Policy SP5: Countryside and Green Belt

Showing comments and forms 61 to 90 of 120

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3650

Received: 29/11/2016

Respondent: Letchworth Garden City Society

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Removal of Green Belt to north and east of Letchworth, SA does not consider undesignated heritage asset status of Green Belt around Letchworth, Green Belt Review flawed,

Full text:

Policy SP5 Countryside and the Green Belt
Policy SPG15 Site LG1 North of Letchworth Garden City
Paragraph 13.215 LG3 Land East of Kristiansand Way and Talbot Way
Where a large areas of existing Metropolitan Green Belt North and East of Letchworth has been re-designated as residential development land and proposals for the use of these sites (LG1 and LG3) for housing development.
These policies are not Legally Compliant as the Sustainability Assessment does not form a suitable assessment of the sustainability of the council's proposals. The SA does not consider the undesignated heritage asset status of the Green Belt which was an integral part of the design of Letchworth, and the first designed Green Belt in England. The Green Belt is an important factor in the setting of the Heritage Asset which is the town of Letchworth.
These policies are not Sound as:
a) They are not positively prepared as they are not consistent with achieving sustainable development as set out in NPPF. 7 pg 2
"There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:"

"an environmental role- contributing to protecting and enhancing our natural, built and historic environment;......"
They are not justified or consistent with national policy as they do not comply with the following sections of NPPF:
a) 9 Protecting Green Belt Land
79 The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence.
80 The Green Belt serves five purposes:
to check the unrestricted sprawl of large built up areas
to prevent neighbouring towns merging into one another
to assist in safeguarding the countryside from encroachment
to preserve the setting and special character of historic towns
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
The proposals in SP5, SP15 and para 13.215, to re-designate the Green Belt land north of Letchworth, do not recognise or conform to all of the above five purposes.
83"...Once established Green Belt boundaries should only be altered in exceptional circumstances..."
MP Brandon Lewis confirmed in his letter to Boris Johnson of January 2015, that the need to meet Housing Targets did not constitute exceptional circumstances.
"NPPF is clear that Green Belt should be given the highest protection in the planning system and is an environmental constraint which may impact on the ability of authorities to meet their housing need. This Department published guidance on 6 October 2014 which re-affirms that Green Belt boundaries should only be altered in exceptional cases, through the preparation or review of the Local Plan. The guidance also states that the housing need alone does not justify the harm done to Green Belt by inappropriate development when drawing up a Local Plan."
The exceptional circumstances have not been demonstrated and reasonable alternatives to the use of sites LG1 and LG3 have not been identified, described and evaluated before the choice was made. The sites included in the appraisal were only those which owners put forward and the Draft Sustainability Appraisal document sets out in para 5.2.1 that to be considered a site had to be available for development. No alternative sites which would not cause such harm to the significance of Letchworth and its Green Belt were sought.
b) 11 Conserving and enhancing the natural environment

109 " The planning system should contribute to and enhance the natural and local environment."
110 "...Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this framework."
The Green Belt Review Study, sets out a scoring process for the sites put forward by owners which aims to establish which sites make the most significant contribution to the Green Belt. This system is flawed in the following ways and therefore not justified or consistent with national policy:
a) It says on page 30, para 44. "Letchworth Garden City has a relatively strong relationship with the surrounding countryside, particularly to the south where there is a clearer connection to the original footprint of the town."
This statement is not justified, the "original footprint of the town" quoted is simply the first area developed, from Norton Road in the north to Baldock/Hitchin Road in the south. This was by no means the intended size of the Garden City, Howard designed it to have 32,000 residents, that number has only recently been achieved with the addition of the Grange, Jackmans, Lordship, Manor and Westbury Estates. The town's relationship with the surrounding countryside is equally as strong in the north as in the south.
The following quote from Ebenezer Howard's book, Garden Cities of Tomorrow 1902 is relevant:
"Garden City has, we will suppose, grown until it has reached 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a "Garden City"? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then as the town filled up, the agricultural land would become ripe for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately not in the hands of private individuals: it is in the hands of the people: and is to be administered not in the supposed interests of the few, but in the real interests of the whole community."
b) Page 25, Parcel 22, under heading "Preserve setting and special character of historic towns"
"Forms part of countryside between Letchworth and Stotfold in Beds. Performs a more limited function due to landform resulting in limited views of any historic towns".
This analysis is far too simple, the historic town of Letchworth, the world's first garden city, and its integral Green Belt is completely ignored. The built up boundaries of Letchworth are clearly visible and its surviving Green Belt still performs its original design function to allow residents access to the countryside and for the grade 2 agricultural land to be farmed, and to provide the countryside setting for the Garden City as envisaged by Howard.

