 4 ie it is not consistent with national policy as West of Stevenage has not been properly considered.
The NPPF para 28 says that planning policies should support economic growth in rural areas. It should 'promote a strong rural economy' and plans should 'provide the development and diversification of agricultural and other land-based rural businesses.' The proposed site at Blackhorse Farm means building on Grade 2 and 3 active and productive agricultural land. These rural agricultural businesses underpin the rural economy and the character of the landscape. We are encouraged to buy local and buy British, and to encourage UK self-sufficiency. It a strong message that will be undermined by destroying local agricultural land. The proposals will destroy the County Council small holdings on the fringe of Baldock, and will shatter the lives of those who work these areas. They are not just a dot on a map to be erased, they are someone's livelihood and home and it would also be an agricultural loss to the area. Once it has been eroded and developed, it cannot be reclaimed.
Air pollution
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 the same reason. Para 124 in the NPPF states that 'Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (ref Priory Fields) and fails the criteria 4 ie it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
Local facilities
Within the proposals there are plans for new schools and health facilities, but these will only be triggered by actual population numbers. So what happens in the meantime to all the new residents while they wait for numbers to reach a threshold? Local services would be unable to cope. We currently have no capacity in our schools and the doctors, hospital and police are all severely stretched. SP14 states that a masterplan must be produced prior to any other detailed matters. No detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give detailed plans. Para 177 in the NPPF states that 'it is equally important that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.'
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.
Amenities
We live in one of the most water-stressed areas of the country. The proposed site at Blackhorse Farm would have a huge impact on the local environment. Where would their water be sourced from and where would their sewage be treated? There are already capacity problems at the local sewage works and aquifier. In addition, the area has a known problem of frequent surface water flooding. The NPPF states that Local Plans should take account of flooding risk. This does not appear to be evident in the North Hertfordshire Local Plan.

In the Minister's foreword in the NPPF, he refers to 'sustainable development', 'change for the better', 'positive growth' and 'enhancing and improving where we live'. We need a Local Plan; we need housing for local people. We accept that Baldock will need to grow but the proposed numbers of dwellings are unacceptable. Baldock cannot take this kind of overdevelopment. Residents choose to live in this market town because of its rural character and the way of life it offers. We should protect and preserve its identity.
The proposals in the Proposed Submission Local Plan will irreversibly alter the character of the town, double its population, cause immense traffic flow problems on a heavily-congested road network, further parking problems and add infrastructure problems to our over-subscribed schools and limited healthcare facilities.
In respect of Baldock, The North Hertfordshire Local Plan is not sustainable. Exhaust all the brownfield sites in the area. Be innovative and creative and focus all efforts on a new garden city for the region.

I would like to raise that I am very concerned about the local plan. It seems very disconnected to what is happening to local facilities and transport locally:
The A1m traffic from junction 9-6 is the worst it has been and adding more homes to Baldock, Letchworth and Hitchin will drive more cars to use it.
The trains service in Baldock is going through consultation to reduce services at the same time as a consultation to add housing! This does not feel joined up.

Schools and doctors are under pressure in Baldock currently. This needs significant consideration.

Please find enclosed my response to the NHDC 2016 Local plan.
My objections are mainly based around the proposals for Baldock, in particular the land to the North of Baldock, BA1 - referred to as Blackhorse Farm, but which is in fact known on the Ordnance Survey maps as Bygrave Common.


I believe the Local Plan is Unsound, and Not Justified because of the following:


1. Traffic, noise and pollution during the BA1 houses construction period
Site - BA1; Policy - SP14; Paragraph -

During the extended period to build 2,800 houses to the north of Baldock, this will cause the traffic along North Road to increase, and the current traffic to be disturbed by the additional construction traffic.
It may even affect the Police forces who I understand occasionally use the North Road into Baldock for high-speed pursuit training.
The building of the houses will cause noise, traffic and air pollution problems for local residents.


2. Traffic through and around Baldock - increased volume and noise
Site - BA1; Policy - SP14; Paragraph -

With the building of 2,800 houses to the north of Baldock (BA1) there will be at least one car per household which may choose to gain access to Baldock for shopping, and to local towns for commuting to work.
At the moment all of this traffic will try to pass south under the Baldock railway bridge, causing even more congestion down London Road, into Station Road up to the traffic lights on the corner of White Horse Street.
If as suggested there may be a northern loop road built from London Road to the Royston Road / Bypass roundabout, the traffic for Baldock will turn west along the Royston Road to the Whitehorse traffic lights. The resulting queuing at the traffic lights will add to the traffic congestion and air pollution.


3. Traffic through and around Baldock - increased Air Pollution
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Good Air Quality is critical to the public health. Concern has already been raised within NHDC about the poor air quality near the Paynes Park and Three Moorhens roundabouts in Hitchin.
With a greatly increased flow of traffic into Baldock passing through (and waiting at) the Whitehorse traffic lights, this will have an adverse effect on the air quality for the local residents, including residents of the retirement homes close to the traffic lights. Poor health in the local residents will result in more visits to the local Baldock Surgery, and to Lister Hospital for serious cases. Poor Air Quality in Baldock was part of the justification for the current Baldock Bypass. Poor Air Quality has not been included in the Local Plan.


4. Baldock Railway Bridge footpaths- inadequate for more pedestrians from the new houses
Site - BA1; Policy - SP14; Paragraph -

The footpaths under the Baldock Railway Bridge are narrow, especially on the east side of London Road, where it is just about wide enough for a mother and push chair. If she has a toddler, then it can be dangerous, especially if none rush hour traffic is speeding under the railway bridge inches away from the pedestrians. Pedestrians from 2,800 houses to the north of Baldock will only exacerbate this problem.
Baldock Railway Bridge is low (4.4m / 12ft 6in) and lorries hit the bridge several times per year. This can cause disruption to London Road traffic for a few hours, and can even affect pedestrians if the bridge strike is serious. I do not believe this problem has been highlighted in the Local plan.


