Policy SP8: Housing

The Plan has adopted as the proposed sites for development in and around Baldock land belonging to Hertfordshire County Council(HCC) - mostly Green Belt used for small-holdings and recreation. Baldock has more HCC owned land than the other North Herts towns and so it has been proposed that the town will take a disproportionately large number of new homes which will increase its size by more than 70% during the Plan period. Other sites of similar size in Letchworth and Hitchin were originally put forward but were withdrawn and it is not apparent that these sites have been assessed for suitability which could have spread the load more equitably. In particular there has been insufficient co-operation with Letchworth Heritage foundation over the site North of Letchworth (LG1) which has been allocated only for the needs of Letchworth. The West of Stevenage site has not been considered for this stage of the Plan, again for no apparent reason, and its adoption would have reduced significantly traffic movement through Baldock's historic town centre.
Site BA1 is Green Belt land and the Plan acknowledges that it has moderate to high landscape sensitivity as well as being difficult to integrate successfully into the rest of Baldock.
The sites on and close to Clothall Common (BA2, BA3, BA4, BA5) will deliver several hundred homes when complete but are not treated as strategic sites and so won't provide the infrastructure that so many new residents will need.

See attachment

Object to Chapter 4, Policy SP8
Sites, including SP2, have been added at a very late stage and should be removed as they are not needed.
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. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
require SP2 to be removed from the local plan

I object strongly to the proposal to remove Green Belt protection from land West of Stevenage and regard this as an unnecessary step which will inevitably open the way for an eventual expansion of Stevenage into North Herts. It staggers me that para 4.104 states that Stevenage's plan is likely to have limited development opportunities when it seems that when available sites which could be used for housing are given over to yet more retail development.

Removal of proposals to develop Priory Park for housing

I accept that houses need to be built but the plan is *hugely* unfair, placing an excessive burden on Baldock and its infrastructure and has been *very* poorly thought through.
* The plan proposes a doubling of the population which will entirely change the character of the small market town
* The also uses green belt land which should be the last resort for development
* The areas B2,B3,B4,B5 propose to add 500 houses. These areas will cause a large volume of traffic to route via the North Road crossroad, or the roundabout at the end of High Street. Access out to Cambridge and Letchworth/Hitchen is therefore very heavily constrained by these two pinch points. Such an increase in traffic on Clothall Road past the nearby Hartsfield school inevitably will cause an increased danger to children and increase in pollution.
* Direct access from the B656 to the Clothall estate and the new areas B2,B3,B4,B5 *MUST* be addressed, to ease congestion at the crossroads
* Reconsider the possibility of a junction between A505 to A507
* The road network around the small town is already very busy and polluted at rush hours, and cannot easily be redesigned due to its tight layout and its many historic listed buildings. The traffic at the crossroads is already a problem and backs up along the B656 and North road and into High Street and excessively inhibits journey times and causes pollution.
* Construction work will take place over a long period and will cause massive disruption to the town, for which it will receive no compensation.
* Local services are already stretched and are certainly not sufficient to serve such an enormous increase in the population of this small town and *must must must* be extended to comfortably serve the proposed population *before* the houses are built
* Fresh water supply is likely to be an issue, as is drainage, potentially flash flooding in the town centre unless managed appropriately.

My feeling is that the development has been insufficiently thought through and the proposed suggestion of a New Town has been outright rejected on the grounds of not having enough time. However this is a very weak excuse for a plan that is meant to take into account long term development over a period of 20 years. Why can other councils manage to properly plan housing in a sustainable and creative way but NHDC cannot?

It *is* possible to build housing in a thoughtful and considerate way. The plan for Baldock does not.

See attachment

I have again reviewed the plans for the proposed development of Baldock and wish to raise my objections. I think everyone understands the need to build more properties but the sheer scale of the proposed development around Baldock is ludicrous and will totally destroy the town and surrounding areas.
- If you look at the current traffic situation in Baldock it is a disaster. At certain times of the day you can queue from a mile outside Baldock and it can take 20 minutes to get to the junction on Station road. The whole town is extremely busy and cannot cope with anymore traffic. As well as all the local roads the A1 is total grid lock every morning and these vast amount of new houses will have more than one car and will make things drastically worse.
- The rail station at Baldock is tiny and during rush hour gets very overcrowded and simply cannot cope with a huge influx of people without it becoming extremely dangerous and simply unfit for purpose. Also the carpark and roads/junctions near the station are totally unsuitable for more people. Alongside the Great Norther trains are about the change the timetable to reduce the number of fast trains which will only make things worse.
- The doctors, dentists and schools are all full and cannot cope with more people.
- The shops and recreational activities cannot cope with the current population of Baldock let alone thousands more.
- Baldock will become totally overrun and from being a very historic town with lots of heritage and history will be totally destroyed.

