Policy SP6: Sustainable Transport

I am writing to object to policy Sp6 based on the lack of robust evidence and the plans being based on cheapest options and not taking into account he key evidence documents of AECOM local plan testing technical note dated 6 th July 2016 and the Odyssey Markides technical review of 23rd September 2016. These failed t o lol at proposed development of Luton and this trip generation.in addition the council does not take into account the traffic growth sources.
Consequently mitigation proposals Hm8, Hm10 and Hm15 should be dropped in favour of an enhanced road linkage west of Hitchin which will resolve current and future tragic issues which are an accident waiting to happen due to increased traffic and pedestrians and other road users on this very busy road system.
Safety and health issues are paramount in this decision rather than money as the situation needs a solution which has long term aims rather than short term goals.

Being a recent Immigrant from Africa ( 12years) and used to wide open spaces I find the proposed Developments in our area ,to say the least ,extremely alarming. I shudder to think of how the Infrastructure like Schools, Hospitals, Policing, Surgeries and above all Roads are going to cope? I find it a Nightmare driving on Country lanes and some A & B Roads due to the extremely poor condition..on some of our local roads potholes have been there for past 18 months, even though they have been reported!
The damage to car suspensions must be costing a fortune to repair ..I know from personal experience and cost.

So my main concerns are 1. Medical and 2 Roads and Traffic congestion.

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

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

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

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

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

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

Site WY1

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

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

I doubt this will be read but I want to know if anyone has thought about the impact extra housing will have in the transport infrastructure. The A1m this morning was diabolical almost a complete standstill between Letchworth and the M25 a journey that normally takes 45mins has taken 2 hours, but this is becoming the norm. More housing will only make this worse. Govia aren't even running a decent train service now what will happen when extra housing is introduced and further people start using the service, and if more houses are built at baldock and the train service is reduced there will then be parking issues at other towns and stations where people are then commenting to get the train.

Maybe invest in the local infrastructure first, improve the current services already in place , force govia to run a decent train service ( trains that are actually on time would be nice). And then think about more housing.

I object to the policy SP6 and its supporting text on the basis that the evidence base supporting the policy is flawed.

Policy SP6 states that the Local Council will deliver accessibility and promote the use of sustainable transport modes in so far as reasonable and practical.

The Hertfordshire Local Transport Plan and the supporting documents are fundamentally flawed:
1. Lack of consideration of the proposed developments within the Luton Borough
2. Associated Traffic along the A505

Also it seems the evidence used in the AECOM and also Odyssey evidence seem to fail to take into account the growth of the traffic based on the growth plans.
It also seems that the supporting plans are also inaccurate missing our housing developments on Upper Tilehouse Street.

Basically all the evidence fails to accommodate the future demand. As a resident on Upper Tilehouse Street, I am also very concerned about the safety of pedestrians especially children en route to school, the narrow pathways on a densely populated area of town and also the Air Quality, Upper Tilehouse Street suffers from high evels of pollution currently, all these factors will only be exacerbated.


All the factors lead to the fact that the Moormead Hill and Upper Tilehouse Street are not suitable to be strategic roads in light of the Luton Airport expansion and the Luton Borough Council Developments.

The mitigation proposals (HM8, HM10 and HM15) should be dropped in favour in an enhanced road linkeage to accommodate further demands.

I object to the policy SP6 and its supporting text on the basis that the evidence is the evidence base supporting the policy is flawed.

Policy SP6 states that the Local Council will deliver accessibility and promote the use of sustainable transport modes in so far as reasonable and practical.

The Hertfordshire Local Transport Plan and the supporting documents are fundamentally flawed:
1. Lack of consideration of the proposed developments within the Luton Borough
2. Associated Traffic along the A505

Also it seems the evidence used in the AECOM and also Odyssey evidence seem to fail to take into account the growth of the traffic based on the growth plans.
It also seems that the supporting plans are also inaccurate missing our housing developments on Upper Tilehouse Street.

Basically all the evidence fails to accommodate the future demand. I am also very concerned about the safety of pedestrians especially children en route to school, the narrow pathways on a densely populated area of town and also the Air Quality, Upper Tilehouse Street suffers from high levels of pollution currently, all these factors will only be exacerbated.

All the factors lead to the fact that the Moormead Hill and Upper Tilehouse Street are not suitable to be strategic roads in light of the Luton Airport expansion and the Luton Borough Council Developments.

The mitigation proposals (HM8, HM10 and HM15) should be dropped in favour in an enhanced road linkeage to accomodate further demands.

