BA2 Land west of Clothall Road

See attachment

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
General comments for the Baldock area (especially sites BA1/BA2/BA3)
Baldock is a small town and is ill-prepared for the high level of expansion that this proposed plan would entail. It is disproportionate that Baldock has such a high proportion of houses allocated compared to other towns in the area.
The sites around Clothall Common area (BA2/3) need to be treated as one site and a separate masterplan for the area to be prepared to consider fully the whole area. This must include additional doctors and schools to be in place as the first houses are completed. School places in particular are already a problem without any additional houses being built on any site in Baldock (when my daughter started school in 2014 many children were allocated schools outside Baldock as there were 32 too few places within Baldock).
"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure at any site and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
All houses to be built should have room for at least 2 cars.
Suggested changes:
Reduce the housing allocation for Baldock and allocate some of this to other sites in the other towns in North Herts. Consider also an entirely new settlement elsewhere away from the 4 towns.
Treat all sites in Clothall Common area as one site and create master plan for the area to include doctors and schools.
All houses to be built should include parking for at least 2 vehicles.
Infrastructure planning and timescales should be in place before building starts; detailed investigations of all aspects (especially traffic) must be carried out for the plan to be approved.

Specific comments
Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1)
1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14)
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

3. Baldock is situated in a valley and air pollutants are known to be trapped and concentrated in Baldock. The traffic levels in Hitchin Street and Whitehorse Street are already causing the level of pollutants to be in danger of exceeding EU permitted levels (para 9.28). The number of extra vehicles associated with the increased number of homes and services in and around Baldock will cause these levels to be surpassed and will affect the health of the people of Baldock (particularly with regard to respiratory disease). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

4. The roads pose a major obstacle for this plan. The crossroads where Whitehorse Street, North Road, Clothall Road and Royston Road meet are heaving with traffic for much of the day. There are frequent queues. Almost all of the traffic coming through Baldock passes through this crossroads. There is no way to expand this crossroads because it has listed buildings on it. It is already the case that Raban Court has been hit several times by lorries turning left from North Road (A507) to Royston Road (B656).
Traffic coming to and from the station and the houses on Icknield Way East further impacts the pinch point at this junction. In addition the railway bridge over the A507 is hit frequently by lorries and this causes disruption on the roads while everything is cleared up. Delays also occur when lorries realise that they cannot fit under the bridge and have to perform manoeuvres to turn around.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
Traffic modelling has not been carried out sufficiently to prepare for the potential impact of building so many houses on the BA1 site. With 2-3 vehicles projected per house and almost all people working outside Baldock (and many of them using the B656/A507 crossroads) the implication is that an extra 5000-7000 vehicles may be on our roads and many of those would be coming down to this already heavily congested junction. The proposed link roads will not reduce the pressure on this junction or other parts of Baldock enough. The junction of the High Street with Hitchin/Whitehorse Street is another part of Baldock where air pollution and traffic levels cause concern.
The Plan is NOT JUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14). There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.
5. As most new Baldock residents will work outside Baldock the railway station would also need expanding to accept an 80% rise in commuters and the longer trains that would be needed. The current proposal (in consultation at the moment) to cut fast off-peak services to Baldock will not make Baldock desirable to people as a place to live.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network. There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Building a new development BA1 on the other side of the railway line to the main part of town would divide the community and will cause traffic problems. "By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land showing what "exceptional circumstances" there are that necessitates building on the Green Belt. Site BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as in NPPF chapter 9. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" (NPPF 112) - the land at BA1 is high quality land.

7. The provision of sewerage and potential risk of flooding over this vast site has not been fully investigated. The details of the protection of the Ivel Nature reserve are not clear; neither is it clear how other wildlife will be protected such as the endangered corn bunting on BA1.

8. Insufficient green spaces such as parks have been provided and there are no details of extra leisure facilities within Baldock.

The Plan is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Suggested changes (site BA1):

* Reduce size of site to enable transport and community to cope
* More equitable distribution of houses across North Herts
* Reduce number/density of houses to reduce flood risk and protect wildlife
* Additional railway parking
* Additional town centre parking
* Require site to include at least two large children's play parks and parking to allow people to visit them.
* Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
* Every house to have a back and front garden to aid water drainage and reduce flooding risk.
* Tree planting along every public road
* Ensure houses have sufficient parking (2 cars per house minimum)
* Build key infrastructure in advance of allowing new building (link road to ensure that construction traffic does not have to go through existing road network pinch points.)
* An additional large green space with ample parking to be provided as part of the new development in order that Baldock has a facility which can cater for both increased demand and the need to drive to its location.
* Plan to include sports facilities.
* Work in partnership with the rail companies and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation). Increase the size and amenities of the station (i.e. more manned ticket office hours) in order that it can cater for the increased demand.

