Policy SP8: Housing

I strongly object to the NHDC Local Plan 2011-2031. Firstly, with regard to "Removing this land from Green Belt status to meet 'Luton's Unmet Need". The National Planning Policy Framework document states that the Removal of Green Belt Status does not fit the Government's criteria of "Except in exceptional circumstances." Luton's Unmet Need is not an exceptional circumstance. It also states: "an Unmet Need is unlikely to outweigh the harm to the Green Belt unless there are very Special Circumstances."
There are already sufficient undeveloped Brown field sites in Luton to meet its Unmet Needs. The Unmet Housing Need figure also shows inaccuracies. During Executive Meetings, LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment in order to re-examine once more the Unmet Housing Need figure assumptions. This was due to their estimated nature, with far-reaching consequences and drastic impact upon the area. Luton's Unmet Housing Need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either. The removal of this land from Green Belt Status as proposed by NHDC in their plan leaves this land unprotected and open to applications from developers. Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport. The Transport Assessments were not robust. The data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity; they were not carried out for long enough and some studies from Luton Borough Council assumed roads that did not even exist. Furthermore, Luton Borough Council base their traffic modelling on an unbuilt link road to the A505 at Lilley. A Freedom of Information request states: "This transport modelling includes the alignment of the proposed spine road through that development site and LBC have also assumed by 2031 that will be extended at its northern end to join the A505 near its junction with the road into Lilley". However, NHDC state on P27 of the NDHC Local Plan Para 4.222 - "Our assessments show that this level of development can be accommodated without a significant adverse impact on the wider highway networks of Luton and Hertfordshire". Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion. The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also. If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate. In fact, the whole proposal is out of proportion. 2,100 homes is 14% of the total allocation of houses in the NHDC Local Plan; a 1,025% increase on the 205 houses in the three hamlets placing these - and the houses in Wigmore bordering the development - into the middle of an estate. With respect to Wigmore on its own, currently around 4,500 houses, again this proposal is at an unacceptably disproportionate level of expansion since 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again. Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it. Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree. There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area. Finally I mention the impact on wildlife. There are areas of woodland containing Bluebells - a protected plant species. There are Red Kites in the area - a protected bird species. These are my objections to the proposed plans

I object to the planning of housing on the Green Belt Land, Application Local Plan 2011-2031.

Due to the increase in Road Traffic on Crawley Green Road, and surrounding areas - the infrastructure is not in place - a problem on the M1 affects all of Luton, and also Harpenden and St. Albans

Plus:

Since January 5 2015, all GP practices in England have been free to register new patients who live outside their practice boundary area - this could affect the local surgery in Wigmore and surrounding practices.

Also, Asda, the nearest supermarket does not have enough car parking space to accommodate these extra household customers.

Also, traffic surveys were carried out during School holidays.

Also, at the presentation in Wigmore Church earlier this year, it was suggested that cycling would be encouraged instead of cars (???) and to aid this the pavements would be widened- Oxford Dictionary definition of pavement: "A raised paved or asphalted path for pedestrians at the side of a road".

Also, the local Red Kite re-introduction program could be compromised.

Also, there are empty properties in Luton - the flats at the bottom of Eaton Green Road have been empty since 2001 at least.
Flats have been built in Luton town centre for Luxury Student Accommodation - the University has no requirements for all these buildings and accommodations.

AND - THIS IS GREEN BELT LAND - HOW CAN PLANNING FOR HOUSING BE GRANTED????????

Also I agree with the concerns as listed on the KEOLG Website:

The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

There are 205 dwellings in Cockernhoe, Mangrove Green and Tea Green currently. An additional 2100 dwellings will be an increase of 1124%. This development is completely out of proportion to all other developments in the district - these villages and communities will cease to exist.

Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.
There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally. ->The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop. In the shorter term, the projected airport development/business park/light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles. The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

The paths and woodlands are used by villagers and people from neighbouring Luton as a leisure area for walking/running/cycling. These will be destroyed despite the national push to encourage people to keep fit.

In the presentation of the local plan Councillor Levitt stated that "the development plays a key role in supporting the growth of our economy planning for the right type and number of homes, in the right place to create sustainable communities" How can a development only linking north Herts by two single track lanes be considered as a sustainable community?

There is sufficient brown field land in Luton to accommodate 'Luton's Unmet Need' at the same housing density as this proposed development.

Teeming wildlife, owl, bats, deer, etc., will be displaced. Wildlife corridors are no substitute

And to reiterate: THIS IS GREEN BELT LAND - HOW CAN PLANNING FOR HOUSING BE GRANTED????????

PLEASE ACKNOWLEDGE RECEIPT OF THIS EMAIL

I am writing to submit my objection as a resident of the Parish of Bygrave to the Draft Local Plan, and the designation of Green Belt land to be allocated as housing sites within the Parish of Bygrave, to the north of Baldock.

I submit this objection on the basis that I do not think that the Local Plan has been objectively prepared, is justified, or effective and consistent with national policy.

It is appropriate that you should know that I am not a 'NIMBY', and fully understand and support the need for the country to have plans for future housing requirements. However the 'Updating the Overall Housing Needs' by ORS in 08/2016 document, states at;

para. 2 - that the 'projected increase in households across Stevenage and North Hertfordshire... based on rates from the 2012-based data and migration trends established using Mid-year Estimated data from the period 2005-15.

para. 6 - ..household projections are based on the ONS 2014-based SNPP, which are informed by migration trends from the 5-year period 2009-14. Future projections are particularly sensitive to the period on which migration trends are based, and PAS advise to Local Authorities suggests that the official projections are "VERY UNSTABLE". ...This viewed is echoed by academics and has been promoted by Planning Inspectors at numerous Local Planning Examinations.

Based on the above, I believe there should be greater 'push back' by NHDC in their Local Plan until numbers can be produced with greater clarity and certainty. Of greater importance is the fact that the EU Referendum has not been factored in to any of these projections, a situation which in the period up to 2031, could have dramatic implications both to the immigration numbers, to the number of EU citizens who currently live in the UK but who potentially could be forced to return to their home country, and to the economic situation of the UK (with its attendant housing implications). To use some of the wording of the North Hertfordshire Proposed Submission Local Planning Sustainability Appraisal Report under the heading of Nature of Effect, 'the loss of agricultural land is cumulative across the Plan area, of high probability, permanent and irreversible'. This Plan needs to be compiled on the basis of facts, which can be substantiated, not a wish list, based on guesstimates.

Turning to the North Hertfordshire Green Belt Review - July 2016, Table 2.2 'Green Belt Assessment Criteria' states that it is, "To preserve the setting and special character of historic towns" (Baldock is known as a 'Historic Market Town') Referring to the parcel of land marked 21 "Bygrave", it states that it "makes a Significant Contribution to restricting sprawl" and "Prevents urbanising influences". Figure 2.4 - "Contribution to checking the unrestricted sprawl of large built up areas", and Figure 2.6 "Contribution to Safeguarding the Countryside from Encroachment" both show parcel 21 "Bygrave" as making a SIGNIFICANT CONTRIBUTION.

Para. 49 states "The areas which contribute most to the purposes of the Green Belt are those around the periphery of, and between, the existing settlements of Hitchin, Letchworth and Baldock ... An additional factor in the assessment is the historic nature of the three Hertfordshire towns located within the Green Belt and their proximity to one another, resulting in increased sensitivity to development".

Page 125, "Green Belt Review Site Assessment - Baldock and East Letchworth" states that the whole site, designated this time as 200 representing the area north of Baldock, is shown as providing a SIGNIFICANT CONTRIBUTION TO GREEN BELT".

Page 134, Conversely at another site designated "West of Stevenage", this provides only a Moderate Contribution.

Para. 87, includes the statement "Stevenage Borough Council has removed an area from the Green Belt to the West of the A1(M)".

Para 93, states that "... consideration has been given to the need to identify safeguarded land for meeting development needs in the longer term. This function is met by the removal of the west Stevenage strategic site and employment land at Baldock from the Green Belt".

In this Green Belt Review, the Baldock sites have been identified as making a significant contribution to achieving the aim of a Green Belt. However the statement in para. 93 simply says that land at Baldock has been removed from that Green Belt. I can find no objective approach or basis for this action. Given that other sites have been identified as generating a lesser contribution to the Green Belt aims in this document, NHDC should be required to demonstrate why these sites have not taken precedent over the Baldock sites which make a greater contribution, since the approach they have taken is neither effective nor consistent with national policy.

The following now make reference to the National Planning Policy Framework (NPPF) 03/2012.

