Policy SP8: Housing

There are rules laid down re building on green belt land. This from the CPRE: Development on Green Belt land is supposed to be tightly controlled so that it can fulfil its main purpose: to serve as a buffer between towns, and between town and countryside. This gives the incentive to regenerate damaged and derelict land within the urban areas surrounded by Green Belt. At the same time, Green Belts bring social, environmental and economic benefits, while giving people a chance to tap into natural capital on their doorsteps.
Some housing plans are encroaching on the Green Belt around our towns when there are alternatives. The Green Belt should be fully maintained in the new local plan.

I have lived and worked in North Herts for the last 40 years. I have worked in the health service at the local Lister Hospital, Stevenage for 25 years and now work in primary care in Knebworth, and live in Graveley near Hitchin. I understand well the needs of the community and the increasing and ageing population in the area and demands on the hospital and community services. I also travel daily & am aware of the daily struggle along clogged up roads between the north and south of Stevenage.
The proposal is for 15,950 houses to be built in North Herts under the plan. Use of green belt land to meet housing needs is inconsistent with national policy & only permitted in exceptional circumstances. Development of green belt land will cause untold damage to the environment & cannot be justified by Unmet housing need at this stage when other options have not been investigated thoroughly.
The proposed Travellers site in proximity to Graveley village is inappropriate use of Green Belt land. This site will have significant impact on Graveley Village as this site will be in close proximity via a short walk to housing developments in Ashwell Common and also a village school. These Travellers sites are only allocated to places where there is a known buffer area between Site & residential area.
Graveley has been ear-marked for 916 new homes. Most of the parish of Graveley is green belt. the village is of historic interest with an ancient church & number of listed & historic buildings. With the proposed building the village will be just 400 metres away from the new Stevenage development. This will result in the inevitable coalescence with Stevenage & the loss of yes another unique Hertfordshire village.
The traffic flow at present on to the the B197 from the side roads - namely Oak Lane and Church Lane in the mornings is continuous particularly in term-time and between 8-9am and between 5-6pm. The traffic is nose to tail all through Stevenage old Town or on the AIM going North or South at these times. If building work starts or house numbers increase, inevitably traffic will increase. The village & surrounding area cannot take this traffic increase. The arguement that this is the responsibility of Herts Highways will not help this situation as Herts Highways is already underfunded & cannot cope with existing road network/improvements needed/work requirements.
Lister Hospital has serious capacity issues already,and the hospital is expected to grow over the next few years to reflect this growing population need. It will need ease of access for ambulances/emergency vehicles and also parking will need to increase to accomodate the extra facilities. This was the reason why Lister won over QE2 - because there was supposed to be more space/easy access for future planning/expansion. if houses are built & traffic increases, this will severely compromise the hospital's functioning.

If we are building homes to meet national quotas, rather than healthy green-belt environments, we should look at local need in this area i.e. commuters, retirement homes, schools, doctors etc.

Surely, as I suggested to David Levett, a new town (preferably based on Garden City principles) could be built around Ashwell station and the A505 which could meet the need and quota and ease the pressure on local communities.

I was subsequently told this was not possible as the area would cross the Cambridgeshire border. If our border can be negotiable with Bedfordshire to cope with Luton expansion why can this not be applicable to us extending slightly into Cambridgeshire?

Can we not be more creative?

I am objecting to the above proposed development. The site must be one of the most unsuitable for development due to traffic issues, flooding, destroying countryside within the Green Belt and also the fact that it will shrink the ever narrowing gap between Hitchin and Ickleford. Ickleford has been designated to take considerably more than its fair shares of additional dwellings without any improvement in infrastructure. The roads are already congested for parts of the day now.

If it is really necessary to build these extra homes (and bear in mind that our leaving the EU is very likely to reduce this demand) then the Burford Grange development is the last place that should be considered.

In response to the North Herts Development Local plan.

As long term Hertfordshire county council tenant farmers of this land we obviously do not want this development to go ahead!

Living & working the land surrounding Baldock we have been able to provide a valuable service to the surrounding towns, providing a choice of local produce & provide services & facilities for the equestrian leisure industry, on selling off these small holding these valuable businesses will be lost for good! Small holdings on Greenbelt land provides unique businesses to serve rural towns once lost you won't get them back....

In response to the development of Baldock town, this will almost double the size of a attractive & vibrant coaching town completely distorting a already congested centre. I can not see even with putting in a road link from the A507 across the railway line will you be able to ease an already congested road, unless the railway station moves out of the site its at & moves further north it will not be able to cope with the volume of people & traffic.... I can only envisage total grid lock!!!

2,800 new homes should be allocated on a site away from existing towns, this is a new town which should be positioned on its own, its own right where infrastructure can be laid out in place where it will work, example an 'Odsey Development' by Ashwell Station on A505, a town in its own right, oh but of course that's not North Herts Land you say... Drop the boundaries & plan together!!!

I strongly object to the Outline North Hertfordshire Local Plan 2011-2031 especially the Sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green and east of Luton for the several strong reasons:-

This area is Green Belt, and there is no supporting evidence that the application meets the "Very Special Circumstances" required to build on it as stated in paragraph 80 and 83 of the National Planning Framework. The Green Belt Boundaries should not be amended in response to an individual planning application.

The plan cites 1950 buildings are required to be built to support Luton' unmet needs. This statement cannot be supported by Luton Borough Council who in the past five years have used Brownfield sites to meet 2200 such dwellings, with more planned in the period 2016 to 2031. This number has not been qualified when challenged and there is insufficient evidence to conclude the dwellings are needed.

The Local Plan itself outlines strategic Objectives which need to be met by its own standards. These are:-

ENV1 The site needs to be sustainable.... this is clearly not the case as there is no public transport to this development from North Herts, there is no school on the EL3 site, and the proposed school on the EL1 site is too far away for pupils to walk, this means that the vast majority will be driven to school. The mere fact that the local dentists, doctors surgery, pharmacy, Tidy Tip, Library, banks, Hospital and shops are all in the Borough of Luton mean that these resources will be oversubscribed.

ENV1 reduce water consumption .... this will not be the case with 2100 homes being proposed.

ECONT discusses the need to minimise travel,, which will not be achievable as the only roads into North Hertfordshire are single access roads which are already used as rat runs.

SOC1 and SOC3 will not be achievable either.

Transport links as described above will not pour out towards the North Herts Borders. This will see droves of vehicles pour down the Crawley Green Road, to the already over breached Wigmore Lane Roundabout intersection. The consequence of this will knock on to the access routes to the Town Centre and the Airport, where access is limited in normal time, let alone rush hours at each end of the day.

The airport itself is looking to expand with more passengers and business parks the objective. This growth inevitably means more than 5000 vehicles pouring in to this already over congested area on a daily basis, without the building of these dwellings.

The obvious need for a link road from the A505 to the Airport itself would balance this out, but as yet there is no plan for this on the Luton Borough Council schedule and this is not apparent in the North Herts District plan either... without this road this planned development is doomed to failure, let alone the fact that funding for such a road has not ben mentioned by either Council. The traffic survey carried out in 2015 was not representative and was not carried out to industry standards and needs to be revisited.

Unjustly the burden for the resources will be borne by Luton Borough Council, whilst the benefits of government grants and rates revenue will be enjoyed by North Herts.

As stated, this development is not needed, meets no objectives of the Luton Borough Council, gives no thought for sustainability and as for traffic in an already overcrowded area, no provision has been made to counter the already compelling argument that the roads will be unable to cope. For these reasons I wish to register my objections.

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WY1 is partly on an old landfill site. The landfill site was in operation before there were any record kept of what was dumped there. The land is toxic/contaminated and you can not build WY1 on an unsafe old landfill site.

I would like to express my objection to the above plans. In particular I have strong objection about the plans for new housing in Baldock.

Whilst I accept that there needs to be some new housing in Baldock I object to:

1) The huge and out of proportion amount of new houses proposed for Baldock town. The plans propose that 34% of North Herts are to be in Baldock. This will dramatically alter the nature of this small market town and have a magnified impact on a small town. The proposed plans, almost doubling the size of the town are too big a change. They need to be scales down considerable.

2) The current infrastructure in Baldock would not be able to cope with the proposed increase. In particular:
* School - Baldock primary schools are already full. In fact children living in Baldock are already having to travel to schools in Ashwell, Letchworth, Norton and surrounding areas as there is no room in Baldock schools currently. Adding 3000+ homes will not help! Before any new houses are built - new primary schools need to be built.
* the Secondary School is full. Again, a new school needs to be built before new houses can be built.
* Roads - the traffic going into Baldock is already bad, in particular North Road. Adding several thousand more cars to the town's traffic will create gridlock.
* Trains - there are already problems with parking and carriage space during peak times. This will be exacerbated by the proposed plans.
* There will need to be increase health, police and fire infrastructure.
3. Green Belt land is green belt. It should not be built upon and town/village envelopes stretched.

In my opinion the plans for 3000+ new homes in Baldock are flawed. Whilst new homes are required in North Herts, and some should be built in Baldock, the number is just too big.

Alternatives would be to look to:
a) Spread the proposed housing far more proportionately across North Herts
b) Create a whole new, small Garden City within the North Herts area - like Cambourne in Cambridgeshire.
c) Where ever more than a few hundred house are to be built, schools and infrastructure needs to be addressed, planned and paid for before the house building starts. With punitive damages for not doing so. Referring back to Cambourne the town existed for 10 years before a site for a secondary school was even looked for - and the school then took a further 5 years to open. 15 years to provide the fundamental infrastructure of schooling is too long. North Herts needs to learn from this and ensure the education of our young people - of our future - is not compromised for the profits of a few builders. The schools, the GP surgeries, the roads, the parks all need to be planned before the builders start building houses and punitive damages applied if and when the planning constraints are breached.

I strongly object to the current proposed plans. They need a drastic rethink.

While the need for housing is not in doubt the local plan for Baldock co terminally lacks imagination and viability.
Until a northern relief road and bridge are constructed the centre of Baldock will become virtually gridlocked between 0700 and 1900. Currently delays of up to 20 mins can be experienced in passing through Baldock using the A507. This will only get worse with the building an additional 2800 heriditiments to the North of the town.
There are no sensible recommendations in the plans for sustainable transport solutions other than very vague generalities and seemingly no consultation with the local railway company about increasing passenger capacity.
The whole plan smacks of a poorly thought out approach to the future needs of the area needs that could be better met by creating a new town between Royston and Baldock.

The Parish Council objects to policy SP8 and the District Council's housing strategy, which is set out in paragraphs 4.85 - 4.112 of the Local Plan. The objectively-assessed needs for housing have recently been updated for the District Council in the report Updating the Housing Need (ORS, 2016). This leads to the assumption in policy SP8 that the Local Plan should provide for at least 14,000 dwellings in the plan period. The This in itself is questionable. The District Council does not have to accept this figure, particularly in those parts of the area which are designated as Green Belt. It is noted from the 2016 SHLAA Update that 63 sites are allocated in the Green Belt, amounting to 12,722 dwellings.

The allocations of land are based substantially on the results of the SHLAA, which has also been updated. The methodology results in a "scatter gun" pattern of development across the rural areas of the District. In village such as Knebworth, proposed housing allocations are way in excess of the capacity of the settlement to receive the amount of development.

In our view, the overall strategy is flawed and should be changed. In the SHLAA and in paragraph 4.104 of the Local Plan, a potential strategic development site has been identified to the west of the A1(M) at Stevenage. Most of this site lies within North Hertfordshire, and it was originally specified for development in the draft Hertfordshire Structure Plan Review of 1996. It was subsequently included in the East of England Plan, which was abandoned by the government in 2012.

Over a period of years, a considerable amount of work was done on the planning of this site. Initially, it was supported by the County Council, but this was withdrawn following a change of political control at County Hall. Nevertheless, a consortium of developers was formed to deliver the development via a Master Plan. Although the proposal was withdrawn with the demise of the Regional Plan, a considerable amount of detailed work was done. In our view, this means that the project could be revived in a short period of time. With a capacity of 3,100 dwellings, the site could make a major contribution to satisfying the dwellings requirements for North Hertfordshire in the plan period.

The inclusion of this site in the Local Plan (policy SP8) as a Strategic Housing Site would mean that 10,800 dwellings could be provided from seven sites. Thus, the requirement for local housing provisions could be reduced form 4,860 to 1,760 dwellings. The bulk of this development would be provided in the 21 Category A villages, via Neighbourhood Plans to be prepared by town and parish councils with the assistance of the District Council policy team.

The consequent changes to policy SP8 and the accompanying text are set out below.

Baldock is the smallest town of the five listed for development in N Herts, yet it is proposed to increase it by nearly 75%. Hitchin and Stevenage are larger towns with far better infrastructure - road, rail and bus.

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We would like to comment with reference to the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016) and specifically the massive proposed development at the Blackhorse Farm site to the north of Baldock. We are not opposed to houses being built in the area, in fact we are very much in favour. However the plans put forward by the Council are completely ill-advised, inappropriate and irresponsible and will mean an increase of 80% in the size of the town. This we believe will destroy the historic town of Baldock and its surrounding area.

Our objections are based on the two tests of soundness that local plans are required to meet:

1. Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities;"
2. "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework

We do not believe that the Council has shown to the public and the residents of Baldock and surrounding villages that it has a deliverable plan in relation to:

* The volume of traffic in Baldock. There is a key area of traffic congestion in Baldock which has not been covered adequately by the Council - the junction where the A507 North Road meets the Royston Road. The junction is used by local traffic as well as a through route for all vehicles from surrounding main roads including the A1M. This is already a severe bottleneck especially at busy times - commuter rush hour, school runs etc. The junction cannot be widened due to listed building on either side of the junction. Therefore building a massive housing estate on the Blackhorse Farm estate will only make the current problems even more intolerable. The council has made little or no attempt to resolve this issue even though the National Planning Policy Framework clearly requires a Transport Assessment to be produced.

* Baldock Train Station. The town train station is situated between the congested junction (as raised in the previous point), and the railway embankment with its reduced access due to the railway bridge. The council does not appear to have taken into consideration that the building of 2,800 houses will put an intolerable strain on the station not least regarding parking and access at peak times of the day. It is expected that many people who will move into the new Blackhorse farm estate will work outside of Baldock - Cambridge, Stevenage, London etc. - and will use the local train station.

* As well as accessibility to the train station the capacity of the train station and the actual rail journeys capacity required to meet the commuter demand will be a significant issue if the Blackhorse Farm estate is built. The council has not indicated how this increase in capacity will be handled by the current station or indeed by the rail company who runs the rail franchise (Govia). The Council has not shown how they are working with Govia to deliver a sustainable plan. Indeed it appears that Govia are actually planning to reduce the overall Baldock service which indicates that the Council are not working "with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
as required by the National Planning Policy Framework.

* Road Infrastructure - Bypass connecting A507 and A505.
The council has proposed that a new bypass should be built connecting the A507 and the A505 (although as yet no plans have been produced. The proposed bypass will not address the issues raised in the previous paragraph as residents will need to access Baldock in order to use the railway station or alternatively use a station further up or down the line (which is unlikely). The full implications of the increased traffic on Baldock and the train station have not been fully considered by the Council.
The bypass, which will go through the Blackhorse farm estate, will inevitably lead to an "M25 effect" with traffic increasing as access is made easier from all points between the M1 through Ampthill and on to Royston and Cambridge. Once again we have seen no evidence that the Council has taken this likely effect into account

* The Council have not shown any realistic plans with regards to how the Baldock town infrastructure will be enhanced to take account of an 80% increase in size. The historic town of Baldock will be severely ravaged by this proposal and the Council has not shown the residents of Baldock and the surrounding impacted villages how it proposes to realistically cope with the proposed increase. What are the clear proposals for road infrastructure for the whole area, doctor surgeries, schools, impact on waste, water usage etc. The council has tried to put off all queries with meaningless platitudes and vague statements but unless there is a clear strategy and clear plans, the Blackhorse housing development could be given the go ahead without all the evidence and plans being made available for scrutiny.

* The proposed Blackhorse Farm development is on Green Belt land which is owned by the Council. It is in our opinion the ownership of the land that is driving the plans - it is a relatively easy and "cheap" decision for the Council to make without having to look for other more acceptable solutions. The council does not appear to have taken into account the National Planning Policy Framework covering the Green Belt. The Council plan will lead to urban sprawl which they are obliged to avoid. This proposal appears to ride roughshod over the Government's stated aim with regards to the Green Belt and that Councils should not build on Green Belt land merely to meet planning targets. The Council has failed to prove to Baldock residents that there are no alternative sites available rather than this massive development which will ostensibly double the size of Baldock but will not increase the required facilities to meet demand.

Conclusion

In our opinion the Council has failed to prove that it is meeting the "Tests of Soundness" that local plans are required to meet and has failed to develop an adequate strategy and detailed plans with regards to the impact of the Blackhorse Farm estate on Baldock, the surrounding villages and settlements, the overall road and rail infrastructure and the impact of the internal town infrastructure.

Baldock is already struggling with the traffic due to its historic buildings and road access which was not developed for modern day traffic volumes. To increase this by almost doubling the size of the town is completely unacceptable.

We are not against building houses in Baldock and the surrounding area but we are against a massive development with no clear strategy for the area which appears to be based on the main fact that the green belt farm land is owned by the Council and so can be used as they wish without taking into account local concerns and their statutory duty around the National Planning Policy Framework. The Council need to revisit their plans, dramatically reduce the size of the Blackhorse development and form a clear strategy and detailed plans in order to meet their requirements for the 2011 - 2031 Plans.

I am writing to express my concern at the proposal contained within the local plan.

It appears to me that insufficient account has been taken of green belt constraints, as set out in paragraph 14 of the NPPF. The very substantial housing numbers, almost 16,000 much of which will be scheduled for land which is currently green belt agricultural land is totally at odds with the spirit of the NPPF section 9. The long term effect of implementation of the plan in it`s current form, will be a loss of amenity for residents of North Herts together with the progressive erosion of the rural environment.

The local transport network is struggling to meet current demand, both road and rail. As a regular user of the latter, I am all to aware that delays and cancellations are a daily occurance whilst trains at all times of the day are frequently crowded. I am not aware of any planned proposals for the very large scale investment needed to meet a further substantial increase in demand.

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4.88 The Plan concludes that sensible expansion of towns and villages is the best way of delivering growth needed, whilst protecting the rural character of the District - however, the massive development to the north of Baldock is not a sensible expansion, it is too large and too fast for the district and county councils to manage and will destroy the rural character of that area and Baldock as a whole. Furthermore, the conclusion that expansion of existing towns is the best option is based on a Sustainability Assessment which is flawed in a number of ways. Firstly it assumes that homes delivered by town expansion would be covered by the local housing market which is the Stevenage HMA, however, the massive site north of Baldock is land, being released from Green Belt, that is very close to the train station with a direct fast (34 minutes) link to central London - any part of this development within 20 minutes walk of the station will be affected by London house prices and more over will go to meet London housing need and not to meet North Hertfordshire housing need. This is easily mitigated by maintaining a strip of Green Belt between the new development and Baldock, or by developing this strip only when the rest of the site has been developed. Secondly the Sustainability Review appears to make no regard for how overstretched existing facilities and infrastructure are in the existing towns and whether they can in fact be sustainably increased as part of expansion of the town - in Baldock for example the road layout with narrow roads at pinch points and the position of listed buildings hundred of years old along key roads and junctions, makes it almost impossible for it to accommodate much increase in traffic, but this has not been considered. Finally, it makes no regard for whether several small extensions are as achievable as a single large one - I believe, based on recent experiences at Great Ashby and the Church Gate fiasco that the district and county council may have the ambitions but do not have the capability to deliver single large developments, and that smaller, more evenly spread developments would be more achievable. Furthermore, the plan as it currently stands appears to stifle development of villages of all sizes (by restricting development and trying to cover large new areas with Green Belt needlessly).

Re: Point 4.90 There are several sites that surround Clothall Common on the east of Baldock. Although they are separate sites, they are almost adjacent and are all adjacent to Clothall Common. The total number of homes delivered by these sites is greater than the 500 level set in this plan as the requirement for a strategic plan, and given the dramatic effect these sites will have on Clothall Common and that they are all planned to be developed first and rapidly in order to facilitate the development to the north of Baldock, then these sites should be covered by their own strategic plan. It seems that a lot of the initial conversations about schools and roads have already happened in regard of these sites (from comments made by councillors at information meetings), so creating a strategic plan would not delay implementation, but would ensure that effects and benefits of the sites are considered in combination - for example, do they create a need for more open space, playing fields, sporting facilities, leisure facilities, community facilities, local shops, bus routes, tree planing, etc.
It is clear that a large part of the site (BA1) north of Baldock, within 20 minutes walk of the train station with a direct fast (34 minutes) link to central London, will go to meet London housing need and will leave North Hertfordshire housing need unmet, whilst increasing the load on local facilities and infrastructure and driving up house prices. It is also clear the the district council has failed to make progress on establishing new settlements over the existing period and I see no reason to expect that they will do so over the new period - leading to an even greater housing need at the end of the period of the Plan. The solution is ensure building of new settlements has begun (even if it is only a few homes!) by the end of the period of this plan and that this commitment is included in this plan.
4.100 should have an additional sentence. "This plan commits to the establishment of 2 new settlements, including at least the very first stages of development, that will be able to grow into Garden Villages and then Garden Towns in the future. This is the best way of creating sustainable options for development in the future."
4.101, the first sentence should be changed to The Council is committed to fully exploring settlement options in the District and to establishing at least 2 new such settlements over the period of the Plan.
4.103 is conjecture - it is correct that there are constraints, but whether additional sites can meet future need is unknown, but starting on them will certainly create new options. 4.103 should be changed to "If a new settlement is pursued, it might not meet all future need and there might still remain a need to identify additional sites".
4.109 Self-build is an excellent way to increase the plurality of delivery methods of new development in the plan. I believe that there has been a resurgence in self build across the country (based on perceptions from media reporting and from anecdotal evidence - a close friend is looking at self build as the only way to provide his family with an affordable home). Self build also provides affordable housing and tight knit communities, with varied, interesting and characteristic housing stock. The target for self build should be increased, 1 % is too low.
A another strategic housing site or masterplan requirement should be added, comprising the sites surrounding Clothall Common on the east of Baldock - almost adjacent to each other and dramatically affecting Clothall Common. Together these sites deliver well over the 500 homes minimum that the Plan says will require a housing strategy/masterplan, and are intended to be delivered at the same time and rapidly in order to help facilitate the development of the site to the north of Baldock (BA1 Blackhorse Farm). However, if they are delivered as a set of separate developments, even with the planning that has already been done, there is a risk that matters such as open space, leisure facilities, shopping, transport and infrastructure requirements will be considered separately rather than in aggregate resulting in insufficient facilities and infrastructure being created as a result of the developments. In other words, by developing so many sites, so close to each other, around an existing community, but doing so separately it looks as if the Plan deliberately attempts to separate out the considerations of the requirement for new facilities and infrastructure and deliberately sets out to result in under-supply - or at least to allow this to be possible without contradicting the plan. Since planning for these developments appears to be well under way (since these sites are intended to be developed first and rapidly, and from comments made by district and county councillors at Local Plan information meetings) then the creation of a master plan/strategic proposal for these sites should be possible with little or no impact to the schedule and deliverability of the plan, but with significant improvement on the sustainability of the resulting development of Clothall Common.