I am writing to give my views on Policy SP6 within the draft North Herts Local Plan. I object to the proposals to widen the road and use traffic signals to accommodate higher volumes of traffic on the road. I believe this is absolutely the wrong approach to be taking to the high levels of traffic as the key point is that this volume of traffic is already passing through an infrastructure totally incapable of bearing it.

The A505 around Upper Tilehouse Street is an extremely busy road. Heavy lorries thunder through it at all times of the day. This is a narrow, single lane road with houses on both sides and many pedestrians using the unusually narrow pavements. These pedestrians are primarily families and parents with young children walking to Samuel Lucas JMI School and the preschool on Upper Tilehouse Street. I myself have young children and the brief distance we need to walk on Upper Tilehouse Street itself makes me extremely nervous. Wheels taller than the children's heads pass within centimetres of where they are walking. It is dangerous and steps should be taken to divert traffic away from this area, particularly the heavy goods vehicles, rather than making changes which will encourage traffic through this narrow corridor. I hate to think of the council being in the position of making these changes only at the point that a tragic accident demands it, but I feel this is an accident waiting to happen.

Moreover, there is the serious consideration of air pollution around this area, which has already been established, with the junction of Upper Tilehouse Street and Paynes Park to become an Air Quality Control Area. The proposals will not help this situation and moreover, introducing traffic lights with tailbacks of stationary queueing vehicles is more likely to produce higher levels of air pollution.

The council should consider growth which would be generated not just by new housing, but also by the proposed expansion of Luton Airport. I believe that these factors have not been taken into account in the evidence presented and that they will render a street already overloaded well beyond its capacity, totally incapable of managing the traffic flow. These measures are not sufficient and do not address the real problems in this area, nor do they provide a long term solution of any kind. I believe a bypass is needed to relieve the traffic through this part of Hitchin and make it a safer place for all of us, but especially for our young people.

Please do keep me informed about this policy. I have not been happy that as far as I can tell, there has been no attempt so far to inform residents in the local area about the proposals or this consultation.

I object to policy SP6 on the basis that i) the evidence basis is flawed, as it does not take account of traffic growth generated by developments in neighbouring boroughs, such as the expansion of Luton airport.
ii) That proposals HM8/HM10 are inadequate. We really need a bypass (such as scheme 80 in long list of schemes for Herts Transport Vision) to cope with the volume of traffic and address noise, pollution, safety and congestion caused by such a high volume of traffic travelling from Luton to Hitchin on A505. Once the road enters Hitchin (Offley Road) the single carriageway is inadequate, there are already long queues for hours every day. In addition to the resulting loss of time/productivity and resultant pollution in a residential area, there are safety issues given the narrow paths (particularly Upper Tilehouse St) used by many children ( e.g. route to Samuel Lucas school) and local residents, many of whom are elderly.

We are writing in support of the concerns and objections raised by Mr D Bennett [...]
We are especially concerned about short term/small scale actions that, in our view, grossly underestimate the impact of increased future traffic flows. We do not support minor works that do not tackle the root causes of traffic problems; such action is not cost effective, and also increases the risk that perceived action now relieves the Authority, in its view, of the need to take effective action in the near future. Given the increased importance of east-west traffic flows, as well as a general increase in traffic, it is essential to revisit plans to by-pass Hitchin. The need, and intention, was clear in the 1980s.
We can also see inconsistencies eg Hertford compared to Hitchin, which cast doubts on the thoroughness of the evaluation of possible projects.

Policy SP6: Sustainable Transport and Supporting Text

Objection

I object to the policy SP6 and it's supporting text on the basis that the evidence base supporting the policy is flawed.

It is indicated these changes are proposed to both address existing traffic capacity issues on the local road network and provide increased capacity to accommodate traffic generated by the additional housing being proposed in Hitchin in the Draft Local Plan.

However, the Councils evidence base supporting these changes, fails to factor in traffic generated by the expanded Luton Airport or development proposed in the emerging Luton Local Plan that would travel along the A505 into and through Hitchin. Furthermore this evidence base indicates that the proposed transport changes would only just provide sufficient capacity to accommodate the demand identified. Clearly if the traffic generated by the expanded Luton Airport and development proposed in the emerging Luton Local Plan were factored in, then these works would be insufficient.

An additional factor should be the suitability of the existing roads to accommodate the level of predicted traffic. All of this traffic would travel through Hitchin via Moormead Hill and Upper Tilehouse Street. These are single lane roads with residential dwellings on either side and run through a catchment area for Samuel Lucas JMI school. These factors conflict with increased capacity in the following ways:

1. The roads and pavements along Upper Tilehouse Street are narrow and result in extremely close proximity of high volume traffic and pedestrians. The traffic includes a high volume of HGV's and the pedestrian flows include a large number of infants and children travelling to and from the school. This is just an accident waiting to happen.