A part of the Ministerial prologue requires that "Sustainable development is about change for the better. ... This should be a collective enterprise. Yet in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling this unaccountable region apparatus, and introducing neighbourhood planning, addresses this".

Para. 9 provides that "Pursuing sustainable development involves seeking positive improvements in ... the conditions in which people live, work, travel, and take leisure".

Para. 17 addresses "Core planning principles - a set of core land-use planning principles should underpin both plan-making and decision taking. The 12 principles include;
Bullet 1 - "be genuinely plan-lead, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area";
Bullet 5 - "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belt around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it";
Bullet 7 - "contribute to conserving and enhancing the natural environment and reducing pollution"; and
Bullet 11 - "actively manage patterns of growth and make the fullest possible use of public transport".

Para 28 requires "Supporting a prosperous rural economy. - Planning policies should support economic growth in rural areas, and should (bullet 2) promote the development and diversification of agricultural and other land-based rural businesses".

So taking the requirements of the NPPF, we need to have change for the better, not just change. The people of Baldock and Bygrave should be included and have notice taken of their views and wishes to shape the town and surrounding area, not to have been excluded, which is how I see the process of communication by NHDC at meetings has taken shape, with a tone of 'go away you little people, I have things to do my way'. Once again reference is made of the need to protecting the Green Belt, and also to promote agriculture, the activity currently undertaken on the land north of Baldock. Far too little attention has been paid to travel requirements, to determine whether the existing arrangements could cope with approx. 2,800 houses north of Baldock. Currently the Bygrave Road is totally unsuitable to take more traffic, there is no plan shown (and if there is one, why has it not been declared to the public) for a bridge or underpass over / under the railway to the south, which leaves any traffic wishing to go south into Baldock having to go under the railway bridge on the Great North Road, almost under the railway station. That section of road already suffers considerable and lengthy delays, and realistically, should not be considered an option should the north of Baldock site go ahead.

In summary, it feels as if the fact that Hertfordshire County Council own the land at the north of Baldock site, makes it an easy option for NHDC to choose this site as their Local Plan for 2015-31, and as a result they have not put together an object argument to justify this location, as opposed to others in the area, but which would not give them such an easy option. As stated above, once land has been built on, there is no going back. Greater consideration also needs to be given to the actual number of houses NEEDED, and if this means deferring a decision until substantive data is available, then that should be the appropriate action to take. Greater consideration should also be given to transport - one might assume a fair number of the people would need to commute by train. Rather than the plan saying that the platform at Baldock will be extended to take the extra commuters, the latest plan, recently released by the railway operator, shows that they actually plan to CUT the number of trains stopping at Baldock station. Likewise, how will people be able to drive into Baldock given that the existing road is already suffering major delays.

Finally I again submit that I am not a NIMBY, but it certainly is not equitable that a small historic market town, which is on the edge of a Green Belt, should be burdened with totally disproportionate to the size of the town, the largest number of houses for the NHDC Local Plan.

The plan should not be accepted in its present form, but overhauled to make it objective and proportionate across all towns in the area.

I shall be grateful if you will keep me informed of all developments in the matter.

See attached

The following comments relate to the Local Plan 2011-31: Proposed Submission Draft. They are not intended as detailed root and branch comment on the document as a whole. They are meant to highlight issues from perspective of 'What will this Plan do for Hitchin?'.

Section 4: Strategic Policies - The need for better background

* 'Strategic' (and cascaded) policies should be policies resting on an evidence based District framework and accorded precedence/weightings according to realities identified within that framework. A general criticism of the Plan is that the District background/framework - its depiction of the detail, variety, distinctiveness, comparative strengths and opportunities within North Hertfordshire - is generally shallow and inconsistently drawn. This weakness in background is especially marked where that framework is specifically focused in Section 13: Communities. This section, with a thorough-going evidence base, should be the starting point for policy making not, as it is, a 'tack-on' at the end.

Section 5: Economy & Town Centres - The need for realistic hierarchy

* It is clear that Hitchin provides the District's main market, retail and service centre. It qualifies within the top 300 such town centres in the country. It is also clear that, overall, the levels of user satisfaction with its role are relatively high (see the NLP Town Centre and Retail Study 2016).

* District policy should, therefore, give a much clearer strategic priority to maintaining this key role for Hitchin and thereby reducing leakage elsewhere of business from the District: to do this would be to build on success. Yet the Plan actually recommends (see Section 13.220) in the medium to longer term the diversion of business away from Hitchin within the District. Such a policy risks undermining North Hertfordshire's key retail-commercial asset and should be rejected.

* Given its success and attractiveness some additional retail/commercial development in Hitchin town centre is logical. It must not, however, be a 'big-hit' scheme (such as the whole-scale redevelopment of Churchgate and its area) as the town centre's success has long been based on incremental growth and adaptation. Keeping this in view is particularly important given the major long term pressures of on-line commerce currently affecting traditional high street provision. In this context phased refurbishment of Churchgate and the Market area (identified as key contributors to the retail health of the town centre even in their present condition) should be linked to a sequential development of additional retail space (including some additional parking) on Paynes Park.

* Given Hitchin town centre's key place within the District a specifically focused and integrated policy to support it must be developed rather than resting on the fragmented catch-all approach advocated in the draft Local Plan (eg SP4, ETC3-5; policies HT11-12 need support from a wider Hitchin framework). A Hitchin specific town centre policy should recognise the significant input to town centre business activity provided by voluntary effort over many years and commit the District Council to support (but not control) that effort much more significantly than it does at present.

* Hitchin is an important 'evening economy' hub in Hertfordshire; such a function is an additional strand of commercial strength. There is, however, no specific recognition of this 'evening economy' and how such provision needs careful management in relation to more conventional day time retail and service functions eg working to avoid 'dead' frontages in key shopping areas.

* Hitchin is not recognised as a major employment centre in the District although it is, in fact, difficult to judge its ranking from the lack of systematic analysis provided; mention (SP3) is made of 'bringing forward' employment land but there is no Hitchin provision for this aim. Hitchin has a diverse and active industrial/employment area that is well occupied despite suffering some major access problems; the solution of these problems deserves a very much higher priority (SP3; there should be a HT policy to support the town's main employment area in addition to the access question; see also Section 7: Transport).

Section 7: Transport - The need for better coordination of congestion relief and public transport

* Transport issues, beyond the very local, pose a challenge to a District Council Plan given the key responsibility of the County Council although SP6 promises to 'deliver' on sustainable transport. It is important, therefore, that the District Council develops coherent views on the transport issues within North Hertfordshire so these can be deployed effectively to influence County decision making.

* The draft notices, but not effectively enough, a number of key (judged in county terms) road congestion hotspots within Hitchin but has no decisive proposals to 'deliver' any amelioration.

* The draft Plan fails to recognise Hitchin's key role as the District's main railhead (a junction, variety of services and destinations and over 3m passengers per year making it the busiest station on the Great Northern after Kings Cross/Finsbury Park, Cambridge, Peterborough and Stevenage). The draft Plan also fails to confront the challenges of Hitchin station access (pedestrian, cyclist, bus, and car), especially from the east. Nor does it recognise the need to improve significantly linkages at the station with Hitchin's useful portfolio of bus services, including key east-west links to/from Luton and Bedford. These omissions need remedy to achieve 'delivery'.

* As noted above the draft Plan does not have any effective response to the problem of vehicular access to Hitchin's important industrial-employment area; a specific transport or Hitchin policy is needed to achieve a solution to this problem.

Section 8: Housing Strategy - The need for variation, inclusion and Green Belt reinforcement

* Hitchin has seen steady population growth over recent decades; in the period 2001-11 it took over 60% of the new dwelling permissions that were granted in all of the four towns of the District and is again the largest urban centre. The town has recently appeared several times in 'Top Ten' surveys of desirable national living locations, has a good quality retail-commercial base, excellent state primary and secondary education, and good road and railway connections. As such it is inevitable that pressure for housing development in Hitchin will continue.

* It is, however, becoming increasingly difficult to accommodate this pressure while preserving both the town's attractive mixed residential make up and its vital Green Belt buffers, especially in the east. The draft Plan understandably allows for some additional expansion (SP17, HT1-10) including one major estate development (Highover Farm) on the east side. This latter does, however, require very sensitive handling to preserve long term Hitchin's eastern Green Belt and also to allow for the effective 'stitching' of the new housing into the adjacent residential areas with some forms of access to Grovelands Avenue and Highover Way along with a carefully sited access on Stotfold Road. The scope for housing development elsewhere (including infill) is now very limited and would raise significant historic environment and Green Belt/countryside issues (SP5).