c) Page 117 section 5.3. Assessment of Potential Development Sites Land East of Talbot Way, and Land North of Croft Lane.
These sites adjoin Norton Conservation Area and Norton should be assessed as a village whose built boundaries should not be extended (in the same way that Willian the village to the South of the town, has been assessed). The statement in the Local Plan 2011-2031 page 181 para 13.209, that Willian has not been absorbed into the Garden City whilst Norton has, is not correct, Norton retains 3 sides of the village in contact with the countryside and it is only the houses on the East side of Norton Road which link it to the Garden City. Willian has a similar link along Willian Road from Letchworth Gate.
d) Page 118 North Letchworth
We do not consider the assessment to be accurate, this potential development site has 3 sides (North, East and West) which do not have development adjacent, if this had been used for analysis, rather than how many sides have development adjacent, then this site would have scored more highly. The wildly different shape of sites means that this method of assessment is not accurate.
There is no mention in the NHDC Local Plan or any background documents, of the proposed 22.5 hectares of residential sites to the East of Hitchin Road, in Central Beds Draft Local Plan, (work has already started on some of the houses). These proposals will bring the proposed development of North Letchworth closer than 500m to this Central Beds development, which as an extension of the Fairfield development will almost link Letchworth and Fairfield. The effect on the Green Belt has not been taken into account and this should result in a higher score under Towns Merging heading. The proposed development would also reduce the Green Belt between Letchworth and Stotfold to 500m in places. It is evident that the development of this North Letchworth site would result in the unrestricted sprawl that Green Belt designation is designed to prevent. The issue of co-operation on strategic and cross-boundary issues is relevant here.
Under the heading of "Preserve setting of historic town" this analysis says "site not within or affecting setting of a conservation area of a historic town". This is not a correct assessment of the importance of Letchworth's Green Belt as an integral part of the town's design and an important factor in its setting. The significance of the historic town of Letchworth, the world's first Garden City, would be seriously harmed by the loss of this area of Green Belt. A higher score should have been given here.
There is no Heritage Assessment Document for Letchworth prepared as part of the Background Papers, although Baldock Hitchin etc. have such assessments. A well informed Heritage Assessment for Letchworth would have identified the special historic character and significance of the World's First Garden City and its Green Belt, the first designed Green Belt in England.

Whilst Letchworth has its designated heritage assets in the form of listed buildings and Conservation Areas, it is also of local heritage importance in its entirety, as designed, with its Green Belt. This has not been considered in this Local Plan exercise.

Policy SP17 Site HT1 Highover Farm Hitchin
This policy is not Sound as it is not consistent with national policy.
NPPF says that green belt should only be altered in exceptional circumstances. Here the green belt between Hitchin and Letchworth will be reduced to 500m if this development goes ahead. No exceptional circumstances have been demonstrated.
The development will result in the unrestricted sprawl that the green belt is designed to prevent.

The modifications we would like to see are the removal of LG1, LG3 and HT1 from the list of proposed development sites and an exercise to identify sites to provide the housing needed in locations which do not harm the significance of Letchworth Garden City and its Green Belt.