5. Baldock Railway Station - inadequate for more commuters from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

There is a probability that many of the new residents in the houses to the north of Baldock (and elsewhere in Baldock) will have bought their houses to be near to the Baldock Railway station, where they can commute to their place of work, be it London, Cambridge, or stations in between. If these commuters choose to drive to the station, they will be delayed by the additional traffic. The current provision for car parking at the rail station is limited, and will not cater for the increase in commuter's cars.
Likewise only the 4 and 8 carriage trains can stop at Baldock Station, due to the short length of the Platforms. The rush hour trains are already full to standing capacity. Either more trains will be needed, or the platforms would need extending (by the Rail operator) to take the new 12 carriage trains.


6. Baldock Town Centre Parking - inadequate for more shoppers from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Since the re-development of Baldock Town Centre parking, the parking spaces are just adequate for the current population of 4,500 houses. With an additional 3,300 houses in Baldock, the car parking spaces in Baldock will be woefully inadequate, and shoppers will drive elsewhere to park and shop.
For the 2,800 houses to the North of Baldock, it will be just as easy to drive up the A1 to the shops in Biggleswade, Bedfordshire. Their alternatives could include driving to Letchworth, Hitchin and Stevenage, where parking is currently just about adequate. Wherever the shopper's cars go, they will cause an increase in local traffic volumes, noise and Air Pollution, giving poor Air Quality for the local residents.


7. Sewage system in Baldock will need enhancing for the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

At the moment all the sewage from the 4,500 Baldock houses flows to the Ivel Springs Sewage Pumping Station, where it is pumped up to Norton, along a pipe which passes under the Baldock Football ground, and over the Norton Road Bridge, passing over the A1M road. From Norton the Baldock sewage flows by gravity down to the Stand Alone sewage works in Letchworth. During a conversation with an engineer at the Baldock pumping station, he believed the current pumps and pipe are close to capacity, and would have to be doubled in size, to cater for the additional 3,300 houses in Baldock. This required increase to the sewage Infrastructure has not been mentioned in the Local Plan.


8. Surface water run off and flooding in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With 174 hectares of prime agricultural land being covered over by houses, roads and driveways, the rain water will not be able to soak into the land, as at present where it adds to the underground water table.
All of this run-off ground water will either pass into the already overloaded sewer system, or flow into the adjacent River Ivel, where it would disrupt the fragile eco system. I believe this water run-off problem has not been considered in the Local Plan, as has the effect on the River Ivel eco system.


9. Provision of Water to the additional houses in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

The local water authority are already trying to move all of Baldock's residents to a metered water supply, due to the lack of water available from the local Aquifer under Weston Hills. A presentation was made by the water authority to the local Baldock councillors saying they were unable to pump water down from the Grantham reservoir, because Aquifer water and reservoir water should not be mixed (due to differing salts and acidity), and that it can cause problems to the water network if it was mixed. The additional 3,300 houses in Baldock (and more houses in other North Herts areas) will only make the water shortage more critical. I believe this water shortage has not been considered in the Local Plan.


10. Lack of spaces for additional pupils in Baldock Schools
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain families whose children are of school age, and will need to travel to a school each weekday, probably by car. At the moment the headmasters of local Baldock schools say they do not have the space for these additional pupils, and the schools will need to be increased in size to take the additional pupils. An alternative would be for the pupils to attend schools in other areas, travelling by road, causing further traffic problems.
I believe the needs of children from the additional 3300 houses in Baldock, have not been fully addressed in the Local Plan.


11. Increased pressure on the Baldock Doctors Surgery
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain young families. It is probable that the parents would normally be initially quite healthy and would not require a doctor. Where there are children, the parents may need to consult a doctor regarding injections, breakages, child illnesses, etc. The Local Plan does not take this need into account.


12. Loss of Green space in and around Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

As part of the Green Space Management Strategy, NHDC have identified green spaces in the following North Herts towns for improvement / revision - Hitchin (12), Letchworth (12), Royston (9), Great Ashby (9). Baldock currently has only 5 green spaces for the current local residents. This is inadequate for the health and fitness of the current residents in 4,500 houses. No mention has been made for the provision of additional green spaces for the new residents in the proposed 3,300 new houses in Baldock (which are to be built on Green Belt land). It would be useful if the new houses were separated from the existing houses by green spaces. This lack of green space in Baldock has not been addressed in the NHDC Local Plan.


13. Not all available land around Baldock has been included in the revised Local Plan.
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Additional HCC (Herts County Council) land had been previously identified as being available to the South of Baldock (to the south of the Bypass, near the old airfield, off the A507 Buntingford Road), but this has not been considered by the NHDC planners, and has not been included in the latest NHDC Local Plan.
Likewise, some of the farmers in the Bygrave area have additional land, which could be made available for housing. I believe the owners of this additional land should have been proactively approached re the inclusion of this additional land in the revised North Herts Local Plan.


14. Duty to Co-operate / not Positively Prepared
The North Herts Local Plan is taking into account the needs of Luton.
I believe South Cambridgeshire should likewise take into account the needs of North Herts, by considering the land in the Odsey area around Ashwell Railway Station for additional houses for North Herts.
This area has excellent links to the road (A505 Royston to the A1M), and rail (Cambridge to London Kings Cross) Networks.
The land to the south of the A505 is HCC (Herts County Council) land and could form part of this new development. It is on a slight slope, but houses in many parts of England are on much steeper ground.
A bridge over the A505 would give easy access to the Ashwell Rail Station (which has land available to be extended to take the 12 carriage trains, unlike Baldock Station).