These plans need changing. The infrastructure and the residents cannot cope! There are areas in North Herts where brand new towns could be developed from scratch. These plans need amending or you will be destroying our town. Areas of Baldock are already be developed and the plans need to be much more realistic.

A very concerned resident

The Strategic Housing Sites, particularly Site BA1, have not been properly considered against all reasonable alternatives (or if they have there is no evidence for it) and have therefore not been shown to be a part of the most appropriate strategy. NHDC appears to have been entirely reactive, considering only sites put forward by landowners, instead of proactively considering all feasible sites and approaching landowners where appropriate.

The largest site, BA1, was not in the Housing Options documents of February 2013. It was first proposed (covering an even larger area) in the Housing Additional Location Options document dated July 2013, leaving relatively little time to evaluate it adequately. Baldock is the smallest of the four towns in the District, with a historic centre on a medieval street layout within a conservation area. With the proposed developments on Site BA1 and the other development sites around the town it will have by far the largest number of new homes, increasing the size of the town by a massive 73% with inevitable and severe negative effects. Road traffic is a constant problem because major traffic routes run through the central conservation area and there is very little scope for providing alternative routes. The nature of the town centre precludes enlarging retail and other infrastructure provision within the central area.

If reasonable alternatives had been properly considered there is a strong probability that site BA1 would have been at least significantly reduced in size, thereby reducing the stress on the town. The following examples, which are not necessarily exhaustive, indicate possible alternative sites. By not using the most sustainable locations the plan fails to meet strategic objective ENV1.

Letchworth Garden City Heritage Foundation has - entirely properly - considered the needs of Letchworth and offered a strategic site, LG1, for 900 homes, However, NHDC does not appear to have considered whether, looking at the needs of the District as a whole, it would have been appropriate ask the Heritage Foundation to make more land available.

The Housing Options February 2013 document included a large strategic site south-west of Hitchin, much of which was owned by a developer who also had options agreed with other landowners, sufficient for between 6000 and 7400 homes. It then disappeared from the Local Plan. The reason may be found in the Housing and Green Belt Background Paper, para. 3.14, that former site 209e, Priory Fields, was excluded because 'There was insufficient certainty that a scheme could be realised here without triggering an objection on air quality grounds.' The Local Plan notes similar air quality problems in the Hitchin Street/Whitehorse Street area of Baldock and these will be exacerbated by development on site BA1, but this site was added to the Local Plan regardless of this problem. Full development of the Hitchin Site would be excessive but using part of it could reduce the pressure on Baldock without having such a large effect on Hitchin.

There is land to the west of Stevenage which it is proposed to safeguard for future development for up to 3100 homes, which could be allocated to meet housing needs now without the adverse impacts associated with site BA1, and which has the advantage of being closer to main centres of employment, retail facilities, and public transport.

Also in the Housing Options February 2013 document there were three sites numbered 15, 014 and 012 to the south of Baldock, together estimated to be sufficient for 468 homes. Site 15 'failed one of the tests' for unspecified reasons, and the other two were rated 'priority 3', with no reasons given. These have disappeared from the 2016 Local Plan document. Although it would not reduce the total number of new homes for Baldock, if some or all of these sites were to be included it would allow a reduction in the number of homes on site BA1, which would have specific advantages, especially for transport. Being to the south of the town, these sites have easy access to the one large supermarket serving the town, at the south end of the High Street. They allow direct access to the south via London Road, to Letchworth and the west via London Road and Letchworth Gate, and to the eastern side of Letchworth (including the retail trading estate on Baldock Road) via Weston Way and the A656. All these routes avoid the congested and historic town centre conservation area.

Identify other potential housing sites, both strategic an non-strategic, and systematically evaluate these and existing sites, initially without considering availability, then open discussions with landowners of suitable sites not previously put forward. The objective should be a more proportionate distribution of planned housing among the four towns that would eliminate or at least reduce the size of Site BA1 and reduce the excessive stress on Baldock.

1. The proposed development would be a serious encroachment into the existing Green Belt located on the eastern side of Luton. Such extension in addition to being into the Green Belt is into an area of considerable landscape character and its urbanisation would be detrimental to the attractive area lying between the villages of Great Offley, Kings Walden and Luton.

2. The proposed development is an uncoordinated extension of Luton out into open countryside with a lack of defensible boundaries, such that the Local Authority would be under pressure to allow further expansion into open countryside and the Green Belt at times into the future. Such pressure might lead to additional development to the north and east of Mangrove Green with pressure to expand further into the historic area of Putteridge Bury Park.

3. The existing villages of Mangrove Green and Cockernhoe would be completely dominated and absorbed into the overall development area and would lose their rural character.