2. Traffic travelling up Moormead Hill regularly travels far too fast and represents a safety hazard for children and parents trying to cross this road.

3. Upper Tilehouse Street is suffering from high levels of air pollution and the Upper Tilehouse Street/Paynes Park junction is to be designated an Air Quality Control Area as a result. The predicted additional traffic, and the additional traffic not taken into account, will exacerbate this problem within a residential area.

The above safety and health factors demonstrate that Moormead Hill and Upper Tilehouse Street are unsuitable as strategic roads and strategic traffic should be diverted along an alternative route.

I understand from the Hertfordshire County Council Local Transport Plan that it states that Hertfordshire County Council are encouraging 'all members to give their views on the consultation, and to promote the consultation to their constituents'. I find this difficult to believe as neither myself or any of my neighbours, had been made aware of these proposals.

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Policy SP6: Sustainable Transport and supporting text

Objection

I object to policy SP6 and its supporting text on the basis that the evidence base supporting the policy is flawed.

Policy SP6 states that the Local Council will deliver accessibility and promote the use of sustainable transport modes insofar as reasonable and practicable and sets out a number of objectives. Objective a. is to comply with the provisions of the Hertfordshire Local Transport Plan and other supporting documents as considered necessary.

However, the Hertfordshire Local Transport Plan and its current supporting documents are fundamentally flawed in its consideration of the transport implications for North Hertfordshire in that they fail to take into consideration recent and proposed development within Luton Borough and the associated generated traffic flowing along the A505 into North Hertfordshire.

Furthermore, the Council's transport related evidence base also fails to take this traffic growth into consideration. The key evidence documents are as follows:

* The North Hertfordshire Local Plan Testing Technical Note prepared by AECOM dated 6th July 2016

* The Local Plan Transport Technical Review prepared by Odyssey Markides dated 23rd September 2016

The North Hertfordshire Local Plan Testing Technical Note prepared by AECOM looks at what impact the preferred Local Plan Scenario would have on the transport network in the future and sets out a series of proposals for mitigating existing transport issues issues generated by the new development proposed in the Local Plan. However, the technical note fails to factor in trip generation from both recent development in Luton such as the expansion of Luton Airport, and development proposed within the Luton Borough Local Plan travelling into North Hertfordshire along the A505, A602 and B656 to access the A1M.

Similarly the Local Plan Transport Technical Review prepared by Odyssey Markides fails to factor in this trip generation. It relies on various AECOM evidence reports which all fail to factor in this additional trip generation as they focus entirely on trip generation within Hertfordshire only.

As a result of this failure to factor in trip generation from Luton the mitigation proposals are only sufficient to address trips generated by predicted baseline growth and the development proposals in the Local Plan. The Local Plan Testing Note admits that the proposals will barely address the predicted trip generation and further measures will be required to address further growth in the future. Given the growth predicted in the assessments fail to factor in trip generation from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan the proposed mitigation measures will not be sufficient to accommodate future demand.

The proposals to increase capacity on the A505/A602/B656 route to the A1M comprise:

* Signalisation of the Pirton Road/A505/Upper Tilehouse St/Wratten Road junction (Scheme HM8);

* Signalisation of the Upper Tilehouse St/A602/Paynes Park junction (Scheme HM10); and

* Improvement of the A505/B656 Hitchin Hill roundabout (Scheme HM15).

These schemes are recognised in the testing documents as barely accommodating the growth predicted by the assessments, and would not therefore accommodate the additional traffic growth from Luton travelling to the A1M or additional growth beyond the plan period. They are in effect a sticking plaster solution which accommodates an incorrect level of predicted traffic growth.

The Local Transport Plan and the Local Plan should be proposing a transport strategy that accommodates the correct level of predicted growth and which provides scope for accommodating future predicted growth beyond the plan period. The current proposals fail to do this.

An additional factor should be the suitability of the existing roads to accommodate the level of predicted traffic. All of this traffic would travel through Hitchin via Moormead Hill and Upper Tilehouse Street. These are single lane roads with residential dwellings on either side and run through a catchment area for Samuel Lucas JMI school. These factors conflict with increased capacity in the following ways:

1. The roads and pavements along Upper Tilehouse Street are narrow and result in extremely close proximity of high volume traffic and pedestrians. The traffic includes a high volume of HGV's and the pedestrian flows include a large number of infants and children travelling to and from the school. This is just an accident waiting to happen.

2. Traffic travelling up Moormead Hill regularly travels far too fast and represents a safety hazard for children and parents trying to cross this road.