I wish to object to the Local Plan as I consider it unjustified, ill thoughtout and not consistent with National Policy, in particular with reference to sites BA1, BA2 and BA3 around Baldock.
North Hertfordshire and Baldock, in particular, will be ruined if this goes ahead.
The plan currently under consultation is fatally floored before it is started and I fail to comprehend why it has even got this far. I feel let-down by North Herts District Council as I don't believe they have kept to the Select Committee's conclusion that councils need to get plans in to protect areas that should not be built on. And that includes Green Belt. It is my understanding that Countryside and Green Belt should not be taken away until ALL other possible land has been considered exhaustively. This has not been done for Baldock, because sadly, much of the land contained in the plan is owned by Hertfordshire County Council. With government cuts to councils, I should think they are rubbing their hands in glee at the thought of such an easy cash-cow as Baldock apparently is.
As a whole area, the number of houses being discussed for North Hertfordshire is still huge and I think well over what it needs to be. I agree with Oliver Heald who has previously said that a whole new garden city-based town would be much more feasible for the area. It would save Green Belt and valuable agricultural land. The infra-structure would be in place from the start of the development - rather than trying to make current infra-structure 'fit' all the extra homes, people and traffic.
Roads and Rail
This is key to the development plans for Baldock in particular. You cannot avoid bringing in unacceptable levels of traffic to an already over-used sticking point - I'm thinking of the traffic lights and railway station areas in particular here. Also, consideration has to be given to the logistics of bringing the traffic to the new development areas of Baldock. Moving the railway line will presumably not be an option. The Buntingford road should also be considered. It too will not be fit for extra traffic and is not suitable for the amount of lorries and cars already using it.
More generally, the North Hertfordshire section of the A1 cannot cope with current traffic levels and is regularly gridlocked at both peak and off-peak times. s I understand it, the bridge sections cannot be widened. How is it ever going to take yet more commuters?
Having said that, assuming that somebody's 'grand plan' for this area can rectify that situation, I understand that there is an area to the West of Stevenage that could take a new town to accommodate all of the housing planned for North Hertfordshire. Why can that particular area not be triggered? Would it be triggered if Stevenage made it part of their plan? If it were, I believe that it could then become viable for the rest of the North Hertfordshire allocation. I feel the current plan is 'make do and mend' rather collaborating with other councils to ensure the best plan for the whole of the local area. Hertfordshire Infrastructure Investment Strategy (HIIS) should look at the bigger picture for the whole area.
The plan makes no significant points other than the convenience of Baldock's location next to a station. NHDC had not even consulted with Govia the train provider during the course of the preparation of this inadequate local plan and indeed, Govia are currently planning to reduce the service to Baldock station. Is there enough capacity for the railway to take a doubling of passengers? How will commuters access the station? Where will they park?
The NPPF - Section 4 Promoting sustainable transport. 'All developments that generate significant amounts of movement should be supported by a Transport Statement..." It goes on to state that "development decisions should take account of whether improvements can be undertaken with the transport network that cost effectively limit significant impacts of development.
The Plan is simply not effective as it cannot be delivered in the plan period. It fails the consistency with the national policy test as it does not properly assess the transport improvements that would be needed for the site/s to work.
Infrastructure
Traffic and travel is just one issue, there is also the strain and chaos expected for doctors, schools and The Lister Hospital to be considered - until trigger points in the master plan are reached and somebody then does a make-do-and-mend job on local services. It is not good enough and it is not what the area deserves.
No detailed plans have been given. There is an infrastructure development plan included in the evidence bas (not added until September 2016) but it does not give detailed plans.
The NPPF - Paragraph 177 states it is equally important that planned infrastructure is deliverable in a timely fashion. Local planning authorities must understand district-wide development costs at the time the Local Plans are drawn up.
Once again this is not consistent with national policy. The plan has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.
Green Belt
Is it truly right and fair to remove the Green Belt from around Baldock? Much of which is prime agricultural land. Have brownfield sites been exhausted first?
Baldock is a quaint, rural, and historic market town. There are views that will be lost forever if sites BA1, BA2 and BA3 in particular are moved ahead. Grade 1 agricultural land should not be considered as part of this plan. It is a criminal waste of resources that England cannot afford to keep losing.
I sincerely hope that sense can be seen here and the current plan in question for Baldock and North Hertfordshire will be seen for what it is.Too big and disproportionate. In October 2014, Communities Secretary Eric Pickles and Housing and Planning Minister Brandon Lewis said that "thousands of brownfield sites are available for development and should be prioritised. "The new guidance reaffirms how councils should safeguard their local area against urban sprawl and protect the green lungs around towns and cities. Green Belt boundaries should only be altered in exceptional cases. The housing need does NOT justify the harm done to the green belt by inappropriate development.
Source: https://www.gov.uk/government/news/councils-must-protect-our-precious-green-belt-land
The NPPF acknowledges that the Green Belt is to protect areas from urban sprawl and towns merging. This has already failed once for Baldock/Letchworth. Please do not exacerbate the problem by allowing the Green Belt 'to be moved' for convenience.
In a separate document that covers the reassessment of the Green Belt, para 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements "in the first five years following adoption of the plan." This is then contradicted in the Plan itself as the site will only be developed after small sites across the town. Policy SP8 makes provision for land in Stevenage West to be safeguarded for future needs outside of the Local Plan allocation, for up to 3,100 homes, to be used after 2026.
This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It may also fail the criteria 4 - ie. is not consistent with national policy with regard to the Green Belt.
Air Pollution
Baldock is located in a bowl, where pollution can nest. I don't believe there has been an assessment made on the impact of the extra traffic through the town and the pollution levels. I can testify that my husband had only 'sport induced asthma' on moving here 15 years ago. That is now a chronic condition for which he has to use multiple inhalers, one of which has to be used multiple times, daily.
The NPPF Paragraph 124 states that "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants..."
This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (Priory Fields) and fails the criteria 4 ie. is not consistent with national policy on account of the likelihood of exceeding air quality limits.

Baldock is already severely lacking in recreational amenities for its current population - we would be inviting more bored teens and young adults to hang around in a town filled with pubs and little else. There is no longer any resident police to deal with problems that arise now, never mind the future.
Please consider the current plans for Baldock and the whole of North Hertfordshire carefully. The North of England is crying out for growth and yet the South continues to be further and further stretched and ruined.
Whatever building is eventually decided for Baldock, I would like to be assured that it will be allocated to local people first. There must be a guaranteed proportion set aside for local people. After all, this is supposed to be meeting our needs - rather than accommodating yet more commuters moving in to an area. The number of dwellings currently being planned for Baldock is unjust, unfair and completely disproportionate compared to the rest of the area.
There are many more reasons to not develop certain planned areas around Baldock - excavation of Roman sites, flooding, sewerage, access roads, local work opportunities (or lack of) etc. I hope that other residents will take up clearer and more informed reasoning on those points than I can. I again ask you to consider carefully all the objections put forward and look at the wider picture for the whole of North Hertfordshire.
I would like to be kept updated on the Plan's progress and I would like to be invited to the Public Hearing. Thank you for your time and informed consideration.