4. Access to the site is poor. Whilst there are roadways leading to the west, these are only of sufficient quality to absorb further residential traffic once they cross over the boundary into Luton Borough. Whilst this might adequately serve traffic leading to the centre of Luton or via Crawley Green Road to the M1 motorway, the road layout is poorly served for residential occupants wishing to travel to the north and east.

5. The tendency will be for traffic wishing to travel in the direction of Hitchin on the A505 to either travel through residential streets over a distance of 1¾ miles before joining the A505 at Stopsley, or alternatively to take to the local lanes by means of Chalk Hill, Brick Kiln Lane and Stony Lane to access Lilley Bottom some 11/2 miles to the east. The three aforementioned lanes are essentially single track roadways and are quite incapable of absorbing traffic from a development of some 2,103 dwellings, and on the earlier planning application of Bloor Homes under Planning Reference 13/02000/1 there appears to be little in the way of proposed improvement to those roadways.

6. Each of the three roadways lead down onto the Lilley Bottom Road, which runs from the village of Lilley through to Whitwell. Lilley Bottom is essentially a single track road for much of its length with passing places. It is already a well used rat run and is not capable of absorbing traffic from such a sizeable development.

7. It is almost inevitable that those wishing to travel to Hitchin, Stevenage and Welwyn will use Lilley Bottom in spite of any signage to attempt to direct traffic away to the residential areas of Luton. This is because it is a shorter distance and avoids the congestion within Luton.

8. Much of the traffic will eventually find its way onto the A505 dual carriageway and head in an easterly direction to Hitchin. It is well known that during peak times there are significant delays and queues on the western side of Hitchin due to a lack of any bypass arrangements to the town. A development of this size would therefore only exacerbate the situation and is another reason why development should not be considered at this location.

9. The current planning application in respect of Site EL1 makes provision for a primary school, but there is no provision for secondary education. This will inevitably place a strain upon the resources of North Hertfordshire rather than Luton, to which the development is aligned. Existing transport for school children in the rural areas of North Hertfordshire relies upon mini buses, but with the extent of development proposed and the number of children involved, this would be quite unsuitable for Wandon Park. The direct routes from Wandon Park via Chalk Hill, Brick Kiln Lane and Stony Lane are not capable of accommodating full size buses, which will mean that children face a lengthened journey by having to travel into Luton before returning to North Hertfordshire. This is not the mark of a sustainable development.

10. The present planning application makes no provision for a medical centre or library facilities. Access to existing medical and library facilities within North Hertfordshire are poor.

11. The emergency services will struggle to gain access because of the poor nature of Chalk Hill, Brick Kiln Lane and Stony Lane, and inevitably such access will need to be via Luton, which will substantially increase response times.

12. Paragraph 12.2.5.1 of the Preferred Options Consultation Paper made it clear that the Wandon Park site is only included as "an allowance to meet the specific needs arising from Luton rather than North Hertfordshire". As demonstrated by the above, expansion to the east of Luton due to its relatively isolated location, Green Belt status and landscape character, make a site to the east of Luton unsuitable. Luton should undertake a comprehensive study of its own needs, and consideration should be given to the "Bushwood" site which has earlier been proposed within submissions to the Joint Core Strategy prepared by Luton Borough together with South Bedfordshire District Council (now Central Bedfordshire).

13. The Bushwood site lies immediately to the south-west of Luton and adjoins the western side of the M1 motorway.

14. It provides for up to 5,500 houses together with a higher degree of local facilities than that proposed at Wandon Park. The Bushwood master plan provides for:

i) Community stadium, hotel and conference centre
ii) Dedicated public transport route
iii) Lower and middle school
iv) Neighbourhood centre
v) Retirement village
vi) Supermarket
vii) Academy school
viii) Sport village - multi indoor facilities and swimming pool
ix) A new site for Luton Town Rugby Club
x) Employment
xi) Open space to include parks, children's play, sports facilities, ecological landscape, and allotments
xii) Park and ride
xiii) Landscape and habitat creation
xiv) High density housing
xv) Retained woodland/area of landscape value
xvi) Connection to the Luton/Dunstable bus way

15. The site is also closer to the centre of Luton than Wandon Park and also is within 4 miles of Dunstable with its associated facilities.

16. The Bushwood site provides more defensible boundaries for further expansion than that of Wandon Park and does provide a long term solution for Luton's expansion over not only the next decade but beyond. It provides a more sensible location for that development than Wandon Park can achieve.

17. North Hertfordshire has made provision within the December 2014 consultation document for needed expansion of housing within its own district. As demonstrated above, provision of additional housing for the purposes of Luton cannot be sustainably provided by an eastern expansion of Luton and such expansion should be to a more appropriate site such as Bushwood, which will be able to provide space for any needed expansion of Luton to include the necessary support services.

