Hitchin

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Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 219

Received: 23/10/2016

Respondent: Mr Justin Richards

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to development in Hitchin on the grounds of:
- existing traffic congestion
-insufficient public transport (buses and trains)
- expensive railway car park and capacity issues
- air pollution

Full text:

The roads in Hitchin are saturated during peak hours and any roadworks on the major roads result in significant congestion through the area.
The public transport infrastructure is either insufficient (buses) or utterly saturated (trains). The railway car park is hugely expensive and full everyday.
Meanwhile area pollution is above legal limits and causing health issues.
Yet the council sees it appropriate to build more houses by just adding on to existing towns.
Be brave and build new communities rather than drowning existing communities.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2835

Received: 30/11/2016

Respondent: Mr David Howlett

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (in general):
- Strategic Policies
- Evidence Base
- Economy & Town Centres
- Retail and leisure
- A Hitchin specific town centre policy
- Not recognised as a major employment centre
- Industrial/employment area with major access problems
- Transport - Congestion relief and public transport
- Rail services, infrastructure and access
- Specific transport or Hitchin policy
- Housing Strategy
- Population growth
- Scale of development
- Loss of Green Belt
- Significant historic environment and countryside issues
- Historic Environment, Town, Character, Assets and landscape
- Communities

Full text:

The following comments relate to the Local Plan 2011-31: Proposed Submission Draft. They are not intended as detailed root and branch comment on the document as a whole. They are meant to highlight issues from perspective of 'What will this Plan do for Hitchin?'.

Section 4: Strategic Policies - The need for better background

* 'Strategic' (and cascaded) policies should be policies resting on an evidence based District framework and accorded precedence/weightings according to realities identified within that framework. A general criticism of the Plan is that the District background/framework - its depiction of the detail, variety, distinctiveness, comparative strengths and opportunities within North Hertfordshire - is generally shallow and inconsistently drawn. This weakness in background is especially marked where that framework is specifically focused in Section 13: Communities. This section, with a thorough-going evidence base, should be the starting point for policy making not, as it is, a 'tack-on' at the end.

Section 5: Economy & Town Centres - The need for realistic hierarchy

* It is clear that Hitchin provides the District's main market, retail and service centre. It qualifies within the top 300 such town centres in the country. It is also clear that, overall, the levels of user satisfaction with its role are relatively high (see the NLP Town Centre and Retail Study 2016).

* District policy should, therefore, give a much clearer strategic priority to maintaining this key role for Hitchin and thereby reducing leakage elsewhere of business from the District: to do this would be to build on success. Yet the Plan actually recommends (see Section 13.220) in the medium to longer term the diversion of business away from Hitchin within the District. Such a policy risks undermining North Hertfordshire's key retail-commercial asset and should be rejected.

* Given its success and attractiveness some additional retail/commercial development in Hitchin town centre is logical. It must not, however, be a 'big-hit' scheme (such as the whole-scale redevelopment of Churchgate and its area) as the town centre's success has long been based on incremental growth and adaptation. Keeping this in view is particularly important given the major long term pressures of on-line commerce currently affecting traditional high street provision. In this context phased refurbishment of Churchgate and the Market area (identified as key contributors to the retail health of the town centre even in their present condition) should be linked to a sequential development of additional retail space (including some additional parking) on Paynes Park.

* Given Hitchin town centre's key place within the District a specifically focused and integrated policy to support it must be developed rather than resting on the fragmented catch-all approach advocated in the draft Local Plan (eg SP4, ETC3-5; policies HT11-12 need support from a wider Hitchin framework). A Hitchin specific town centre policy should recognise the significant input to town centre business activity provided by voluntary effort over many years and commit the District Council to support (but not control) that effort much more significantly than it does at present.

* Hitchin is an important 'evening economy' hub in Hertfordshire; such a function is an additional strand of commercial strength. There is, however, no specific recognition of this 'evening economy' and how such provision needs careful management in relation to more conventional day time retail and service functions eg working to avoid 'dead' frontages in key shopping areas.

* Hitchin is not recognised as a major employment centre in the District although it is, in fact, difficult to judge its ranking from the lack of systematic analysis provided; mention (SP3) is made of 'bringing forward' employment land but there is no Hitchin provision for this aim. Hitchin has a diverse and active industrial/employment area that is well occupied despite suffering some major access problems; the solution of these problems deserves a very much higher priority (SP3; there should be a HT policy to support the town's main employment area in addition to the access question; see also Section 7: Transport).

Section 7: Transport - The need for better coordination of congestion relief and public transport

* Transport issues, beyond the very local, pose a challenge to a District Council Plan given the key responsibility of the County Council although SP6 promises to 'deliver' on sustainable transport. It is important, therefore, that the District Council develops coherent views on the transport issues within North Hertfordshire so these can be deployed effectively to influence County decision making.

