Policy SP4: Town and Local Centres

Showing comments and forms 1 to 26 of 26

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 283

Received: 07/11/2016

Respondent: Martins of Letchworth

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Levels of trade have dropped by 50%, the traffic flows in the Letchworth town centre need to be reversed.

Full text:

See attached

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 284

Received: 29/11/2016

Respondent: Knebworth Parish Council

Agent: Mr Jed Griffiths

Representation Summary:

Support for policy SP4, but pointing out concerns about impact of traffic on the village centre.

Full text:

The Parish Council supports policy SP4 and paragraph 4.42 of the Local Plan. The village centre is a vibrant and lively trading environment, serving not only the village but also a wider rural area. There are no vacant units, but there are concerns about traffic congestion on the B197 and car parking, which is concentrated on the main street. These are addressed in our representations on Knebworth (Policies KB1 - KB4).
The current plans for a new library, doctors' surgery, and pharmacy are welcomed and should assist in supporting the future viability of the shopping centre.
It is not clear, however, how the District Council intends to deliver this policy, particularly with reference to the Local Centres, including Knebworth.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 458

Received: 22/11/2016

Respondent: Mrs Carole Ann Brown

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP4: Impact of development proposals on Baldock town centre

Full text:

Baldock is a historic town with a mediaeval street pattern. It has a lively pub and restaurant scene but few shops. Since the development of Clothall Common, shops have closed and there is no reason to expect the new development to be any different. Residents will probably use the town for commuting and not for their every day needs. This will mean more cars through the town making access to the shops more difficult and will not encourage a variety of retail provision. Pollution is likely to exceed the legal minimum and to cause material damage.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 460

Received: 29/11/2016

Respondent: Mr Alan Gordon

Representation Summary:

Support SP4: Creation of a new town centre in new development north of Baldock

Full text:

I support the creation of a new town centre in the new development to the north of Baldock - this should include leisure facilities and green space.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 461

Received: 29/11/2016

Respondent: Mr Alan Gordon

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP4: Omission of sites to south of Baldock from consideration in retail hierarchy

Full text:

With the additional development around Clothall Common, a single local shop will be supporting a large neighbourhood of dwellings. Either the cluster of developments around Clothall Common nearly 600 additional homes should have a strategic plan/masterplan, which could consider options such a new local shop or community facilities such a hall or leisure facilities - or it should be specifically mentioned in this plan.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 500

Received: 19/11/2016

Respondent: Mr Joseph Busuttil

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

I agree with the principles of the policies outlined in SP4. I would however strongly recommend incorporating the provision of A4 business facilities into the proposed plans for the new local centres being created. Public houses serve as focal points for the local community. The precedent from recent community developments such as Cambourne, Cambridgeshire suggests that inadequate provision of public houses undermines and slow the establishment of a new community. I therefore object on the basis that the proposals do not currently make allowance for A4 businesses.

Full text:

I agree with the principles of the policies outlined in SP4. I would however strongly recommend incorporating the provision of A4 business facilities into the proposed plans for the new local centres being created. Public houses serve as focal points for the local community. The precedent from recent community developments such as Cambourne, Cambridgeshire suggests that inadequate provision of public houses undermines and slow the establishment of a new community. I therefore object on the basis that the proposals do not currently make allowance for A4 businesses.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 955

Received: 27/11/2016

Respondent: Hertfordshire Local Enterprise Partnership

Agent: Dan Bone

Representation Summary:

Herts LEP supports this policy

Full text:

Herts LEP supports this policy

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1106

Received: 28/11/2016

Respondent: Mrs Lisa Haywood

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

4.38 ....The Council is committed to protecting the vitality and viability of all centres.
Having driven around Baldock for 15 minutes on Friday morning trying to find a parking space it is impossible to see how the town will be viable with such a level of additional traffic.

Full text:

4.38 ....The Council is committed to protecting the vitality and viability of all centres.
Having driven around Baldock for 15 minutes on Friday morning trying to find a parking space it is impossible to see how the town will be viable with such a level of additional traffic.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1385

Received: 29/11/2016

Respondent: Mr Scott Oliver

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP4: Plan does nothing to fulfill the objective of this policy for Knebworth, no engagement with village residents on this matter.

Full text:

The plan does nothing to fulfill the objective of this policy for Knebworth, despite the village being referenced in the policy.