First, the plan is not justified as it does not present the most appropriate strategy for the distribution of housing, given the detrimental effects on Baldock of the proposed scale of growth; in particular the acknowledged negative impacts of site BA1, serious questions about its deliverability, the fact that it is not proposed for early release, and the availability of alternative sites that do not appear to have such significant drawbacks:
1. Impacts: the plan and its supporting documents acknowledge that site BA1 would have several adverse impacts:
a) Although Green Belt land will need to be released to meet North Hertfordshire's housing requirements, 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);
b) The sustainability appraisal notes (Table 9) that this site, along with the others proposed for the edges of Baldock, creates a high probability of adverse impacts on landscape and townscape character - with the Landscape Sensitivity Study (July 2013) identifying the land north of Bygrave Road having moderate to high landscape sensitivity;
c) Increased traffic arising from this scale of development is likely to breach air quality standards in the Whitehorse St/Hitchin St areas, which the plan notes are already close to being exceeded in these locations (para. 9.28). The Housing and Green Belt Background Paper notes that former site 209E (Priory Fields, Hitchin) was considered unsuitable for allocation for precisely this reason;
d) The site is highly likely to impose severe and unsustainable pressure on the local highways network, for reasons set out below;
e) Development would be difficult to integrate effectively with the rest of Baldock, due to the extent to which the railway line creates a hard barrier with limited existing or potential crossing points;
2. Deliverability: there are serious questions about whether this site is deliverable without unacceptable highways impacts, and whether it is viable. This is covered under whether the proposals are effective (below).
3. Phasing and availability of alternative sites: the proposed release of this and the other strategic sites from the Green Belt is justified by the Council partly on the basis of its ability to contribute to meeting housing requirements "in the first five years following adoption of the plan" (Housing and Green Belt Background Paper, para. 5.52). However the plan itself is clear that other proposed sites at Baldock would be developed first. This fact also undermines the rationale for allocating site BA1 in preference to land at Stevenage West, which is proposed to be safeguarded for future development for up to 3,100 homes rather than being released during the plan period (Policy SP8). Land at Stevenage West could be allocated to meet housing needs in a way that does not have the range of adverse impacts associated with BA1, and which would be closer to main centres of employment, retail and public transport.

Second, the plan is not effective, because it is very unlikely that the scale of growth proposed for Baldock can be achieved without an overwhelming negative effect on the local highway network, but insufficient evidence has been provided about the highways impacts and the potential effectiveness and viability of the suggested mitigation measures. As a result there can be no confidence that the plan's proposals for Baldock are deliverable:
1. Baldock is a historic town with a medieval street pattern at its core. The plan acknowledges (13.29) that the Whitehorse Street/Royston Road crossroads is a key pinch point. Both it and Station Road/North Road already suffer from congestion and long queues both peak and off-peak, with the narrow width of the railway bridge also inhibiting easy pedestrian and cycle connections from north to south. AECOM's technical note identifies the crossroads and Letchworth Gate as problem junctions (above capacity, unacceptable queuing) by 2013 even without further development (table 4.1).
2. The proposed allocations for residential and employment development in Baldock will generate a significant increase in trips through the Whitehorse St/Royston Rd crossroads due to:
a) The high proportion of trips from site BA1 (North of Baldock) that are likely to be towards Letchworth and Hitchin. The plan stresses how interconnected these towns are for movement (paras. 2.31, 4.27, 13.14), and that many new residents will commute out (paras. 4.25-6).
b) The way the employment allocation (policy SP3) deliberately 'over-provides' for the needs of the town, even on its expanded basis (paras 4.25-6), which is likely to lead to more peak hour trips between Baldock, Letchworth and Hitchin.
c) The fact that the proposed link road through BA1 would involve a long round trip to Letchworth/Hitchin for most residents of the site, rather than following natural desire lines. Experience following the opening of the Baldock bypass shows that a lot of traffic follows the shortest route rather than the least congested.
3. The plan acknowledges (4.179) that "not all" traffic from Blackhorse Farm will have to use the Whitehorse St/Royston Rd crossroads - so it is clear the Council accept that at least a proportion of it will.
4. However there has not been adequate modelling of these impacts. It is only this year that AECOM's transport model has been extended to Baldock. While it identifies the crossroads and Letchworth Gate as problem junctions by 2031 even without development (table 4.1), it makes clear that it does not attempt to identify specific highways impacts of the proposed developments, or their dependency on new infrastructure (section 7 of AECOM's note); it has not modelled the effect of the proposed new highways links; it provides no assessment of post-mitigation impacts; and no information is given about the sole mitigation measure proposed within the town (mini roundabout and signal optimisation of the Whitehorse St/Royston Rd crossroads). We have seen separate modelling work undertaken for the promoters of the site - Hertfordshire County Council - by White Young Green, which appears to underestimate the extent to which trips are likely to use the crossroads, especially as it looks solely at the proposed residential developments and not the employment allocation as well.
5. It is clear, therefore, that the is a high probability that the highway network in the centre of Baldock would be unable to cope with the level of development proposed, but insufficient work has been done on behalf of the Council to assess the deliverability and impact of mitigation measures. As the plan's single largest site relies in part on this local road network functioning, there can be no confidence that this aspect of the plan is deliverable, or indeed that the overall scale of growth planned for Baldock can be accommodated in highways terms.
6. Nor does it appear that the financial viability of the proposed mitigation measures has been tested fully, especially if a new crossing of the railway is to be delivered without unacceptable visual impacts, and without prohibitive costs being imposed by Network Rail. The Local Plan Viability Assessment (Update, August 2016) has only taken an indicative approach to assessing the potential viability of the major sites, rather than looking at the specific infrastructure pressures and mitigation measures associated with each.