* The draft notices, but not effectively enough, a number of key (judged in county terms) road congestion hotspots within Hitchin but has no decisive proposals to 'deliver' any amelioration.

* The draft Plan fails to recognise Hitchin's key role as the District's main railhead (a junction, variety of services and destinations and over 3m passengers per year making it the busiest station on the Great Northern after Kings Cross/Finsbury Park, Cambridge, Peterborough and Stevenage). The draft Plan also fails to confront the challenges of Hitchin station access (pedestrian, cyclist, bus, and car), especially from the east. Nor does it recognise the need to improve significantly linkages at the station with Hitchin's useful portfolio of bus services, including key east-west links to/from Luton and Bedford. These omissions need remedy to achieve 'delivery'.

* As noted above the draft Plan does not have any effective response to the problem of vehicular access to Hitchin's important industrial-employment area; a specific transport or Hitchin policy is needed to achieve a solution to this problem.

Section 8: Housing Strategy - The need for variation, inclusion and Green Belt reinforcement

* Hitchin has seen steady population growth over recent decades; in the period 2001-11 it took over 60% of the new dwelling permissions that were granted in all of the four towns of the District and is again the largest urban centre. The town has recently appeared several times in 'Top Ten' surveys of desirable national living locations, has a good quality retail-commercial base, excellent state primary and secondary education, and good road and railway connections. As such it is inevitable that pressure for housing development in Hitchin will continue.

* It is, however, becoming increasingly difficult to accommodate this pressure while preserving both the town's attractive mixed residential make up and its vital Green Belt buffers, especially in the east. The draft Plan understandably allows for some additional expansion (SP17, HT1-10) including one major estate development (Highover Farm) on the east side. This latter does, however, require very sensitive handling to preserve long term Hitchin's eastern Green Belt and also to allow for the effective 'stitching' of the new housing into the adjacent residential areas with some forms of access to Grovelands Avenue and Highover Way along with a carefully sited access on Stotfold Road. The scope for housing development elsewhere (including infill) is now very limited and would raise significant historic environment and Green Belt/countryside issues (SP5).


Section 12: Historic Environment - The need for better more consistent enforcement

* The policies supporting the Historic Environment (SP13, HE1-3) are to be welcomed. Hitchin's continued success as a 'historic market town' commercial hub and attractive residential centre rests heavily on high quality management of its historic character. This cannot be an 'aspic' policy if the town is to continue to adapt and thrive but it must be a constructively enforced policy. Too often in the past historic environment issues have been over-ruled by short sighted reasoning in favour of unsuitable redevelopment.

* Management of Hitchin's historic environment also requires a more intelligent and connected policy towards its urban morphology as a whole. It is deeply disappointing that modest but intrinsically interesting suburban townscapes have been damaged by over intensive or out of keeping redevelopment. There is also the point that the shape of the modern town, as defined by roadways, paths and building plot shapes and sizes, is an important legacy of the fact that the town was never formally 'enclosed' meaning many of its urban 'patterns' still show influences dating back to its very earliest origins centuries ago. It makes sense to ensure that the policies on Design are truly tuned to distinctive local circumstance (SP9, D1) and linked to the historical contexts.

* Hitchin's historic landscape also includes the surviving extent of Priory Park. Despite the insertion of a relief road in 1981 this area still has many historic features (defined as including key planted areas) and as such should be accorded a much higher level of protection, such as English Heritage Designation, in the context of its Grade I Listed Building. Additionally, there should be no possibility of any of this area being considered for residential development.

Section 13: Communities - The need for a much better encapsulation of the District

* The poor quality of this section as a foundation for policy making has been noted above. If the question is posed 'Can you recognise Hitchin?' from its entry the answer is 'no' because the coverage is thin, partial and inconsistent.

* All the District's settlements need much more careful, consistent description and analytical assessment. The District is very clearly not a 'one centre' authority suited to top-down policy making: only by understanding and responding to local characteristics and variations can policies be properly applied and, as important, gain local acceptance. There needs to be much more scope for 'bottom up' influence in achieving solutions.

* The whole Communities section requires, therefore, a tighter and more systematic treatment of historic background, retail/commercial, service, industrial and agricultural aspects so the characteristics and needs of different areas of the District can be more easily compared and prioritised. This picture should be supplemented with relevant comparative analysis of the employment, economic ranking, district function and travel-transport importance of the various settlements. A logical outcome based on this revised background would be the development of a more graded Settlement Hierarchy to inform decision making. The draft Plan is prefaced (Section 2.6) with the remark that 'North Hertfordshire is a diverse area' but the following 240 pages do far too little to give reality, in the delivery of policies, to this key observation.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4320

Received: 30/11/2016

Respondent: Stevenage Road Petition Group

Number of people: 210

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (in general):
- Highway infrastructure and congestion
- Noise and air pollution
- Highway safety
- Parking infrastructure
- Consultation process and prepared petition
- Need for new dual carriageway by-pass
- Pedestrian safety and infrastructure

