Letchworth Garden City

General Comments

1. Historic Towns
I am disappointed and surprised that Letchworth Garden City is not included in your designation of historic towns. The world's first garden city is of national and international importance, much studied and visited by researchers and planners. It is valued too by residents.

2. Numbers
Where have the enormous numbers of required housing come from? Increases of this size cannot be justified for the extension of small settlements such as Letchworth. Many existing residents are beyond child bearing age, so will not be producing more children who require housing. Where will the new residents come from? Letchworth has now reached its planned maximum size of 32,000.

3. Green Belt
Letchworth's Green Belt is an integral part of the garden city. It is where the idea of a green belt was pioneered. It has been much copied around this country and is revered around the world. It is part of national legislation, a valuable and popular part of planning laws. It has been reaffirmed by the present government which states that green belt should not be built on just to meet housing numbers. Open space is needed as well as housing.

Specific Areas
1. LG1 Land north of the Grange Estate
This area is not suitable for a large number of houses, which will destroy the green belt leaving only a narrow one field strip between Letchworth and Stotfold. As well as preventing urban sprawl, this land is valuable for biodiversity.

2. LG3 Land north east of Kristiansand Way
Here the green belt provides separation between Letchworth and the village of Norton, which has a long history as a separate settlement and is valued as such. There are archaeological sites here which need investigation and should not be built on.

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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.

Water and sewerage infrastructure is already struggling to cope with the density of housing in North Herts, one of the driest parts of the country. Local rivers such as the Beane are already over-exploited and suffering environmental damage. The Local Plan avoids all mention of the problem, let alone solutions. It assumes the local water authorities will cope with swathes of new housing, as is their statutory duty, but no-one has come up with an answer as to where the extra water is to come from.
It is assumed that new traffic congestion can be remedied by road-widening but in Letchworth this solution is not available. All Letchworth roads are narrow as its conception as a self-sustaining town would obviate the need for travel. Workers would walk to work, children would walk to school and car-ownership would be low. Narrow roads were bordered by grass verges, generously studded with trees, some of them rare. In this environment, road-widening would be totally destructive of character. The proposed new estate North of the Grange will feed its extra traffic through these narrow roads , causing severe traffic congestion through the Grange and Letchworth Centre, and, as it becomes predominantly a dormitory town (through failing to balance new housing with new local employment opportunity), extreme parking pressure on routes leading to the station (such as Cowslip Hill, Norton way North, Icknield Way) . On the other hand, if to avoid town centre congestion, it is decided to create new routes through to Stotfold Road to the West, or through to form a new junction with Norton road to the East, the new estate will lose its identity with the community of Letchworth. (Presumably, or hopefully, this is not the planners' intention.)
Significant erosion of the Green Belt (the first ever) means there will be only 500 metres between Letchworth and Fairfield to the North and Letchworth and Hitchin to the West. If this isn't Urban Sprawl then I don't know what is, and Green Belt was put in place precisely to prevent this sort of development. Once it's built on the land is gone and the wildlife will not just move to the next field!

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