Policy SP1: Sustainable Development in North Hertfordshire

The Parish Council supports this policy and the principles which underlie it. Application of this policy, however, depends on the detailed policies and proposals set out elsewhere in the Local Plan.
These points are elaborated in the Parish Council's representations on specific sections of the Local Plan, particularly on Knebworth.
For example, Policy SP1(c) (I) states that the District Council will "deliver and appropriate mix of homes, jobs, and facilities." In Knebworth, this is not embodied in policies KB1 - KB4, which are concerned with the delivery of housing and no employment. In fact the implementation of policy KB3 would result in the removal of a key employment site in the middle of the village. This is not sustainable.
Policy SP1 (d) pledges the District Council's support for Neighbourhood Plans. In our view, this has not been delivered in the four years since the launch of the Government initiative on Neighbourhood Plans.
The District Council's approach needs to be strengthened to give a more positive encouragement to town and parish councils and other qualifying bodies. For example, in East Hertfordshire, the recently-published District Plan contains a policy which devolves the responsibility for housing allocation and detailed local planning policy to town and parish councils in Group 1 settlements through Neighbourhood Plans. It is recommended that this approach should be adopted in North Hertfordshire. This would ensure that the scale and mix of development provided in Category A villages is appropriate to the size and status of the settlement and is endorsed by the local community.

The Parish Council is concerned that no account appears to have been taken of the recent Knebworth Parish Plan, which was published in 2007. This does set out some clear guidelines on the character of the area, the constraints and opportunities for development, and the aspirations of the local community.

Rose Farm. Boundary Appeal/ Sustainable Development. doc attached.

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Herts LEP supports this policy

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!

The entire plan is not sustainable, due to the piecemeal approach of the plan. It is obvious the plan is not a plan as such but rather that NHDC has asked land owners and developers to suggest sites for development with little thought to the problems some sites might create, such as increased flooding, increased gridlock at peak times, especially on the A1 (M) and junction 8 in particular, increased air pollution from standing/slow moving traffic, destruction of established communities, destruction of villages and the character of those villages and the views of local people. For example, any local plan should have the support of the local people - NHDC have been advised in previous consultations on this plan, and in particular site WY1, that the local people do not support 1) removal of green belt in their small villages, 2) developments which are inappropriate in size and scaled (such as site WY1, which is an increase of 100% of dwellings in a very small village) and 3) anything which threatens to increase flood risk, air pollution or gridlock - the plan unfortunately, across many sites, and when viewed along with Stevenage Borough Council's plan, does indeed cause some very serious and irreversible problems for all residents, current and new, with the majority of their proposals in this plan. Green belt is supposed to permanent, and supposed to stop urban sprawl. NHDC's proposals to move the green belt from around site WY1, massively increases the risk of the tiny village of Little Wymondley merging into a mega town of Stevenage and Hitchin (locally known as "Stitchin"). Furthermore, there is no local need to double the size of the village. As well as there being no local need for such a large development in this village, there is also a local fear that such a sizeable development would irreversibly alter the character and social cohesion of the village. We have an excellent community spirit in Little Wymondley, where people know and help each other, and it is a safe environment for people to live, which is why so many of the residents chose to live in a small village, surrounded by Green Belt, which the government led people to believe would always be there. It is worth noting the that the NPPF states there must be the existence of exceptional circumstances to alter the green belt, but none are demonstrated in this plan. Whilst it is recognised that there is a housing shortage in the area, NHDC state in this plan that there are 1,600 households on their housing waiting list so why do we need to build 14,000+??? The existing figure in the plan was created prior to the UK voting for Brexit, where any plans had to take account of the free movement of people throughout the EU. Once the UK is not part of the EU, it is highly likely that this free movement of people will not be a feature of the UK, so any calculations based on this policy, need to be revisited. It is also recognised that there are people not on the waiting list who will require housing in the plan period, such as young adults currently living at home, however, the answer to the housing need, IN A SUSTAINABLE FASHION is to build a new Garden City - NHDC has the land, just not the will, to do this, and yet this solution to sustainable development is not a new suggestions to them and I believe they have now requested the funding for this but fear they won't be able to deliver it within the plan period, but this is not true. There is also no adequate assessment of infrastructure needs in the NHDC plan, instead, the buck is passed to HCC. This is therefore not a positively prepared, justified, or effective plan, and it is not sustainable, nor is it consistent with national policy. In fact, the plan actually contradicts it's own policy SP1, particularly with regard to these comments in the same:

b. Ensure the long-term vitality of the District's villages by supporting growth which provides opportunities for existing and new residents and sustains key facilities;
c. Grant planning permission for proposals that, individually or cumulatively:
ii. create high-quality developments that respect and improve their surroundings and provide opportunities for healthy lifestyle choices;
iii. provide the necessary infrastructure required to support an increasing population;
iv. protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure (including the water environment); and
v. secure any necessary mitigation measures that reduce the impact of development, including on climate change;

The build on site WY1 is in direct contradiction to all the above points. Particularly as it is already in a pollution hotspot and the plan increases standing traffic and gridlock in and through the village, contributing to hight levels of nitrous dioxide and the associated healthier issues. Also, it is worth noting that the site WY1 was previously a landfill site, so who knows what is buried in the ground there and what harm it may cause should it be built on with houses and/or a school? There could be radioactive material buried there which could cause huge health problems in the future.

David Levett opens the plan document with the statement "North Hertfordshire is one of the best places to live in the country and with that comes a unique set of challenges to keep it that way. People want to move here to enjoy our lifestyle, those of us who are lucky enough to live here want to stay" he then goes on to state "That growth needs to be managed and controlled in a way that will protect and enhance the area in which we live and keep it one of the best places to live" unfortunately, nothing in his plan will make Little Wymondley a better place to live - it's residents will be forced to live with a heightened risk of/fear of our homes being flooded, more health issues as we deal with at least twice the amount of passing traffic and a huge increase in standing/queing traffic to get onto the A1 (M), irreversible changes to the character of the community as such a large development will intrinsically change the character of our environment, and a loss of open countryside/green belt, all of which leads to a picture of it being far from a great place to live with a good lifestyle, but rather a miserable existence with our homes and health put at unnecessary increased risk of damage.

IMPORTANT Note - I left the "Soundness test" boxes unticked, as a tick indicates a positive, and I thought ticking them meant "yes, the plan is . . " however I cannot submit my comments if I do not tick the boxes, therefore i have ticked them all to say that the plan does NOT meet any of the soundness tests.

I support the notion that development should be sustainable.

With particular respect to Knebworth there are insufficient park and green spaces; the railway is running to capacity and cannot be expanded without upgrading the viaduct at Digswell; people are already parking up to half a mile from the station causing inconvenience to local residents and to anybody trying to use the residential streets; Deards End lane is a conservation area and is unsuitable for commercial traffic; the listed railway bridge over the East Coast main line has a weight limit.

We support the principles of sustainable development and policy SP1. However, the proposed policy SP2 are not compatible with the principles of this Policy (SP1) as they do not ensure the long-term vitality of all villages in the District as they restrict the development in particular settlements.

how can you be prepared to put 900 houses in an area where has no facility to take the extra load of traffic. Every morning its gridlock down into the old town down rectory lane and pass the hospital, how can we take 100s more cars every morning and evening at peak times we cant get out onto north road now we will be queueing for half hour maybe an hour to get to the old town it is ridiculous to think a change to the graveley junction will solve this. Apart from this the land is one of the only beauty sites left in Stevenage that is used by residents and walkers every day all year round which must not be ruined by Stevenage borough council. Has anyone in this process thought about and been involved with the views of the residents asked opinions and kept them up to date with the plans it has been handled in a disgusting manner by Stevenage borough council.