Third, the plan is not consistent with national policy. While the National Planning Policy Framework is clear that the evidence base for plans should be proportionate, it is equally clear that plans should identify whether transport improvements can be made to limit the significant impacts of development, and that where the residual cumulative impacts are severe there may be a case for preventing development (para. 32).

The Proposed Submission Local Plan does not satisfy this test. As set out above, it's very clear that the full impact of the scale of development proposed for Baldock, or of individual major site proposals, has not been properly assessed, with no information available on the impact and viability of the proposed mitigation measures.

This applies not only to site BA1, but also to the other major sites: for example, the plan mentions a new "southern link road" in relation to sites BA3 and BA4, but no further information to explain its route, viability or impact is provided in the plan or supporting documents.

The Odyssey Markides technical note for the Council asserts (para. 1.5) that "there are no issues that have emerged from the transport modelling work that... would cause a significant highway issue that cannot be resolved through appropriate mitigation measures". This conclusion is fundamentally flawed, resting as it does only on the wholly inadequate transport modelling work that has been undertaken.

Amount of housing to be delivered

The LEP is generally supportive of this policy but would welcome the exploration of the potential to deliver housing growth in excess of the OAN figure than currently proposed, to allow the potential to meet housing needs not capable of being met elsewhere and/or to add flexibility through a higher level of overplanning (say 10%)

Helping to meet the growth needs of Luton outside of its boundaries

The LEP questions whether the level of development that the plan seeks to accommodate within North Herts to meet Luton's growth incapable of being met within the town's boundaries (c 2,100 of the 11,000 homes required) is sufficient or whether the level of growth should be set higher (subject to environmental constraints)

Composition and mix of new housing development

The LEP supports this policy. The identification of 6 substantial Strategic Housing Sites will in the LEP's view be at a scale to allow for the delivery of relatively sustainable environments with residential development combining with a mix of other uses

Proposed safeguarding of land west of Stevenage for development post 2026 (subject to the review of the plan)

The LEP considers that it is a failing of the plan not to bring forward within the plan period the land within North Herts forming part of the west of Stevenage development site, and that to promote safeguarding for development post 2026 (and then subject to the review of the plan) may give rise to haphazard, piecemeal and potentially unsustainable development, with the potential for the North Herts land to be rendered unviable if the Stevenage land is developed in isolation (or alternatively the potential for the Stevenage land to be rendered unviable until - and if - the North Herts land comes forward)

It is the LEP's view that both landholdings need to be brought forward in tandem as part of a single overarching masterplan. Herts LEP would be willing to work with both districts and other appropriate parties to co-ordinate development as a single entity, with an overarching masterplan covering land both in North Herts and Stevenage.

Planning for a new settlement

The LEP supports the principle of this policy but considers that (a) the search needs to commence as soon as the local plan is adopted (if not immediately) and that this should be made clear in the local plan and (b) that the search could be conducted with appropriate adjoining authorities to widen the area of search, given that there can be no certainty that a suitable location can be identified within the district and with the possibility that other locations beyond the district may prove to be more appropriate

Responding to accelerated housing delivery rates

The LEP recognises the challenges the district faces in meeting much accelerated housing delivery rates from 2021 onwards but is concerned that no mechanisms to support such delivery (and the infrastructure required to support it) are identified within the local plan. Mechanisms such as infrastructure delivery partnerships, local housing companies and modern methods of housing construction should all be identified within policy SP8 (with other initiatives as appropriate) to signpost actions that will need to happen to turn these aspirations into reality

I am in principle in support of a local plan for North Herts in order to control sustainable house building that is required in our vicinity. However there are aspects of this local plan that are in contravention of the four "Tests of Soundness". Overall I object to the inequality of the size of developments which have targeted Baldock. Building of houses in Baldock is a necessity however to propose an increase of 80% over the next 14 years would not be sustainable in such a small and historical town. My reasons for objection are listed under the appropriate sections.