3. Upper Tilehouse Street is suffering from high levels of air pollution and the Upper Tilehouse Street/Paynes Park junction is to be designated an Air Quality Control Area as a result. The predicted additional traffic, and the additional traffic not taken into account, will exacerbate this problem within a residential area.

The above safety and health factors demonstrate that Moormead Hill and Upper Tilehouse Street are unsuitable as strategic roads and strategic traffic should be diverted along an alternative route.

The policies reliance on compliance with the Local Transport Plan and other supporting documents in order to mitigate adverse impact arising from the development proposed in the plan is flawed as these documents do not factor in all traffic growth sources. The Council's evidence base on transport issues should be updated to factor in growth from from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan.

The mitigation proposals HM8, HM10 and HM15 should be dropped in favour of an enhanced road linkage between the dualled A505 west of Hitchin and the Hitchin Hill roundabout. This scheme matches Scheme 80 assessed within the Hertfordshire Transport Vision High Level Project Appraisal of Long List of Schemes for Hertfordshire Transport Vision produced by AECOM in February 2016. This will resolve the current capacity issues, accommodate additional traffic generated by the local plan proposals, accommodate additional traffic generated by Luton Airport and the proposals within the Luton Local Plan, and reduce safety and health issues on Moormead Hill and Upper Tilehouse Street.

Paragraph 7.6

Objection

I object to paragraph 7.6 as the transport models referenced in the paragraph are flawed in that they fail to factor in trip generation from the expanded Luton Airport and the proposed development allocations of the Luton Borough Local Plan. The models therefore support proposal that will be inadequate to accommodate future traffic growth within Hitchin.

The transport models should be re-run including these additional traffic generation sources.

I would like to raise that I am very concerned about the local plan. It seems very disconnected to what is happening to local facilities and transport locally:
The A1m traffic from junction 9-6 is the worst it has been and adding more homes to Baldock, Letchworth and Hitchin will drive more cars to use it.
The trains service in Baldock is going through consultation to reduce services at the same time as a consultation to add housing! This does not feel joined up.

Schools and doctors are under pressure in Baldock currently. This needs significant consideration.

See attachment

I am writing this email in response to the NHDC Local Plan Consultation to express my concerns and objections on the proposed plan. My comments and concerns are as follows:

1. Spatial Strategy - On review of the proposed Local Plan, the percentage of proposed housing to and around the small historic town of Baldock is extremely high. Based on the current size of Baldock, the proposal to build 3290 new homes will double the size of this historic town. Baldock has a thriving community as it stands which would be hugely impacted on with this number of properties. Based on an average of 3 to 4 people per property, this would equate to between 9,870 to 13,160 additional residents of Baldock, which in turn has further implications as I will identify below.

2. The number of proposed residents if we use the above average (which could potentially be 4 or more depending on the number of bedroom spaces proposed for each development), will have an impact on the current town centre of Baldock.
Baldock is a small town with limited parking. The high street has a good historic feel to it with the St. Mary's church at the end of the high street.
The parking on the high street of Baldock already is insufficient, with the number of people visiting Baldock during the day and evening exceeding the number of parking spaces, which proves difficult to park when you need too.
With the proposed number of new residents, Baldock town will be choked.

3. Under Policy SP6 - Sustainable transport. The proposal is already at risk of being flawed. The current rail network company (Govia) are proposing to reduce the number of trains stopping at Baldock Station. The current Baldock station platform is at the limit, the number of passengers boarding the train during peak times is already large and virtually fills the train. As a commuter, I have noticed that as soon as the train reaches Letchworth station (being the next stop from Baldock), there is insufficient seats or space for commuters from Hitchin, Stevenage and the following stops. The proposed number of new residents in Baldock will consist of a majority of commuters moving to the countryside with good links to London. This will mean the trains will be overcrowded to a point where the trains are unable to function safely. This in turn will cause a loss in revenue for companies due to the number of people that will not arrive to work on time. It has become clear that NHDC have not been in consultation with Network Rail or Govia in relation to the proposals.
This was confirm via the Save Baldock Trains petition, when a local MP discussed the proposals with Govia, which they knew nothing about the proposed over development of Baldock.

4. The proposed new development is to include a new surgery. Currently Baldock Surgery has over 12,000 Baldock residents registered, The proposed new surgery would have to be part of the first phase to be constructed to enable the practice to be set up sufficiently to accommodate the proposed number of residents. The surgery would have to be of a substantial size similar to Baldock Surgery. One concern here is whether the surgery is able to employ the number of doctors and medical staff to accommodate the extremely high number of residents proposed. I believe our country is struggling to find the number of doctors required to run a doctors practice sufficiently.