See attached

See attachment

I am writing this email in response to the NHDC Local Plan
Consultation to express my concerns and objections on the proposed
plan. My comments and concerns are as follows:

1. Spatial Strategy - On review of the proposed Local Plan, the
percentage of proposed housing to and around the small historic town
of Baldock is extremely high. Based on the current size of Baldock,
the proposal to build 3290 new homes will double the size of this
historic town. Baldock has a thriving community as it stands which
would be hugely impacted on with this number of properties. Based on
an average of 3 to 4 people per property, this would equate to between
9,870 to 13,160 additional residents of Baldock, which in turn has further implications as I will identify below.

2. The number of proposed residents if we use the above average (which
could potentially be 4 or more depending on the number of bedroom
spaces proposed for each development), will have an impact on the current town centre of Baldock.
Baldock is a small town with limited parking. The high street has a
good historic feel to it with the St. Mary's church at the end of the high street.
The parking on the high street of Baldock already is insufficient,
with the number of people visiting Baldock during the day and evening
exceeding the number of parking spaces, which proves difficult to park when you need too.
With the proposed number of new residents, Baldock town will be choked.

3. Under Policy SP6 - Sustainable transport. The proposal is already
at risk of being flawed. The current rail network company (Govia) are
proposing to reduce the number of trains stopping at Baldock Station.
The current Baldock station platform is at the limit, the number of
passengers boarding the train during peak times is already large and
virtually fills the train. As a commuter, I have noticed that as soon
as the train reaches Letchworth station (being the next stop from
Baldock), there is insufficient seats or space for commuters from
Hitchin, Stevenage and the following stops. The proposed number of new
residents in Baldock will consist of a majority of commuters moving to
the countryside with good links to London. This will mean the trains
will be overcrowded to a point where the trains are unable to function
safely. This in turn will cause a loss in revenue for companies due to
the number of people that will not arrive to work on time. It has become clear that NHDC have not been in consultation with Network Rail or Govia in relation to the proposals.
This was confirm via the Save Baldock Trains petition, when a local MP
discussed the proposals with Govia, which they knew nothing about the
proposed over development of Baldock.

4. The proposed new development is to include a new surgery. Currently
Baldock Surgery has over 12,000 Baldock residents registered, The
proposed new surgery would have to be part of the first phase to be
constructed to enable the practice to be set up sufficiently to
accommodate the proposed number of residents. The surgery would have
to be of a substantial size similar to Baldock Surgery. One concern
here is whether the surgery is able to employ the number of doctors
and medical staff to accommodate the extremely high number of
residents proposed. I believe our country is struggling to find the number of doctors required to run a doctors practice sufficiently.

5. SP11 - Natural Resources & Sustainability - Areas BA3, BA4 and BA5
were prone to flooding prior to the A505 Baldock Bypass being
constructed. The ditch alongside the Old Wallington Road used to
Flood. There was numerous remedial works that had to be carried out to area BA4 after the bypass was constructed.
The Land within Baldock is made up of chalk.

6. SP14 BA1 site North of Baldock - This is the largest area proposed
to construct housing, retail and schools. The proposal for a new link
road between the A1 and the A505 would not work. Has Network Rail been
consulted on this proposal, has Herts County Council actually reviewed
the level change to create a link road, if they have, then the proposal should be issued for public view.
From our understanding at consultation meetings, the proposed bypass
is proposed as a single carriageway road. This will only shift the
traffic jam onto the new road. Before any development on Baldock takes
place the following needs to be constructed:
i) - The proposed new bypass from A1 to A505 needs to be a dual
carriageway
ii) - The A1 to A505 bypass would need to be extended to the A10. The
traffic running through Baldock not only goes to the A505, but a huge
number of traffic and HGV vehicles cut through Baldock and Cottered to
reach the A10. The number of potential residents and traffic that will
take this route may cause the road to the A10 to be gridlocked. The
road through Cottered has not even been considered during the
consultation period. This will have a substantial impact on Cottered,
Walkern and Buntingford. This needs to form part of the consultation,
a traffic assessment needs to be carried out on the Cottered / Buntingford Road o ascertain the traffic levels now prior to any development.
iii) - We understand from media reports that the A1 is subject to
being widened to 3 lanes. This is a good thing, but needs to be
completed before any construction takes place in Baldock. The A1 would
need to be widened from the Baldock Services all the way to Welwyn
where it has already been widened to 3 lanes. As it currently stands,
the A1 is gridlocked between Baldock and Welwyn on a daily basis
during rush hours (6am until at least 9:30am and 3:30pm until 7pm).
This would ease congestion substantially before any works take place
in Baldock which may ease the level of traffic trying to go through Baldock slightly.

Infrastructure - Drainage and risk of flooding. With the number of
houses proposed, the local plan mentions a provision of Sustainable
Urban Drainage Systems will be required. The number of houses proposed
will have a dramatic impact on SUDS. The houses would produce
approximately 105 litres of water per day each (based on Code for
Sustainable Homes values). This will impact on the current drainage
system and potential create a higher risk of flooding over a
15 - 30 year period. The drainage infrastructure would need
substantial improvements to accommodate the number of proposed
properties. This needs consultation with the water authority.

If you have any queries, please let me know.

