Policy SP8: Housing

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I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to the NPPF (Promoting sustainable transport, para 31) which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development". It is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. In 2014 the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

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

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

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

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

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

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

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

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

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