We would like to participate at the oral part of the examination.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3787

Received: 30/11/2016

Respondent: Taylor Wimpey & Persimmon Homes

Agent: Barton Willmore

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5: Safeguarded land west of Stevenage should be referenced

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3796

Received: 30/11/2016

Respondent: Welwyn and Hatfield District Council

Representation Summary:

Support SP5: Support meeting objectively assessed housing need in full

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3834

Received: 29/11/2016

Respondent: Pigeon Land Ltd

Agent: Keymer Cavendish Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5: Unclear that new Green Belt has been considered in light of levels of housing growth required, unclear why Rural Area policy is so restrictive

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3847

Received: 30/11/2016

Respondent: Mr Edward Seebohm

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5:
- HCC propose a secondary school north of Manor Farm
- Green Belt Review should be carried out in this area and housing land relocated on Manor Farm

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4030

Received: 30/11/2016

Respondent: Ms Joanna Simpson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Sites within the green belt and 'exceptional circumstances'
- Green Belt review
- Relocation of the Green Belt
- Available brownfield sites
- Not consistent with national policy and cannot be justified as being the most appropriate strategy when considered when considered against the reasonable alternatives such as using previously developed land

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4148

Received: 29/11/2016

Respondent: Mr Iain Frearson

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Heritage and Historic significance
- First Garden City
- Loss of Green Belt
- No heritage assessment of Letchworth Garden City

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4159

Received: 30/11/2016

Respondent: Mr Robert Moore

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Green Belt and creating more Green Belt
- Land west of Stevenage

Full text:

Thank you for your letter dated 17th October 2016, regarding the proposed Submission Local Plan consultation.

Broadly speaking, I am a supporter of the LPA's aspiration to adopt a new Local Plan to cover the twenty year period to 2031. It can only be right that at a time when the whole nation is facing an increasingly severe housing shortage, each and every Local Authority helps towards meeting that pent-up demand.

This proposed Local Plan addresses some of the deficiencies missing from the 1996 Local Plan No. 2 with Alterations. The new Local Plan will hopefully ensure a better standard of new-build, although it remains to be seen whether such an increased building programme from 2017-2031 is actually achievable. But, unquestionably, having a Local Plan in place is the single biggest key step, going forward.

However, whilst we would not wish to see any further delays, nevertheless, I consider the current Submission Draft has two serious shortcomings.

Firstly; ever since the 1986 Plan was first adopted, the North Hertfordshire District already has too much Green Belt, covering approximately 38% of the entire District. You will recall the primary purpose of the 1986 Local Plan:- Green Belt was principally designated in order to constrain expansion of Stevenage eastwards and Luton westwards. In addition, Green Belt was also established around the principal towns of Hitchin, Letchworth and Baldock. The fact that some of that original Green Belt now needs to be reviewed is primarily in order to provide housing in the most sustainable locations on the side of Baldock, Letchworth, Hitchin and Luton. Ironically, now to be located in four out of the five places most considered, back in 1986, to be highly sensitive, and where any new housing development was to be resisted.
The courageous decision to review the current Green Belt boundaries by removing approximately 750 hectares of land from the Green Belt is, as your recent reports to Full Council and Cabinet suggests, the "least worst" option, but vital if new house building, sufficient to meet Objectively Assessed Needs is to be anywhere near achieved. But, the past mistakes from 1986, now resulting in the necessity to review the current Green Belt, should not, to my mind, be compounded by the pointless "creation" of a further 4,700 hectares of new Green Belt; which would only appear to be for reasons of pure political presentation/expediency.

Historically, one of the great problems following the piecemeal creation of Green Belt by various local authorities has in the past, been its great overuse. Thoughtlessly, unscientifically and in some cases simply for NIMBY reasons, far too much land has been included in the Green Belt; only now can we really understand, in some cases, to the detriment to some of our communities.