See attached

3,590 new homes have been proposed for Baldock. This will increase the size of the town by 80%. It is unfair that Baldock should be expected to take such a large number of dwellings. Baldock is a small historic coaching town. All character of the town will be lost with such a massive expansion. Why has the number of required dwellings not been equally shared throughout the district? The building of such a large number of dwellings in this small rural town has not been properly thought through. This is not democratic or sound.
Green Belt
The proposed sites of BA1, BA2, BA3, BA4 and BA10 are all on Green Belt land and therefore should not be developed unless there are "exceptional circumstances". I have been unable to find 'exceptional circumstances' in the Local Plan which justify the removal of land from the Green Belt. For this reason I consider that the Local Plan is not sound as it is not consistent with National Policy.
Grade 2 Agricultural land - BA1, BA3
This is Grade 2 Agricultural land. If this valuable land is used for dwellings the opportunity to use this as Agricultural land in the future will be gone forever. We cannot continue to build on land as agricultural land is needed to feed the expanding population. The more land we lose the greater the food miles and pollution.

Separate town
The proposed development of 2,800 dwellings at BA1 (Blackhorse farm site) would create a separate town from Baldock. This has already proved a problem for Baldock with the building of the Clothall Common estate, which has never been seen by the original Baldock town community as being part of the town and there was much opposition to its building. Such a large development just increases the urban sprawl from Hitchin and Letchworth. One of the functions in designating land as Green Belt is to check the unrestricted sprawl of built up areas. The Local Plan is therefore unsound as it is not consistent with national policy.
Review of Green Belt
Does Baldock need this number of houses for our families and future generations? Are we instead building to accommodate people from other areas?
The plan states that it is not possible to accommodate all the identified housing and employment needs in sustainable locations outside of the Green Belt. Therefore as a result of these exceptional circumstances a review of the Green Belt has taken place. However the National Planning Policy Framework states that Green Belt boundaries should only be adjusted in exceptional circumstances through the Local Plan process and with the support of local people "the demand for housing alone will not change Green Belt boundaries".
The Local Plan is not therefore consistent with national policy.
One of the key functions of Green Belt is to assist in safeguarding the countryside from encroachment. By rolling back the Green Belt to accommodate dwellings NHDC is actively encroaching on the countryside and more importantly in some places on Grade 2 agricultural land.
Historic Environment
Another function of Green Belt is to check unrestricted urban sprawl. However the over development of Baldock is actually adding to the urban sprawl from Hitchin to Letchworth to Baldock. Baldock is a small historic town with links to the Romans and as far back as the Iron Age. A large Roman settlement has been discovered here. Being an historic coaching town with many old buildings and having a special character, Baldock is a tourist attraction. One of the functions of Green Belt is to preserve the setting and special character of historic towns but this is now threatened by the proposed over development of Baldock and resulting increased population, traffic congestion, insufficient parking and possible increase in pollution.
Use of urban land
A function of the designation of Green Belt is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. There appears to be very little urban land included in the plan. Why is this?
I consider that development in the area of BA1, BA2, BA3, BA4 and BA10 would be inappropriate development in the Green Belt. The Local Plan is not sound in respect to the way in which it has considered Green Belt.
Transport
Baldock is a historic town with in places narrow streets and listed buildings. Roads in the centre of the town are already congested at peak times and have little scope for alteration to take the increase in traffic that 3,590 homes will bring. The junction of Whitehorse Street, Royston Road and Clothall Road is a busy junction. Listed buildings on both sides of the road have been damaged; one building is in a particularly vulnerable position when large HGV's are turning from Station Road into Royston Road.
The Sustainability Appraisal Framework notes "avoid exacerbating local traffic congestion". However, due to the existing congestion, with the additional vehicles provided by 3,950 homes congestion will be greatly increased.
To divert traffic away from this junction a bridge over the railway and a new link road has been proposed through site BA1. It is presumed that this will take a significant amount of traffic as it will avoid the Whitehorse Street, Royston Road, Clothall Road junction. However running through a residential development carrying HGV's as well as cars, with the associated problems of noise and air pollution, this road will have a considerable impact on the surrounding environment. I was unable to find any plans or Transport Statement in the Local Plan on which to comment. It seems unfair that I cannot make proper comment on this road as part of the Consultation, when this road and railway crossing will have such a major effect on the future residents of BA1 as well as the residents of Bygrave.
Transport - air pollution
Baldock is situated in a valley. Concentrations of pollutants can be greater in valleys than for areas of open or higher ground. Since the building of the Baldock bypass air quality which was previously a problem has been reported to have improved. However with the additional cars, often 2 per household and service vehicles that the 3,590 houses will bring there is concern that the level of air pollution will rise again.
Transport BA3
Some of the houses in the area BA3 will be built along the edge of the bypass. The Local Plan states that there will be:
Appropriate mitigation measures for noise associated with the A505 to include insulation and orientation of living spaces.
However noise will remain an issue when windows are open or residents are using their gardens. Air quality in this area also needs to be given consideration.
Access to the station from BA1, BA3
Due to the distance from the station residents living in BA1 and BA3 may use their cars to travel to the station. Additional cars will increase carbon emissions and congestion at peak times and further increase the parking difficulties. Is this sustainable?
Southern link road
The Local Plan states that site BA3 will deliver, in combination with site BA4, a southern link road connecting Wallington Road to the B656 Royston Road.
It is not clear from the Local Plan whether any traffic studies have been carried out to consider the effect of building this road. I was unable to find a plan showing the route of the proposed road or a Transport Statement and it is therefore difficult to be able to make comment on the proposed road. This seems to be an unfair situation, when the proposed road will have considerable impact on the residents of BA3 as well as the existing residents of Clothall Common, most of whom will not be aware of this proposal.
My concern is that the proposed road will:
1. Create a "short cut" for vehicles wishing to avoid the junction of Whitehorse Street, Royston Road and Clothall Road. Traffic, including HGV's, wishing to move between the south of the town and the Royston Road, or gain access to the Buntingford Road will have a quicker route through the area of proposed new housing.
2. Air quality may be affected and noise pollution created, if a significant number of vehicles use the proposed road
3. Increased traffic will be a hazard to residents of Clothall Common as well as to those living in BA3
4. The amount of traffic waiting to enter the roundabout where the Wallington Road joins the Buntingford Road is likely to increase
Slip road from A505 to the Buntingford Road
If the new southern link road is created, building a slip road from the A505 by pass to provide access to the Buntingford Road, would reduce the traffic flow through BA3 and Clothall Common.
Infrastructure
Such large developments as proposed for Baldock requires appropriate infrastructure. However we have only one GP surgery, A & E at the Lister Hospital is frequently full to capacity with long waiting times. Our community Police Station has been closed and the land converted to dwellings. Our library hours have been reduced. We have no Public Toilets. Frequently there is little parking in the town.