5. SP11 - Natural Resources & Sustainability - Areas BA3, BA4 and BA5 were prone to flooding prior to the A505 Baldock Bypass being constructed. The ditch alongside the Old Wallington Road used to Flood. There was numerous remedial works that had to be carried out to area BA4 after the bypass was constructed.
The Land within Baldock is made up of chalk.

6. SP14 BA1 site North of Baldock - This is the largest area proposed to construct housing, retail and schools. The proposal for a new link road between the A1 and the A505 would not work. Has Network Rail been consulted on this proposal, has Herts County Council actually reviewed the level change to create a link road, if they have, then the proposal should be issued for public view.
From our understanding at consultation meetings, the proposed bypass is proposed as a single carriageway road. This will only shift the traffic jam onto the new road. Before any development on Baldock takes place the following needs to be constructed:
i) - The proposed new bypass from A1 to A505 needs to be a dual carriageway
ii) - The A1 to A505 bypass would need to be extended to the A10. The traffic running through Baldock not only goes to the A505, but a huge number of traffic and HGV vehicles cut through Baldock and Cottered to reach the A10. The number of potential residents and traffic that will take this route may cause the road to the A10 to be gridlocked. The road through Cottered has not even been considered during the consultation period. This will have a substantial impact on Cottered, Walkern and Buntingford. This needs to form part of the consultation, a traffic assessment needs to be carried out on the Cottered / Buntingford Road to ascertain the traffic levels now prior to any development.
iii) - We understand from media reports that the A1 is subject to being widened to 3 lanes. This is a good thing, but needs to be completed before any construction takes place in Baldock. The A1 would need to be widened from the Baldock Services all the way to Welwyn where it has already been widened to 3 lanes. As it currently stands, the A1 is gridlocked between Baldock and Welwyn on a daily basis during rush hours (6am until at least 9:30am and 3:30pm until 7pm). This would ease congestion substantially before any works take place in Baldock which may ease the level of traffic trying to go through Baldock slightly.

Infrastructure - Drainage and risk of flooding. With the number of houses proposed, the local plan mentions a provision of Sustainable Urban Drainage Systems will be required. The number of houses proposed will have a dramatic impact on SUDS. The houses would produce approximately 105 litres of water per day each (based on Code for Sustainable Homes values). This will impact on the current drainage system and potential create a higher risk of flooding over a
15 - 30 year period. The drainage infrastructure would need substantial improvements to accommodate the number of proposed properties. This needs consultation with the water authority.

If you have any queries, please let me know.

I strongly object to the huge number of homes planned for the North of Hertfordshire, in excess of 7,000 that due to their siting will inevitably render the A1 corridor and surrounding road network, completely overwhelmed and unable to accommodate the weight of traffic. Even the most conservative estimate would put an additional 13,000 cars on the roads in the towns and villages adjacent to the A1 extending from Knebworth and Codicote to Stevenage, Hitchin, Letchworth and Baldock.

I strongly contest that NDHC has satisfied it's Duty to Cooperate with Welwyn Hatfield District Council, given the planned village at Simonshyde which would see a further 1,400 homes situated adjacent to the A1 that would add to the weight of traffic on the already burgeoning A1.

I reside in the Limberlost, Welwyn which is situated just off the B656, Codicote Road. The B656 is an essential commuter route that drivers use to access the A1 at junction 6 in Welwyn heading from Hitchin. Every morning on my journey to my children's school in Codicote, I have a clear view of the traffic trying to access the A1 on the B656 through Codicote. Since the new development of housing at the old Clock Hotel, the new development at Wilshere Park (The Frith) and the Welwyn exit lane for junction 6 on the A1, Welwyn village and the Welwyn Bypass have become gridlocked during peak times.

Any minor incident in the morning on the A1 or M25 will extend back to Welwyn and Stevenage to the point that the B656 is queueing for up to 2 miles beyond the northern boundary of Codicote. Not to mention the actual effect to the A1, and all major routes heading south.

My own family are already experiencing intolerable traffic jams travelling 6 miles from Welwyn Garden City to Codicote that can take as long as 50 minutes. These traffic jams are entirely due to cars trying to head north on the A1 from Welwyn to Stevenage and beyond. This is the kind of congestion that one would expect to experience during rush hour in London, not in North Hertfordshire. Policy SP7 details Infrastructure Requirements and stipulates that the plan should:

"avoid placing unreasonable additional burdens on the existing community or existing infrastructure."

Given the current weight of traffic on the A1 in North Herts and surrounding road network during peak times, it is unavoidable that the proposed scale of development will place a thoroughly unacceptable burden on the existing community and infrastructure.