I wish to be kept informed about the plan.
I do not wish to appear at the oral examination.

See attachment

with regard to the number of additional dwellings on this and other sites, BA2, BA3 and BA4

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.

See attached

We would like to say at the outset that we understand the need for a Local Plan and the national need for more house-building. However the Local Housing Plan for North Hertfordshire, as proposed by NHDC, is, we believe flawed in many respects.

Unequal division of housing allocation
Some building has taken place in Baldock over the lat few years, but NHDC now proposed to increase the size of Baldock by 3,290 homes by 2031. This will double the population of the town. Baldock is the smallest of the towns in North Herts but is now required by the council to have more housing than each of the other three larger towns of Hitchin, Letchworth and Royston. The main reason for this seems to be that all the land proposed for the new development is owned by Hertfordshire County Council who are willing to see it for this purpose; therefore NHDC do not have to contact individual landowners asking if they would be willing to sell.

Many people have said that the number of houses stipulated to be built in Baldock could easily be contained in a new town situated elsewhere in the County. NHDC say they may well have to consider this in the future, but that there isn't the time now to do that now.

Previous emails
I also append copies of two emails sent to NHDC at previous consultation stages, which we would like you to read, but would also like to add the following.

Infrastructure
We are particularly concerned about the developments BA1 and BA2/3. With developments of a certain size eg BA1, infrastructure will be provided eg schools, doctors, dentists, shops etc, but with smaller developments ie BA2/3 infrastructure will not be provided so no new schools, doctors, dentists etc.

We are particularly concerned that insufficient thought has been given to schools; provision. The three Baldock primary schools are currently over-subscribed so that Baldock children, even those living within walking distance of the schools, now cannot be accommodated an so have to be driven to local village schools eg Sandon and Ashwell.

It is already difficult to get a doctor's appointment so this will also be adversely affected by such a large number of new homes.

Traffic
The centre of Baldock consists of just four main streets with very limited parking. Three-bedroom houses are now allocated two parking spaces each; if just a fraction of new householders want to use the facilities in the town centre at any one time, then we foresee enormous problems.

Railway travel
The number of commuters on the local line into Kings Cross is growing all the time as more houses and apartments are being built. GOVIA are currently planning to reduce the number of fast trains stopping at Baldock and are in the process of a consultation period. Our councillors have been in touch with GOVIA who, apparently, had no knowledge of this proposed local plan but have said they will review their decisions regarding changes to times of trains from Baldock. However, even if the trains remain as now, journeys will become more difficult and uncomfortable as people already have to stand on their journey to Kings Cross. Many people moving into the new houses will inevitably be commuters so this will only exacerbate the situation.

Sporting facilities
We are all encouraged to play more sport and be more active, but according to Baldock Town Football Club's figures, Baldock's current leisure facilities are 60% for adults and 40% for children below the national average. So, when infrastructure is being planned we believe that land should be set aside for providing more leisure and sporting activities for the whole town.

Nature Reserves
We currently have two nature reserves in Baldock: one on the Weston Hills and the other at Ivel Springs. Access to these and the wider countryside is vital to people's well-being. Residents need to be able to relax and benefit from contact with nature which is proven to reduce stress. So, parks and green areas within new settlements is vital as well as easy access to the wider countryside. We also need to preserve green space between us and other settlements (towns and villages) and so a large area of designated nature space between Baldock and Bygrave, for instance, would be beneficial and aid the well-being of both the people in the town and natural habitats.

Below are Emails sent to NHDC at various times during the consultation period.
Since writing in November, many people have supported the idea of a separate development elsewhere in the county with its own centre and identity, where there could be shops, pubs, schools, doctors and dentists' surgeries, new roads etc, built on 'Garden City' lines. One such development is, I believe, proposed for a disused airfield in Northamptonshire, where 1,000 houses are proposed. If the authorities in that area think that 1,000 new houses justifies a completely new and separate development, then surely a development of 3,591 houses should have the same claim. It was distressing to hear Cllr Andrew Young admit (and he was only being honest) that initially there would not be enough school places for all the children living in the proposed new homes, but he wanted to reassure parents that their children would be transported to those schools in the area where there were places, be it Letchworth, Hitchin or Stevenage. No parent wants this for their child. Precious, but delicate, friendships are formed at these young ages and it's good if those friendships can be carried on out of school, so obviously if all children go to schools in their own town, they will be able to socialise after school and at weekends. It is not so easy for working parents to keep transporting their child to other towns all the time.