Despite the building of the new bypass a great deal of traffic goes through the town. This includes many large lorries travelling between the A1M and the bypass. These have to negotiate the low railway bridge and occasionally become stuck under it.

What studies have been carried out to assess the potential effect that an additional 7,180 cars might have on the town and the surrounding roads? This is assuming 3,590 new dwellings with a minimum of 2 people per household each with a car. I was unable to find this information in the documents provided for Consultation.

BA10 employment sites
Baldock is a small town. Employment opportunities are limited. Due to the railway and position near the A1M many people living in the town commute to other areas for employment.

Employment sites are to be extended at BA10 to provide jobs for occupants of the new dwellings. However there is no guarantee that these jobs will not be taken by people from out of the area. The additional vehicles used by potential employees to access the site, together with delivery vehicles, will further add to the congestion on the existing roads around the town and pollution.

A reasonable alternative would be to locate new dwellings near to areas with higher employment opportunities, such as the West of Stevenage. This would be in line with National Planning Policy Framework which states that "plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised".

Ivel Nature Reserve
The River Ivel and its Springs are a Chalk river. These are rare with about 200 globally. We therefore have a duty to take care of our river and springs. Has the effect on the river and springs of building so many dwellings on nearby land (BA1) been assessed? Any development should not have a negative effect on the river or the wildlife in this area. All Green Belt sites will result in loss of habitat. This is of particular concern for the hedgehog, which is already endangered and red listed arable farmland birds which are present on site BA1
Master plan for BA2/BA3 / BA4/ BA5
A site master plan is to be provided for BA1 as this "will be substantial new community". However with a proposal for 500 houses to be built between sites BA2/BA3/BA4/BA5 a site master plan should also be provided for these areas as together they will also be a substantial development that will have a significant impact on the local road network.

Plan with vision and imagination
North Hertfordshire is the home of the first Garden City. This was planned in 1904 with vision and imagination. Town planning should have moved on from this to provide an even better vision for future housing and yet in Baldock we have a proposal for 3,590 new homes, which will increase the size of Baldock by 80%. There seems to be no clear vision for transport, infrastructure, and the creation of a desirable place to live.
The number of houses proposed should be appropriate for the size of the town, not create a separate town as in the case of the development at BA1. The required number of houses could be built by constructing an appropriate number in Baldock and with the cooperation of South Cambridgeshire District Council, give consideration to building a new town at a site such as Odsey which already has a railway station but no obvious constraints for future development.
General comments
In view of the large scale of development proposed by NHDC in Baldock I have been disappointed that there has been no public exhibition in the town about the consultation detailing the proposals. Documents were provided for viewing in the local library but there was no large signage to indicate to people entering the library that the documents were there.
Making comment on the Local Plan is a complicated process and thank fully we have had the support of the SaveRural Baldock campaign to guide people through this.
NHDC changed their website on the final day that comments were to be submitted, which did not assist the process for those still needing to submit their comments.

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
With regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7000 vehicles from Baldock would add to this congestion causing North Herts to become gridlocked during peak times.
At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modeling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite 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 7000 vehicles away from the A505/A507 junction.
There are severe doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. The local plan 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. The local plan 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.
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland.
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 states that planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

NE1 Landscape
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

NE8 Sustainable drainage systems
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable.

NE9 Water Quality and environment
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of Baldock..

I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to the NPPF (Promoting sustainable transport, para 31) which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development". It is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. In 2014 the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