There is no strategy for improving or maintaining employment opportunities in Knebworth. The closure of the Chas Lowe site and its replacement by housing is the complete opposite.

In order to accommodate the predicted population growth with the minimum impact on carbon emissions and traffic congestion ConnectedCities focuses all development on sustainable transport. See http://www.connectedcities.co.uk/sustainable-growth

It does not consider development where this is not possible to be sustainable. See http://www.connectedcities.co.uk/vision-2050/green-belt

Site at Cricketers PH, Damask Green Road, Weston

We support the principles of sustainable development and in particular sub-section b) "Ensure the long term vitality of the districts' villages by supporting growth, which provides opportunities for existing and new residents and sustains key facilities."

The principles of sustainable development within North Hertfordshire as set out in Policy SP1 are supported.

In particular the Council at section (b) the policy is correct in seeking to ensure the "long-term vitality of the district's villages by supporting growth which provides opportunities for existing and new residents and sustains key facilities". This growth includes at C(i) the need to "deliver an appropriate mix of homes, jobs and facilities that contribute towards the targets and aspirations of this plan".

The Council is to be applauded insofar as the Council states at paragraph 4.2 that in implementing the Plan it "will take a positive approach that ensures we can continue to permit the significant majority of planning applications for new development".

This policy is considered generally sound in that it recognises at (a) the need, inter alia, to focus development in key settlements and on Previously Developed Land. The district being largely rural in character, the policy acknowledges the need at sub-section (b) to "ensure the long-term vitality of the District's villages by supporting growth which provides opportunities for existing and new residents and sustains key facilities".

Weston

This policy is considered generally sound. In particular we support sub-section (b) which seeks to ensure: "b) the long term vitality of the districts' villages by supporting growth, which provides opportunities for existing and new residents and sustains key facilities."

We support the general principles of sustainable development set out in the above policy. In particular, we support sub-section b) which "ensures the long term vitality of the districts' villages by supporting growth, which provides opportunities for existing and new residents and sustains key facilities".

The draft Plan is neither positively prepared nor fully justified, as it proposes the erosion of, and development on, a significant amount of Green Belt, for a housing requirement based on unsound data. The draft Plan does not consider a number of potential alternative brownfield sites, nor housing development sites recently approved. Furthermore, the estimate of future housing requirement has been reached from the Strategic Housing Market Assessment, which was prepared before the EU Referendum vote and does not consider the resulting effect of reducing immigration. It therefore does not demonstrate sufficient need to justify removing Green Belt.

The Blackhorse Farm site in the plan will be a new settlement, with new infrastructure required and the updating of old, requiring the destruction of natural habitat and a burden on the existing environment and structures. This does not satisfy the requirement of 'effective use' of land by re-using land that has been previously developed. The plan clearly contravenes the whole 'Sustainable Community Strategy' encouraged by the National Planning Policy Framework. The allocated site does not promote and improve the economic, social and environmental wellbeing of the area

