Spatial Vision

I live in Knebworth and run a professional small business there.
Although my knowledge is strongest for the area Codicote-Knebworth and its links to Stevenage, Hitchin, WGC, St Albans and Luton, the vision for growth is highly necessary for the continuing economic sustainability of North Herts, and the vital provision of homes. However, the impact of the proposed growth at the margins on settlement centres, roads and access demands clearer statement of over-arching obligations of developers.

1. You cannot state that "North Hertfordshire will be an attractive and vibrant place " when you continue to build and over-populate the area. This is absolutely contradictory.

2. "New development will help to maintain and enhance the vibrancy of existing settlements" - this is not accurate as the transport infrastructure is already saturated.

3. "The District will play its part in addressing climate change by improving opportunities for travelling by public transport" - Nitrogen dioxide levels are already above legal limits. How can the council make this factually inaccurate statement as more housing will increase pollution.

How can an increase of 73% in housing stock in such a short time safeguard the "vitality and vibrancy" of Baldock. It will stifle and kill it. I also fail to see how over 3,000 new houses in a rural area will "protect and enhance" our rich biodiversity.

The vitality & viability of Baldock have not been taken into consideration with the proposed houses for the Town. Increasing the size of the town by 80% will do nothing for Baldock's historic market status. It is 1 of only 5 Herts towns classed as being of National importance for its historic character and has over 100 listed buildings. The extra pollution from the 'Baldock bowl' phenomenon will affect both human health as well as that of the historic architecture. We would either have a 'new town' on the edge of Baldock that has little involvement with the Town or a settlement that will destroy the fabric of the Town. Neither should be allowed to happen.

Site BA1 does NOT meet any of the aspirations laid out in bullet point 2 of 'vision'

New development will have contributed to the creation of sustainable communities.
- A near doubling of the size of Baldock in site BA1 is NOT sustainable, it makes another town with poor transport links and virtually no local shopping facilities.

These are safe, attractive and inclusive;
- Not attractive, being built on Green belt land which gives Baldock its character, and not inclusive, being divided from the rest of Baldock by the railway line.

well integrated into settlements;
not Well integrated, being divided from the rest of Baldock by the railway line and provided by transport links which are already congested.

respect local distinctiveness;
- Actually destroys local distinctiveness by building over a very large tract of open green belt land which gives Baldock its distinctiveness.

raise the standards of sustainable design and architectural quality;
- No comment

make a positive contribution to the local area;
- Gridlock on local roads and flooding in its rivers is not a positive contribution.

and ensure the protection, restoration and enhancement of valuable natural and historic resources.
- Building over a very large tract of open green belt land does none of these things.

Strategic sites will have been masterplanned in accordance with the guiding principles set out within this Plan
- Remove site BA1 because it meets none of these guiding principles.

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The Bedfordshire and River Ivel Internal Drainage Board makes the following comments to your proposed Local Plan 2011 -2031 consultation.

The Plan does not adequately address Flood Risk and should be amended to strengthen the requirements of addressing flood risk and development, particularly in the north of the District in Letchworth and Baldock.

Below are some examples of paragraphs which should be redrafted to ensure development does not have a detrimental effect on flooding:

2.29 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

2.78 The paragraph must include infrastructure that is required to accommodate growth as SuDS which are strategic, integrated and maintained. This is critical given the scale of development in Letchworth (900+ houses) and Baldock (2800 + houses).

3.6 The spatial vision of high quality sustainable design and managing flood risk needs to refer to the provision of strategic and integrated SuDS, which include effective and funded SuDS maintenance.

4.73 Policy SP7. This infrastructure should include SuDS and flood risk management, such that a public authority can ensure drainage infrastructure operates as designed in the future.

4.131 Policy SP11. It is inadequate to state that this Plan 'seeks'.... when other policy state 'will'. The Policy should state the Plan will deliver the provision of strategic and integrated SuDS that will be maintained.

4.136 For clarity, WFD seeks to meet good ecological "potential" for heavily modified and artificial water bodies, as well as good ecological "status" for natural water bodies.

4.137 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

SP14. Downstream of Baldock is Stotfold which has experienced flooding from the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

SP15. Downstream of Letchworth is Stotfold which has experienced significant flooding from the Pix Brook and the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

NE7. There is a requirement to reduce the existing flood risk in Stotfold immediately downstream of the urban runoff areas of Letchworth and Baldock, as in SP14 and SP15, this Policy should be strengthened to include mitigation being designed and implemented on development sites to attenuate flows c) and d). It is fundamental that flood risk is minimised and that functional and effective infrastructure is provided that is maintainable in addition to items e).

NE8. This Policy should include strategic, integrated and maintainable SuDS for all sources of flood risk, and not just surface water, particularly given that flood risk exists from the Ivel and Pix Brook. The area is heavily modified with public storm sewers, modified watercourses and large flood attenuation reservoirs (Pix Brook), so any solution for development needs to be appropriate to the scale of development, rather than simply mimic the natural drainage pattern.

NE8 and 11.59. For developments draining in the Ivel and Pix Brook catchment, the Council and developers should also consult the IDB, as well as the Lead Local Flood Authority and the EA.

NE9. For any development in the Bedfordshire and River Ivel IDB district, a developer will be required to comply with the Board's Byelaws including maintaining a minimum 7 m wide undeveloped buffer zone for ordinary watercourses and applying the land drainage consenting regime.

I trust you find the Board's comments clear and informative.

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