For these reasons, I strongly object to the creation of a further 4,700 hectares of Green Belt. It is I believe, completely unnecessary, largely proposed for a location, most of which would not ever be considered sustainable to build on, would achieve none of the listed purposes at paragraph 80 of the NPPF, and would be entirely contrary to paragraph 82 of the NPPF. Furthermore, if the proposal to remove land immediately to the West of Stevenage from the existing Green Belt is implemented, countryside which will clearly in future be under some threat from new development, simply replacing 4700 hectares of alternative countryside with a quite pointless "infill" of Green Belt is absolutely not the answer.

My second area of concern about the shortcomings of the proposed Submission Draft concerns the lack of provision for self-build. Previously, the Coalition Government took firm action to support and encourage individuals and communities who want to build their own homes. Those who choose to build their own "Custom Homes" often build cheaper, greener, more affordable and more innovatively designed homes than those available on the standard/market housing. The Coalition Government had introduced its "Custom-Build Homes Programme", which was announced as part of The Laying the Foundations: a Housing Strategy for England (published in November 2011), to support and encourage more individuals and communities to build their own homes. The overall aim of the Coalition Government's programme was to double the size of the sector over a decade and make self-build housing a main-stream housing option. It remains government policy to help increase supply, promote economic growth and sustain local jobs. The Coalition's aim was to increase the number of new self-build homes from the 8% nationally of today, to 16% of the new-build total by 2022.


Nationally, interest in self-build continues to grow following the adoption of The Housing and Planning Act 2016, which included at Chapter 2, an entire new section on Self-Build and Custom- house building. In contrast, NHDC's proposed Draft Submission Local Plan is almost silent, whilst suggesting only a derisory 100 self-build homes throughout the period 2011-2031.
Whereas, even taking just the lower-end 8% nationally, this should translate into more than 1100 self-build or custom-build homes by 2031. In fact, North Herts is beautifully suited to the aspirations of local self-builders. Across the four towns and forty other smaller communities, there are widespread opportunities in and around many of our settlements for individual high-quality small-scale homes for local residents. But I'm afraid that without new intelligent policies and support from North Herts Council, many will potentially miss out on these small-scale opportunities, otherwise overlooked by the big builders in their rush to develop large urban extensions.

I hope it is not too late to correct these two deficiencies in the Proposed Submission Draft, and that the Inspector will encourage some further changes/improvements at the Inquiry stage. I would welcome the opportunity to address the Inspector during the Examination in Public. Other than that, I wish you every success, and my support for the overall thrust of establishing a much improved Local Plan as soon as possible.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4167

Received: 29/11/2016

Respondent: Graveley Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: No exceptional circumstances, housing need alone insufficient justification, NPPF caveats allowing for development to be restricted disregarded.

Full text:

See attachments

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4177

Received: 30/11/2016

Respondent: Pirton Parish Council

Representation Summary:

Support SP5: Some protection from inappropriate unrestrained development

Full text:

See attachments

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4214

Received: 30/11/2016

Respondent: Bloor Homes South Midlands

Agent: White Peak Planning

Representation Summary:

Support SP5: Sound, justified and effective in enabling strategic development

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4249

Received: 30/11/2016

Respondent: Mrs Christine Watson

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Green Belt, 'very special circumstances' and 'exceptional circumstances'
- Sustainability appraisal
- Landscape and Townscape character
- Landscape sensitivity study
- Agricultural land
- Biodiversity and wildlife

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.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4258

Received: 29/11/2016

Respondent: Save Rural Codicote

Agent: Hutchinsons

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object on the following grounds:
loss of green belt and countryside;
proposed allocations will result in encroachment of development into the countryside; and
contrary to national guidance in the NPPF.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4304

Received: 28/11/2016

Respondent: Save The Worlds First Garden City

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Loss of Green Belt and "very special circumstances"
- Access to open space
- Community health
- Wildlife and biodiversity
- Biodiversity Action Plan 2005
- Protected species

Full text:

I object to North Herts District Council's Local Plan 2011 - 2031 on two main counts: first the violation of the Green Belt; second, the specific proposal to build on Green Belt land North of Letchworth (LG1).
NHDC proposes to build large housing estates East of Luton, East of Hitchin, North of Letchworth, North of Stevenage and North of Baldock. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see attachment 1). Nowhere in the Local Plan are any "very special circumstance" identified. The Green Belt was expressly put into place to curb urban sprawl. The siting of these proposed developments, mostly adjoining already existing estates is typical of the urban sprawl long discredited by town planners for its poor environmental impact and weakening of community and sense of identity. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed or annexed. The Green belt promotes physical and mental health by providing recreational space. It is vital for biodiversity, especially when 60% of British wild species are in decline. Up to the present, NHDC has a good record of management of the Green belt. In its Biodiversity Action Plan of 2005 it pledged to protect it (see attachment 2). This measure, having had no formal modifications since, is deemed to be still in force. Therefore I question the legality of NHDC's proposed flagrant disregard of it.
My second main objection is specifically to the Green belt site North of Letchworth (LG1). Apart from my objection above to building on the Green belt in general, there are three further objections specific to this site: first, the uniqueness of this site for its archaeology, geology and biodiversity; second, its particular unsuitability owing to the unique heritage of Letchworth Garden City; third the role of the Letchworth Garden City Heritage Foundation in selling the site for development to NHDC.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artifacts of early agricultural systems of archeological significance. There are a number of pollarded oak trees estimated to be over four centuries old. These features carry their own biodiversity which has evolved over the same time-span. The richness of biodiversity is also the result of soil diversity, generated by the particular mix of sand, gravel, chalk and boulder clay laid 500,000 years ago in the last glaciations and known to geologists as 'The Letchworth Gravels'. NHDC has played its part too, cutting down the use of agri-chemicals and encouraging wide field margins. 114 bird species have been recorded, 28 of which are endangered, together with Great Crested Newt, Brown Hare, Common Toad, Polecat and 3 rare butterfly species (see attachment 3). There is a House Sparrow roost of over 300 birds, the biggest in the county which is now under consideration for a designation of protected status. There is in increasing currency an idea that land lost to the Green Belt can be balanced by new Green belt designation elsewhere. Quite apart from the fact that there is no spare land in North Herts for such new designation, an eco-system such as that of LG1 cannot be moved as its centuries of evolution has been specific to that site. Therefore I object to the proposed development of site LG1 because it will necessitate the destruction of biodiversity and study opportunity for archaeology and geology.

I object to site LG1 because of the threat it poses to the unique heritage of Letchworth. This heritage is that of the world's first garden city, embodying influential principles of town planning and social welfare. Proximity to the open countryside was one of them, to which end the founding father, Ebenezer Howard, proposed to limit the population to 32,000 (thereby limiting the footprint of the town)(see attachment 4). He further stated nowhere on the urban boundary should be more than 15 minutes walk from the town centre. Such principles have already been infringed but this is no reason to abandon the spirit of them; there is still a heritage to be preserved if tourists and visiting students of town-planning from all over the world are not to be disappointed. Another principle was the town should be self-sustaining, in the sense that the population would work locally, so housing and industry were carefully balanced. Rather than use the opportunity to restore this balance, the Local Plan proposes to upset it further. With the increase in population generated by LG1, plus the change of use from industrial to residential of many of the smaller sites in the town under the Plan, the percentage of residents employed locally will sharply decrease. Letchworth will become predominantly a dormitory town with all the weakening of community that entails. The increase in commuter numbers will cause insuperable problems for road infrastructure as Letchworth's narrow roads were designed for low car use. In a self-sustaining town everybody could walk to work or school. The crucial routes from LG1 into the town centre and station are already bottlenecks: narrow roads lined with grass verges and specimen trees, some rare, which cannot be removed for road widening without completely destroying the distinctive garden city ambience. There is no scope for enlarging the railway station carpark.
I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, proposes to abdicate its responsibilities to protect and preserve the site. The Foundation was set up by Parliament in 1993 to continue the town's development by the principles espoused by Ebenezer Howard. The Green Belt was integral to the project, deemed essential to the concept of combining the best of both town and country living. As such it was the world's first Green Belt. The sad irony is this proposed sale represents a betrayal of principle by those whom Parliament has charged to be its protector. The sale of the land could be (and should be) open to legal challenge.
Attachments:
1. Extract from Hansard 15.7.16
2.Foreword to NHDC Biodiversity Action Plan 2005
3. Endangered species on LG1
4. Extract from Ebenezer Howard's Garden Cities of To-morrow (Faber and Faber, London, 1902)