I have been a resident of North Herts for ten years and have grown to love this part of the world, having lived in London and Kent previously.
That development is needed in North Herts is axiomatic; it is clear that at this time, demand outstrips supply and ONS figures suggest that the District needs 14,400 new homes built between 2011 and 2031. North Herts District Council (NHDC) has increased this figure by 2,100, to take into account any 'unmet need' in respect of growth from neighbouring Luton, bringing the total number of new homes to be built in the period covered by the Local Plan (LP) to 16,500.
NHDC proposes that around 60% of these homes should be sited within the Green Belt, which will have dramatic effects on well-established communities in the District. The council seems to adopt a pragmatic view of this rolling up of the Green Belt, by simply designating land on more convenient sites as Green Belt. In this way NHDC can say that far from diminishing the Green Belt, they have increased it; this is rather like building a new football stadium in the middle of Dartmoor and recovering that lost moorland by designating a similar area in the centre of Exeter as National Park. It may look good on paper, but it is unlikely to fulfil its original purpose.
NHDC seem to insist on the adoption of a plan that covers the period 2011 to 2031, when legal advice commissioned by the Council has clearly stated that the minimum requirement is a five year plan, which would give time to properly plan for additional numbers. It is this insistence on a plan which covers twenty years which is at the heart of the Council's indecent haste and lack of preparation.
Two Stage Plan
The three MPs for this area, Sir Oliver Heald, Peter Lilley and Stephen McPartland have all endorsed the creation of a two stage plan, initially dealing with the first 10 years (2011 to 2021), which would look at planning for 6,050 sites. Planning permissions have already been given for over 2,600 homes; this leaves 3,450 new homes to be found district-wide before 2021. This period should be well used in identifying and planning a new 'Garden Village' development. We have an opportunity to create something worthwhile, rather than simply adopting a 'bolt on' principle to new homes within existing communities. I appreciate that this could not be included in this plan but the concept is only being included in the next planning cycle after much public opprobrium and protest, demonstrating the paucity of strategic thinking that runs through the whole plan.
Master Plans
NHDC has identified a number of significant sites, including Baldock, Letchworth and Stevenage, where infrastructure will be provided for within a 'Master Plan'.
Unfortunately no details of these plans have been made public. Public concerns about such sites have been met with assurances that concerns will be dealt with "as part of the Master Plan". My reservations concerning the efficacy of NHDC's planning were heightened when it was discovered during the previous consultation period (for the Preferred Options Plan), that Network Rail had no knowledge of the proposed settlement north of Baldock (BA1), that will mean 2,800 homes built on Green Belt land, as a bolt on to the medieval town of Baldock. It is accepted by the Planners that for the development to be viable, a bridge will have to be built over the railway for access and transport. But Network Rail hadn't even been approached at that time!
If the other Master Plans are built on such shaky foundations, I cannot see these plans becoming a reality without significant cost to the public purse. The Local Plan should include, where appropriate, full details of a viable Master Plan, which has the buy in of all stakeholders. At the moment, the Local Plan does not fulfil these criteria.
Transport Strategy
Trains. In September 2016, Govia Thameslink Railway, (GTR) issued a consultation document detailing proposed timetable changes. These changes, as originally published, would result in a significant reduction in trains stopping at Baldock Railway Station. I arranged a meeting with Jane Cobb, the Consultation Project Manager and Peter Lane, Lead Service Delivery Manager, of GTR to discuss the Baldock situation. The meeting was also attended by all the Baldock Councillors and the NHDC portfolio holder for planning and enterprise. This meeting was held on 2 November 2016.
I commenced the meeting by setting out our concerns, particularly in the context of a reduced train service when the Local Plan was intending to increase the size of Baldock by 80%; this would increase passenger flow to/from London from 330,000 journeys (GTR's own figures in the condoc) to 600,000 journeys annually. To my surprise, neither of GTR's representatives knew anything about the Local Plan and had not been included in any consultation/liaison. Both representatives acknowledged that they would now have to take this extraordinary growth into account when doing their modelling. This flies in the face of the NPPF (Promoting sustainable transport, para 31), which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development..." It indicates that this plan was conceived in isolation and that NHDC has failed in its duty to cooperate with other bodies.
Roads. There are a number of gaps in the evidence offered relating to local traffic flows and I shall highlight three of them.
Road bridge. The major development north of Baldock has at its heart, the requirement to build a road bridge over the railway to provide access; indeed the provision of "a new link road connecting the A507 London Road to the A505 Baldock bypass, including a new bridge across the railway" is one of the site specific requirements for development north of Baldock. All enquiries about the provision of infrastructure were met with the response "It will be dealt with in the Master Plan". But when the 'Preferred Options' plan was sent out for consultation (2014-15), Network Rail knew nothing about any plans to build such a bridge. This is what the Senior Planning Officer of NHDC (in charge of the plan at that time), Richard Kelly, called a "show stopper", but NHDC only engaged with Network Rail after intervention from Sir Oliver Heald MP. Again no evidence of cooperation until the plan was sent for public consultation and very little progress made in this area since.
Gridlocked crossroads. The junction in Baldock where the B656 meets the A507 is a major junction; in many respects, all roads lead to it and it is currently at capacity, with traffic jams both during and outside rush hour periods. No traffic survey has been done at this junction, which is expected to deal with a significant rise in traffic once the new development begins. To cope with such an increase in traffic, the junction must be re-engineered; however, the options for such work are severely limited. Houses on two sides of the junction are listed, the oldest having been built in 1540. This seems to have been ignored by NHDC planners. Without solving the issues around this junction, traffic in Baldock is destined to remain gridlocked for most of the day, with consequential delays for traffic throughout the area. No coherent traffic plan has been put forward at any stage for coping with a massive increase in traffic and parking issues in Baldock town centre.
Deteriorating Bus Service. The removal of the 98 bus service between Baldock, Letchworth & Hitchin and the 391 service to Stevenage has resulted in a significant deterioration of quality of life, particularly for older people in the town of Baldock. There is, of course, no Sunday bus service. The impact of this hits the most vulnerable of our society; the Local Plan's Transport policy focusses almost entirely on private vehicular transport with the barest of nods to the needs of bus users and there is no evidence that NHDC has not failed in its duty to cooperate with transport providers for the provision of viable infrastructure necessary to support sustainable development.
Environmental Matters
The effect of traffic on air quality in Baldock. A Baldock GP recorded his concern some 20 years ago (before the Baldock bypass relief road was built) that "traffic generated pollution is responsible for the near epidemic proportions of asthma cases we see at the surgery." There is only one GP surgery covering the town of Baldock.
On looking at the evidence presented to the Baldock Bypass Public Inquiry the Inspector recognised a link between air pollution and asthma levels in the town, these being above the national average and rising. Despite the road being opposed by NHDC the Inspector approved its construction.
To underline how bad air quality was in Baldock at that time, the subject was raised by Sir Oliver Heald in the House of Commons in 1997, in support of the construction of the bypass to take traffic generated pollution away from the area. In 1994, figures from the local asthma register show that the child asthma rate was almost 12% (twice the national average), going up to 15% before the building of the Baldock Bypass in 2006. This year that same figure has declined to 6% (equal to the national average).