Regarding the Countryside and Green Belt of North Hertfordshire, section 4.51 acknowledges that: "The vast majority of land in North Hertfordshire is rural in nature". With the scale of development planned for green belt areas, particularly in Codicote, the local plan threatens the very "nature" of the district. Further in section 4.144 the plan claims to acknowledge the importance of the "natural environment" in North Herts:

"The natural environment forms the setting to the towns and villages in which people live, work and spend their leisure time. Where possible, it should be protected and enhanced in the future to maintain the existing high quality of life that people in the District enjoy."

With this proposed level of development largely on green belt land, it is clear that the local plan has little regard for the quality of life of the existing residents, which will surely suffer as a result of the proposed new housing and vast swelling of the number of cars and new residents.

With particular reference to Codicote and the proposed site CD1 south of Cowards Lane, this site boarders an area of extreme environmental significance and supports an array of rare wildlife species in what is locally known as the Riddy, a wild meadow with wetland and a natural spring. This is a private wildlife habitat, part of Hollards Farm that has been managed as a wildlife preserve for more than 15 years. Policy SP12 states that the local plan should ensure that the "natural environment is protected and enhanced". Section b. provides further that NDHC should be making planning decisions to:

"Protect, enhance and manage biodiversity networks including wetlands and riverine habitats....and seek opportunities for net gains in biodiversity."

To think that it is possible to achieve a net gain in biodiversity is an absolute nonsense. Biodiversity relates to the complete ecosystem of an environment, which essentially includes wildlife. If you decimate the natural habitat of a wildlife population, you destroy the wildlife within that habitat. Why is it that conservation and wildlife preservation is only a matter for the tropics, the rainforests and the oceans? Wildlife preservation is your responsibility too.

If you destroy rural habitat in North Herts, particularly in Codicote, South of Cowards Lane, you are destroying the wildlife and there is no coming back from that. It is entirely impossible to achieve a "net gain in biodiversity". That is just lip service to environmental policy and so bitterly disappointing.

It seems that much of the local plan is paying lip service to what the District Community would want to hear, but I call upon the NHDC to protect and preserve our quality of life in Hertfordshire and the rural nature of our environment. The local plan is not sustainable! The scale of housing growth and development in Hertfordshire is not a viable solution to the national housing shortage.

If you fail to protect the very nature of North Herts, a sharp decline in the living standard of this area is inevitable and a sharp increase in mental illness and poor health is certain to follow in the wake of such a devastating blow to North Hertfordshire.

Having read the outline proposals in the plan we would like to make an objection to the plan to
change the roundabouts to traffic lights and widen the road.

Bearing in mind the increase in traffic due to the expansion at Luton Airport and new housing in both Luton, Stotfold, Hitchin, and surrounding areas . The problem of the transport will only get worse .

As residents of Upper Tile House Street we are fully aware of the traffic backing up the hill to Luton and continuous from Hitchin going toward Luton during peak times.

The idea of narrowing the pavements when the foot flow of local children going to school and mothers with buggy's at these times is an accident waiting to happen.

The volume of heavy goods vehicles going through this junction is very large and apart from the
danger to pedestrians the air quality must be very hazardous - this will only get worse.

We don't mean to be NIMBY'S and we have recently moved to the area , but surely common sense
should prevail and what is proposed is a short term fix, ( I for one think traffic lights slow traffic down )
and will only push the queues further back.

What is the obvious solution is a bypass to the A1 or a bypass to The Three Moorhens
roundabout which will filter traffic to the A1 and that will take a considerable amount of the traffic away from this traffic hot spot .

Eventually a bypass will have to be built and this short term (Non) fix will be a complete waste
of money .

I await any information you may have on this issue .

Regarding the consultancy process for the local development plan, please find below my representation. I would like to start by saying that in principle, I am fully supportive of the need to increase housing stock within the area however I would like to raise two comments in relation to proposed local plan and its impact on Royston.

Firstly, it is my firm belief that the redevelopment of brown field sites should be prioritised over the development of any new sites. Take, for example the site on Lumen Road (RY8) that has been derelict for many years. Unfortunately any progress towards redevelopment has been difficult to determine often due to closed council sessions. I appreciate that there is a concern that the site is potentially contaminated however I would assume that it would make sense (morally and ethically if nothing else) to decontaminate the land and convert it to residential use rather than leave it as a contaminated, derelict eyesore that encourages vandalism and other anti social activities. Everyone gains as decontaminating the land would clearly benefit the wider community making the area a better area to live.