The proposed development of 3,591 houses is almost four times the size of the Clothall Common development and it would be difficult to integrate people living in those houses into the community life of the present town. When the houses started to be built on the Clothall Common estate, people in the 'old town' maintained that everything should be done to integrate it into the existing town, so not have separate small shopping precincts, nor village halls nor pubs, but that there should be an active desire to integrate people there with the current Baldock residents. Over time this has happened, with people living on Clothall Common taking part in activities in the town, joining organisations and helping run the social and community life of Baldock.

We cannot hope to do this with a settlement four times the size of the present Clothall Common development. Much more sensible would e a new development which had its own identity and could have shops, community halls and maybe even a pub. People like to have an identity and to feel part of something and belong. It helps a community coerce and I believe that because people in a small community quickly get to know one another, it deters crime. Youngsters can be given a place where they can meet and again make them feel a part of the community. As I said in my previous email, this isn't NIMBYism but trying to come up with a workable solution, not just for the present residents of Baldock, who will find life difficult with more traffic and more demands on school places, doctors, and dentists etc, but also for new people coming into the area.

This idea has also been mooted by our three local MPs: Sir Oliver Heald, Peter Lilly and Stephen McPartland. Cllr David Levett says in a report in the Midweek Mercury that '... longer term this idea should be pursued ...' Why not now? Why go for a quick fix solution because it is easy for planners at NHDC and joyful for Herts County Council who own the land?

I don't fee that NHDC have fully investigated the possibility of building a small 'Garden City' development elsewhere because it would take too much work to approach landowners to see if they would be interested in selling their land to developers. It is so easy to accept HCC's offer as they conveniently own nearly all the land around Baldock.

We would also go back to the statement made by Cllr David Levett at the public meeting at the Leisure Centre when he said that this is a 'far from perfect plan'. Is NHDC not ashamed to be putting forward a plan that is 'far from perfect'. How on earth can anyone support it? We really do think that NHDC needs to think long and hard about this. They say they have to come up with a plan and this is the best one, or the developers will move in and they will have no control on what is built. But surely everything has to have planning permission, so they do have some control. However, to prevent that happening, it seems to many people that the best solution is a completely separate development - and preferably not on Green Belt land that is also valuable agricultural land.

We have also seen the letter from the Council for the Protection of Rural England who express grave concerns about the Proposed Plan. We would urge you to take all their points into consideration. We were particularly interested in their quote from the Planning Minister to the Chief Executive of the Planning Inspectorate: 'We have set out in our recent guidance that a Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints which indicate that development should be restricted,' also: a SHMA is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans.' (my underlining). I think this does then give all councils more leeway than we have been given to understand and maybe more leeway than they realise.

Finally, on more than one occasion, we have been told that if we do not accept this plan with the number of houses involved, then developers will simply be able to move in and build what and where they like. In the letter from the CPRE it would appear that actually that is not the case at all. So it looks to us as though there has been some scare mongering.

Please see below copy of original email sent in November 2014:

Dear Sirs

We feel very concerned about the size of the proposed development around Baldock. We understand that 3,500 houses are proposed for Baldock, a much higher number than for any of the other towns in North Hertfordshire. It is this inequality that incenses the people of the town. We appreciate that new houses will have to be built to accommodate the ever-growing population of this country - and it would be good to know that those who have families locally could buy houses nearby if they choose, but we feel that a development of this size would be detrimental to the town.

At the moment, Baldock works very well as a small community - everyone says what a friendly place it is and the amenities we have currently serve the town well - just. A new development such as this would put overwhelming pressure on schools, roads and NHS services. Hertfordshire County Council, who own the majority of the land that would be required for the proposed development, have said that there would be no problem with the infrastructure - they would manage that. But these houses will be built over a period of years up to 2031, so we cannot imagine that new schools, doctors, surgeries etc will be built in Phase 1 of the development. So families moving into the area will naturally want their children to go to Baldock schools and the families will want to use local doctors and dentists. This will not only affect people in the new houses but also current residents, who will find it increasingly difficult to get appointments.

One of the reasons Baldock works so well is that although we have three primary schools, the majority of those pupils will end up at Knights Templar School, immediately forming a cohesion for the town of the future. We know so many people who went to Knights Templar when our children were there who have stayed in the town because they like it here. They like the amenities and the lively 'small-town' feel of the place. This is not something to be dismissed lightly. It may well be one of the reasons why Baldock has such a relatively low crime figure.

At the meeting at St Mary's Junior School when many fears were expressed about this proposed development, someone who had worked for Anglian Water expressed real concern that the utilities - and particularly the water supply and sewerage disposal - wouldn't be able to cope. Electricity and gas supplies are also a worry. We already hear rumblings that if we have a severe winter there might be power cuts.

When the bypass was built, for a short time, the number of cars and lorries coming through the town was noticeably less. However, volumes have gradually built up and at times queues of cars can again be seen in the town. How on earth will the town cope with all the people and cars living in another 3,500 houses. Presumably they will sometimes want to come into the town to shop - particularly as we have a large Tesco in the town. It is understood that new roads will be built connecting a new estate to the bypass and this could, in effect, then produce a satellite town with little connection to Baldock. Why not then build a separate town, with its own identity elsewhere. This is not nimbyism, but practicality. Obviously the fact that Herts County Council owns so much land around the town is an attractive proposition and an easy option.

There is also the fact to be taken into consideration that so much agricultural land will be used up. We are told we need to grow more of our own food, but with agricultural land being snapped up for housing how is this possible? We feel that the whole question of how much housing is being built in the South East needs to be looked at, but recognise that this isn't something that NHDC or HCC can do. However, we do believe that they can question the government as to its quotas for the South East. If HS2 and HS3 rail links are put in place, then in 20 or so years time the north of the country might be more attractive both for people to move there and for people currently living there to find it a more attractive proposition to stay there rather than to move to the over-crowded and over-priced South East.

Even if the 12,100 homes proposed for North Hertfordshire were to be evenly distributed between the four towns in North Herts and the villages, we would probably be looking at getting around 2,500 - still a great number, given the current size of Baldock - probably another half a town. We urge you to think very carefully how you allocate this housing, both for the well-being of the current population and those who might wish to move to the area.

We apologise for the length of this email and, if you have managed to read it to the end, thank you for doing so.

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
Policies SP8 and SP14
The proposed allocation of 2,800 houses North of Baldock (site BA1).

1. GREEN BELT: The site makes a significant contribution to the Green Belt
(Housing and Green Belt background paper para 3.14).
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

2. LANDSCAPE: The site creates a high probability of adverse impacts on landscape and townscape character (Table 4 sustainability appraisal notes) The land north of Bygrave has moderate to high landscape sensitivity. (Landscape Sensitivity Study of July 2013)
The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

3. POLLUTION: Baldock sits in a valley, which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated.
The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution. Since then traffic has risen and now the levels of pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28).
The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

4. HIGHWAYS: The local highways network will be severely affected by the development of this site. Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The A507 passes the only access to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac (Icknield Way East) and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which they both deliver traffic.
Station Road passes under the 14ft 6in railway bridge, which historically has suffered frequent hits by lorries (8 or so per year - As a resident in Larkins Close, I feel the vibrations from each hit). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted and two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do.
The Plan is UNJUSTIFIED and NOT EFFECTIVE

5. TRAFFIC: The traffic on the A507 is constant and heavy especially in peak periods, which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
In the IDP the Traffic Baseline (para) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.
No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. The traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.
All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.
The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modelling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief that Baldock traffic problems have not been acknowledged and addressed.
The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. RAILWAY STATION: Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinch point for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.
The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.
Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. There is also no access for disabled passengers.
Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not until recently known of NHDC's plans such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts. It is quite exposed at this point.
This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.
The link road proposed through BA1 will not relieve congestion at the Whitehorse St/Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505 to A507 and will deliver more air pollution to the site BA1.
There is no modelling of the impacts from developments or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable. The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.
The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

7. TRANSPORT NETWORK: The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether" "the opportunities for sustainable transport modes have been taken up but the Plan does not give information of things such as cycle ways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE".

8. SCALE OF DEVELOPMENT: The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.
The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

9. WATER/WILDLIFE: Water provision at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.
The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on water provision and wildlife.

SUMMARY:
The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinch point for traffic and a pulling apart of the community.
Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66). NHDC have not sought the views of existing residents.
"By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality NPPF 112.
It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

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