An NHDC draft Air Quality Report of January 2000 itself recognised the topographic influences on the situation (Baldock is, of course, located in a valley) by referring to the "physical character of Baldock inhibiting good dispersal of air pollutants." It also recorded that the annual mean standard (that applied at the time) for nitrogen dioxide had been exceeded in 1999.
North Hertfordshire District Council acknowledges that "no specific assessment (of air quality) using historical data has been undertaken at this stage." (email of 2 November 2016 from NHDC Strategic Planning to John Gingell).
Bearing in mind the inherent weakness of the Transport Strategy, I believe that there is a real possibility of rising air pollution within the Baldock basin as traffic levels rise due to the unparalleled expansion of this medieval town. The local authority is failing in its duty to the residents of Baldock by failing to conduct any meaningful assessment of that risk. In November 2016, Julie Girling, the MEP for South West England affirmed that poor air quality has a huge impact on human health, the environment and the economy, saying "Poor air quality is an urgent public health issue... estimated to cause 400,000 premature deaths across the EU... The UK should be a leader in the fight to tackle bad air quality... With our national health system, we bear the economic consequences of bad air quality directly and we should not allow the progress made in recent years to slip." No specific assessment of air quality is a major flaw in determining the environmental consequences of the Local Plan, which may well result in an increase in premature deaths in Baldock.
Natural Environment
The National Planning Policy Framework (NPPF) states that the purpose of the planning system is to contribute to the achievement of sustainable development with its three dimensions (economic, social and environmental). Development should support the local economy, provide social benefits in the form of new homes and social facilities and protect & enhance the natural environment.
The development north of Baldock (BA1) will seriously and adversely impact on wildlife in the area. The Corn Bunting was once a common, widespread farmland bird (originally called the Common Bunting). Due to changes in farming practices, the Corn Bunting has experienced a dramatic decline of 90% between 1970 and 2010. It has become extinct in Ireland and is possibly extinct in Wales. It is a Red Listed Bird. During 2014 an extensive survey was carried out, which indicated that the area north of Baldock is central to the population of this declining bird. This area also provides habitat for the following Red Listed species: Yellow Wagtail, Grey Partridge and Linnet. Development of this area will destroy the habitat of these protected birds with a disastrous effect on their overall numbers and sustainability.
Ivel Springs is a large Nature Reserve in Baldock and a Scheduled National Monument which means the site has national significance and is protected under statute. The springs, which are the source of the River Ivel, provide a diverse area for wildlife, including woodland, wetland and pasture; it is carefully managed to keep a mixed habitat and encourage wildlife to flourish. Chalk Rivers, such as the Ivel, are extremely rare and included in the Hertfordshire Biodiversity Action Plan. The River Ivel and its wetlands are important habitats for a wide range of species; however, for the past six summers, the river at Ivel Springs has dried up. It is contended that the imposition of the north Baldock development will increase the strain on this fragile ecosystem that has existed for at least 5,000 years. The loss of this Nature Reserve will have a catastrophic effect on wildlife and before NHDC embark on the development of north Baldock, research should be conducted to measure the level of threat that such proximity to a large development of 2,800 houses poses.
On 6 February 2015, the Natural Historic & Built Environment Advisory Team informed NHDC that site BA1, north of Baldock, in the Local Plan could contain heritage assets, which could be a constraint on the principle of development. This led to Hertfordshire County Council (the landowner) undertaking an archaeological trial dig evaluation of the site. So far, archaeological remains have been discovered, which probably date to the time of the Roman conquest of Britain; this investigation continues, but I have been informed that a principal archaeologist has stated that some finds may predate the Roman conquest and that indications are that the finds include a Roman villa, with muralled walls, which are incredibly significant. This is still being investigated, but indications are that much of this land may not be suitable for development, and inclusion in the Local Plan at this time is, to say the least, presumptive.
Green Belt
As previously stated 60% of homes in the plan are to be built on Green Belt land. Such land should only be used for development in exceptional circumstances. It is implicit in this policy that Brownfield and non-Green Belt land should be used before building on the Green Belt. Yet North Herts Homes (NHH) Brownfield Regeneration Project has not been included in this plan. This project aims to provide 400 homes, solely from the use of Brownfield sites between 2014-18. I have asked NHDC whether they have done any work to identify similar schemes without receiving any meaningful answer.
The proposed sites in the Baldock, Hitchin and Letchworth area will lead to a ribbon of development from Baldock to Letchworth, to Hitchin, creating unrestricted urban sprawl, with encroachment into the countryside. This proposition counters recent Government statements on the use of Brownfield sites. In 2014, the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside."
Virtually doubling the size of Baldock will damage the setting of Baldock in its natural basin, currently surrounded by countryside. The unique character of the town, dating back to medieval times with a strong connection to the Knights Templar and many listed buildings will be irrevocably and fatally marred.
More and more development is occurring on Green Belt land; in 2008, less than 20% of new homes were built on Green Belt land. In 2011, that figure had risen to 34% and will now be much higher.
Spatial Strategy
This plan focuses development squarely on the four towns within the district, who between them will have to accept 70% of the development. Of these four towns, the smallest and most historic, Baldock, is expected to assimilate 3,590 homes, or 25% of the total. This is not fair, nor is it equitable; neither does it take account any possibility of the development of a Garden Village/City. In this respect, the plan is shown to be short term and tactical, rather than strategic.
This plan relies on land that is put forward by developers and does not seem to be proactive in any way. Rather than look at land that would enhance future development and approach landowners, NHDC seems to have merely reacted to sites offered up by landowners, preferring sites that are Green Belt and owned by another public body (Herts CC).
Other Evidence
During the course of the development of the Local Plan, a number of sites have been put forward and then rejected by the planners of NHDC. The consultation paper related to the Housing Growth Targets consultation run by NHDC from 17 February to 30 March 2012 outlined eight different options for housing growth, ranging from 15,800 to 2,500 new homes. Unfortunately no rationale for rejection of individual sites has been published, which leaves residents frustrated and unable to understand a) what specifically has excluded a particular site and b) whether once a site has been rejected anything can be done to reverse that decision.
The NPPF states that Local Plans must be supported by a local evidence base, which means that NHDC must plan to meet objectively assessed needs for market and affordable housing and identify a five year supply of specific deliverable sites. I have been unable to ascertain why certain sites have been rejected in favour of others.
On the evidence, I believe that the plan, as it stands, is flawed; three local MPs believe the plan is flawed; even the NHDC Portfolio Holder, responsible for the submission of the plan believes it is flawed. There is public condemnation of the plan across the District and an overwhelming desire for a two stage plan looking at deliverable sites for 6,000 homes in the first ten years and working with other housing authorities to provide a new Garden Village/Town style settlement. I urge you to consider the overwhelming public view across the District and adopt a two stage plan, which will embrace localism and demonstrate objective and equitable measure to deliver the right level of development across NHDC.
If you think I can assist, I am willing to attend and give evidence at the Public Inquiry.

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