The second point relates to certain of the significant employment and residential sites proposed. The plan describes a significant employment opportunity on the north west of Royston - RY9 - and two significant housing proposals on the east side of town - RY2 (330 homes) and RY10 (300 homes) - on the opposite side of town. Given the locations of these sites and together with the location of the rail station, it is reasonable to assume that one consequence of this would be a significant increase in cross-town traffic. These two residential sites alone represent an almost 10% increase in housing compared to the 2011 census number of 6800 dwellings and the increase in volume of traffic would be expected to be similar. There are only a very limited number of routes to get from one side of town to the other with people preferring to use either the route through the town centre, or rat-runs predominantly consisting of Mill Road, Queens Road and Stamford Avenue, rather than using the A505 bypass. The areas described (Mill Road, Queens Road and Stamford Avenue) are residential areas and should not be considered as major conduits to aid traffic flow. These residential areas are already blighted by traffic and excessive speeding (with the very limited speed restriction humps on Mill Road being virtually pointless) and if anything, efforts should be in place to reduce or control traffic flow rather than increase it.
To the best of my knowledge, no studies have been presented to determine the impact of having employment and residential areas on the opposite side of Royston will have on the local roads - with Aecom transport studies not extending as far as Royston. There is apparently a COMET study of traffic flow in Royston however details of the study (methodology and results) have not been provided as part of the Supporting evidence. Some limited data is available through the supporting document (Local Plan Transport Technical Review (Odyssey Markrides 2016) which suggests several roads with volumes over capacity during peak times including through the town centre. This will only serve to force even more traffic through "rat-runs". Currently, it is not clear whether the impact on side roads and residential roads was considered in the study. Regardless, I would emphasise that as part of any development strategy, measures should be included to ensure that traffic flow these areas (Mill Road, Queens Road and Stamford Avenue) are not adversely affected by the proposals in question.

Finally, the document describes a vision to make North Hertfordshire an attractive and vibrant place where people will want to live. This is an admirable vision however I believe this can only be achieved if the existing residents views are taken into account during the consultancy.

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I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1).
Other policies referred to are SP1, SP4, SP5, SP6, SP7, 9, 10, 11, 12, 13.

1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

3. Baldock sits in a valley which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated. The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution. Before the build asthma levels in 5-16 year olds was at 15% and the bypass brought them down to the national average of 6%.
Since then traffic has risen and now the levels of pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

4. The local highways network will be severely affected by the development of this site.
Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.

The proposed mini-roundabout at Whitehorse St/Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.

The A507 passes the only access road to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac, Icknield Way East, and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact of these new houses at this junction refers only to Icknield Way East, not the Station Approach nor the A507 on to which they both deliver traffic. Inadequate research and modelling.

Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do. See appended photo of lorry hitting bridge just before photo taken at 12.43pm on November 9th 2016 necessitating two police vehicles. Also the screen shot of ongoing congestion as a result at 1.30pm. This is a regular occurrence. Screenshots of the A507/ B656 junction and A1 at other random times show congestion.

The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.

In the IDP the Traffic Baseline (para 5.1) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.

No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. I can report, as a resident of this road, that the traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.

All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock, that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles at least can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.

The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modeling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief
that Baldock traffic problems have not been acknowledged and addressed. There is no Masterplan for BA1.

The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinchpoint for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.

The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.

Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not till recently known of the Local Plan which includes recommendations such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts as it is quite exposed at this point.

This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.

The link road proposed through BA1 will not relieve congestion at the Whitehorse St/ Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505/ B656 to A507 and will deliver more air pollution to the site BA1. Roundabouts through this development would increase air pollution and associated problems as brakes and gearboxes add to particulate production.

There is no modeling of the impacts from Baldock developments BA1-4 and BA10 employment area or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable.

The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

6. The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether.....the opportunities for sustainable transport modes have been taken up" but the Plan does not give information of things such as cycleways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE". I believe that in this case they are severe.

The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development, or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

7. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinchpoint for traffic and a pulling apart of the community.

Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents.

"By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land, going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" NPPF 112.

Water provision, at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.

"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area e.g. Great Ashby have discovered this to their cost.

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

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

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

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North Hertfordshire Local Plan 2011-2031 proposed submission
Representations and objections

I object to Policy SP6 (Sustainable Transport) and supporting text.

In particular I object to the proposals for mitigating the transport issues that may be caused as a result of the Local Plan being implemented. These proposals are set out in the North Hertfordshire Local Plan Testing Technical Note prepared by Aecom dated 6 July 2016 (a copy of which is attached).

I object to the following specific proposals in the technical note:

* Reference HM8 - Signalisation and road widening of the Pirton Road/A505/Upper Tilehouse Street/Wratten Road junction.
* Reference HM10 - Signalisation and road widening of the Upper Tilehouse Street/A602/Paynes Park junction.
* Reference HM15 - Alterations to the A505/B656 Hitchin Hill roundabout.
I object for the reasons set out below.

