BA3 Land south of Clothall Common

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.

Please consider this email as my representation as part of the public consultation on the new housing development within Baldock. I shall be commenting on sites BA1, BA2, BA3 and BA4.

Section 4 - Communities

Site BA1:
Objection to the proposal on the following grounds -
* It is inequitable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20% and yet Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.
* 2400 new houses in Baldock will cause significant additional pressure on the roads. The cross roads by the station, linking the A507 and A505, is already jammed with traffic during peak periods with long (slow) tailbacks. There is also a lot of industry traffic that moves from the Letchworth industrial estate across to the A505 via Baldock.
* The crossroads cannot be widened as it is surrounded by listed buildings. The proposed road linking the A1 Baldock Services directly with the A505 does not account for the increased traffic which will be moving to and from Baldock rail station.
* Limited parking is available at Baldock railway station.
* Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
* The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new build will generate additional children to be catered for, with nowhere to go and yet it is already significant problem.
* Air quality will be significantly reduced within the town following increased traffic of at least 5000 cars on the roads.
* There is no mention of tree planting to improve the air quality issue, or % of green space planned to aid surface water drainage and improve aesthetics and well-being.
* Construction traffic would need to go through the town causing air quality, noise and congestion issues.
* BA1 housing site is on a slope. Baldock town has issues with flooding when there is heavy rain. Building will reduce the natural drainage resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings.
* Its my understanding that the proposed site for building is the habitat for a number of endangered species (birds and bats) which I believe should be protected through either a reduction in the size of the development to limit damage to the species or reduce the density of the housing to ensure species can co-exist with the development.
* Without sufficient new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional railway parking
*Additional town centre parking
*Fewer houses to be built within this site as Baldock road network and current community services will struggle to cope.
*Reduce number of houses and / or density of houses to reduce flooding risk to the town.
*More equitable approach to the build allocation across Hertfordshire
*Construction of Schools and Healthcare facilities to be prioritised within the first phase of development.
*A variety of housing styles and increase the allowance of self-builds; this will reduce the monotony often associated with a housing development.
*Require this site to have a few a children's play parks.
*A large green space with ample parking
*Require a minimum of green space across the site to ensure improved air quality, surface water drainage, and general asthetic 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.
*Tree planting along every public road
*Every house to have a back and front garden to aid water drainage and reduce flooding risk.
*Reduce number of houses and / or density of houses to ensure endangered wildlife is protected
*Ensure houses have sufficient parking. Modern developments seem to assume one car families and thus causes congestion on the roads outside.
*Build key infrastructure in advance of allowing new building to prevent construction traffic going through existing road network pinch points.
*Funding to extend the library and community centre.
*Work with rail and bus providers to ensure that services are increased rather than reduced (see Great Northern 2018 consultation).
*Increase the size and amenities of the station (i.e. more manned ticket office hours, possibly more parking)
*Rather than build as an extension of Baldock should the Council not consider developing a town of the same size away from existing communities in order that the road network and other infrastructure can be developed from scratch and thus be suitable for the needs of the community rather than exacerbating existing infrastructure issues? This has worked successfully in a number of places, such as Milton Keynes.

Site BA2 & Site BA3 & BA4:
Objection to the proposal on the following grounds -
*Informed that the first build will be in site BA2 and BA3. As a result there will be pressure on the current schools, doctors surgery and other amenities such as the community centre, library and town centre parking. There is no mention of providing additional school or doctor services within the current plan for BA2 and BA3. This also applies to BA4.
*Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
*The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new 495 combined builds will generate at least another class worth of primary school children with nowhere to go and yet it is already significant problem.
*Limited parking available at Baldock railway station. Also, increased commuter traffic would put further pressure on already congested junctions such as the A505/A507 crossroads.
*No mention of what % green space will be provided, nor mention of tree planting to improve air quality, nor mention of parks for children.
*All construction traffic would need to go through the town causing air quality, noise and congestion issues.
*Without new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional primary school provision along with the new builds at sites BA2, BA3 and BA4 to cater for both the sites and the current children of Baldock. This to be available and online at completion of first phases of building.
*Recommend a variety of housing styles and increase the allowances of self-builds; this will reduce the monotony often associated with a housing development.
*Require each site to include a children's play park.
*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.
*Additional railway parking
*Additional town centre parking
*Funding to extend both the library and community centre
*Work rail 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)
*Ensure houses have sufficient parking. Modern developments seem to assume 1 car families and this causes congestion on the roads outside.