There has been no engagement with village residents on this matter.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1478

Received: 29/11/2016

Respondent: Mr Chris Rodis

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP4: Commitment to accessibility improvements in Hitchin Town Centre required.

Full text:

I am writing on behalf a number of wheelchair users who find too many problems with physical access to shops and services in Hitchin Town Centre. We would like to see a commitment to ensure that all new retail development and rebuilding etc commits shops and other 'shop fronts' (e.g. banks, pubs) to move towards ramps, doors (preferably automatic) wide enough for electric wheelchairs (84 cms) and accessible lifts where there is a floor other than the ground floor. Also please remove and avoid bollards by disability parking spaces as these hinder the opening of disability vehicle doors.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1757

Received: 30/11/2016

Respondent: Ms Jane Neal

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP4:
- Plan does not safeguard the vitality of the Town centre
- Net loss and net gain of biodiversity

Full text:

The plan does not safeguard the vitality of Baldock Town Centre, or enhance the sense of community especially when the proposal is to build a new town Centre with shops and factories within the new development. Two separated communities will create a dearth of empty amenities in two locations, neither with a sense of community, nor will it recognize town centers as the heart of the community or support their viability and vitality.
Creating further industrial complexes simply adds to the already abandoned industrial areas around Baldock, which will only be exacerbated by the development of more empty industrial warehouses. It is difficult to see how this new settlement development will overall move the area from a net loss of biodiversity to a net gain.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2069

Received: 24/11/2016

Respondent: Dr Brendan Walkden

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP4:
- Does not comply with the NPPF
- Scale of development
- Town heritage
- Overwhelm the current infrastructure
- Promoting sustainable transport
- Highway infrastructure and congestion
- Significant number of rail commuters.
- Baldock station and services
- Protecting Green Belt land
- Landscape/Village Character
- Ensuring the vitality of town centres

Full text:

As I am sure you are aware the North Herts local plan has caused a great deal of concern amongst local residents and I wanted to include my representations for consideration even though I am sure these mirror those of a great number of local residents. I believe the plan as it currently stands does not comply with the National Planning Policy Framework. Whilst most people could accept some degree of development, proposals which increase the town population by 80% and increase the number of cars by as many as 5000 will destroy the town heritage and overwhelm the infrastructure

Specifically I believe these to be the main issues
1. NPPF Section 4 - promoting sustainable transport.
1. Currently the crossroads in Baldock town centre, linking Whitehorse Street to the High Street is a significant bottle neck. The plan currently has 2800 homes planned for north of Baldock. As things currently stand, a trip across Baldock in morning rush hour, starting in Bygrave takes as much as 45 minutes, with traffic streaming back towards the A1.
2. The significant number of new residents will likely be rail commuters. There appear to be no plans to accommodate extra parking at Baldock station and the rail company, Govia are currently in consultation to downgrade the Baldock service. As things stand many trains into and out of London from Baldock suffer from significant overcrowding. I have doubts as to whether the current rail service and station at Baldock could cope with the addition of additional commuters from more than 3000 new homes in the town
3. In the absence of accessible town centre parking to accommodate more cars, the additional strain on parking capacity will effectively isolate residents from both upper and lower Bygrave, who, unable to walk into town will have nowhere to park should they drive


2. NPPF Section 9 - Protecting green belt land
1. The individuality of the town will be lost by this upsurge in population. In addition the area on which the houses are planned is very scenic. There are alternative brown belt sites in the area which could be used to absorb at least some of the proposed development.
2. Bygrave is a rural community and a scenic, historical village. This identity will be lost with the number of houses proposed at the North Herts site and effectively create 3 pockets of housing


3. NPPF Section 2 - Ensuring the vitality of town centres
1. I have not seen any plans for additional parking in Baldock town centre. Even though it is only a 15 minute walk into the town from the north Baldock site, we know many people take the car even for short journeys. This will strangle the town.