Economic growth and sustainability

A major cause of the traffic generation on the roads noted above is travel from Luton into North Hertfordshire to access the A1M.

However, the mitigating proposals are based on forecasted growth in traffic from journeys within Hertfordshire only. They fail to take into account increased traffic into and through Hitchin that will be generated by the expansion of Luton airport, and other development activity within Luton. The evidence base is therefore flawed.

Furthermore the Aecom technical note admits that the proposals will barely address the traffic caused by the forecasted growth in travel within Hertfordshire, and that further measures will be required to address any above-forecast growth (or presumably growth from other sources such as the expansion of the Luton economy).

The proposals are therefore not a long term solution to the growth in traffic into and through Hitchin, and do not represent adequate infrastructure to support development in the area. The proposals do not represent a sustainable solution to a problem that is only going to grow as the economies of Hitchin and neighbouring Luton continue to develop, and so are not value for money for the local taxpayer.

Transportation proposals should instead reflect a more realistic forecast of future growth in travel into and through Hitchin. The mitigation proposals proposed by Aecom should therefore be rejected in favour of an improved road link between the A505 west of Hitchin and the Hitchin Hill roundabout. This is consistent with Scheme 80 assessed within the Hertfordshire Transport Vision High Level Project Appraisal of Long List of Schemes for Hertfordshire Transport Vision produced by Aecom in February 2016.

Health and safety

The roads noted above are predominantly single lane residential roads that fall within the catchment areas of Samuel Lucas JMI School and the various Hitchin secondary schools. Upper Tilehouse Street is also home to Tilehouse Street Pre-School.

The roads and pavements along parts of Upper Tilehouse Street are already extremely narrow and the Aecom proposals appear to suggest a further narrowing of the pavements. The road is used by a large number of heavy goods vehicles, coaches and buses and this creates existing safety issues when combined with the large amount of pedestrian traffic (including infants, children and buggies) during the school run. Pedestrian traffic is likely to increase in the short term as Samuel Lucas JMI School continues its programme of expansion (which will ultimately result in a doubling in size).

The Aecom proposals will exacerbate pedestrian safety issues as follows:

* Further narrowing of pavements, increasing the risk of collision between pedestrians (infants in particular) and large vehicles.
* Increasing the number of lanes, adding to the difficulty of crossing the road safely.
* Removing roundabouts that act as a natural speed restriction, thereby encouraging an increase in traffic speed that will inevitably increase the risk of accidents occurring. Traffic travelling up Moormead Hill already travels too fast on a regular basis, presenting a safety hazard for children and parents trying to cross the road.
These safety concerns demonstrate that these roads are already unsuitable for use as through roads for strategic and commercial traffic heading to and from the A1M, and that the Aecom proposals will only make these issues worse.

The transportation proposals that form part of the Local Plan should therefore reflect the need for an alternative route for such traffic.

Air quality and the environment

By increasing road capacity, the proposals will worsen levels of air quality within a residential area that is also home to schools and pre-schools.

The proposed Local Plan confirms that the Upper Tilehouse Street/Paynes Park junction is to be designated as an Air Quality Management Area this year, therefore recognising the pre-existing air quality issues in the area. The Aecom proposals will increase traffic capacity and attract further traffic into the area. The proposals are therefore inconsistent with the recognised need to actively manage air quality in the area.

I would hope that any proposed road developments will be subject to a detailed impact assessment that takes into account the health of residents and the users of schools and businesses in close proximity to the relevant roads.

It is clear that the most effective way of managing air quality and protecting public health in the area is to establish an alternative route for through-traffic heading to the A1M. An alternative route should take the form of a bypass along the lines described above and below. This will reduce the impact of through-traffic from high polluting coaches and heavy goods vehicles in particular.

Recent development

The Aecom design proposals are based on an out of date map of the area which fails to recognise that four new houses have been built next to the Highlander pub. The map used by Aecom for proposal reference HM8 appears to show this area as empty land, and so the proposals should be reconsidered in light of this relatively new building development.

Accessibility

Residents of Upper Tilehouse Street already experience significant difficulty in accessing the road from their driveways due to heavy levels of congestion at peak times.

This will be made worse by the proposal to widen the road to three lanes and to make our driveways smaller.

Alternatives

As mentioned above, the mitigation proposals proposed by Aecom should therefore be rejected in favour of an improved road link between the A505 west of Hitchin and the Hitchin Hill roundabout. This is consistent with Scheme 80 assessed within the Hertfordshire Transport Vision High Level Project Appraisal of Long List of Schemes for Hertfordshire Transport Vision produced by Aecom in February 2016.


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