I am writing with concern to the proposed plans for the development of housing in Baldock. Whilst acknowledging that extra housing is necessary to meet the needs of the local population I must question the disproportionate number of new houses in Baldock compared to other areas in North Herts and the justification of the plans.
Concerning BA2 and BA3
There is no mention of providing extra provision for the increase in numbers arising from the 400 houses proposed, requiring registering at the only doctors surgery in the town. It is very difficult to book a same day appointment, unless you are lucky enough to get through on the telephone in the first few minutes of opening time. Long term bookings are at a premium and similarly difficult to secure, usually a two week wait.
There is no reference to school places for this stage of development. Currently there are two faith schools and one Primary school which is oversubscribed. The new houses will surely generate the need for extra places to be provided.
There is no reference to the planting of extra trees, the lungs of a community, as well as being of an aesthetic value. Do not the residents deserve a quality environment?

Concerning site BA1
The road network is already very congested at peak periods and this is exacerbated when either of the by passes are closed in times of emergency, which is not infrequent. As there are few opportunities within the town for employment, to which people might walk, it follows that the extra population will need to travel beyond the town. This will be either a rail or road journey.
There is tremendous pressure at the traffic light junction where the A505 and A507 meet. The tail back queues are a reminder that the junction cannot cope with the existing demand. This is an historic situation which has failed to be resolved due to the fact that the properties at this junction are listed. The impact on people who need to arrive in Baldock for work or school is significant and I have personal knowledge of a shop manager who has failed to open on time due to being held up in this traffic for up to an hour. The proposed mini roundabout (AECOM Table 5.1) will not resolve the congestion that already exists and therefore will not cope with the added volume of traffic.
If, as frequently happens the railway bridge with a head height of 14'6'', is struck by over height vehicles, then the congestion is severely impacted upon. The increase in traffic will only add to the probability of this occurring more frequently.
This road is not capable of carrying the current volume of traffic and as the IDP Traffic Baseline (para) shows that traffic in North Herts will go up by 16.1% anyway then the building of extra homes in this corridor is surely unjustified and not effective.

I am very concerned about air quality in the town; Baldock is located in a valley and consequently air circulation is not good. The volume of existing traffic means that there is a high level of emissions. The invisible ultra fine particles, PM2.5, emitted by diesel engines are a major risk to health as they penetrate the lungs and circulatory system. This increases the risk to the health of our children, the old and the vulnerable and in fact, to the whole community. It has been reported that prior to the Baldock By-pass being built in 1995, the levels of asthma in local children was well above the national average.
One only has to walk along Hitchin Street or Whitehorse Street at the beginning and end of the school and working day to be aware of this. In fact the levels are close to exceeding EU permitted levels (para 9.28). The housing and Green Belt background paper informs us that site 209E was considered unsuitable for these very reasons. Is not the quality of the air for Baldock residents not of equal value? The increased volume of traffic can only add to these levels. For this reason alone the plan is unjustified.
The plan is unjustified and not effective as there is not an adequate highways structure to take the extra traffic that will come with the development. Both vehicular and pedestrian, currently the A507 /Bygrave Road junction has poor sight lines when accessing the A507 from Bygrave Road, a significant increase in vehicular traffic onto the A507 will increase the accident probability at this junction; Bygrave Road is not even classified as a B Class road; the width of the road is not sufficient for safe passage, together with the blind bends, lack of pedestrian footpath along the rural section all add up to an inadequate facility, which would not be funded by the developers at the outset as the infrastructure aspects are always funded from housing receipts in retrospect, invariably resulting in a reduced scope, if at all!
The existing station is very small and there are proposed cuts to the existing train services by Govia. It appears that this company were unaware of the proposed development. Many people commute out of Baldock and the proposed development would significantly add to the volume of traffic entering the town. The car park is already limited and many commuters park in the surrounding residential streets. This has an impact on domestic parking. No provision appears to have been made for the extra parking spaces that will be required.
There is also no reference to provision of extra play facilities. Although some do exist within the town they do not have car parking provision, the BA 1 development will be too great a distance for young children to travel to enjoy any of the existing sites. Children need to have safe areas in which to play and exercise. There are already signs of obesity amongst primary children (in my professional role as a teacher I have seen an increase in such cases). We cannot deny them this essential facility.
No consideration appears to have been given to the natural environment and the fact that the area is home to several endangered species including the corn bunting, pipistrelle bats and newts. It is our duty to protect these species, not further add to the destruction of their habitats.
There is no modelling of the impact from the new developments on the infrastructure (AECOM section 7 summary). The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites especially the BA1 site.
Drainage is also a concern; as Baldock sits in a valley, flood risk could potentially be high. During recent heavy rainfall, the town has suffered flooding with St Mary's school suffering several times within a few weeks as the drainage system was unable to cope. This caused severe disruption to the school. A significant increase in hard landscape due to housing will always increase the rate of flooding (especially if the required infrastructure is not in place), the infrastructure in Baldock does not have the capacity for additional storm water or sewage treatment.
Baldock has a thriving community, we as residents; enjoy a good quality of life. The proposed expansion will irreparably damage the unique feature of this historic market town. Surely we should be preserving our heritage for future generations; it is their right to inherit this and ours to protect it for them.

