Policy SP3: Employment

With reservation. The Plan focuses on houses and does not recognise that almost all the settlements, like Knebworth and Codicote, have minimal employment; 90% of households in Knebworth are commuters. Why not assign sites for small business parks, and creative space, as a way of reducing the commuting traffic, and bringing more income directly to the settlements. Furthermore, the Plan should assign space for additional retail and office space in the Centre of Settlements. Knebworth currently has no further space for the shops needed to cater for a 30% increase in population. Please, don't let this Plan ignore parallel development of Settlement Centres.

I support the creation of additional space for business by the railway line in the east of Baldock. This is sensible - it will create employment opportunities in the local area and may help to reduce a small part of the additional through traffic that will be caused by so much housing development to the east of Baldock (when all other areas of employment lie to the west of Baldock and the district). Such development should be of the B1 categories described, due to the limited road access, the rural setting and the proximity to the new housing developments, and due to the size and shape of the area (large industrial or warehouses would not fit well and so be unlikely to be developed).

Site BA10 deliberately allocates more employment places than the expanded town needs (paras 4.25-6). This is likely to increase the number of journeys through Baldock undertaken each day especially at peak times. Paras 2.31, 4.27 and 13.14 stress that Baldock, Letchworth and Hitchin are interconnected for movement.
An increase in traffic will increase the pollution levels in the town especially in Hitchin Street / Whitehorse Street area and could well cause damage to the historic buildings.
As with the proposed number of dwellings, this places a disproportionate burden on the smallest town.

Re SP3 f. (Promote and support the expansion of the knowledge based economy in the District), the success of this policy will depend significantly on transport by train. Workers in the knowledge economy will require frequent fast train services to London, Stevenage and Cambridge, throughout the day and not just at peak times. Many will need to commute at peak times to jobs outside the district, and others will need to commute outside of peak times to accommodate flexible working (e.g. to manage childcare). Those with jobs in the district will need to travel to major centres in the knowledge economy, e.g., London, Cambridge or Stevenage, for purposes such as business development or training. At present the train operator, Govia, is consulting on timetable amendments which would significantly reduce the frequency of fast trains to London. This should be opposed in order to help ensure the success of SP3 and SP3 f. in particular.

Re SP3 f. (Promote and support the expansion of the knowledge based economy in the District), the success of this policy will depend significantly on transport by train. Workers in the knowledge economy will require frequent fast train services to London and Cambridge, throughout the day and not just at peak times. Many will need to commute at peak times to jobs outside the district, and others will need to commute outside of peak times to accommodate flexible working (e.g. to manage childcare). Those with jobs in the district will need to travel to major centres in the knowledge economy, e.g., London, Cambridge or Stevenage, for purposes such as business development or training. At present the train operator, Govia, is consulting on timetable amendments which would significantly reduce the frequency of fast trains to London. This should be opposed in order to help ensure the success of SP3 and SP3 f. in particular.

There are not enough employment opportunities with the Town to support the likely 4000 new adults on the proposed development north of Baldock. The 19.6ha set aside in the plan will meet a fraction of the demand which means that most people will be commuters. Para 34 of the NPPF states that developments that generate significant movements should be minimized. Upwards of 3000 people commuting is 'significant' and therefore this development is at odds with the NPPF. The Town can hardly cope with traffic and rail use at present let alone with another 4000 people.

Whilst being generally supportive of policy SP3, and welcoming the new employment designations, the LEP has the following concerns:

- there is neither reference to the East of England Forecasting Model's estimate of the number of jobs created as a consequence of growth to 2031 nor an estimate of employment floorspace expected to be created and therefore anticipated floorspace densities, making it impossible to make any sort of judgement over whether sufficient additional employment land is being designated in the plan

- whilst the plan seeks to promote such higher order activities including research and development, policy SP3 contains no specific measures to promote such activities, which could be achieved through imposing a minimum proportion of B1(b) (research and development activities, restricting uses entirely to B1(b) activities or limits on the level of non B1 uses for one or more of the new employment sites

- the rollout of the new employment designations will be greatly assisted by partnerships of appropriate private and public interests to work collaboratively together to promote their delivery, and policy SP3 needs to be explicit about the need for such arrangements to be put into place

- there is a failure to identify the need for employment related activities as part of the mix of uses on appropriate strategic housing sites; the LEP considers that at minimum there should be such a designation for either or both the North of Baldock and East of Luton strategic housing sites

- the absence of any new employment sites in Hitchin and only one small additional site in Letchworth means that there will be limited new employment opportunities in the district's two largest towns, and this should be addressed in the plan

- No specific policy to identify new employment activities within suitable smaller settlements within the district.

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Policy SP3: Employment:
Whilst the policy is not objected to in principle, Croudace have concerns in relation to Item (d) in that the phrase 'an appropriate amount of employment land to be included through the masterplanning process in major new developments' is considered to be too vague and imprecise.
Whilst Croudace have no objection to the inclusion of a small amount of employment land in the proposals for the North Stevenage site (i.e Policy SP8/SP16-NS1) as part of a new Local Centre, required to meet local needs, the NS1 site is primarily a housing allocation and would struggle to accommodate a large area of land set aside for employment, nor would this be appropriate. Item (d) of the policy therefore needs to be more specific, perhaps including a Table setting out the employment requirement for each of the major strategic sites.

