Policy SP8: Housing

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I wish to support the contents of this submission in their entirety.
REPRESENTATION TO THE LOCAL PLAN
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).
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.
Since then traffic has risen and now the levels 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 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 at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which both deliver traffic.
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.
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) 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 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 modelling." 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.
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 pinch-point 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 NHDC's plans 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. 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 to A507 and will deliver more air pollution to the site BA1.
There is no modelling of the impacts from developments 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".
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 pinch-point 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 eg Great Ashby have discovered this to their cost.
The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

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I wish to object to the Local Plan as the proposal to build 3,290 new homes in Baldock by 2031 is unjustified, not effective not sustainable and is inconsistent with National Policy.
Quite simply, the local plan is proposing to build too many houses in the wrong places. Rather than distributing the numbers equitably across the locality and making full use of available brownfield sites, there appears to be have been a desire to provide a 'quick fix' regardless of policy and the consequences, by building a large proportion of these houses on Hertfordshire County Council owned green belt land.
This approach is unjustified, not effective, not sustainable and not in the interests of the Historic town of Baldock, its residents, the surrounding community nor the resident wildlife, much of which has protected status.
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). 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. Since then traffic has risen and now the levels 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, stress 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 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 at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which they both deliver traffic. 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.
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) 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 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 modelling." 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.
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. [Type text] 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 pinch point 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 NHDC's plans 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. It is quite exposed at this point. This indicates that NHDC has produced a poor plan without much foreward 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 to A507 and will deliver more air pollution to the site BA1. There is no modelling of the impacts from developments 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.
Where will these new residents work and how will the land designated for industrial development be used? There are few new work opportunities here so most will commute out of Baldock. This will have a massive impact on roads and railways which are already overburdened and close to breaking point. Should areas closer to centres of employment such as West of Stevenage not be considered.
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". 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.
The impact on local wildlife has also been ignored. Many rare species of birds including corn buntings breed and are resident in this area. Corn buntings are protected in the UK under the Wildlife and Countryside Act, 1981, classified in the UK as a Red List species under the Birds of Conservation Concern review and as a Priority Species in the UK Biodiversity Action Plan.
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 eg Great Ashby have discovered this to their cost. The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.
I should like to be kept updated on the Plan's progress I should like to be invited to the Public Hearing.

REPRESENTATION TO THE LOCAL PLAN

I wish to object to the Local Plan as the proposal to build 3,290 new homes in Baldock by 2031 is unjustified, not effective not sustainable and is inconsistent with National Policy.
Quite simply, the local plan is proposing to build too many houses in the wrong places. Rather than distributing the numbers equitably across the locality and making full use of available brownfield sites, there appears to be have been a desire to provide a 'quick fix' regardless of policy and the consequences, by building a large proportion of these houses on Hertfordshire County Council owned green belt land.
This approach is unjustified, not effective, not sustainable and not in the interests of the Historic town of Baldock, its residents, the surrounding community nor the resident wildlife, much of which has protected status.
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). 1. This site is acknowledged by the council as making a signicficant 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. Since then traffic has risen and now the levels 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, stress 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 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 at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which they both deliver traffic. 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.
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) 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 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 modelling." 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.
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. [Type text] 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 NHDC's plans 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. It is quite exposed at this point. This indicates that NHDC has produced a poor plan without much foreward 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 to A507 and will deliver more air pollution to the site BA1. There is no modelling of the impacts from developments 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.
Where will these new residents work and how will the land designated for industrial development be used? There are few new work opportunities here so most will commute out of Baldock. This will have a massive impact on roads and railways which are already overburdened and close to breaking point. Should areas closer to centres of employment such as West of Stevenagenot be considered.
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". 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.
The impact on local wildlife has also been ignored. Many rare species of birds including corn buntings breed and are resident in this area. Corn buntings are protected in the UK under the Wildlife and Countryside Act, 1981, classified in the UK as a Red List species under the Birds of Conservation Concern review and as a Priority Species in the UK Biodiversity Action Plan.
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 eg Great Ashby have discovered this to their cost. The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.
I should like to be kept updated on the Plan's progress I should like to be invited to the Public Hearing.

Object to Chapter 4, Policy SP8
The plan is not sound as it provides for too much housing to the detriment of the open countryside. Sites, including SP2, have been added at a very late stage and should be removed as they are not needed. There is no policy basis for increasing the buffer from the previously accepted 3% to 7%
Object to Chapter 4, Policy SP2
The plan is not sound as the evidence used to identify sustainable villages is flawed. This results in isolated villages with no facilities such as a senior school and shops and very little public transport being seen as suitable for significant development. In addition Whitwell is accesses by narrow lanes often requiring passing places. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
Object to Chapter 13, Site Allocation SP2
There is no need for SP2 to meet housing need. The NHDC approach is not sound. It does not comply with NPPF as no consideration has been taken of flood risk and a sequential approach has not been followed in site selection. It was also added at a late stage with an allocation of greater than 5ha - this conflicts with NHDC evidence that large housing extensions to Whitwell could have an unacceptable visual impact due to high visual sensitivities associated with cross country views
Object to Chapter 13, site allocation SP2
The site has a known and identified high risk of surface water flooding as recognised in the Council's Strategic Flood Risk Assessment. The NPPF states that development should be steered to areas with the lowest chance of flooding. Site SP2 should only be considered if there is an identified need that cannot be met elsewhere with a lower probability of flooding
Object to Chapter 13, site allocation SP2
The proposed development is not in a sustainable location and will depend on private transport for most travel. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
NPPF Requirement to empower local people to shape their surroundings (Paragraph 150)
The Local Plan has ignored our local community. NHDC is well aware of the local feeling towards potential development on this site. The site is not needed to meet the identified housing need and yet NHDC Planners remain determined to use this site even with known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside. Thames Water state lack of sewerage capacity. The Planners even ignore their own Planning Committee who recently rejected the site for development
Object to the allocation of SP2 for housing
The Local Plan Preferred Option allocated the site for Green Belt. This was fully supported by the Parish Council. NHDC has provided no justification for the site no longer being categorised as Green Belt. Latest figures (reduction in OAN) show that SP2 is not needed for housing. Green Belt status is also needed to mitigate for Green Belt losses elsewhere in the District where additional housing is being provided in more sustainable locations. The Local Plan pragmatically adds in late sites. The submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes for SP2 to remain Green Belt
For the reasons above I consider that SP2 should be removed from the 2011 - 2031 Local Plan

Although I accept that more (affordable) housing is needed in North Herts, that
there are not enough brownfield sites to meet the targets NHDC has been given,
and that in effect NHDC is caught between a rock and a hard place, I am objecting
to the NHDC Local Plan for Knebworth (paragraphs 13.183-13.202) because it is
unsound. My reasons are the following:
1. It is not positively prepared because:
* NHDC conducted a preliminary consultation, but despite record numbers of
people attending public meetings and responding in writing, NHDC have not
addressed the community's areas of concern. Nor have they modified their
proposals for Knebworth in line with the community's objections - in fact, they
have actually increased the housing provision by 50%. Therefore, NHDC have not
engaged adequately with local residents.
* The proposal to build a minimum of 663 dwellings in Knebworth by 2031would
increase the number of houses in the village by a massive 31%, which would have
an overwhelmingly detrimental effect upon Knebworth's character, traffic,
infrastructure and Green Belt.
* The only access to the proposed homes on the western edge of Knebworth
would be via Gypsy Lane or Deards End Lane, which are narrow country lanes with
blind bends and no pedestrian paths. They are already heavily used as rat runs and
are notoriously dangerous for drivers and pedestrians alike. They could not sustain
the traffic associated with a 31% increase in population.
* Watton Road, St Martin's Lane (much of which is private), and Swangley's Lane
could not take the increased traffic from 200 homes built to the east of
Knebworth (site KB4). Watton Road in particular, which runs between the B197
and the A602, is already a major bottleneck in the village.
* The B197 running from Welwyn to Stevenage is often clogged with bumper-tobumper
traffic during the extended rush hours (even when there are no problems
on the A1(M), for which the B197 has become an overflow road) and would come
to a standstill with the large increase in traffic. Solving the notorious parking
problems in Knebworth High Street would not solve the problem, as it is caused
mainly by the sheer volume of traffic. The plan does not identify any specific
traffic-mitigation plans.
* The only access from the town centre to the proposed dwellings on the western
edge of Knebworth is under one of two railway bridges (in Station Road and Gun
Lane), which are each so narrow that there is not room for two cars abreast, and
where there is only a very narrow pedestrian pavement, causing people (especially
children) to step into the road when passing another pedestrian. There is an
electricity sub-station alongside each bridge which could hamper any attempts by
Network Rail to widen the road under each bridge (even assuming Network Rail
were willing to attempt any widening, which is unlikely).
* Trains running from Knebworth station are used not just by residents of
Knebworth but also by those from the surrounding villages, resulting in
overcrowded carriages and inadequate parking in the village. The station car park
is small and usually full, so commuters' cars are parked in the roads, creating
traffic hazards particularly in Park Lane, Gun Lane, Lytton Fields and Deards Wood.
These would only be exacerbated by a 31% increase in the village's population.
* The plan does not take into account the local infrastructure, which is inadequate
for such a large increase in population. As well as the transport problems (see
previous five points), the doctors' surgery is struggling to cope with the existing
population. In addition, there is only one primary school in Knebworth, which takes
60 pupils a year and is always oversubscribed, and there is no secondary school.
None of these could cope unless they were substantially enlarged.
* The plan makes no provision for a secondary school; it does claim that a primary
school could be built on site KB2/Gypsy Lane, but there is no actual provision for
it. In fact, its proximity to the A1(M) would mean that children - who are
especially vulnerable to black carbon, nitrogen dioxide and particulates, which
stunt their lung growth and brain development and cause asthma - would be
subjected to severe air pollution at the proposed school.
* The plan is unsustainable because the close proximity of the A1(M) would cause
irreversible damage to the well-being of future generations, not only in relation to
the proposed primary school (see previous point) but also because of its being the
site for two-thirds of the total number of houses proposed for Knebworth. The
184+ houses on site KB1/Deards End Lane would be less than 500m from the
A1(M) and the 200+ houses on site KB2/Gypsy Lane would be less than 250m
from the A1(M); at one end, the outer boundary of site KB2 is only about 100m
from the A1(M). This motorway is a pollution hotspot, meaning that the expected
life span of people living in the houses would be reduced. Noise pollution would
also be an issue for residents of these houses.
* The plan does not take into account the county's own plans for widening the
A1(M) between junctions 6 (Welwyn) and 7 (Stevenage) by one lane northbound
and one lane southbound. This is listed by herts.gov.uk as a medium-term scheme
and would surely drastically affect the proposed sites KB1/Deards End Lane and
KB2/Gypsy Lane, in terms of both land available and proximity to air pollution.
* There are drainage issues relating to the KB2/Gypsy Lane site. Parts of
Knebworth (including Broom Grove, Orchard Way, Gipsy Lane and site KB2 itself)
have been subject to localised flooding in the recent past, caused by surfacewater
drainage problems, an overflowing lagoon alongside the A1(M), and runoff
from this motorway, and these problems have still not been solved by NHDC.
Paving over the fields of sites KB1 and KB2 would exacerbate this problem. There
is also an acknowledged capacity issue at Thames Water's Rye Meads Sewage
Treatment Works, which treats Knebworth's and Stevenage's sewage.
* The proposals would remove 46.7 hectares of agricultural land, which is
important for wildlife and local residents' use, as well as agriculture. The impact on
Knebworth's setting in open countryside would be substantial and damaging.
* There is no guarantee in the plan that the majority of the proposed homes
would be social and affordable housing rather than the more expensive 'executive
homes' that developers prefer to build. Likewise, there is no guarantee that the
minimum number of houses would not be exceeded, creating an area of dense
housing that would be incompatible with the leafiness and rural nature of the
surroundings.
2. It is unjustified because:
* NHDC has not properly examined the possibility of building a proper 'garden
community' instead of drastically expanding Knebworth and other villages. In
addition, there are undoubtedly more brownfield sites that could be utilised.
Because of pressure to complete the plan by the deadline, NHDC, rather than
choosing the most appropriate strategy for Knebworth, has simply chosen the
easiest option - to use land from just two sources, both of which are eager to sell.
Because it is nearly all big chunks of Green Belt land rather than numerous small
brownfield sites, the land is cheaper to develop and therefore more attractive to
developers.
* The NPPF states that the Local Plan must identify a five-year supply of specific,
deliverable building sites, but the NHDC plan covers 20 years (2011-2031) rather
than five. Furthermore, NHDC has chosen an arbitrary housing target over the 20-
year period, designed to compensate for the unmet housing requirement
elsewhere, particularly in west Luton - this is indefensible and unnecessary.
* Ten years ago NHDC decided that 'Knebworth is not suitable for further
development as it would risk the sustainability of the village'. Now NHDC has
reversed their stance and recommended a housing target that is higher than
elsewhere in North Herts. This is unjustified and will have a disproportionate
impact on Knebworth, as NHDC's 2006 study foresaw.
* The plan for Knebworth does not take account of the impact of the Local Plan's
proposal for 150 new houses in the adjacent small village of Woolmer Green, the
population of which uses Knebworth facilities.
* There is no provision for additional employment in Knebworth; in fact, it reduces
employment by earmarking site KB3/Chas Lowe's, which has been commercial
premises, as residential development.
3. It is ineffective because:
* The number of houses the plan proposes would be impossible to achieve during
the designated time periods, particularly the final phase. There are not enough
builders to actually do the work within the time frame, given that they will be in
demand all over the county and indeed the country. Nor would there be time to
alter the infrastructure sufficiently to support a 31% increase in the population.
* The proposed Local Plan will not deliver a sustainable plan for Knebworth
because of the problems associated with overwhelming demands on the local
school and doctors' surgery, and with parking, traffic congestion, A1(M)-widening,
air pollution, drainage, and loss of Green Belt land that surrounds the village and
protects it from merging with Stevenage and nearby villages. The plan is
unrealistic and unattainable.
4. It is inconsistent with national policy because:
* NHDC has proposed that 46.7 hectares of land be built on, of which 99 per cent
is Green Belt. Yet the NPPF stipulates that Green Belt land should only be used
under 'exceptional circumstances'. These are not exceptional circumstances. The
Green Belt around Knebworth is vital to help retain its rural nature. Earlier in 2016,
the Dept for Communities and Local Government said, 'Ministers have repeatedly
been clear that demand for housing alone will not justify changing Green Belt
boundaries. Councils are already expected to prioritise development on brownfield
sites.' Furthermore, the local government secretary has recently said that the
Green Belt is 'absolutely sacrosanct'.
* The national policy is to try to keep villages' own identities and prevent them
from coalescing into one sprawling suburban conglomerate. The proposed
development of Green Belt land on the east side of Knebworth (site KB4) would
take the boundaries closer to Stevenage and to Datchworth, while Woolmer
Green's Local Plan would bring it closer to Knebworth.
* Government planning policy states that any development must be sustainable
with the current or planning infrastructure, but the proposed plan does not take
Knebworth's infrastructure inadequacies into account.
* The Air Pollution Minister for the Dept for Environment, Food and Rural Affairs
has said that the government has committed to cutting air pollution to which
people are subjected, yet the Knebworth plan proposes that 384+ houses and a
primary school be built right next to a pollution hotspot, the A1(M).
* Government policy is to preserve the unique character of conservation areas.
Yet 59% of the proposed building land, containing two-thirds of the proposed
homes, is adjacent to one of Knebworth's two conservation areas - Stockens
Green conservation area and Deards End Lane conservation area - upon both of
which this development would have a seriously detrimental effect.

Now that NHDC has decided that it does not intend to develop an equitable Local Plan across North Herts and that Baldock will take a disproportionate number of the new housing which will result in the town being doubled in size, there are a number of questions and considerations that arise with such a large increase which need to be carefully considered and answered before the development commences.

Firstly and most importantly the proposed road network for Baldock is weak and undefined and will be totally inadequate for the number of new houses proposed. The bottle-neck problems today are well known particularly at the Whitehorse Road / Royston Road crossroads and also on the A1 south around Stevenage. A new road connecting the A507 London Road to the A505 Baldock bypass including a new bridge across the railway and some tinkering around the station area will not provide the road infrastructure that will be required from three thousand new homes and as a consequence in excess of four thousand additional vehicles.

Has anyone associated with the Local Plan considered where these new homeowners might work and how will they travel to their work and what the impact will be on roads in and around Baldock. It is most likely that people will work either south or west of Baldock given the limited employment opportunities to the east or north. There are no provisions in the Local Plan to address these requirements, which render it unsatisfactory and ineffective as it stands. These needs must be addressed as a matter of priority if this Local Plan is seriously to be pursued.

The proposed development of 2,800 new homes to the north of Baldock is effectively the development of a 'new town' adjacent to the oldest market town in North Herts and therefore, the planning must be considerably more robust and effective than has been identified in the Local Plan. Areas of weakness relate to road infrastructure, water and sewerage provision, employment provision, infrastructure and its funding, greenspaces and landscaping of the 'new town'.

Furthermore what provisions have been made for the retention of the community based culture that currently exists in Baldock?............the answer....... none whatsoever.

My request is for the Local Plan to be withdrawn in order that all or at least some of these issues are adequately addressed.

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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.

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