GA1, GA2, NS1 will promote the urban sprawl of Stevenage and coalescence of Stevenage, Great Ashby and Graveley.
HT1 and LG1 are contrary to the principles of garden cities where the idea of a green belt to protect the garden city were first applied at Letchworth
EL1, EL 2 and EL3 promote coalescence of discrete settlements at Mangrove Green and Cokernhoe with the urban sprawl of Luton

This is contrary to Section 9 of NPPF ,and also affects settings of parks at Putteridge Bury, Chesfield Park and Letchworth Garden City itself contrary to Section 12 of NPPF

See attached

Policy SP8 Housing. The policy is supported. The provision of 'at least' 14,000 new homes to meet the District's own needs during the plan period is consistent with the findings of the SHMA and the ORS 'Updating the Overall Housing Need' report (August 2016), which sets out the OAN for the area.

It should be noted, and acknowledged, that an outcome which resulted in the delivery of a higher number of houses than set out in the OAN would not be an objectionable outcome, given the severe shortage of housing completions throughout England.

Policy SP8: Housing - (c)(ii):
The allocation of land at North Stevenage for 900 homes in Graveley Parish is supported. Croudace has been promoting an integrated strategic urban extension at North Stevenage for some years (i.e. involving land in both Stevenage Borough and North Hertfordshire District), in association with a group of land owners and house builders representing adjoining interests within Stevenage Borough. Croudace has an Option over the land included within the NS1 designation in North Hertfordshire. The strategic urban extension scheme would deliver a sustainable development that would contribute to meet the housing needs of both Authorities.

Whilst the objective is to ensure the delivery of an integrated strategic urban extension combining the land in both Stevenage Borough and North Hertfordshire District, it is relevant to note, in relation, in particular, to the timing of the delivery of the NS1 development, that the NS1 site would have its own highway access in the form of a new junction onto Graveley Road/North Road and could therefore be brought forward for development at a time to suit North Hertfordshire District Council's housing needs, without jeopardising integration with the development of the land in Stevenage Borough through the use of a combined Master Plan approach. This flexibility may be important to ensure that the housing needs of North Hertfordshire can be met in an appropriate and timely way, meeting localneeds.

Policy SP8: Housing (f):
This part of the policy is objected to. The proposals in item (f)(i) that 33% of all homes over the plan period should be Affordable Housing is not objected to. However, the aspiration beyond the 33% figure, introducing a 'target' of delivering up to 40% Affordable Housing where viable, is objected to. The policy needs to contain a single clear and unequivocal Affordable Housing target. This is important and necessary because land owners and house builders need to have certainty and clarity when negotiating land sale/acquisitions. Setting a target of 33% and then caveating it by saying actually the LPA may seek 40% if the Council judge that a particular site can stand it in viability terms will result in a lack of certainty and make land sale/acquisition needlessly complicated and indeed may well serve to frustrate certain sites being brought forward for development (i.e. where the Council considers a 40% target is appropriate but where the land owner concludes that such a high provision would result in an unacceptably low return on the land sale and may not agree to sell the land).
Further, it is also a concern that this part of the policy overlaps with policy HS2 with the mechanism of how those two policies interact being unclear. HS2 (despite poor drafting and presentation) is reasonably clear that the level of affordable housing for sites over 25 dwellings is 40%, but criterion (f)(i) of SP8 suggests that the 40% is somehow linked to a viability test.

Also, where is the evidence supporting the housing mix proposed in Item (f)(ii). Whilst the SHMA's evidence on mix of housing points towards more smaller units, the continuing impact of the bedroom tax and pressures on registered providers will make it harder to sell the affordable housing to an RP if there is an excess of larger units by comparison to what they are able to let. If the policy aspiration is that the supply of new affordable housing should be more mixed, the Council should acknowledge that this may have negative viability consequences.

Similarly, the policy and supporting text fails to set out the evidence and justification for the figure of 100 self-build plots in (f)(iii). This needs to be clarified before being included in a Development Plan policy.

Criterion c(iii) discusses the local housing allocations which the plan makes. The second bullet point refers to "sites released from the Green Belt as part of a comprehensive, District-wide review". We support the fact that the Green Belt Review has been undertaken and the conclusions which have been drawn in respect of our sites. That said, we have a concern that the wording of this policy in respect of the local housing allocations is ambiguous and may give the impression that there is some further process to be undertaken in future before the sites are released from the green belt. For the avoidance of doubt we suggest this policy should be clearer that the Local Plan itself is the vehicle amending green belt boundaries. Perhaps change the wording of this bullet point to be "sites which this Local Plan removes from the Green Belt following the comprehensive District-wide review."

My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.

My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.

Not enough consideration has been made to alternative suggestions other than landing 2,800 new homes in Baldock thus effectively doubling the size of our town. How can it be equitable that effectively with 5,900 houses being required in North Herts DC Baldock has been unfairly given over 47% of the required allocation.