We wish to protest about the utterly unfair, disproportionate and unjust proposed housing developments at Baldock which will ruin our lovely town. Ever since NHDC was formed Baldock, as its smallest town, has been at the back of the queue for everything and now the Council has decided to dump the bulk of its housing allocation on us simply because it is easy to do so and because we do not have the power or the votes to prevent it. It is a mockery of democracy and so-called localism.
Baldock has already undergone enormous expansion in the last 60 years or so and
particularly in the last 35 years. It is remarkable that it has managed to keep some of its rural charm, historic character and sense of community through all those changes and the indifference of successive Councils. It is unlikely to survive the sheer scale and rapidity of these latest proposals and a unique community will be lost forever.
Natural Environment, Historic Environment, Countryside and Green Belt:
* The Ivel
These four large developments are bound to have an adverse effect on the water table, threatening not only our water supply but also the rare chalk stream habitat of the River Ivel which rises on the northern edge of the town and draws its water from the same chalk strata. The Ivel already suffers from the growth of the town as it is now and the effects of an increase of a further 75% of housing could cause severe damage.
The Plan does not seem to have made any assessment of the likely damage to the water supply or the river nor does it include any plan to avoid these effects.
* Sewerage
The Plan does not say whether or not it has been ascertained if the sewerage pumping station at Baldock (all Baldock's sewerage flows into the Ivel after treatment) can cope with a 75% increase in sewerage and prevent an overflow into the Ivel.
* Green Belt
The Plan involves building on Green Belt contrary to Government guidelines when there is a preponderance of non-Green Belt land in the District.
* Heritage:
No account been taken of the historic landscape setting of the town contrary to
Government guidelines specifying 'that heritage assets are an irreplaceable resource'
and should be conserved 'in a manner appropriate to their significance'.
The Plan quotes the NPPF guidelines as saying that there should be 'conservation and enhancement of the natural and historic environments, including landscapes' yet it treats the historic environment as a separate matter relating only to conservation areas and listed buildings. A town or village is often an important part of a landscape and it is ridiculous to treat them separately.
The Plan claims to refuse developments (NE1) that are 'have a detrimental impact on the appearance of their immediate surroundings and the lanscape character of the area' without 'suitable mitigation' yet have not even considered the matter in regard to the proposed spoliation of some fine landscapes, particularly the very attractive valley and landscape views leading down to the town from the hills around Clothall and Quickswood which will be badly spoilt by BA2 & BA3. BA1 will also spoil an attractive piece of countryside on Bygrave Common which is an important part of the setting of the Ivel Springs Nature Reserve and of the town itself.
Infrastructure Delivery:
* Roads:
Baldock's road system in the historic town centre is already badly congested at certain times of the day with consequent severe pollution in Whitehorse Street and Hitchin Street where, according to |NHDC, levels of NO2 are 'close to exceeding National Air Quality objectives'. This is despite two major bypasses carrying non-local traffic.
Most of the traffic through and in the town is local traffic which appears to be going
between Baldock and Letchworth (the industrial estate of the latter being the main local source of local employment). This congestion is severely aggravated at the times of the school run. The main traffic queues occur in Hitchin Street, Station Road/North Road and Clothall Road because of the junctions at either end of Whitehorse Street (only about 250 yards apart) which street carries the greatest volume of traffic. The proposals for all four sites will add to this problem by adding local traffic in significant volumes yet the Plan claims that it 'addresses the protection of the health of residents'.
The great size of the BA1 scheme would greatly increase the problems in North
Road/Station Road, Whitehorse Street and Hitchin Street for the above reasons. The
railway line blocks any convenient alternative. The proposal to run a relief road to the eastern Baldock exit on the southern bypass is impractical because it is incovenient for most local traffic flows (ie. to Letchworth, where it would meet queues at Letchworth Gate,) and would mean a long detour to most local destinations to the west. It would also be very expensive. One might also add that if two major bypasses have not prevented traffic problems in Baldock this proposed relief road running in the wrong direction is unlikely to succeed.
The plan does not include any idea of the cost that the railway may impose for allowing a bridge to be built for the relief road, or the cost of the bridge, or who would be liable for the cost.
BA2, BA3 and BA4 would also cause further congestion at the Whitehorse Street
junctions and would cause increased traffic along South Road, a residential street not well adapted, or adaptable, to high traffic flows and already suffering as a 'rat-run'.
There is no obvious, viable means of alleviating these problems.
* The Railway:
The railway is already at capacity how will it cope with this number of extra commuters?
It is even proposed that the number of trains is to be cut which will make the situation
intolerable because many of the likely new residents will be commuting by train.
Logically large scale housing would be better sited near to the main line railway, not
this branch line, and near to the three lane section of the A1.
* Pedestrian access:
Pedestrian access to the town from BA1 is poor because of the narrow pavements under the railway bridge and the consequent risk to pedestrians and especially children, this will only add to the traffic problems as people would use cars for school runs etc. instead of walking.
* Services
The scale and speed of these changes will mean that the schools, medical services, the doctor's surgery will be unable to cope. Where is the money going to come from to pay for all this? Where will the extra doctors and nurses come from?
Conclusion There seems to be no attempt in the Plan to find any alternative to this inequitable and disproportionate distribution of housing. No real attempt has been made to encourage other landowners to come forward with possible sites, not even the County Council which holds many other parcels of land in the District. Why, for instance, have the large HCC holdings north of Ickleford not been considered? They are conveniently placed for the mainline railway at Arlesey and for major employment centres at Hitchin, Bedford and Letchworth.
Like so many plans of this sort this Plan contains many fine sounding aspirations and
policies which are simply ignored when it does not suit and is therefore so much highflown verbiage. This cannot disguise the failure to follow the NPPF guidelines in many instances, or the basic dishonesty and unfairness of these proposals which threaten the future of this town, its sense of community and its quality of life as well as the natural environment.

I would like to protest most strongly, on behalf of the members of this Society, about the possibility of massive and disproportionate housing development at Baldock. The following remarks refer to site references BA1, BA2, BA3 and BA4.
1. Historic Environment (HE) & Countryside and Green Belt (CGB):
As a History society the first matter we wish to draw your attention to is the effect any large increase in housing would have on the historic character and culture of Baldock and its setting within the countryside. This historic value of the town has been noted over the years by various authorities and I summarise them below for your information:
* Sir Patrick Abercrombie's Greater London Plan of 1944 considered Baldock to be
compactly developed with little discordant building and with a pleasing
relationship with the countryside, especially towards the north. In other words an
unspoilt, small country town. The report concluded that the town was "not
topographically suited for any appreciable expansion".
* In 1974 the Department of the Environment assessed the Baldock Conservation
Area as being of Outstanding Historic Interest.
* In 1977 NHDC and HCC jointly published the Baldock Town Scheme which
stated that "Baldock is one of five Hertfordshire towns listed by the Council for
British Archaeology as being of National Importance".
* Today the town has over 100 listed buildings in the town centre, equivalent, pro
rata, to an historic centre like Ely. It has one of the finest medieval churches in
Hertfordshire and the relationship of the church with the town clustered around in
its attractive valley setting is an important part of its charm.
Over the years neither BUDC nor NHDC have taken notice of these views or taken much care of the historic townscape and the rural setting which is so vital to it. The town has doubled in population since 1945 but nevertheless has managed to retain some of its rural charm and small-town feel because to the north and north-east there has been little development and because the countryside still reaches into the town from the south-east.
Yet these are precisely the areas that the Council have listed for development.
The Council planners appear to have completely ignored the requirement of the National Planning Policy Framework which requires that councils must "recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance."
Likewise they have ignored the Government's intention that the Green Belt (which, like all the countryside, must surely also be considered a 'heritage asset') should be
preserved. Instead the only discernable planning issue that appears to have been taken into account is availability and political expediency, that is to say, 'let us dump these houses on the smallest town with the smallest vote'. As Sir Oliver Heald, MP, has pointed out, Green Belt land is supposed to be protected wherever possible yet, even though most of the District is not Green Belt, the Council have allocated the bulk of the housing on Green Belt land.
It seems from their Local Plan documents that the Council considers that its
responsibility for the heritage aspect of the towns in its care extends only as far as the boundaries of their conservation areas (this is despite the requirement of the NPPF that there should be 'conservation and enhancement of the natural and historic environment including landscapes' clearly implying that the two are one and the same, and that the setting of one in the other is important.) The Council's Plan is indifferent to this and the likely consequence, as far as Baldock is concerned, can be seen elsewhere all over the country in, what English Heritage calls, 'heritage ghettos': isolated islands of old buildings along a street frontage surrounded by unsympathetic and inappropriate urban development and infilling. Baldock's heritage character is that of a small country town in its country setting and that is the 'heritage asset' that should be preserved and not simply a selection of old buildings.
2. The economic effect on the town (ETC):
To a great extent, the economy of Baldock town centre, such as it is, relies on its
attractive character to draw people into the town. However, if there is to be any
significant return to a prosperous town centre it will need to attract more tourists and visitors from outside the town because the experience of the last 30 years has
demonstrated that population growth does not bring noticeable extra trade to the town centre. The town has only one real asset to attract that further trade and that is its historic character, because it has little else to offer a visitor. Without that asset there is little hope of a recovery. The Plan says that the survival of tourism "depends upon conserving and maintaining the quality of the resources upon which it depends" (ETC5) yet in Baldock the housing proposals threaten to destroy that very quality of attractiveness that is its only relistic hope.
In fact there are signs of prosperity returning to the town centre for the first time in
decades and visitors are being attracted to the town because of its character. The recent improvements to the town centre seem to have played a part in this and, with the new Arts and Heritage Centre project, there are grounds for hope that things may improve further, but it is a tenuous hope and could easily be destroyed by massive, unsympathetic development.
I should also point out that these considerations do not apply, to anything like the same degree, to the other towns in the district which are already of such a size that a few thousand extra houses would make little difference to them. The proposals are more akin to hugely increasing in size an historic village like Ashwell. It will be noted that Council would not countenance such an increase at Ashwell and yet almost precisely the same arguments apply to Baldock as they do to Ashwell.
Natural environment (NE):
Apart from the aesthetic damage to the landscape these proposals will bring and the loss of valuable farmland (which ought to be considered vital for our food security) we are concerned about the potential damage to the River Ivel. It is noticeable that the Ivel, which is an important and rare chalk-stream habitat, as well as an important local amenity, has run dry on several occasions in recent years and there is the possibility of doing irreversible damage to the river, its flora and fauna and environment, if the local water table or the capacity of the sewerage treatment works is overwhelmed by such a large increase of housing. This is not a concern that is really dealt with in the Plan except in vague terms.
There is also the related question as to whether local ground water sources can adequately supply the river and a development of this size with water especially in time of drought.
A great deal of money was spent on carefully landscaping the A505 Bypass to minimise its environmental impact on the lower end of what is surely one of the prettiest valleys in the District with its picturesque views of the town from the hills at its head. This would be so much money - ratepayers' money - wasted if the 'trapped land' is to be developed in BA2, and BA3.
Infrastructure delivery (ID):
Baldock's road network is already under strain despite having two bypasses. For large parts of the day there is congestion in the historic town centre which cannot be relieved because it is caused largely by local traffic. The Council acknowledges that this already causes significant pollution in the Whitehorse Street and Hitchin Street areas which nearly exceeds national guidelines and yet despite claiming that your policy 'addresses the protection of the health of the residents' it will, in fact, make it worse.. A massive increase in housing would exacerbate these problems and, because so much of the traffic is local with local destinations, they are unlikely to be solved by the proposed relief road to the eastern A505 junction in area BA1. If the present town is still congested after the construction of two bypasses then a town 40% larger is not going to be relieved by a third bypass heading in the wrong direction. Wrong, that is, because most of the traffic through the town centre seems to be going to or from Letchworth with school runs also causing extra difficulties at certain times of the day. No one would use this proposed relief road to go to Letchworth, or the supermarkets, or the schools, because of the length of the
diversion and the likelihood of traffic jams on Letchworth Gate.
Area BA1 is a particular cause of concern here because its sheer scale is likely to cause severe congestion at the Whitehorse Street/Clothall Road/Station Road/Royston Road junction which will also have to cope with added traffic from BA2, BA3 and BA4.
Pedestrian access to the town from BA1 would also be severely limited by the
dangerously narrow pavements under the railway bridge and it is hard to imagine that parents would be happy for younger children to use it. This would add to the likelihood of BA1 being cut off from the town and increasing congestion on the school run.
The proposals for BA2, BA3 and BA4, as well as increasing traffic volume at the
abovesaid junction would mostly add to the existing problems in South Road, a
residential road that is already being used as a 'rat run' and is too narrow to deal with greater volumes of traffic The Preferred Options Plan appears not to have investigated the feasibility of the third bypass/relief road for BA1, either as a realistic means of relieving the congestion in the town centre or for its economic viability. In effect the railway holds a ransom strip and may use it to extract a sizeable sum. There is also the cost of building a bridge over the railway. Who would pay these costs? Is it the developer or the Council? If the latter why
should we be throwing ratepayers money at, what the NHDC's own planning portfolio
holder considers, a 'flawed plan'?
The proposed increase is proportionately so large and so rapid that it is going to put
severe strain on schools, medical services, surgeries, water supply and the railway system none of which are likely to be adequately catered for and some of which are beyond the control of the Council but nevertheless need to be considered. It will therefore cause significant problems and severely impact on the quality of life of the residents of this town and neighbouring villages.
As Baldock's treated sewerage flows into the Ivel it is vital that the treatment system is able to cope with a 75% increase in volume and be in place before a problem occurs. Has the cost of this been assessed and, again, who is to pay for the consequent costs?
NHDC's Vision and Objectives for Baldock:
It would seem that there is no discernable vision or viable plan for the future of Baldock beyond dumping the bulk of the District's housing problem here. There is no indication that there will ever be an ultimate capping of population/housing or any alternative to further urban sprawl, just a rush to solve an immediate problem.
There seems to have been no attempt to find alternative sites for housing in order to
spread the distribution more fairly. In particular there is no indication that Herts County Council has been approached about any of its other considerable landholdings within the District. There is a sizeable holding north of Ickleford, for example, on a very unremarkable, flat piece of countryside (unlike the attractive countryside around Baldock); it is convenient to Arlesey Station on the mainline which would be far better able to cope with increased traffic than the Cambridge branch line and it is on the main Hitchin to Bedford road with consequent employment opportunities in those towns, yet it has not been considered.
Baldock, on the other hand, has few employment opportunities, except those offered on the Letchworth Industrial Area, and this fact will be another cause of increased traffic through the town.
The consequence of dumping far more houses than the town needs, or that local
employers require, is that Baldock will become largely a dormitory town with a
consequent detrimental effect on its sense of community and its economy.
All three of our MPs consider the plan flawed, inadequate and unfair; even the NHDC
Planning Portfolio holder apparently agrees. If so, how can it be acceptable to proceed with a flawed plan?
Most people would surely agree that to meet the District's quota each town and village should accommodate its own housing needs and those of the employers and industries within those communities. It is against all natural justice and fairness that the quota should be allocated largely to one town simply because the land has been made available and because it is the smallest town with the least votes and power to oppose it.
This Local Plan threatens to destroy the identity of the last remaining small rural market town in your District and the equally precious sense of community that makes it such a pleasant place to live.

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

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

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 to 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.

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.

See attached

See attached

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 attachment