Where will the new residents work and how will the land designated for industrial development be used? Most will end up commuting either by train to London or by car along the A1(M) which is already horrendously congested each morning and evening.

Policy SP3 gives details of potential additional employment on the land east of Baldock and the council's wish to promote the expansion of new technology in the district.

The plan cannot be justified as being an appropriate strategy when considering against other alternatives like West of Stevenage. It also fails the criteria 4 regarding national policy as it doesn't comply as it has not taken account of this area.

I am writing to object to the North Hertfordshire District Council's Local Plan 2011-2031, and in particular to proposed site BA1, the Blackhorse Farm site to the north of Baldock. as I believe it does not fully meet the soundness criteria laid out by the National Planning Policy Framework (NPPF).

1.Traffic congestion:
*The junction where the A507 and A505 cross already suffers from considerable congestion during peak periods, and it has been getting steadily worse in recent years. These cross roads are constricted by listed buildings, one of which has been damaged several times as a result of limited space to manoeuvre for some of the larger vehicles that use these routes. The 14'6" railway bridge on Station Road is frequently hit by lorries, despite recent work undertaken to reduce such incidents. These traffic issues are further exacerbated by any incidents occurring on the A1. Building 2800 houses (equating to c. 5600 cars) is only going to cause gridlock at an already excessively congested junction.
* Policy SP14 in the local plan suggests a new link road between the A505 and the A507 so that not all traffic from the proposed site will have to use the crossroads, however inevitably not all of the additional vehicles will elect to use the new route, therefore substantially increasing congestion at the crossroads.
*The NPPF (section 4) indicates that as part of promoting sustainable transport, a transport statement/assessment should be generated for any developments that generate significant amounts of movement. To my knowledge, there is no evidence that such an assessment has been generated which means the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

2.Green Belt:
*It is not acceptable to remove green belt status from land surrounding Baldock simply to meet housing requirements, even if land elsewhere is awarded green belt status to compensate. In my opinion this calls into question the whole concept of green belt policy.
*The proposal for the Blackhorse Farm site is a clear demonstration of urban sprawl, precisely the kind of development that green belt status is intended to prevent. This area is good quality agricultural land, and a haven for walkers, runners and cyclists.
*The NPPF (section 9) states that once established, Green Belt boundaries should only be altered in exceptional circumstances. NHDC have failed to demonstrate what these exceptional circumstances might be and therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

3.Air quality and pollution:
*Baldock is located in a valley and as a result suffers from high levels of air pollution. The bypass to the east of Baldock helped to allieviate this initially, but traffic volumes (and therefore air pollution) have subsequently risen in recent years resulting in pollution levels in Hitchin St and Whitehorse St now being in danger of breaching levels permitted by EU law.
*The additional vehicles resulting from the proposed development on the Blackhorse Farm site will increase traffic in and around Baldock, thereby increasing pollution levels further and adversely impacting the health of local residents.
*The NPPF (section 1) indicates that to prevent unacceptable risks from pollution, there is a requirement to ensure that any new development is appropriate for its location, and the effects of pollution on health, and the potential sensitivity of the area to adverse effects from pollution should be taken into account. Given the already excessive levels of pollution currently plaguing Baldock I would suggest that this has not been taken into account and that therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

4.Employment:
*A significant number of Baldock residents commute outside of the immediate area for work, to London, Cambridge, Stevenage, Welwyn/Hatfield and further afield, particularly higher skilled residents who are less able to find appropriate employment in the immediate vicinity.
*Policy SP3 describes additional employment provision for the area, and also indicates that the council will promote and support the expansion of the knowledge based economy in the area. However such action is unlikely to absorb the majority of the working population likely to inhabit the dwellings proposed for the Blackhorse Farm site. Realistically these people will be commuting in the same way as existing residents of Baldock, and placing increased pressure on already congested road and rail networks.
*The NPPF (paragraph 34) states indicates that plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised. Since sufficient employment opportunities are unlikely to be made available in the immediate area, and therefore result in a significant increase in the number of people commuting outside the area, I would suggest that the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

To conclude, I feel that the proposal for the development of the Blackhorse Farm site is hugely inequitable when you consider the suggested number of houses in comparison to the existing number, and then further compare this to the number of houses that other towns in the local area have been asked to accommodate. It will dramatically compound already existing problems with regards to traffic congestion, pollution, and access to local amenities, and furthermore has the potential to destroy a charming town centre. I support careful, well thought out development that will enhance the local area, but what is being proposed is far removed from this and cannot be a good thing.

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The removal of land from the green belt for strategic development at the locations referred to in Policies SP8 and SP3 is in direct contradiction of the Governments guidance. The planning guidance makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances. SP3 & SP8 would fail the fundamental aim of green belt policy to prevent urban sprawl, neighbouring towns from merging into one another, safeguarding the countryside from encroachment, preserve the setting of an historic town and restrict the regeneration of derelict and urban land within North Hertfordshire. NPPF para 14 & 83.

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