The plan is not justified as the exceptional circumstances for removal of Green Belt around Knebworth (sites KB1,2,4). These sites provide a significant contribution to maintaining the spacial strategy between Stevenage, the villages and Welwyn Garden City along the B197. The identify of Knebworth is under threat from co-existence with Stevenage and Woolmer Green. NHDC does not appears to have co-operated with Welwyn Hatfield Borough Council on their submitted Local Plan as the impact of site HS15 (150 homes) on the boundary with Knebworth has not been considered in the assessments for Knebworth.

The only exceptional circumstance for green belt development in the region is that NHDC have failed to implement their plans the West of Stevenage site or a new Garden City and are now tight on time to provide any Local Plan at all regardless of quality.

I am writing to express my concerns, hopefully just like many other Baldock residents will in the consultation period, towards the proposed developments on what is currently, rich and diverse rural countryside which comes under the green belt. We, as residents who remain unconvinced about the plans are becoming rather concerned as to whether democracy will prevail in the decision and that logistics and communication appear severely lacking.

I sincerely hope you will take the time and the effort to read through my response. Being a younger individual whose 16 years old possibly 17 by the time you read this, and always lived in Baldock, the views put across may come from a different perspective from what you read on a more regular basis and above all the fact I have different concerns to the 'typical' youngster.

I fully except the fact that we need houses but is this proposal one that has been properly thought out in a logical manner?
After attending the public meeting on the 31st January in Baldock Community Centre I have been made aware of the fact that less that only about a third of land in North Hertfordshire comes under the 'Green Belt' and that green belt should only be used in exceptional circumstances.
Have you really considered other options seriously?

This was the question theme among many people on the protest march which certainly helped publicise the topic.
Brownfield sites and liaising with private land owners appear to be far more viable options in the eyes of Baldock residents.
In my opinion, you should consider the idea of adding a far smaller amount of houses over a much larger area. Figures suggest that 12,100 houses are needed in the North Hertfordshire district, between 2011-2031. My theory states that you should add approximately 1500 houses to the 5 major towns, Royston, Baldock, Letchworth, Hitchin and Stevenage but leaving green belt land alone if possible by making use of brownfields. This would leave around 4600 houses to be spread across the 33 villages and hamlets in the district. This would mean adding approximately only 130 houses to each village. On a map you wouldn't notice a difference and the population density across the district would be more proportional. It was have less of a detrimental effect in specific areas and every getting their fair share in development.

From following the proposals it appears to me that you're taking the 'easy' option and burying your heads in the sand so to speak at the expense of fairness to Baldock residents and the environment. Baldock would be no longer a closed community. Around 3400-3600 houses to be placed in one specific area just seems a little extreme especially for is currently relatively small historic market town with a current population of around 10,000 people. The population density will increase dramatically and I firmly believe that the town itself could not cope unless infrastructure is developed.

Green belt around Baldock is open countryside laden with bridleways and footpaths providing a free leisure facility to improve the health of its people and potentially cut down levels of obesity which in turn will cost the NHS less money. These bridleways will be destroyed but most of all, the views North East of Baldock of will be ruined and we'll never get them back as Hertfordshire becomes one large urban sprawl with Bygrave, Baldock, Letchworth, Hitchin and Stevenage becoming linked together as one mass of houses.

I have an allotment on the Clothall Road allotment site and with my eyes set on a future in farming, seeing the countryside and tenant farms(the only way of being able to farm in your own right due to land prices unless you have a large sum of cash) built on would be me to tears. I stand and try to visualize the urban development on site BA2 but I can't. The thought of the allotments losing their traditional appearance and increased vandalism due to the increased number of young people stuck for something to do is unbearable. This is because the government and local councils do not push for leisure facilities for young people.
From attending the meeting it sounds as though lots of pieces of paper and pencils are being used.
Have you actually put your wellies and 'high vis' vests on and walked up to your paper proposed sites and physically tried to look at how the development will look and the eye sore it will put in the landscape?

Baldock sits in a dip surrounded by rolling hills. From up on these hills, there would no longer be a view to admire.
The proposed Blackhorse Farm site currently, is home to several successful agricultural businesses producing a wide range of products from things as simple as Free Range local eggs through to large scale combinable and root crop production on what is Grade 2-3 agricultural land (some of the best found in Britain).

These businesses will lose their jobs, livelihoods and the money these farms bring into the local economy would not be any more if this unorganised development goes ahead. All things I've mentioned above are keys elements to Britain's survival and all things the government currently seem fairly keen to support.
The developments on Works Road in Letchworth are not a long term answer and the people who would occupy the houses would just be people who commute into the hubs of London and Cambridge in order to earn a decent wage. This commute business will be struggle given the ludicrous proposals to cut train services.

Less land for food and more people will mean that food miles and quantities needed, will increase due to imports, leading to greater pollution. Importing food is by far, not a long term solution in the 21st century economic situation of Britain and the rest of the world. We need to look into more long term solutions in this world which ministers fail to address. Farming shapes the countryside not houses.

I've already gone into detail about things that link to the environment but the increase in cars, concrete, waste water and electricity usage all pose problems. Waste/run off water will pose a huge problem in terms of flooding in wet years. At least crops use the water in a useful way.
Have you considered sustainability when constructing plans?
If not then here are some ideas solar powered street lights and waste water harvesting and treatment for reuse.
The number of species in our countryside is rapidly decreasing and building on such a vast acreage of land is just going to exacerbate the problem. Farmland ecosystems are vital.
If waste/run off water is left to go off into the rivers rather than being used by crops and animals then it is just go into rivers and flow into the sea where it will become expensive in future to extract. The river Ivell and Weston Hills dry up most years due to over extraction to cope with the ever growing population. This puts huge pressure on river ecosystems.
So, will there/are you going to make sure there will be enough water today, tomorrow or in 50 years' time?

I attend the Knights Templar School and am heavily involved in Sustainability in the school, hence that fact that environmental issues concern me the most as I see the importance of them as my passion lies the countryside.
From my point of view as a student I feel that the communication between schools and the council has been severely lacking and students are making decisions on the topic that are non viable because there's been no encouragement.

Views expressed by the local councillors and local MP's including Sir Oliver Heald seem to display a sense of concern towards the plans. Up to 3591 homes on green belt land doesn't appear viable in current circumstances. Some of my thoughts clearly display this having focused on many points on more of a national scale and what could be done across the whole district.

We would like to strongly object to the proposed number of houses that the North Hertfordshire Local Plan has allocated to Baldock, there are just too many.

Baldock is the oldest and smallest market town in Hertfordshire and has a large number of listed buildings and conservation areas. We acknowledge that new houses are needed in North Hertfordshire but the amount of over 3,400 which is proposed for Baldock would double the size of the town and totally change the towns ambience. Our roads are already very busy and the centre of Baldock still has jams despite the bypass. The southbound A1 traffic is always at a standstill in the morning rush hours and very often at other times, due in part to the two lane only stretch which passes Stevenage. It has now been disclosed that our train service is to be cut to one train an hour at all but peak times starting in 2017. New houses mean people who will need to travel to work and it is impossible that they will all find work locally they will therefore add to the already overloaded road and rail networks. Much of this proposed housing is to be built on Green Belt land which we all have a duty to protect and nurture. Green Belt land was designed for a very good reason and should be respected. Future generations will loose our countryside if Green Belt land is allowed to be built on.

We hope that you will take into account the wishes of the local community and revise the proposed number of new houses to a much smaller number.

I object to the above application for the following reasons.
It is said this development is to help Lutons unmet housing needs, this would only be true if the properties were only sold to persons on Lutons housing list, and the Hertfordshire county boundary would need to be redrawn to include this development into Luton council boundary. Lutons unmet needs could be met if the Bushwood site was developed, as was planned when the M1 motorway was built, when 2 very large tunnels were built to allow access to this site. Luton also has plenty of unused brownfield sites. So has no need of NHDC "help".
Some towns and villages in North Herts have no or limited developments planned, but NHDC have ensured they keep a complete Green belt around them, this follows government guidelines that communities should not coalesce.I wonder how many councillors and officials from North Herts live in these places, there are certainly none living in Luton as NHDC do not care if Luton residents loose part of their green belt, which is against government guidelines that communities should not coalesce.

The infrastructure of Luton cannot cope with any more traffic, they are gridlocked around Crawley Green and Eaton Green roads as it is. 2000 extra homes could quite easily mean 3000 extra vehicles on Lutons roads at peak times, as there is no feasible route for any of these vehicles to go into North Herts unless the council and government commit to spending £millions on new roads before planning consent is granted, roads which would need to be in place before any building work starts. NHDC has not taken into account the new special needs school being built on Crawley Green Road. This will need access, probably a roundabout. Further slowing traffic at peak times.

No account of the Luton Airport expansion has been taken into account, this will inevitably lead to further air pollution, already depending on wind direction and cloud cover, kerosene fumes drift over the area, with further aircraft movements this will increase. Are NHDC and the Government prepared for legal action over cancers, asthma and other illnesses that can result from their granting of building development in an area of known high pollution, when proper investigations have not been carried out.

I and plenty of other people have registered with NHDC over this matter, and we are all finding it impossible to register our complaints on this website, and are having to use other sites to complain., either your website is not fit for purpose, or is this deliberate. I will be sending a copy of this e-mail to the Secretary of State for him to ask questions about your website.
Please send acknowledgement of receipt.

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