4. NPPF Section 17 - Promoting healthy communities
1. I have not seen robust plans for schooling to accommodate such a drastic uplift in population. This is key. The schools in Baldock are already extremely difficult to gain entry into (the acceptance criteria to Hertsfield Primary school in 2015 was 360 metres distance to the school gates). Knights Templar secondary school is excellent, but is also heavily over-subscribed. Without adequate planning for schools existing resident's children in the rural communities such as Bygrave and Ashwell face horrific commutes. Going out in the direction of the Cambridgeshire villages then having to come back through Baldock
2. The road planned to link Bygrave Road with the A507 roundabout is planned to be above ground. This will create a great deal of noise and destroy the beautiful views. I believe if this road is to be built it should be in a cutting and go under the railway line.

I understand the need for additional development in Baldock, however I strongly believe the scale of planning is disproportionate with what can be coped with by the town. 3,290 homes are simply too many and I do not believe the local plan complies with the NPPF in several areas.


Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2731

Received: 30/12/2016

Respondent: Ms Angela Kane

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object on the following grounds:
loss of village character;
traffic;
education provision; and
insufficient infrastructure.

Full text:

I would like to register my objection to the amount of housing being planned for Codicote. I appreciate that you must build houses somewhere but I don't understand why you have to destroy villages in the process. I don't think there is anyone in the council that appreciate how much traffic goes through this old village from outside the village let alone the locals. How do you plan on dealing with this?... Knock one side of the high street down. This high street was never built to cope with this amount of traffic, we are now inundated with huge lorries. Obviously we are going too have to take legal action somewhere along the line...as every house you build will have at the very least two cars....there is not in infrastructure here for that amount of housing. Last year we had all the trouble with the school not being able to allocate places for all the local children...that will only get worse. I know there must be some housing, but there is constantly houses being built here on every scrap of land...in gardens...you name it they build there.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3795

Received: 30/11/2016

Respondent: Welwyn and Hatfield District Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Object to SP4: Overall retail strategy and technical evidence supported. Modification to para 4.46 considered necessary

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3898

Received: 29/11/2016

Respondent: Letchworth Garden City Heritage Foundation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object on the following grounds:
policy is precise about the amount and location of floorspace needed which conflicts with the background paper;
question about whether sites allocated for retail provision, LG19, LG20 and LG21 are viable and deliverable in the plan period;
need for the Town Centre Strategy for Letchworth to be reviewed;
uncertainty if the identified sites are solely required for retail purposes or main town centre uses due to the wording of the supporting text; and
the retail allocations are not necessary and may preclude investment for alternative proposals.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4229

Received: 30/11/2016

Respondent: Sainsbury's Supermarket Ltd

Agent: Indigo Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP4: Role of Sainsbury's superstore in Hitchin should be acknowledged

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4248

Received: 30/11/2016

Respondent: Mrs Christine Watson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP4:
- Landscape and Townscape character
- Air quality, pollution and air circulation
- Highway infrastructure and congestion
- Retaining and enhancing town centre
- Employment provisions

Full text:

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.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4266

Received: 30/11/2016

Respondent: Knebworth Estates

Representation Summary:

Support Policy SP4: Commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Full text:

Section 1:

Knebworth Estates congratulates North Hertfordshire District Council on a Plan that has - not before time - been positively prepared, and - within its delayed and limited time frame - appears justified, effective and consistent with national policy.

Section 4.9 - Policy SP2:

Knebworth Estates supports Knebworth's inclusion as a Category A village, and Old Knebworth's inclusion as a Category B village - although it argues that there are sometimes cases where it is preferable for a village to evolve outside of its "built environment" rather than on the open and green spaces within its "built environment", and that the Plan should allow for such cases.

Section 4.37 - Policy SP4:

Knebworth Estates supports the Plan's commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Section 4.127:

Knebworth Estates supports the Plan's commitment to deliver appropriate primary and secondary school facilities for Knebworth.

Section 4.162:

Knebworth Estates supports the Plan's commitment "to find new, appropriate uses and solutions to secure the future of heritage assets."

Section 4.165:

Knebworth Estates does not support the Plan considering serving Tree Preservation Orders within historic parks and gardens as this could run contrary to the Plan's commitments in Section 4.162 and the management of historic parks and gardens - and the preservation of, interpretation of, and access to, the heritage assets within - are unlikely to be any better served than by those to whom it is a day-in-day-out commitment and responsibility. Knebworth Park and Gardens has its own Historic England approved Conservation Plan and an exemplary record in its heritage management, and yet another level of statutory requirement is unjustified, unnecessary and counter-productive.

Section 5.28 & 5.29:

Knebworth Estates supports the Plan's intent that Knebworth village centre should continue to provide a mix of shopping, services and community facilities.

Sections 5.39 to 5.48 and Policy ETC8:

Knebworth Estates supports the Plan's commitment to Tourism and argues that - whilst being an Historic England "Priority Building At Risk" - Knebworth House and Knebworth Park belie Section 5.41's statement that North Hertfordshire is not a major tourist destination. The Visit Herts DMO, VisitEngland, the LEP, and Hertfordshire County Council all recognise the district's strong tourism draw and impact. Knebworth House is one of only two Historic Houses in Hertfordshire with a national profile (the other being Hatfield House in the Welwyn and Hatfield district) and Knebworth Park is unique nationally in its capacity for large music events. The Plan should be aspirational to the benefits and potential of Tourism.

Section 6:

Knebworth Estates broadly supports the Plan's Green Belt policies - although, as in Section 4.9, Policy SP2 above - it argues that there are sometimes cases where it is preferable for communities to evolve outside of the "built environment" rather than threatening the quality of life, open and green spaces, balanced zoning and heritage of the "built environment". Knebworth Estates supports the consideration of "exceptional circumstances" within Green Belt policy.

Section 12 - Policy HE2:

Knebworth Estates supports the Plan's "Heritage at risk" policy.

Section 13.183 to 13.202 - Knebworth:

Knebworth Estates supports the Plan's policy for Knebworth within the context and scope of the Plan's objectives and time scales.

Ref - Knebworth - KB1 & KB2:

Knebworth Estates supports the Plan's Housing Allocation and site specific criteria for KB1 and KB2:

Commitment

As freehold owners of the sites identified as KB1 and KB2, Knebworth Estates reiterates its commitment, as expressed in previous consultation responses - and in consultation responses of the independent charity representing Knebworth House (The Knebworth House Education and Preservation Trust), to which Knebworth Estates is primary donor - that if these sites are brought forward for residential designation, it will move swiftly to work with the Council to deliver the full required housing targets with maximum sensitivity to the community of which it has been a part for over 500 years.

Proof of this commitment is to be found in the Estate's long record of involvement in the evolution of the community of Knebworth - since the settlement's beginnings - and specifically, in its multi-generational quest to restore and protect Knebworth House, its Park and curtilage, for public benefit and access (see "Opportunity" below).

The Estate treasures Knebworth's green spaces and environment - it has been a long term guardian of these - however it also believes that Knebworth should play its part in contributing to housing need identified in the Plan, and in the planned evolution of the District as conceived in the Plan. It recognises, with the Plan, Knebworth's pre-existing infrastructure - "a good range of facilities including a railway station, school, doctors and dentists, library, a range of shops, village hall and churches" - and thus considers it right that Knebworth shares responsibility to provide for residential growth with other communities in the District.

As part of Local Plan residential growth, the Estate supports the provision of affordable housing and schemes to provide homes for those who have grown up in the community. It recognises that new homes generate extra pressure on schools and supports increasing school provision. Increased school provision will strengthen Knebworth's independence of Stevenage and other growing towns, promote community spirit - a deficiency identified in the Knebworth Parish Plan (April 2007) - and ease pressure on road and rail networks at peak times.

Delivery

The Estate recognises the extensive evidence base compiled by the Council to support the suitability of sites KB1 and KB2 and looks forward to working with the Council, the community, neighbouring landowners and future development partners to conduct further studies to confirm and expand on this evidence, which it believes to be sound.

The Estate is pleased to have already contributed to existing evidence with input into Knebworth Parish Council's Knebworth Parish Plan (April 2007 - http://www.knebworthparishcouncil.gov.uk/uploads/knebworth-parishplan-1sted-web.pdf) and Knebworth Sites Appraisal Report (December 2007 - http://www.knebworthoptionsreport.org/).

Sustainability

The Estate recognises the Council's Capacity and Sensitivity Studies of 2006, and - as part of the community, and its owners resident within the community - is particularly sensitive to the issues raised by those who oppose development on these sites. It has listened to, recorded, and considered the practical concerns of its neighbours - through previous consultations, involvement in the Knebworth Parish Plan (April 2007) and the Village Appraisals of 1996 and 2007, and at a number of public meetings over the years - and is confident there are practical solutions and mitigations to the issues raised.

The Estate would seek - in working with the Council, any development partners and its neighbouring landowners - to work with Knebworth's new Neighbourhood Plan to promote a balance of achieving the Local Plan's targets, addressing sustainability and infrastructure issues and concerns, and fulfilling community aspirations. Within the parameters of the Plan, it would look to development in keeping with - and improving on - Knebworth's existing Conservation Areas and Edwin Lutyens' original 1910 framework for "Knebworth Garden Village".

Opportunity

Reinforcing the Estate's commitment, and adding to the opportunity of facility and infrastructure improvement in the wider community, is one factor that is unique to Knebworth Estates. Reflecting the intent of the Plan in Policy SP13a - "Maintaining a strong presumption in favour of the retention, preservation and enhancement of heritage assets and their setting" - the Local Plan's requirement of Estate sites for residential provision would present a once-in-a-generation opportunity to solve the Estate's multi-generational quest to endow the Knebworth House Education and Preservation Trust, a charity created in 1984 for the preservation and enhancement of the heritage asset of Knebworth House and its setting.

Residential designation of KB1 and KB2 would result in sufficient funding for this charity to halt the decay of Knebworth House - an Historic England designated "Priority Building At Risk" - complete its half-finished programme of urgent restoration, and secure an endowment for its future survival, and continued and expanded public access and interpretation.

The Knebworth House charity's record over its 33 year history, its established "exceptional circumstances", its Conservation Plan as submitted to North Hertfordshire District Council in July 2001 - and the Estate's record in endowing, and seeking to complete that endowment - is evidence of the commitment of the Estate and the Charity.

The collateral opportunity presented by the designation of KB1 and KB2 within the Local Plan therefore extends beyond the crucial issue of local residential shortfall, to address also major issues of benefit to the whole region and the nation beyond.

Ref - Knebworth - KB4:

Knebworth Estates supports the Plan's Housing Allocation for KB4. Whilst comfortable that KB1 and KB2 could be successfully delivered without KB4, Knebworth Estates expresses its support for KB4. The Estate enjoys a close and mutually supportive relationship with the landowners of KB4 and, in the event that both landowners have sites proposed for development in the final Plan, we would look to work closely with each other to take an holistic view of Knebworth village and, together, maximise infrastructure advantages for the greater benefit of the wider village and its long-term future.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4306

Received: 28/11/2016

Respondent: Save Rural Baldock Group

Number of people: 3

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Objection to SP4 in relation to BA1:
- BA1 will cause severe integration problems with the town due to the inaccessibility of the existing town
- cannot be justified as being the most appropriate strategy, given the impact on the town character and inability to solve integration issues.

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4496

Received: 30/11/2016

Respondent: Transition Town Letchworth

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP4:
- The section on retail failed to reflect the ongoing decline of town centres
- Consider changing unwanted town retail premises into homes
- The plan should take specific account of this tradition so as to sustain the town's unique character; to help mitigate against climate change.
- Support applications for shops and catering establishments in ways that promote vegetarian and vegan foods

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5183

Received: 30/11/2016

Respondent: The Friends of Forster Country

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Object to SP4:
- Highway access, infrastructure and congestion
- No walking or pedestrian routes
- No sufficient cooperation with neighbouring authorities
- Access to community facilities and recreational activities

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5552

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.

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5861

Received: 30/11/2016

Respondent: Mrs Linda Brookes

Representation Summary:

Support SP4:
- I support this policy

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5920

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 SP4:
-fails to take into account rapidly changing nature of retail growth
-figures used in evidence base(Retail Study Update 2016) not well founded
-not convinced NLP report provides justification for increase in retail provision so much greater than the expected increase in housing since last set of calculations.
-figure closer to28,000sqm of floorspace might better reflect likely growth in population,though still does not take into account increase in online retail since earlier study.
-flexible approach to retail development targets to be made clear and linked specifically to regular reviews and modifications of town centre strategies with clearly defined timescales

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6022

Received: 29/11/2016

Respondent: Mr & Ms Andy & Lisa Darley and Hutchins

Number of people: 2

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP4:
- Bolt-on development on Green Belt
- Fails to ensure the vitality of town centres
- Many of the proposed sites for development are too far away for access to these centres
- Access constraints
- Public transport constraints

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