The Council needs, along with UK Government, to completely overhaul it's current thinking on housing policy for the country's current and future need.
No authority seems to be taking into consideration the sudden expansion of our population, which is driven by immigration, which in turn is causing a steep rise in the birth rate. If our economy were to take a sharp downturn, many new comers would move on to other countries or return to country of origin. Gained knowledge of this from experience working for the London Borough of Bromley's Housing Benefit & Council Tax department for many years. We could build millions of homes which could suddenly become empty having lost our countryside in the process.
The shortage of decent homes we are currently suffering from has many causes and no simple solution. Our old cities & towns need careful consideration how to either replace or refurbish existing housing stock. A stroll around Luton and Stevenage streets can shake you how folk live in run down and ancient housing. Hitchin has it's share, having seen parts of Purwell and the truly awful block of flats in Queens Road overlooking St Mary's Square car park. Who in their right minds allowed that construction, the building is showing it's age and suitability as decent housing. Letchworth, along with the other places mentioned, has many empty retail shops and sites on it's industrial areas. Strong minded ideas for usage of such sites must be considered for change of use to housing. City and town centres need people living in them, not empty when shops etc are closed, dead areas after 6pm.The old and young without cars especially appreciate living in the heart of towns, which can have a good effect on retail, catering and entertainment opportunities for start up of new business.
Climate change is going to drastically change countries ability to produce food for the World's expanding population. North Hertfordshire is blessed with it's arable lands, they should be preserved for the growing of crops, which could change from cereals to orchards, if countries currently growing huge fruit crops are affected by drought, trees also help take up carbon from the atmosphere.
To build on our beautiful countryside when our local cities and towns are in urgent need of regeneration is a crime, particularly for the local young generation, they will be the losers in this rapidly changing face of England as we know it.
All the transport systems in North Herts area suffer from overcrowding at strategic times as am sure the Authority is well aware. Building on sites around our cities and towns will further exacerbate congestion, just make life even more difficult and unpleasant.
Milton Keynes, Peterborough and Cambridge are all expanding rapidly, Biggleswade is looking a mess with the centre deteriorating yet new housing and retail parks erupting on the outskirts, Bedford the likewise, the thought of North Hertfordshire going the same way is unbearable. Our environment, either the built, farming or natural must be comfortable and a pleasant place to live and enjoy. Please reconsider this plan, leave the fields and open spaces and look to the state of existing run down areas or under utilised and brown field sites to provide the housing we currently need.

I wish to object very strongly regarding the District Council's 25 year Development Plan, which in many respects is fundamentally flawed.
By indiscriminately developing such vast quantities of housing in an ill- conceived manner, will create an unpleasant habitat, imparring the excellent quality of life, which the existing population are entitled to. We must also consider the high quality farmland and countryside that your Council will be responsible for ruthlessly destroying.
With regard to the former, the onus must be placed on N.H.D.C.to dramatically mitigate the loss of so much of our rich crop growing farmland that is needed to feed our population.
To develop so much of this confined area with so little attention to the infrastructure, and the necessary added services such as health, schools, policing, is going to be suicidal for this reverred area.
The voice of the electorate must be acknowledged, and respected.

Policy Sp1 - Sustainable Development in North Herts Building 300 plus houses onto a village of 340 properties is not meeting in a sustainable way the needs of the residents of Wymondley. It brings with it issues of coalescence.
There does not appear to be in place any infrastructure, support plans or funding which would be needed to support a development of this scale.
The council has produced no evidence of exceptional circumstance to build on the Green Belt. They have unused Brownfield sites and non- Greenbelt sites available.
A development of this scale with hard surface run-off, particularly from roadways, will increase the flood risk in Little Wymondley which has a recent history of significant flooding.

Policy Sp 5 - Countryside and Green Belt This supports the principles of the Green Belt. The council has not, we believe, demonstrated or justified removing land from the Green Belt to make it available for building.

Policy Sp 6 - Sustainable Transport
The local area is already prone to gridlock on a daily basis in the rush hour and any minor delay can be the trigger.
The junction in Great Wymondley is identified by the council themselves as a particular problem. It already it has extremely high levels of 'rat running' as the Neighbourhood Plan traffic data confirms.
The local country lanes cannot simply be widened as this would destroy the rural nature of the parish.
The situation is made worse by the inability of the A1M to cope with the volume of traffic, forcing motorists to use alternative routes through the villages.

Policy Sp 8 - Housing
A 100% increase in the size of Little Wymondley housing stock is disproportionate to local needs as confirmed by the Neighbourhood Plan.
Hitchin on the other hand is just being asked to have a 10% increase!