Section 12: Historic Environment - The need for better more consistent enforcement

* The policies supporting the Historic Environment (SP13, HE1-3) are to be welcomed. Hitchin's continued success as a 'historic market town' commercial hub and attractive residential centre rests heavily on high quality management of its historic character. This cannot be an 'aspic' policy if the town is to continue to adapt and thrive but it must be a constructively enforced policy. Too often in the past historic environment issues have been over-ruled by short sighted reasoning in favour of unsuitable redevelopment.

* Management of Hitchin's historic environment also requires a more intelligent and connected policy towards its urban morphology as a whole. It is deeply disappointing that modest but intrinsically interesting suburban townscapes have been damaged by over intensive or out of keeping redevelopment. There is also the point that the shape of the modern town, as defined by roadways, paths and building plot shapes and sizes, is an important legacy of the fact that the town was never formally 'enclosed' meaning many of its urban 'patterns' still show influences dating back to its very earliest origins centuries ago. It makes sense to ensure that the policies on Design are truly tuned to distinctive local circumstance (SP9, D1) and linked to the historical contexts.

* Hitchin's historic landscape also includes the surviving extent of Priory Park. Despite the insertion of a relief road in 1981 this area still has many historic features (defined as including key planted areas) and as such should be accorded a much higher level of protection, such as English Heritage Designation, in the context of its Grade I Listed Building. Additionally, there should be no possibility of any of this area being considered for residential development.

Section 13: Communities - The need for a much better encapsulation of the District

* The poor quality of this section as a foundation for policy making has been noted above. If the question is posed 'Can you recognise Hitchin?' from its entry the answer is 'no' because the coverage is thin, partial and inconsistent.

* All the District's settlements need much more careful, consistent description and analytical assessment. The District is very clearly not a 'one centre' authority suited to top-down policy making: only by understanding and responding to local characteristics and variations can policies be properly applied and, as important, gain local acceptance. There needs to be much more scope for 'bottom up' influence in achieving solutions.

* The whole Communities section requires, therefore, a tighter and more systematic treatment of historic background, retail/commercial, service, industrial and agricultural aspects so the characteristics and needs of different areas of the District can be more easily compared and prioritised. This picture should be supplemented with relevant comparative analysis of the employment, economic ranking, district function and travel-transport importance of the various settlements. A logical outcome based on this revised background would be the development of a more graded Settlement Hierarchy to inform decision making. The draft Plan is prefaced (Section 2.6) with the remark that 'North Hertfordshire is a diverse area' but the following 240 pages do far too little to give reality, in the delivery of policies, to this key observation.

See attached

Representation on the Local Plan 2011-2031 submission document ("LPSD")
Objections
1.1 The LPSD proposal of 2,100 homes to the East of Luton will destroy the rural nature of the village of Cockernhoe. Reference to Cockernhoe can be backdated to the 10th Century by a manuscript of 980AD. The village of Cockernhoe, incorporating Mangrove, numbers 130 dwellings. Cockernhoe ward numbers 205 dwellings. The nearest point of Cockernhoe village to the existing Luton dwellings is 200 metres and this boundary around the village should not be encroached upon as it is surely the minimum needed to retain Cockernhoe's rural nature. In my view the release of Green Belt land surrounding the required settlement boundary of Cockernhoe would not meet the "tests of soundness" set out in the National Planning Policy Framework ("NPPF") -see 1.5 below.
1.5 The NPPF specifically seeks to stop urban sprawl where this affects communities. This is clearly the case with regard to Cockernhoe and other villages/communities affected by this East Of Luton proposal, which should be stopped.
1.7 The 2,100 homes to the East of Luton proposal is not "exceptional circumstances". Considering the objections to the proposal by residents of Luton in addition to those of North Herts it is disturbing that NHDC has recommended this proposal.
There are alternative areas, such as land adjacent to Butterworth Green and North of the A505, which could be developed without encroaching upon any existing settlement. There is no need to destroy the rural nature of an existing community, Cockernhoe, which has existed for more than 1,000 years.
The need to properly assess the need for development is difficult. In December 2012 NHDC concluded the need was 10,700 dwellings. By 2014 this had increased to 12,200 for their own needs and now in 2016 to 14,000. This must be due to immigration and therefore it must be concluded that "Brexit" will reduce this figure - but NHDC say not! None of us knows what the result will be! To make a decision in the next 5 years to destroy the rural nature of Cockernhoe and associated communities in Cockernhoe ward and the affected areas of Luton is surely irresponsible! The 14,000 dwellings required by NHDC for its' own needs already represents an increase of 25.5% compared to the 55,000 dwellings existing in NHDC in 2011. In England as a whole there were 22,976,000 dwellings in 2011 (Housing statistics release 28th April 2016 by the Department for Communities and Local Government). A 25.5% increase overall in England would mean this number of dwellings increasing by 6.0m by 2031,representing a population increase of 14m which is clearly incorrect. In the period from 31st March 2001 to 31st March 2015 the increase in dwellings in England was 2.3m. In conclusion the need for 14,000 new homes is virtually a guess having increased by 31% from the estimate in 2012. Thus these additional new homes should not be added to by the extra 2,100 homes for Luton. See clause 2.8 below for calculation of the figure needed.
1.8 The duty to co-operate should be qualified as to "where they are able to". A significant proportion of residents of North Herts already work outside the district, see clause 2.76, and this would be the same with the 14,000 homes required for North Herts own needs. Thus surely NHDC has already complied with its' duty to co-operate.
1.9 To the West of Luton Redrow is building some 350 homes at Caddington Woods. This is some 650m from the outskirts of the Bedfordshire village of Caddington. Why is this development so small? There was a proposal to build 5,500 homes there in 2015 that was rejected by Luton, see www.bushwood.info/docs/Bushwood-Masterplan.pdf. This was as close to Caddington as the 2,100 dwellings are to Cockernhoe. I believe Luton councillors were concerned about objections from residents of the village of Caddington but obviously completely ignored the objections by North Herts residents and those from affected areas of Luton. Similarly the majority of NHDC councillors have ignored the objections from their community.
1.19 Whilst NHDC have consulted with the local community on the incorporation of the 2,100 homes to the East of Luton they have ignored their objections. There is little purpose in requiring a consultation process if you ignore the result.
1.22 Similarly to 1.19 above the previous consultations have been ignored.
1.26 Similarly to 1.19 above the previous consultations have been ignored.
1.27 Similarly to 1.19 above the previous consultations have been ignored.
2.8 The forecast of an increase in population in North Herts of 24,000 by 2031 does not require the building of 16,000 new dwellings. Assuming households on average of 2.4 this would require 10,000 new dwellings. There is significant inconsistency in these figures. If you then add the 1,600 households on the housing register (clause 2.25) you would need a maximum of 11,600 homes.
2.77 The intention to improve physical and mental wellbeing for the several thousand residents of Wigmore, Luton and Cockernhoe ward affected by the 2,100 homes to the East of Luton is completely ignored by this proposal.
2.83 The new development of 2,100 homes East of Luton will not:
(a) Enable the village of Cockernhoe to embrace their role within North Herts. The village will be lost forever and just be part of the urban community of Luton
(b) The District's historical rural areas will not be protected
3.7 Cockernhoe is being sacrificed and it is clear is outside NHDC's strategic objectives for ENV2, ECON4, ECON 6. I do not believe that ECON8 will be possible for the 2,100 dwellings proposed and think the road infrastructure will not be possible to accommodate this growth. I cast doubt on the methods of collection of the data. For instance in the last two months we have had 3 occasions where the roads have been gridlocked for various reasons. When you are sitting in such a traffic jam how does the cables across the road measure that. They surely measure the traffic that crosses them and not the queue of traffic wanting to cross them. SOC 4 is being completely ignored for the rural community of Cockernhoe where its' residents have objected to these plans over the course of the last 8 years.
4.0(b) Once again Cockernhoe is being excluded from this policy. The 2,100 homes surrounding Cockernhoe are twice as big as the future increase to the District's largest town of Hitchin (1,009).
4.9 The settlement boundary of Cockernhoe, within the classification of a Category "A" village, should not be expanded to include the area covered by the land allocated for the 2,100 homes. Such area should be given a classification of its' own so that objections can be raised against that but not reflect on Cockernhoe's own inclusion within the policy of category "A" villages.
4.13 Similarly to 4.9 above the East of Luton development should not be associated with Cockernhoe's own settlement boundary.
4.53 I disagree that the 2,100 proposal East of Luton, resulting in the rural nature of Cockernhoe being destroyed, qualifies as existence of "exceptional circumstances".
4.55 Green Belt is surely pointless if it can be removed by Council at will and against the will of the local community affected by its' removal.
SP6 I do not believe that adequate proposals have been made to deal with the road infrastructure needed for the 2,100 homes proposed.
SP8 (b) I disagree with this policy.
SP19 This policy should be cancelled as inappropriate and undeliverable to the satisfaction of residents of Cockernhoe and the affected parts of Luton.
13.66 I totally disagree with inclusion of the East of Luton expansion within the Cockernhoe settlement boundary. It should have a classification of its own.