Full text:

We, the residents of Stevenage Road, Hitchin, wish to bring to your attention our increasing concerns regarding our area and the impact of the present traffic using Stevenage Road.
Over recent years, the traffic has increased quite dramatically in terms of volume, speed, noise levels and pollution. These factors are having an immense impact upon the quality of life, stress levels and concerns for health and safety, as when trying to park, getting into and out of our cars and crossing the road. The latter activity can often take a few minutes before a gap appears to enable one to cross.
As residents, all of us are aware that the traffic is continually increasing, with a resultant increase in accidents and creating the impression that we are captives on our own residential road.
The following are factors which greatly contribute to the problem:-
1. The road is now a primary route for traffic going to Luton, Luton Airport, Bedford, all of the local Hitchin areas, including industrial areas and rural villages.
2. A significant proportion of the traffic is HGV or very heavy articulated type, often causing tailbacks, particularly when two such vehicles try to pass, sometimes with damage sustained by residents' and visiting cars or vans.
3. For a great number, the road has become a rat-run for many of its users, including for school runs and local businesses. Whenever possible, vehicular speeds are clearly very often in excess of the 30mph road speed limit and quite often up to or exceeding 45mph.
4. The road is also used for parking by many people who work in Hitchin.
5. Quite often, heavy goods vehicles park on the road, thus creating chaos for all road users, particularly residents.
We contacted North Herts District Council about our concerns and were advised to organise a petition. To this end, in the short time allowed us, we have raised a paper petition as best we could, whilst there is also one on Facebook. Herewith this letter are names, addresses and signatures of residents in Stevenage Road and other people in the area who share our concerns and appreciate the problems. Some local schools and churches in the area have also contributed. Should a later date of submission of this petition have been offered, we are certain that we would have raised very many more signatures.
We all believe that there is only one satisfactory solution to the very serious traffic problem in Stevenage Road. This solution would provide a new, dual by-pass, which would carry the traffic from the end of the dual carriageway between Corey's Mill and Hitchin at Wymondley, around St Ippolyts, to connect up with the A505 Luton Road and possibly the A600 Bedford Road.
The above are the basic reasons why we are lodging this petition. We accordingly beseech the Council to kindly promote and organise the implementation of this vital piece of infrastructure, which will make our lives and their surrounds tolerable and benefit the area as a whole.

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5416

Received: 28/11/2016

Respondent: Mr Darren Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (in general):
- Highway infrastructure and congestion
- Luton Airport
- Noise and Pollution
- Highway and pedestrian safety

Full text:

I object to policy SP6 on the basis that i) the evidence basis is flawed, as it does not take account of traffic growth generated by developments in neighbouring boroughs, such as the expansion of Luton airport.
ii) That proposals HM8/HM10 are inadequate. We really need a bypass (such as scheme 80 in long list of schemes for Herts Transport Vision) to cope with the volume of traffic and address noise, pollution, safety and congestion caused by such a high volume of traffic travelling from Luton to Hitchin on A505. Once the road enters Hitchin (Offley Road) the single carriageway is inadequate, there are already long queues for hours every day. In addition to the resulting loss of time/productivity and resultant pollution in a residential area, there are safety issues given the narrow paths (particularly Upper Tilehouse St) used by many children ( e.g. route to Samuel Lucas school) and local residents, many of whom are elderly.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5878

Received: 28/11/2016

Respondent: Mr Andrew Wearmouth

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (in general):
- Highway infrastructure
- Narrow railway bridges
- Local employment opportunities
- Sewerage and drainage

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6017

Received: 24/11/2016

Respondent: Hitchin Town Action Group (HTAG)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection Hitchin:
-'tailor made' approach for Communities needed
-a more accurate description of Hitchin should be devised to support the current and future roles of Hitchin within the District
-Hitchin historically the central commercial and administrative town.
-the major town centre in the District
-main communication focus of the District in terms of rail and bus links.
-diverse social structure
-balanced assessment needed
-largest urban centre in the District
-traffic congestion,car dependency,air quality
- traffic speed reduction needed, safety
- Paynes Park gyratory - hostile for pedestrians and cyclists- possibly making two-way
-water supply
-sewerage

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6036

Received: 29/11/2016

Respondent: Hertfordshire County Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (general): Existing Bearton Green reserve school site allocation should be carried forward, additional stock shelving and IT at Hitchin library to meet demand

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6173

Received: 24/11/2016

Respondent: NHDC Baldock Town Councillor

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Hitchin (general): Green Belt (sprawl, encroachment)

Full text:

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

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6200

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to amended Green Belt boundary (see comment on para 6.26) from current established position solely because there is an equally or more defensible location elsewhere is contrary to national green belt policy. Significant harm to GB and purposes

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