Policy Sp 10 - Healthy Communities
Removing existing Green Belt land seems to be at odds with the policy statement to protect, enhance and create new physical green infrastructure to foster healthy lifestyles.
The levels of airborne pollution on the A602 already regularly exceeds the legal limits at the Air Quality Monitoring Point and is already one of the worst in the county. Additional traffic can only make the situation for the residents.

Policy Sp 11 - Natural Resources and Sustainability There is no budget to address the issue of the collapsed culvert in Stevenage Road which contributes significantly to flooding risk.
The drain clearing programme is ineffective and also adds to the flooding problem.
The SuDs regulation would not cover all aspects of a potential large scale development and hard surface run off would again contribute to potential flooding. The EA flood maps also shows the potential for water run off from the south of Stevenage Road.

Site WY1

The surface water movement through Little Wymondley is a major issue and there is currently no structural plan or adequate financial commitment to address this issue satisfactorily .
Currently surface water runoff from agricultural land to the north of the village and downstream water from Corey's Mill is sufficient to create flooding of properties in Stevenage Road Little Wymondley as has happened historically.
There is not just the problem of surface water runoff from the possible additional building in Little Wymondley but the construction of hundreds of houses in the upstream catchment area on the eastern side of the A1M with its associated runoff.
Additionally plans by Stevenage Borough Council to build an industrial complex directly on the flood plain at Corey's Mill will make the situation even worse.
Downstream at Nine Springs at the bottom of the Wymondley Road a greater flow of water will create a significant additional flood risk to properties bordering the stream culvert.
A practical and funded solution must be found for these problems before any commitment to further building is given the go ahead.

In Conclusion:-
The Wymondley Neighbourhood Plan states the residents' acceptance for housing need but that it must be on a manageable scale.
The Plan also clearly states opposition to building on Green Belt land which provides space between the area's villages and towns thus preventing urban sprawl eliminating the rural nature of a North Hertfordshire.
Clearly the traffic and flooding issues of the area need to be resolved before consideration is given to any substantial house building.
A retrospective approach with the traffic gridlocked and flooded properties in the area is not the way forward.

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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 homes at North of Baldock (site BA1).
Other policies referred to are SP1, SP4, SP5, SP6, SP7, 9, 10, 11, 12, 13.

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 UNJUSTIFIED 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 UNJUSTIFIED as it is not the most appropriate strategy.

3. 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. Before the build asthma levels in 5-16 year olds was at 15% and the bypass brought them down to the national average of 6%.
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. 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 mini-roundabout 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 road 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 of these new houses at this junction refers only to Icknield Way East, not the Station Approach nor the A507 on to which they both deliver traffic. Inadequate research and modelling.

Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). 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, 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. See appended photo of lorry hitting bridge just before photo taken at 12.43pm on November 9th 2016 necessitating two police vehicles. Also the screen shot of ongoing congestion as a result at 1.30pm. This is a regular occurrence. Screenshots of the A507/ B656 junction and A1 at other random times show congestion.

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 5.1) 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. I can report, as a resident of this road, that 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 at least 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 modeling." 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. There is no Masterplan for BA1.

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.

5. 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 pinchpoint 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. 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 till recently known of the Local Plan which includes recommendations 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 as 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/ B656 to A507 and will deliver more air pollution to the site BA1. Roundabouts through this development would increase air pollution and associated problems as brakes and gearboxes add to particulate production.

There is no modeling of the impacts from Baldock developments BA1-4 and BA10 employment area 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.

6. 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 cycleways 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". I believe that in this case they are severe.

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.

7. 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 pinchpoint 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) but NHDC have not done this. They 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.

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.

"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 e.g. Great Ashby have discovered this to their cost.

The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

If indeed development on this scale is really needed in North Herts then I support Sir Oliver Heald in his recommendation to build a new settlement instead of tacking on large areas of development such as these in Baldock which create real problems for the future of existing communities whilst destroying their heritage.

I should like to be kept updated on the Plan's progress
I should like to be invited to the Public Hearing.

See attached

See attached