Support
4.9 Policy SP2 concerning general development being allowed within the defined settlement boundaries of the Category "A" villages is a significant step forward. These 23 villages include Cockernhoe but the settlement boundary of that village has been expanded to include space for the 2,100 new homes planned. This is wrong the settlement boundary of Cockernhoe is clearly shown on the map in white. The additional area coloured brown should not be associated with Cockernhoe's settlement boundary but should be attributed a classification of its' own.
SP5 (a) (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt.
SP7 I'm in full agreement with this policy.
4.128 I agree with the NPPF, which supports the argument to exclude the proposed 2,100 new homes East of Luton.
8.5 Policy HS2 I agree with fully.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.
We all appreciate houses are needed, but someone really needs to visit and look at what the impact would be. They could then appreciate the valid objections made by local people of the Wigmore area are Cockernhoe.
So consider this written address that I wish to change the Local Plan and participate in the Examination.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.
Will someone listen and understand what is being written. Our objections are real and will affect the lives of people living locally and green belt will be gone forever, when other brown sites or other more viable sites are available.

So consider this written address that I wish to change the Local Plan and participate in the Examination.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital! There are many areas of browns sites available, why is it that we have to ruin forever the green belt around us. We appreciate there is a need for housing, but decisions are made by people who do not come from this area and really do not understand the impact these new houses will have on the whole area and peoples lives.

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.

So consider this written address that I wish to change the Local Plan and participate in the Examination.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.
The impact of this proposal and the inadequate infrastructure together with the regular congested traffic will impact enormously on our lives. We should be entitled to live a decent life.
So consider this written address that I wish to change the Local Plan and participate in the Examination.

See attached

I strongly object to the NHDC Local Plan 2011-2031.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.


This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!

Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.

The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.

Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.

The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.

If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.


Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.


Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.

There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.

The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.

So consider this written address that I wish to change the Local Plan and participate in the Examination.

The expansion of Baldock goes beyond what is reasonable for any area to accommodate. It sees the town increasing in size by 80%, without any consideration for local amenities such as doctors, police etc. The school provision is lacking in detail and timing consideration.
The current public footpath to the station is dangerous, only allowing one person at a time to use it on what is a very busy road that lorries use. Dispite Network Rail attempts to reduce bridge strikes here they still continue to happen or we have lorries reversing down the road looking for a point to turn around.
The train service to Baldock is also being reduced which will add even more strain to the community.
The loss of the agricultural land will have an environmental impact to the local community at a time when we are being encouraged to support local business and reduce air miles for our food. This does not take into consideration the job and home losses incurred by this action - the council will be creating this but I doubt that they will support the families effected.
I also find it very interesting that over 90% of the proposed land is owned by the council, where is the investigation into this?
This year we have found newts on this land, I could not find the environment impact and mitigation report for any protected species.
It's claimed that affordable housing will be created yet Baldock is a higher property value area. How does this tally?
Finally why was the proposal to create a new town not fully investigated?

We would like to say at the outset that we understand the need for a Local Plan and the national need for more house-building. However the Local Housing Plan for North Hertfordshire, as proposed by NHDC, is, we believe flawed in many respects.

Unequal division of housing allocation
Some building has taken place in Baldock over the lat few years, but NHDC now proposed to increase the size of Baldock by 3,290 homes by 2031. This will double the population of the town. Baldock is the smallest of the towns in North Herts but is now required by the council to have more housing than each of the other three larger towns of Hitchin, Letchworth and Royston. The main reason for this seems to be that all the land proposed for the new development is owned by Hertfordshire County Council who are willing to see it for this purpose; therefore NHDC do not have to contact individual landowners asking if they would be willing to sell.

Many people have said that the number of houses stipulated to be built in Baldock could easily be contained in a new town situated elsewhere in the County. NHDC say they may well have to consider this in the future, but that there isn't the time now to do that now.

Previous emails
I also append copies of two emails sent to NHDC at previous consultation stages, which we would like you to read, but would also like to add the following.

Infrastructure
We are particularly concerned about the developments BA1 and BA2/3. With developments of a certain size eg BA1, infrastructure will be provided eg schools, doctors, dentists, shops etc, but with smaller developments ie BA2/3 infrastructure will not be provided so no new schools, doctors, dentists etc.

We are particularly concerned that insufficient thought has been given to schools; provision. The three Baldock primary schools are currently over-subscribed so that Baldock children, even those living within walking distance of the schools, now cannot be accommodated an so have to be driven to local village schools eg Sandon and Ashwell.

It is already difficult to get a doctor's appointment so this will also be adversely affected by such a large number of new homes.

Traffic
The centre of Baldock consists of just four main streets with very limited parking. Three-bedroom houses are now allocated two parking spaces each; if just a fraction of new householders want to use the facilities in the town centre at any one time, then we foresee enormous problems.

Railway travel
The number of commuters on the local line into Kings Cross is growing all the time as more houses and apartments are being built. GOVIA are currently planning to reduce the number of fast trains stopping at Baldock and are in the process of a consultation period. Our councillors have been in touch with GOVIA who, apparently, had no knowledge of this proposed local plan but have said they will review their decisions regarding changes to times of trains from Baldock. However, even if the trains remain as now, journeys will become more difficult and uncomfortable as people already have to stand on their journey to Kings Cross. Many people moving into the new houses will inevitably be commuters so this will only exacerbate the situation.

Sporting facilities
We are all encouraged to play more sport and be more active, but according to Baldock Town Football Club's figures, Baldock's current leisure facilities are 60% for adults and 40% for children below the national average. So, when infrastructure is being planned we believe that land should be set aside for providing more leisure and sporting activities for the whole town.

Nature Reserves
We currently have two nature reserves in Baldock: one on the Weston Hills and the other at Ivel Springs. Access to these and the wider countryside is vital to people's well-being. Residents need to be able to relax and benefit from contact with nature which is proven to reduce stress. So, parks and green areas within new settlements is vital as well as easy access to the wider countryside. We also need to preserve green space between us and other settlements (towns and villages) and so a large area of designated nature space between Baldock and Bygrave, for instance, would be beneficial and aid the well-being of both the people in the town and natural habitats.

Below are Emails sent to NHDC at various times during the consultation period.
Since writing in November, many people have supported the idea of a separate development elsewhere in the county with its own centre and identity, where there could be shops, pubs, schools, doctors and dentists' surgeries, new roads etc, built on 'Garden City' lines. One such development is, I believe, proposed for a disused airfield in Northamptonshire, where 1,000 houses are proposed. If the authorities in that area think that 1,000 new houses justifies a completely new and separate development, then surely a development of 3,591 houses should have the same claim. It was distressing to hear Cllr Andrew Young admit (and he was only being honest) that initially there would not be enough school places for all the children living in the proposed new homes, but he wanted to reassure parents that their children would be transported to those schools in the area where there were places, be it Letchworth, Hitchin or Stevenage. No parent wants this for their child. Precious, but delicate, friendships are formed at these young ages and it's good if those friendships can be carried on out of school, so obviously if all children go to schools in their own town, they will be able to socialise after school and at weekends. It is not so easy for working parents to keep transporting their child to other towns all the time.

The proposed development of 3,591 houses is almost four times the size of the Clothall Common development and it would be difficult to integrate people living in those houses into the community life of the present town. When the houses started to be built on the Clothall Common estate, people in the 'old town' maintained that everything should be done to integrate it into the existing town, so not have separate small shopping precincts, nor village halls nor pubs, but that there should be an active desire to integrate people there with the current Baldock residents. Over time this has happened, with people living on Clothall Common taking part in activities in the town, joining organisations and helping run the social and community life of Baldock.

We cannot hope to do this with a settlement four times the size of the present Clothall Common development. Much more sensible would e a new development which had its own identity and could have shops, community halls and maybe even a pub. People like to have an identity and to feel part of something and belong. It helps a community coerce and I believe that because people in a small community quickly get to know one another, it deters crime. Youngsters can be given a place where they can meet and again make them feel a part of the community. As I said in my previous email, this isn't NIMBYism but trying to come up with a workable solution, not just for the present residents of Baldock, who will find life difficult with more traffic and more demands on school places, doctors, and dentists etc, but also for new people coming into the area.

This idea has also been mooted by our three local MPs: Sir Oliver Heald, Peter Lilly and Stephen McPartland. Cllr David Levett says in a report in the Midweek Mercury that '... longer term this idea should be pursued ...' Why not now? Why go for a quick fix solution because it is easy for planners at NHDC and joyful for Herts County Council who own the land?

I don't fee that NHDC have fully investigated the possibility of building a small 'Garden City' development elsewhere because it would take too much work to approach landowners to see if they would be interested in selling their land to developers. It is so easy to accept HCC's offer as they conveniently own nearly all the land around Baldock.

We would also go back to the statement made by Cllr David Levett at the public meeting at the Leisure Centre when he said that this is a 'far from perfect plan'. Is NHDC not ashamed to be putting forward a plan that is 'far from perfect'. How on earth can anyone support it? We really do think that NHDC needs to think long and hard about this. They say they have to come up with a plan and this is the best one, or the developers will move in and they will have no control on what is built. But surely everything has to have planning permission, so they do have some control. However, to prevent that happening, it seems to many people that the best solution is a completely separate development - and preferably not on Green Belt land that is also valuable agricultural land.

We have also seen the letter from the Council for the Protection of Rural England who express grave concerns about the Proposed Plan. We would urge you to take all their points into consideration. We were particularly interested in their quote from the Planning Minister to the Chief Executive of the Planning Inspectorate: 'We have set out in our recent guidance that a Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints which indicate that development should be restricted,' also: a SHMA is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans.' (my underlining). I think this does then give all councils more leeway than we have been given to understand and maybe more leeway than they realise.

Finally, on more than one occasion, we have been told that if we do not accept this plan with the number of houses involved, then developers will simply be able to move in and build what and where they like. In the letter from the CPRE it would appear that actually that is not the case at all. So it looks to us as though there has been some scare mongering.

Please see below copy of original email sent in November 2014:

Dear Sirs

We feel very concerned about the size of the proposed development around Baldock. We understand that 3,500 houses are proposed for Baldock, a much higher number than for any of the other towns in North Hertfordshire. It is this inequality that incenses the people of the town. We appreciate that new houses will have to be built to accommodate the ever-growing population of this country - and it would be good to know that those who have families locally could buy houses nearby if they choose, but we feel that a development of this size would be detrimental to the town.

At the moment, Baldock works very well as a small community - everyone says what a friendly place it is and the amenities we have currently serve the town well - just. A new development such as this would put overwhelming pressure on schools, roads and NHS services. Hertfordshire County Council, who own the majority of the land that would be required for the proposed development, have said that there would be no problem with the infrastructure - they would manage that. But these houses will be built over a period of years up to 2031, so we cannot imagine that new schools, doctors, surgeries etc will be built in Phase 1 of the development. So families moving into the area will naturally want their children to go to Baldock schools and the families will want to use local doctors and dentists. This will not only affect people in the new houses but also current residents, who will find it increasingly difficult to get appointments.

One of the reasons Baldock works so well is that although we have three primary schools, the majority of those pupils will end up at Knights Templar School, immediately forming a cohesion for the town of the future. We know so many people who went to Knights Templar when our children were there who have stayed in the town because they like it here. They like the amenities and the lively 'small-town' feel of the place. This is not something to be dismissed lightly. It may well be one of the reasons why Baldock has such a relatively low crime figure.

At the meeting at St Mary's Junior School when many fears were expressed about this proposed development, someone who had worked for Anglian Water expressed real concern that the utilities - and particularly the water supply and sewerage disposal - wouldn't be able to cope. Electricity and gas supplies are also a worry. We already hear rumblings that if we have a severe winter there might be power cuts.

When the bypass was built, for a short time, the number of cars and lorries coming through the town was noticeably less. However, volumes have gradually built up and at times queues of cars can again be seen in the town. How on earth will the town cope with all the people and cars living in another 3,500 houses. Presumably they will sometimes want to come into the town to shop - particularly as we have a large Tesco in the town. It is understood that new roads will be built connecting a new estate to the bypass and this could, in effect, then produce a satellite town with little connection to Baldock. Why not then build a separate town, with its own identity elsewhere. This is not nimbyism, but practicality. Obviously the fact that Herts County Council owns so much land around the town is an attractive proposition and an easy option.

There is also the fact to be taken into consideration that so much agricultural land will be used up. We are told we need to grow more of our own food, but with agricultural land being snapped up for housing how is this possible? We feel that the whole question of how much housing is being built in the South East needs to be looked at, but recognise that this isn't something that NHDC or HCC can do. However, we do believe that they can question the government as to its quotas for the South East. If HS2 and HS3 rail links are put in place, then in 20 or so years time the north of the country might be more attractive both for people to move there and for people currently living there to find it a more attractive proposition to stay there rather than to move to the over-crowded and over-priced South East.

Even if the 12,100 homes proposed for North Hertfordshire were to be evenly distributed between the four towns in North Herts and the villages, we would probably be looking at getting around 2,500 - still a great number, given the current size of Baldock - probably another half a town. We urge you to think very carefully how you allocate this housing, both for the well-being of the current population and those who might wish to move to the area.

We apologise for the length of this email and, if you have managed to read it to the end, thank you for doing so.

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 houses North of Baldock (site BA1).

1. GREEN BELT: The site makes a significant contribution to the Green Belt
(Housing and Green Belt background paper para 3.14).
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

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

3. POLLUTION: 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 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. HIGHWAYS: 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 miniroundabout 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 - As a resident in Larkins Close, I feel the vibrations from each hit). 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 and 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 Plan is UNJUSTIFIED and NOT EFFECTIVE

5. TRAFFIC: 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. 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.

6. RAILWAY STATION: 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. There is also no access for disabled passengers.
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 until 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.

7. TRANSPORT NETWORK: 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 cycle ways 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".

8. SCALE OF DEVELOPMENT: 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.

9. WATER/WILDLIFE: 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.
The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on water provision and wildlife.

SUMMARY:
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). NHDC 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.
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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Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

This will impact all of Luton; Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital!
Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.
The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist. Traffic congestion in Wigmore is unacceptable levels.
Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.
The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.
If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.
Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.
There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.
The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.
So consider this written address that I wish to change the Local Plan and participate in the Examination.

Infrastructure and transportation networks are inadequately addressed in the parts of the plan relating sites East of Luton, to meet Luton's Unmet Housing Need East of Luton. I object that there is no justifiable need to declassify Land East of Luton from the Green Belt. There are many viable alternatives, so the Local Plan is not in accordance with the National Framework Planning Policy since it is not "absolutely necessary." I wish to change this plan. I want to participate in the Examination.

I feel quite insulted that Herts Council want to dump this carbuncle at the very edge of their boundary and leave Luton, the poor relation, to pick up the pieces. You have plenty of space to the north of your county along the A505 towards Royston, so build there instead please.

This will impact all of Luton; the area up to and from Luton Airport and the M1, Wigmore, Stopsley, Eaton Green, and even Round Green, Stockingstone Road, and even the over-stretched Luton and Dunstable Hospital! The new proposed development at Napier Park will add even more strain to the local services and infrastructure.
Building 2,105 upwards houses will lead to unacceptable problematic congestion consequences for this area, especially in the light of the airport's vast expansion which planned simultaneously for this side of town. Air quality and pollution has not be assessed in the residential areas around the airport.
The Transport Assessments were not robust. The their data was inadequate and inaccurate; they did not include impacts of all new developments in the vicinity, they were not carried out for long enough, and some studies from Luton Borough Council assumed roads that did not even exist.
In a town with 12% higher that average car use, traffic congestion in Wigmore and Luton in general is at unacceptable levels. We currently have 30% too little greenery for a town of this size - building on valuable amenity land - green belt protected land, is a no-no.
Both LBC and NHDC have noted concerns over lack of necessary infrastructure and inadequate road networks due to the already existent congestion.
The Plan is not deliverable if the basic required infrastructure and transportation access has not been delivered also.
If you consider that Cockernhoe is 50 houses, the expansion threat is a huge 4,200 per cent!! This is disproportionate.

Wigmore currently consists of about 4,500 houses, so this proposal is an unacceptably disproportionate level of expansion on that side too. 2105 houses is like taking half the size of the entire Wigmore Area, and sticking it onto the side all over again.

Therefore logic would dictate that all other infrastructure must also be matched by an expansion of 50 per cent too - so half of every public service available in Wigmore; ranging from shops and retail outlets, car parks, secondary and primary schools, petrol stations, policing services, fire services, health services, dental services must all be also expanded to that same degree. Where will the money for all this come from? The developers will not be paying for any of it.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village. It would change the character of the area to an unacceptable degree.
There have been no mitigating solutions to the air and noise pollution that will be generated from the extra cars, or the airport expansion in this area.
The unmet housing need figure also shows inaccuracies. During Executive Meetings LBC stated the need for a collaboration between neighbouring councils to commission another Strategic Housing Management Assessment to re-examine once more the Unmet Housing Need figure assumptions, due to their estimated nature but far-reaching consequences and drastic impact upon the area. Luton's unmet housing need figure is based on migration statistics. The Plan does not consider how Brexit will affect these either.
So consider this written address that I wish to change the Local Plan and participate in the Examination.

I strongly object to the above-mentioned plan and my reasons are detailed below:
* The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it, as stated in paragraphs 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, paragraph 83).
* There are currently 205 dwellings in Cockernhoe, Mangrove Green and Tea Green. An additional 2,100 dwellings will be an increase of 1,124%. This development is completely out of proportion to all other developments in the district - these villages and communities will cease to exist.
* Of these additional dwellings, 150 are for North Herts and the remaining 1,950 are to meet Luton's supposed unmet needs, a number which has not been qualified when challenged.
* There is no planned improvements to the already stretched road infrastructure:
* Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5,000 cars+. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently circa 12.75 million with a projected increase year on year to 22 million by 2030, this is set to worsen. Stockingstone and the A505 will equally suffer.
* The traffic survey undertaken in 2015 was not carried out to industry standards i.e. for a month. Also, the results of this survey showed a negligible or nil effect on local congestion, when the results and thus the underpinning of the proposal were based on a road that does not exist, has not been proposed and as has been stated by the council "there is no funding to develop".
* In the shorter term, the projected airport development/business park/light industry will attract a further 7,000 employees, according to Luton Borough Council. The roads cannot cope with this increase in vehicles.
* The two country lanes that lead out of the sites in to North Herts have insufficient passing places and are already being used as 'dangerous rat-runs'. This will increase as residents seek access to the M1 via Lilley Bottom and Lilley and seek to access Hitchin/Stevenage through Offley.
* The paths and woodlands are used by villagers and people from neighbouring Luton, as a leisure area for walking, cycling and running. These will be destroyed despite national efforts to encourage people to keep fit.
* In the presentation of the local plan, Councillor Levitt stated that "the development plays a key role in supporting the growth of our economy planning for the right type and numbers of home, in the right place to create sustainable communities". How can a development only linking North Herts by two single track lanes be considered as a sustainable community?
* There is sufficient 'brown field' land in Luton to accommodate 'Luton's Unmet Need' at the same housing density as this proposed development.
* Teeming wildlife, owls, bats, deer etc. will be displaced. Wildlife corridors are no substitute!!
I hope that my objections will be taken seriously and duly noted by the relevant personnel. I look forward to receiving confirmation of this in due course.

We object to the following:

Section 2 - Spacial Strategy
1. Spacial Vision

Para 3.6 'Vision By 2031. North Hertfordshire will be an attractive and vibrant place where people will want to live, work and spend their leisure time.' Already the residents of North Herts feel that this area is overpopulated. Inadequate rail services for commuters, inadequate parking at all North Herts stations, inadequate capacity on the A1M with no plans for widening it and with roads gridlocked daily this proposed level of housing development will make people's lives intolerable.


2. Policy SP16: Site NS1 - North of Stevenage

900 homes proposed development. This site for these houses has now increased since the two public consultations resulting in the site abutting the village of Graveley thereby causing coalescence with Stevenage.

Para 4.195 and 4.196
The proposed development of 800 houses on adjoining land to the south of Site NS1 by Stevenage Borough Council will make a total of 1700 houses in this joint development and will result in a huge increase in traffic. The B197 North Road is an already congested road at peak times, often with standing traffic. The proposal of a looped estate road with both ends adjoining North Road will further greatly exacerbate traffic congestion, standing traffic and pollution.

Stevenage's proposed estate road junction will be approx. 250 metres north of the junction with Grandby Road onto the B197 and North Herts proposes 'that the northern end of this road will emerge at, or close to, the existing junction of the B197 at Graveley Road/North Road. A new arrangement, possibly a roundabout, will need to be provided.' This is not deliverable - this junction is already very dangerous with numerous accidents. Previous requests to Herts Highways Department for a roundabout have been refused as the B197 is the designated emergency relief road if the A1M is closed in either direction between Junctions 8 and 9 and therefore roundabouts are not permissible. Many adjustments have been made to this dangerous junction over recent years but there are still frequent accidents. Increased traffic can only result in further accidents and fatalities.
Further to this, the proposal by Stevenage Borough Council for an Employment site opposite this housing site and a large retail store close to the North Road/Graveley Road junction will increase traffic and pollution on the already congested B197.

The looped estate road at the northern end will cause both noise and air pollution to Graveley village.

Since the opening of the Baldock bypass traffic has increasingly used the B197 from the A505 as a rat run to Stevenage. With the proposed employment site east of Baldock and the proposed housing site for 2800 homes north of Baldock both with access to the A505 traffic levels are likely to increase considerably though the village of Graveley with resultant noise and air pollution.

Para 4.197
We object most strongly to use of Green Belt Land for this proposed housing development. Contrary to the AMEC report the Green Belt land between Stevenage and Graveley strongly fulfils the NPPF green belt tests and provides a clear boundary to the further expansion of Stevenage. Graveley is an ancient rural village and it is completely unacceptable that SBC and NHDC's proposed development North of Stevenage would result in the effective coalescence of Graveley with Stevenage urbanisation.
In NHDC's previous two public consultation documents an area of Green Belt land was proposed between the northern edge of the site and Graveley village. This has now been pushed back with the site abutting Graveley village and thereby the loss of all Green Belt between Stevenage and the village. This will result in the loss of identity of this rural community. This Green Belt land is used by many people for leisure pursuits and there are several public footpaths and a bridle path running across this land all of which are heavily used. These would all become paths through an urban sprawl. We object to this loss of Green Belt.

3. Policy SP18 Site GA2 - Land off Mendip Way Great Ashby
Proposed development of 600 houses
Whilst the principal access of this site will be from Mendip Way in reality residents in this development are likely to use Back Lane, a very narrow winding country lane running into Church Lane in Graveley, as a short cut to the A1M and area north of Stevenage. This, together with Site GA1 of 330 houses again with available access to Back Lane, will increase traffic within the village of Graveley with consequent noise and air pollution and further congestion at peak times.
There should be no access available onto Back Lane from either of these proposed developments.

Section 3 - Development Management Policies
8. Housing Strategy

Para 8.1 It is questionable as to whether 15,750 homes are necessary in this area. We have been unable to find any published evidence as to why so many homes are are specifically needed in North Herts a rural area that is already overpopulated and with such a poor existing infrastructure.

How widely known is The New Homes Bonus, the grant paid by central government to local councils to reflect and incentivise housing growth in their area? Is it possible that the vast number of houses proposed is directly related to the alleged £7000 government has offered to councils for every house built? Is it at the end of the day to simply to swell the council coffers irrespective of destruction of the green belt, of air pollution, of traffic grid lock and destroying the quality of life for Hertfordshire's residents?

RE: North Herts Local Plan Site CD3 - I do not want to take part in the oral examination and do wish to be notified when the plan is submitted

I am writing to oppose the housing developments in Codicote, in particular the site at CD3 Land North of The Close.
The charm of Codicote is that it is an ancient village, where the residents, in the main, know each other. The proposed development is going towards turning it into a small town, thus completely ruining it's character forever.
I stated my objections during the last round of consultation and wish to restate them here. In the first instance I would like to ask why the idea of creating a new Garden City has not been further explored in this consultation. This would provide the housing that the plan seems to suggest is needed. It would then be possible to provide the infrastructure that the current plans are sadly lacking in. This would make use of the areas of disused land.
In particular I would like to ask how you plan to overcome the following problems which will inevitably arise from the building of further housing in Codicote.
1. Transport and travel
There is currently no train station and a limited bus service. This already causes problems for residents attempting to get to local doctors, hospitals and to shops. This results in people further taking to their cars, creating yet more congestion within the village. The High Street is the main access for many to reach the A1M, both from Codicote itself and surrounding villages and this is already an extremely congested area with rush hours causing long delays. The added traffic from the new Clock development has already added to this congestion at the A1 roundabout. This along with the added strain of Quarry traffic will make this road dangerous and difficult to park on, therefore reducing the number of people using the local businesses The building of houses in Codicote, Kimpton and Old Welwyn will only add further pressure to this already busy, congested and often dangerous road. An increase in traffic will surely be in contravention of Design Policy D3 Protecting living conditions, in the Local Plan.
There are an additional 315 new houses planned for Codicote, The average number of cars per household in rural villages is 1.77 (source: Department of Transport National Travel Survey). That equates to nearly 560 additional cars in the village. The Local Plan (paragraph 13.82) states: "Sites in Codicote will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures which may seek to address these issues." Given that currently approximately 75% of the residents travel out of the village for work and that this will also be the case for residents in new developments; how could any mitigation measures possibly address these issues to any degree of satisfaction, this surely fails one of the key criteria of the plan - that it be 'justified'.
In particular site CD3 will involve traffic from all 48 houses exiting along an already congested and poorly unkept residential road, Valley Road, exiting the village either through the already busy high street or the again poorly kept lanes leading to Stevenage. I would like to ask how this can be an option which your surveys and investigations found to be preferable to a site where access is via a main road.
Section 4 of NPPF paragraph 34 dictates that Local Plans should prioritise developments in areas where journey times and distances are minimised, where good public transport links exist and where sustainable transport (walking, cycling) can be maximised. Codicote is not such an area and the plan on this count fails the sustainability test.
2. Schools and Education
The local primary school is a successful and outstanding school. It is ideal as a village school for village residents, if the plans to extend the school go ahead then this will change the character and nature of the school completely.
I would like you to tell me your plans for where these children will attend secondary school when schools in nearby Stevenage are already closing. Also to how you see the increase in transportation of these children being achieved without creating more congestion and traffic in our village.
3. Doctors' Surgeries.
Codicote does not have it's own doctors' surgery at present, this means that residents have to travel to outlying villages and make use of the already busy surgeries there. I would like to hear from you how you plan to address this within your current plan of building 315 new houses. How does your plan demonstrate that the infrastructure to accommodate this is present.
4. Green belt land.
Codicote is within the boundaries of the Green Belt area, and subject to it's protections. It protects the boundaries between the villages and provides opportunities for access to open countryside, the ability to see wildlife flourish and get the exercise that the government promotes as so vital to the health and wellbeing of residents. Building on the sites such as CD3 will be a misuse of green belt land and adversely affect those living here.
5. Flood risk
The area adjacent to site CD3 had in the past been vulnerable to flooding. The reduction in open countryside, the addition of further Tarmac and concrete non porous surfaces all built on a steep slope leading down to The Paddocks and Valley Road will surely increase this flood risk to unacceptable levels. Currently my own property is up to 8 inches deep in water in heavy rains with water running down from the higher land at the front of the house and and the back where the proposed housing would be on site CD3, this will only get worse if houses and building goes ahead on this site. I would like to know how you propose to prevent this in your plans.

In conclusion village life is about ' achieving sustainable development which means ensuring that better lives for ourselves don't mean worse lives for future generations' Rt Hon Greg Clark MP, Minister for Planning - National Planning Policy Framework 2012.
'Adding new developments of homes on the edge of villages... Is hugely damaging to the immense strain on public services in the Villages' As stated by Stephen McPartland MP Stevenage. I strongly oppose the plans for Codicote and in particular CD3 for the reasons that I have stated above. Again I ask why the apparent need for housing stated in your proposal is not being covered by the creation of a new Garden City.

BA1
Greenbelt development: The proposed site at Blackhorse Farm is on Greenbelt. The fundamental aim of Greenbelt is to stop ribbon development and urban sprawl by keeping land permanently open. Inappropriate development is by definition, harmful to the Green belt and should not be approved except in exceptional circumstances. How can a housing plan disproportionate to the size of the town and that will destroy farmland and peoples livelihoods be exceptional? In order for this suggested Local Plan to be accepted, the planners have removed Green Belt from around Baldock. This contravenes 3 of the 5 functions of the designation of the Green Belt; 1) To assist in safeguarding the countryside from encroachment, 2) To preserve the setting and special character of historic towns and 3) To assist in urban regeneration by encouraging the recycling of derelict and other urban land. There is a heightened interest in maintaining Green Belt across the UK. Any proposal for new housing should adhere to the latest policies including full investigation of Brown Field sites and respect for legislation governing Green Belt land. There is no evidence that this has been done. The land that is proposed is of productive agricultural use. With an ever expanding population that needs feeding - farming and feeding the nation is essential. Surely food is more valuable than homes?

Housing and development strategy (HDS): I recognise that some housing is required in Baldock however it is the overall size and disproportionate scale of the plan that does not mean soundness test 2) justifed and 4) consistent with national policy. The 2011 census reported that Baldock had 4491 dwellings and therefore the proposed increase of 2800 new houses at the Blackhorse farm site and a total of 3590 houses in Baldock overall will result in increasing the size of Baldock by 80%. If this same ratio was applied to neighbouring towns such as Letchworth and Hitchin it would result in approx 11,000 new homes instead of the 1000 - 2000 being proposed. It is unreasonable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20%. Baldock is a historic market town - increasing the size of the town to this extent will destroy its character, individual identity, community feel and culture. Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.

Inadequate local infrastructure to support existing needs: The plans do not adequately address improvements to infrastructrure that will be required to support a development of such a large scale. The number of houses allocated to Baldock will increase the population by 80% and there has been no attempt to seek to preserve the character and heritage of this historic market town by a sensitive and carefully planned development. The scale of development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched. Schools, doctors' surgeries and other basic amenities such as the community centre, library and town centre parking are already at full capacity. Even water supplies are inadequate (Affinity Water describes our area as being under "serious water stress", and there have been a number of incidents where residents of Upper Bygrave have lost water supplies completely). During a discussion about the alternative option of a new garden city (as proposed by the local MP, Sir Oliver Heald) it was pointed out that a new city would at least start from a position of no amenities, but a massive development at Blackhorse Farm would be put into an area where the amenities are already in deficit. Furthermore, we can be certain that developers will build houses before building any amenities, so the situation will have to get considerably worse before any action is taken.

Traffic Congestion:
Baldock is currently gridlocked on a daily basis at the North Road traffic lights. Traffic access into Baldock is restricted by two major barriers: the railway line and the A1 (M). As a result, a very high proportion of traffic entering or leaving Baldock is forced to cross this particular road junction in the town centre. This junction is used by: Traffic entering Baldock from the north west on the A507; Traffic entering Baldock from the north on the A1;Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages; Traffic entering Baldock from the north east on the A505; Traffic entering Baldock from the south east on the A507. All these major traffic flows pass through this single junction resulting in continuous conjection which during the rush hour can extend back almost as far as the Baldock services. This junction pre - dates the A1 and the railway and was never intended to carry anything like the current volume of traffic. The railway bridge surely constrains the road width at this point and the historical/listed buildings and pavements would surely prevent widening of roads in this area?
Air pollution levels in baldock and particularly between the railway bridge and the junction are high especially during rush hour and congestion. It was stated during public meetings on the draft Local Plan that Baldock has an existing air quality problem and that the "Baldock bowl" concentrates particulates from traffic exhausts.

Baldock station and rail capacity
The location of the Blackhorse Farm development so close to Baldock Station inevitably means that many of the houses will be sold to people who commute to London or Cambridge. The National Planning Policy Framework requires a Transport Assessment that emphasises "alternatives to the car such as walking, cycling and public transport". The railway is a major component of the public transport provision in Baldock and it does not have the spare capacity to carry the additional passengers as a result of this development. Baldock station is small and many travellers are already forced to stand all the way to London.
It has been estimated that the Local Plan will increase the number of rail journeys for Baldock from 330,000 to 600,000 per year and under the current plans announced by Govia Thameslink in their 2018 timetable consultation, Baldock is set to lose semifast services to and from London and they will be replacing the existing trains with newer models that provide air conditioning -but 30% fewer seats. Therefore there is no realistic expectation of any new capacity becoming available.

Proposed new road connecting A507 and A505:
Although the NHDC planners have not produced a Traffic Assessment for the Blackhorse Farm development, they have proposed a road linking the A507 north of Baldock to the A505 east of Baldock

The road would allow some traffic to avoid the north road crossroads already discussed but it is not explained how this link road will address the needs of the Blackhorse Farm development.
It is unlikely that people living on the new development will drive across to the other side of the railway line so they can enter Baldock via the same gridlocked junction from the east instead of from the north. For the residents of the new development and the existing residents of Lower Bygrave, the design of this road and the associated railway crossing is a critical issue.

Natural Environment (NE) The housing site is on a slope. Baldock town already has issues with flooding when there is heavy rain. Building on this site will reduce or possibly even remove the natural drainage that currently exists, resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings. There is no mention of how the developers plan to resolve the drainage issues caused by building on this site and it is often found in recent years that housing developments rarely provide sufficient drainage given the lack of green space, lack of gardens and high density of housing.

The proposed site for building is also the habitat for a number of endangered species (corn buntings and bats). The size of the development is likely to destroy their habitats and/or prevent co-existing, which will result in damage to the species.

Greenbelt development: The proposed site at Blackhorse Farm is on Greenbelt. The fundamental aim of Greenbelt is to stop ribbon development and urban sprawl by keeping land permanently open. Inappropriate development is by definition, harmful to the Green belt and should not be approved except in exceptional circumstances. How can a housing plan disproportionate to the size of the town and that will destroy farmland and peoples livelihoods be exceptional? In order for this suggested Local Plan to be accepted, the planners have removed Green Belt from around Baldock. This contravenes 3 of the 5 functions of the designation of the Green Belt; 1) To assist in safeguarding the countryside from encroachment, 2) To preserve the setting and special character of historic towns and 3) To assist in urban regeneration by encouraging the recycling of derelict and other urban land. There is a heightened interest in maintaining Green Belt across the UK. Any proposal for new housing should adhere to the latest policies including full investigation of Brown Field sites and respect for legislation governing Green Belt land. There is no evidence that this has been done. The land that is proposed is of productive agricultural use. With an ever expanding population that needs feeding - farming and feeding the nation is essential. Surely food is more valuable than homes?

Housing and development strategy (HDS): I recognise that some housing is required in Baldock however it is the overall size and disproportionate scale of the plan that does not mean soundness test 2) justifed and 4) consistent with national policy. The 2011 census reported that Baldock had 4491 dwellings and therefore the proposed increase of 2800 new houses at the Blackhorse farm site and a total of 3590 houses in Baldock overall will result in increasing the size of Baldock by 80%. If this same ratio was applied to neighbouring towns such as Letchworth and Hitchin it would result in approx 11,000 new homes instead of the 1000 - 2000 being proposed. It is unreasonable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20%. Baldock is a historic market town - increasing the size of the town to this extent will destroy its character, individual identity, community feel and culture. Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.

Inadequate local infrastructure to support existing needs: The plans do not adequately address improvements to infrastructrure that will be required to support a development of such a large scale. The number of houses allocated to Baldock will increase the population by 80% and there has been no attempt to seek to preserve the character and heritage of this historic market town by a sensitive and carefully planned development. The scale of development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched. Schools, doctors' surgeries and other basic amenities such as the community centre, library and town centre parking are already at full capacity. Even water supplies are inadequate (Affinity Water describes our area as being under "serious water stress", and there have been a number of incidents where residents of Upper Bygrave have lost water supplies completely). During a discussion about the alternative option of a new garden city (as proposed by the local MP, Sir Oliver Heald) it was pointed out that a new city would at least start from a position of no amenities, but a massive development at Blackhorse Farm would be put into an area where the amenities are already in deficit. Furthermore, we can be certain that developers will build houses before building any amenities, so the situation will have to get considerably worse before any action is taken.

Traffic Congestion:
Baldock is currently gridlocked on a daily basis at the North Road traffic lights. Traffic access into Baldock is restricted by two major barriers: the railway line and the A1 (M). As a result, a very high proportion of traffic entering or leaving Baldock is forced to cross this particular road junction in the town centre. This junction is used by: Traffic entering Baldock from the north west on the A507; Traffic entering Baldock from the north on the A1;Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages; Traffic entering Baldock from the north east on the A505; Traffic entering Baldock from the south east on the A507. All these major traffic flows pass through this single junction resulting in continuous conjection which during the rush hour can extend back almost as far as the Baldock services. This junction pre - dates the A1 and the railway and was never intended to carry anything like the current volume of traffic. The railway bridge surely constrains the road width at this point and the historical/listed buildings and pavements would surely prevent widening of roads in this area?
Air pollution levels in baldock and particularly between the railway bridge and the junction are high especially during rush hour and congestion. It was stated during public meetings on the draft Local Plan that Baldock has an existing air quality problem and that the "Baldock bowl" concentrates particulates from traffic exhausts.

Baldock station and rail capacity
The location of the Blackhorse Farm development so close to Baldock Station inevitably means that many of the houses will be sold to people who commute to London or Cambridge. The National Planning Policy Framework requires a Transport Assessment that emphasises "alternatives to the car such as walking, cycling and public transport". The railway is a major component of the public transport provision in Baldock and it does not have the spare capacity to carry the additional passengers as a result of this development. Baldock station is small and many travellers are already forced to stand all the way to London.
It has been estimated that the Local Plan will increase the number of rail journeys for Baldock from 330,000 to 600,000 per year and under the current plans announced by Govia Thameslink in their 2018 timetable consultation, Baldock is set to lose semifast services to and from London and they will be replacing the existing trains with newer models that provide air conditioning -but 30% fewer seats. Therefore there is no realistic expectation of any new capacity becoming available.

Proposed new road connecting A507 and A505:
Although the NHDC planners have not produced a Traffic Assessment for the Blackhorse Farm development, they have proposed a road linking the A507 north of Baldock to the A505 east of Baldock

The road would allow some traffic to avoid the north road crossroads already discussed but it is not explained how this link road will address the needs of the Blackhorse Farm development.
It is unlikely that people living on the new development will drive across to the other side of the railway line so they can enter Baldock via the same gridlocked junction from the east instead of from the north. For the residents of the new development and the existing residents of Lower Bygrave, the design of this road and the associated railway crossing is a critical issue.

Natural Environment (NE) The housing site is on a slope. Baldock town already has issues with flooding when there is heavy rain. Building on this site will reduce or possibly even remove the natural drainage that currently exists, resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings. There is no mention of how the developers plan to resolve the drainage issues caused by building on this site and it is often found in recent years that housing developments rarely provide sufficient drainage given the lack of green space, lack of gardens and high density of housing.

The proposed site for building is also the habitat for a number of endangered species (corn buntings and bats). The size of the development is likely to destroy their habitats and/or prevent co-existing, which will result in damage to the species.

See attachment

I object to the Local plan for Baldock Hertfordshire BA1 - Site 2 and 3
My reasons are:
1. Having been to the meetings I gained a distinct impression that this was land owned by the council that they could see generating a substantial amount of income. In my opinion these sites have been chosen simply to fulfil the government's demands for housing and enable the council to get on the money making band wagon.

2. Having been a home carer and visiting the older generation of farmers in the area, their comment was that this area would not be suitable for home building as it is susceptible to flooding due to younger farmers filling in the ditches in order to increase their land. One would not like to buy a new build that could possibly flood in the future.

3. As I am sure you are aware from the various objections, the increase in traffic would be unbearable. It was seriously suggested that a bicycle lane would be provided to enable us to get out of Bygrave road. How would this be feasible for any older person? Traffic on North Road from Bygrave Road to the traffic lights can easily take 10 minutes for 2 blocks! Car parking is already stretched to capacity as the station car park is extremely expensive and usually full.

4. At one of the meetings, RT Hon. Sir Oliver Heald QC MP, suggested the creation of a new town where all the correct infrastructure could be installed and planned prior to any building. We have not been offered any alternatives at all and his suggestion appears to be the more sensible option, bearing in mind that when a resident questioned whether the infrastructure, such as the proposed bridge at Bygrave would be built before any brick was laid for a house, Councillor Levitt refused to confirm that! We have not heard another mention of the new town.

5. The most important objection that I have is the loss of farm land leading to loss of livelihood, community, food, and diversity. The air quality will be severely impaired as Baldock is in a dip and we are already surrounded by motorways. The increase in motionless traffic with engines running will be astronomical. The predicted number of extra cars on the road in rush hour is between 3500 and 7200 in Baldock, an impossible number to accommodate.

6. Another town the size of Baldock will be tagged on to the one side with no amenities or infrastructure in place and no means of entering or leaving because of traffic jams. Does this sound like a sensible preferred option?

I would appreciate it if you would consider my concerns and give this matter the attention it deserves.