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4336

Received: 29/11/2016

Respondent: Fairview Hotels & Healthcare Ltd

Agent: Waller Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5 (Letchworth): Inclusion of Letchworth Hall Hotel within Green Belt, site does not meet Green Belt purposes, unnecessarily restrictive.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4420

Received: 30/11/2016

Respondent: Mrs Marie Courtman

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5:
- Loss of Green Belt and 'exceptional circumstances'
- Risk of coalescence

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4430

Received: 30/11/2016

Respondent: Mr Steve Woodward

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
-New Settlement/Garden City
-Green Belt and no "exceptional circumstances"
-Heritage assets and archaeological interest
-Housing numbers/scale of development
-Historic/Rural village
-Available brownfield sites

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4490

Received: 30/11/2016

Respondent: Mr & Dr Gary and Hilary Napier

Agent: Pigeon Investment Management Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Green Belt not appropriately considered in light of housing requirements, Rural Area policy too restrictive, provision of new Green Belt too restrictive

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4498

Received: 30/11/2016

Respondent: Transition Town Letchworth

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5:
- Policy needs to be clear that land designated as Green Belt needs to be protected so as to prevent suburban sprawl
- Policy should recognise sustainable energy/fixtures which do not prevent the long term agricultural use of Green Belt land

Full text:

See attached

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5145

Received: 29/11/2016

Respondent: Mr M Holford and Others

Number of people: 15

Agent: Hutchinsons

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Inconsistencies in Green Belt Review in assessment of land between Hitchin and Ickleford

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5151

Received: 30/11/2016

Respondent: Mr Wilfred Aspinall

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Emphasis a flexible, as against a prescriptive approach, to dealing with both the green belt [ and especially land that lies beyond the green belt].
- Boundaries of villages are going to have to be extended

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5184

Received: 30/11/2016

Respondent: The Friends of Forster Country

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Object to SP5:
- Green Belt review indicates a 'significant contribution'
- Loss of Green Belt, justification and no 'exceptional circumstances'
- Space for Rights of Way
- Historic town

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5220

Received: 29/11/2016

Respondent: Messrs Hyde & Durrant

Agent: Moult Walker

Representation Summary:

Support SP5: Review of Green Belt boundary at Kimpton

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5235

Received: 24/11/2016

Respondent: Mrs Gillian Clarke

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
Building on the Green Belt
Congestion and highway infrastructure

Full text:

Do not build on green belt.
Do not build any houses until the A1M is widened or Knebworth has a bypass.
The village is very often gridlocked, either due to A1M accidents or the build up of traffic from the traffic lights at Broadwater.
Please send your representative to the village on these occasions and see how poorly served Knebworth is when these happen.

Yes we need new homes but let's sort out where all the traffic is going to go first.
663 homes potentially over 1000 more cars.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5252

Received: 30/11/2016

Respondent: Mr and Mrs Adam and Samantha A Shaw

Number of people: 2

Legally compliant? Not specified

Sound? Yes

Duty to co-operate? Not specified

Representation Summary:

Object to SP5:
- Increase in new Green Belt
- Considerations on policy impact on the supply of housing
- Housing allocations

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5476

Received: 29/11/2016

Respondent: Wymondley Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: No exceptional circumstances to support review of Green Belt, contrary to national policy, few developments being proposed on non-Green Belt land

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5495

Received: 29/11/2016

Respondent: Stevenage Borough Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP5: Scale of compensatory / additional Green Belt provision no justified

Full text:

See attachments

Attachments: