Policy SP8: Housing

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Please find enclosed my response to the NHDC 2016 Local plan.
My objections are mainly based around the proposals for Baldock, in particular the land to the North of Baldock, BA1 - referred to as Blackhorse Farm, but which is in fact known on the Ordnance Survey maps as Bygrave Common.


I believe the Local Plan is Unsound, and Not Justified because of the following:


1. Traffic, noise and pollution during the BA1 houses construction period
Site - BA1; Policy - SP14; Paragraph -

During the extended period to build 2,800 houses to the north of Baldock, this will cause the traffic along North Road to increase, and the current traffic to be disturbed by the additional construction traffic.
It may even affect the Police forces who I understand occasionally use the North Road into Baldock for high-speed pursuit training.
The building of the houses will cause noise, traffic and air pollution problems for local residents.


2. Traffic through and around Baldock - increased volume and noise
Site - BA1; Policy - SP14; Paragraph -

With the building of 2,800 houses to the north of Baldock (BA1) there will be at least one car per household which may choose to gain access to Baldock for shopping, and to local towns for commuting to work.
At the moment all of this traffic will try to pass south under the Baldock railway bridge, causing even more congestion down London Road, into Station Road up to the traffic lights on the corner of White Horse Street.
If as suggested there may be a northern loop road built from London Road to the Royston Road / Bypass roundabout, the traffic for Baldock will turn west along the Royston Road to the Whitehorse traffic lights. The resulting queuing at the traffic lights will add to the traffic congestion and air pollution.


3. Traffic through and around Baldock - increased Air Pollution
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Good Air Quality is critical to the public health. Concern has already been raised within NHDC about the poor air quality near the Paynes Park and Three Moorhens roundabouts in Hitchin.
With a greatly increased flow of traffic into Baldock passing through (and waiting at) the Whitehorse traffic lights, this will have an adverse effect on the air quality for the local residents, including residents of the retirement homes close to the traffic lights. Poor health in the local residents will result in more visits to the local Baldock Surgery, and to Lister Hospital for serious cases. Poor Air Quality in Baldock was part of the justification for the current Baldock Bypass. Poor Air Quality has not been included in the Local Plan.


4. Baldock Railway Bridge footpaths- inadequate for more pedestrians from the new houses
Site - BA1; Policy - SP14; Paragraph -

The footpaths under the Baldock Railway Bridge are narrow, especially on the east side of London Road, where it is just about wide enough for a mother and push chair. If she has a toddler, then it can be dangerous, especially if none rush hour traffic is speeding under the railway bridge inches away from the pedestrians. Pedestrians from 2,800 houses to the north of Baldock will only exacerbate this problem.
Baldock Railway Bridge is low (4.4m / 12ft 6in) and lorries hit the bridge several times per year. This can cause disruption to London Road traffic for a few hours, and can even affect pedestrians if the bridge strike is serious. I do not believe this problem has been highlighted in the Local plan.


5. Baldock Railway Station - inadequate for more commuters from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

There is a probability that many of the new residents in the houses to the north of Baldock (and elsewhere in Baldock) will have bought their houses to be near to the Baldock Railway station, where they can commute to their place of work, be it London, Cambridge, or stations in between. If these commuters choose to drive to the station, they will be delayed by the additional traffic. The current provision for car parking at the rail station is limited, and will not cater for the increase in commuter's cars.
Likewise only the 4 and 8 carriage trains can stop at Baldock Station, due to the short length of the Platforms. The rush hour trains are already full to standing capacity. Either more trains will be needed, or the platforms would need extending (by the Rail operator) to take the new 12 carriage trains.


6. Baldock Town Centre Parking - inadequate for more shoppers from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Since the re-development of Baldock Town Centre parking, the parking spaces are just adequate for the current population of 4,500 houses. With an additional 3,300 houses in Baldock, the car parking spaces in Baldock will be woefully inadequate, and shoppers will drive elsewhere to park and shop.
For the 2,800 houses to the North of Baldock, it will be just as easy to drive up the A1 to the shops in Biggleswade, Bedfordshire. Their alternatives could include driving to Letchworth, Hitchin and Stevenage, where parking is currently just about adequate. Wherever the shopper's cars go, they will cause an increase in local traffic volumes, noise and Air Pollution, giving poor Air Quality for the local residents.


7. Sewage system in Baldock will need enhancing for the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

At the moment all the sewage from the 4,500 Baldock houses flows to the Ivel Springs Sewage Pumping Station, where it is pumped up to Norton, along a pipe which passes under the Baldock Football ground, and over the Norton Road Bridge, passing over the A1M road. From Norton the Baldock sewage flows by gravity down to the Stand Alone sewage works in Letchworth. During a conversation with an engineer at the Baldock pumping station, he believed the current pumps and pipe are close to capacity, and would have to be doubled in size, to cater for the additional 3,300 houses in Baldock. This required increase to the sewage Infrastructure has not been mentioned in the Local Plan.


8. Surface water run off and flooding in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With 174 hectares of prime agricultural land being covered over by houses, roads and driveways, the rain water will not be able to soak into the land, as at present where it adds to the underground water table.
All of this run-off ground water will either pass into the already overloaded sewer system, or flow into the adjacent River Ivel, where it would disrupt the fragile eco system. I believe this water run-off problem has not been considered in the Local Plan, as has the effect on the River Ivel eco system.


9. Provision of Water to the additional houses in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

The local water authority are already trying to move all of Baldock's residents to a metered water supply, due to the lack of water available from the local Aquifer under Weston Hills. A presentation was made by the water authority to the local Baldock councillors saying they were unable to pump water down from the Grantham reservoir, because Aquifer water and reservoir water should not be mixed (due to differing salts and acidity), and that it can cause problems to the water network if it was mixed. The additional 3,300 houses in Baldock (and more houses in other North Herts areas) will only make the water shortage more critical. I believe this water shortage has not been considered in the Local Plan.


10. Lack of spaces for additional pupils in Baldock Schools
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain families whose children are of school age, and will need to travel to a school each weekday, probably by car. At the moment the headmasters of local Baldock schools say they do not have the space for these additional pupils, and the schools will need to be increased in size to take the additional pupils. An alternative would be for the pupils to attend schools in other areas, travelling by road, causing further traffic problems.
I believe the needs of children from the additional 3300 houses in Baldock, have not been fully addressed in the Local Plan.


11. Increased pressure on the Baldock Doctors Surgery
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain young families. It is probable that the parents would normally be initially quite healthy and would not require a doctor. Where there are children, the parents may need to consult a doctor regarding injections, breakages, child illnesses, etc. The Local Plan does not take this need into account.


12. Loss of Green space in and around Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

As part of the Green Space Management Strategy, NHDC have identified green spaces in the following North Herts towns for improvement / revision - Hitchin (12), Letchworth (12), Royston (9), Great Ashby (9). Baldock currently has only 5 green spaces for the current local residents. This is inadequate for the health and fitness of the current residents in 4,500 houses. No mention has been made for the provision of additional green spaces for the new residents in the proposed 3,300 new houses in Baldock (which are to be built on Green Belt land). It would be useful if the new houses were separated from the existing houses by green spaces. This lack of green space in Baldock has not been addressed in the NHDC Local Plan.


13. Not all available land around Baldock has been included in the revised Local Plan.
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Additional HCC (Herts County Council) land had been previously identified as being available to the South of Baldock (to the south of the Bypass, near the old airfield, off the A507 Buntingford Road), but this has not been considered by the NHDC planners, and has not been included in the latest NHDC Local Plan.
Likewise, some of the farmers in the Bygrave area have additional land, which could be made available for housing. I believe the owners of this additional land should have been proactively approached re the inclusion of this additional land in the revised North Herts Local Plan.


14. Duty to Co-operate / not Positively Prepared
The North Herts Local Plan is taking into account the needs of Luton.
I believe South Cambridgeshire should likewise take into account the needs of North Herts, by considering the land in the Odsey area around Ashwell Railway Station for additional houses for North Herts.
This area has excellent links to the road (A505 Royston to the A1M), and rail (Cambridge to London Kings Cross) Networks.
The land to the south of the A505 is HCC (Herts County Council) land and could form part of this new development. It is on a slight slope, but houses in many parts of England are on much steeper ground.
A bridge over the A505 would give easy access to the Ashwell Rail Station (which has land available to be extended to take the 12 carriage trains, unlike Baldock Station).

I am writing in response to your communication of 17 October 2016 and the proposed Local Plan for North Hertfordshire. I have read through and digested the large amount of information contained in the plan as well as the National Planning Policy Framework, and, having done so, wish to make representations based on the following aspects of the plan and in particular, the considerable development which has been planned for the site to the north of the market town of Baldock.

Sustainable Transport Issues (SP6)
Firstly, with regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Access into the town of Baldock from the east/west A507 has always been inadequate and the north/south A1(M) consistently over-congested. Increased traffic on to the A507 from the BA1 site would encourage vehicles to use secondary unsuitable routes such as the single track Nortonbury Lane to access the town which would severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. It is probable that approximately 7,000 more vehicles will be generated from the new housing development as well as additional associated commercial traffic. Many of the town's amenities are on the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7,000 vehicles from Baldock would add to this congestion causing North Herts to become even more gridlocked during peak times. At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modelling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite the clear need for major transport projects, such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra 7000 vehicles away from the A505/A507 junction.
In addition to my concerns over the road congestion, I also have doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant mention of any proposed expansion of the railway station nor any mention of it other than the convenience of location near to a station. To my knowledge, NHDC has not consulted with Govia during the course of the preparation of this local plan. Moreover, Govia is currently planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

Housing Infrastructure (SP14)
I have further doubts over the provision of schools, health and recreational facilities and when and how they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.

Air Pollution (D4)
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and which can lead to health problems such as asthma and other breathing problems. It is essential that assessment of the pollution impact of the extra 7,000 vehicles through the town be undertaken. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 states that planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives and fails the criteria in that it is not consistent with national policy on account of the likelihood of exceeding air quality limits.

Town and Local Centres (SP4)
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities but the historic market town of Baldock cannot sustain the proposed 80% growth and the unique character of the town might be lost for ever. It is very possible that Baldock would become two towns with limited integration of social and economic communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

Landscape (NE1)
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1, a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements. In the Local Plan, sustainability appraisal notes identify BA1 having moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused. Also, proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

Countryside and Green Belt (SP5)
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to make it clear at this point that I am fully in agreement with the local council's obligation to provide housing to a growing population and that some housing should be planned for Baldock. However, a development of the size of that which is planned for Baldock is hugely out of proportion to the current size of the town and to the ability of the current transport and civic amenities to support and to sustain it.

I therefore wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of North Hertfordshire. It lacks a sense of clear vision for the future as there are many aspects of this plan which need further consideration and questions about the future provision of health, education and transport services which at this point in time remain unanswered. The plan is clearly at odds with the National Planning Policy Framework and my concerns and questions over the legality of the plan remain, for the time being, unanswered.

I wish to object to the Local Plan as I consider it unjustified, ill thoughtout and not consistent with National Policy, in particular with reference to sites BA1, BA2 and BA3 around Baldock.
North Hertfordshire and Baldock, in particular, will be ruined if this goes ahead.
The plan currently under consultation is fatally floored before it is started and I fail to comprehend why it has even got this far. I feel let-down by North Herts District Council as I don't believe they have kept to the Select Committee's conclusion that councils need to get plans in to protect areas that should not be built on. And that includes Green Belt. It is my understanding that Countryside and Green Belt should not be taken away until ALL other possible land has been considered exhaustively. This has not been done for Baldock, because sadly, much of the land contained in the plan is owned by Hertfordshire County Council. With government cuts to councils, I should think they are rubbing their hands in glee at the thought of such an easy cash-cow as Baldock apparently is.
As a whole area, the number of houses being discussed for North Hertfordshire is still huge and I think well over what it needs to be. I agree with Oliver Heald who has previously said that a whole new garden city-based town would be much more feasible for the area. It would save Green Belt and valuable agricultural land. The infra-structure would be in place from the start of the development - rather than trying to make current infra-structure 'fit' all the extra homes, people and traffic.
Roads and Rail
This is key to the development plans for Baldock in particular. You cannot avoid bringing in unacceptable levels of traffic to an already over-used sticking point - I'm thinking of the traffic lights and railway station areas in particular here. Also, consideration has to be given to the logistics of bringing the traffic to the new development areas of Baldock. Moving the railway line will presumably not be an option. The Buntingford road should also be considered. It too will not be fit for extra traffic and is not suitable for the amount of lorries and cars already using it.
More generally, the North Hertfordshire section of the A1 cannot cope with current traffic levels and is regularly gridlocked at both peak and off-peak times. s I understand it, the bridge sections cannot be widened. How is it ever going to take yet more commuters?
Having said that, assuming that somebody's 'grand plan' for this area can rectify that situation, I understand that there is an area to the West of Stevenage that could take a new town to accommodate all of the housing planned for North Hertfordshire. Why can that particular area not be triggered? Would it be triggered if Stevenage made it part of their plan? If it were, I believe that it could then become viable for the rest of the North Hertfordshire allocation. I feel the current plan is 'make do and mend' rather collaborating with other councils to ensure the best plan for the whole of the local area. Hertfordshire Infrastructure Investment Strategy (HIIS) should look at the bigger picture for the whole area.
The plan makes no significant points other than the convenience of Baldock's location next to a station. NHDC had not even consulted with Govia the train provider during the course of the preparation of this inadequate local plan and indeed, Govia are currently planning to reduce the service to Baldock station. Is there enough capacity for the railway to take a doubling of passengers? How will commuters access the station? Where will they park?
The NPPF - Section 4 Promoting sustainable transport. 'All developments that generate significant amounts of movement should be supported by a Transport Statement..." It goes on to state that "development decisions should take account of whether improvements can be undertaken with the transport network that cost effectively limit significant impacts of development.
The Plan is simply not effective as it cannot be delivered in the plan period. It fails the consistency with the national policy test as it does not properly assess the transport improvements that would be needed for the site/s to work.
Infrastructure
Traffic and travel is just one issue, there is also the strain and chaos expected for doctors, schools and The Lister Hospital to be considered - until trigger points in the master plan are reached and somebody then does a make-do-and-mend job on local services. It is not good enough and it is not what the area deserves.
No detailed plans have been given. There is an infrastructure development plan included in the evidence bas (not added until September 2016) but it does not give detailed plans.
The NPPF - Paragraph 177 states it is equally important that planned infrastructure is deliverable in a timely fashion. Local planning authorities must understand district-wide development costs at the time the Local Plans are drawn up.
Once again this is not consistent with national policy. The plan has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.
Green Belt
Is it truly right and fair to remove the Green Belt from around Baldock? Much of which is prime agricultural land. Have brownfield sites been exhausted first?
Baldock is a quaint, rural, and historic market town. There are views that will be lost forever if sites BA1, BA2 and BA3 in particular are moved ahead. Grade 1 agricultural land should not be considered as part of this plan. It is a criminal waste of resources that England cannot afford to keep losing.
I sincerely hope that sense can be seen here and the current plan in question for Baldock and North Hertfordshire will be seen for what it is.Too big and disproportionate. In October 2014, Communities Secretary Eric Pickles and Housing and Planning Minister Brandon Lewis said that "thousands of brownfield sites are available for development and should be prioritised. "The new guidance reaffirms how councils should safeguard their local area against urban sprawl and protect the green lungs around towns and cities. Green Belt boundaries should only be altered in exceptional cases. The housing need does NOT justify the harm done to the green belt by inappropriate development.
Source: https://www.gov.uk/government/news/councils-must-protect-our-precious-green-belt-land
The NPPF acknowledges that the Green Belt is to protect areas from urban sprawl and towns merging. This has already failed once for Baldock/Letchworth. Please do not exacerbate the problem by allowing the Green Belt 'to be moved' for convenience.
In a separate document that covers the reassessment of the Green Belt, para 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements "in the first five years following adoption of the plan." This is then contradicted in the Plan itself as the site will only be developed after small sites across the town. Policy SP8 makes provision for land in Stevenage West to be safeguarded for future needs outside of the Local Plan allocation, for up to 3,100 homes, to be used after 2026.
This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It may also fail the criteria 4 - ie. is not consistent with national policy with regard to the Green Belt.
Air Pollution
Baldock is located in a bowl, where pollution can nest. I don't believe there has been an assessment made on the impact of the extra traffic through the town and the pollution levels. I can testify that my husband had only 'sport induced asthma' on moving here 15 years ago. That is now a chronic condition for which he has to use multiple inhalers, one of which has to be used multiple times, daily.
The NPPF Paragraph 124 states that "Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants..."
This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (Priory Fields) and fails the criteria 4 ie. is not consistent with national policy on account of the likelihood of exceeding air quality limits.

Baldock is already severely lacking in recreational amenities for its current population - we would be inviting more bored teens and young adults to hang around in a town filled with pubs and little else. There is no longer any resident police to deal with problems that arise now, never mind the future.
Please consider the current plans for Baldock and the whole of North Hertfordshire carefully. The North of England is crying out for growth and yet the South continues to be further and further stretched and ruined.
Whatever building is eventually decided for Baldock, I would like to be assured that it will be allocated to local people first. There must be a guaranteed proportion set aside for local people. After all, this is supposed to be meeting our needs - rather than accommodating yet more commuters moving in to an area. The number of dwellings currently being planned for Baldock is unjust, unfair and completely disproportionate compared to the rest of the area.
There are many more reasons to not develop certain planned areas around Baldock - excavation of Roman sites, flooding, sewerage, access roads, local work opportunities (or lack of) etc. I hope that other residents will take up clearer and more informed reasoning on those points than I can. I again ask you to consider carefully all the objections put forward and look at the wider picture for the whole of North Hertfordshire.
I would like to be kept updated on the Plan's progress and I would like to be invited to the Public Hearing. Thank you for your time and informed consideration.

Please consider this email as my representation as part of the public consultation on the new housing development within Baldock. I shall be commenting on sites BA1, BA2, BA3 and BA4.

Section 4 - Communities

Site BA1:
Objection to the proposal on the following grounds -
* It is inequitable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20% and yet Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.
* 2400 new houses in Baldock will cause significant additional pressure on the roads. The cross roads by the station, linking the A507 and A505, is already jammed with traffic during peak periods with long (slow) tailbacks. There is also a lot of industry traffic that moves from the Letchworth industrial estate across to the A505 via Baldock.
* The crossroads cannot be widened as it is surrounded by listed buildings. The proposed road linking the A1 Baldock Services directly with the A505 does not account for the increased traffic which will be moving to and from Baldock rail station.
* Limited parking is available at Baldock railway station.
* Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
* The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new build will generate additional children to be catered for, with nowhere to go and yet it is already significant problem.
* Air quality will be significantly reduced within the town following increased traffic of at least 5000 cars on the roads.
* There is no mention of tree planting to improve the air quality issue, or % of green space planned to aid surface water drainage and improve aesthetics and well-being.
* Construction traffic would need to go through the town causing air quality, noise and congestion issues.
* BA1 housing site is on a slope. Baldock town has issues with flooding when there is heavy rain. Building will reduce the natural drainage resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings.
* Its my understanding that the proposed site for building is the habitat for a number of endangered species (birds and bats) which I believe should be protected through either a reduction in the size of the development to limit damage to the species or reduce the density of the housing to ensure species can co-exist with the development.
* Without sufficient new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional railway parking
*Additional town centre parking
*Fewer houses to be built within this site as Baldock road network and current community services will struggle to cope.
*Reduce number of houses and / or density of houses to reduce flooding risk to the town.
*More equitable approach to the build allocation across Hertfordshire
*Construction of Schools and Healthcare facilities to be prioritised within the first phase of development.
*A variety of housing styles and increase the allowance of self-builds; this will reduce the monotony often associated with a housing development.
*Require this site to have a few a children's play parks.
*A large green space with ample parking
*Require a minimum of green space across the site to ensure improved air quality, surface water drainage, and general asthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
*Tree planting along every public road
*Every house to have a back and front garden to aid water drainage and reduce flooding risk.
*Reduce number of houses and / or density of houses to ensure endangered wildlife is protected
*Ensure houses have sufficient parking. Modern developments seem to assume one car families and thus causes congestion on the roads outside.
*Build key infrastructure in advance of allowing new building to prevent construction traffic going through existing road network pinch points.
*Funding to extend the library and community centre.
*Work with rail and bus providers to ensure that services are increased rather than reduced (see Great Northern 2018 consultation).
*Increase the size and amenities of the station (i.e. more manned ticket office hours, possibly more parking)
*Rather than build as an extension of Baldock should the Council not consider developing a town of the same size away from existing communities in order that the road network and other infrastructure can be developed from scratch and thus be suitable for the needs of the community rather than exacerbating existing infrastructure issues? This has worked successfully in a number of places, such as Milton Keynes.

Site BA2 & Site BA3 & BA4:
Objection to the proposal on the following grounds -
*Informed that the first build will be in site BA2 and BA3. As a result there will be pressure on the current schools, doctors surgery and other amenities such as the community centre, library and town centre parking. There is no mention of providing additional school or doctor services within the current plan for BA2 and BA3. This also applies to BA4.
*Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
*The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new 495 combined builds will generate at least another class worth of primary school children with nowhere to go and yet it is already significant problem.
*Limited parking available at Baldock railway station. Also, increased commuter traffic would put further pressure on already congested junctions such as the A505/A507 crossroads.
*No mention of what % green space will be provided, nor mention of tree planting to improve air quality, nor mention of parks for children.
*All construction traffic would need to go through the town causing air quality, noise and congestion issues.
*Without new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional primary school provision along with the new builds at sites BA2, BA3 and BA4 to cater for both the sites and the current children of Baldock. This to be available and online at completion of first phases of building.
*Recommend a variety of housing styles and increase the allowances of self-builds; this will reduce the monotony often associated with a housing development.
*Require each site to include a children's play park.
*Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
*Every house to have a back and front garden to aid water drainage and reduce flooding risk.
*Additional railway parking
*Additional town centre parking
*Funding to extend both the library and community centre
*Work rail and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation).
*Increase the size and amenities of the station (i.e. more manned ticket office hours)
*Ensure houses have sufficient parking. Modern developments seem to assume 1 car families and this causes congestion on the roads outside.

NHDC Proposed Local Plan October 2016
This letter sets out a number of objections to the proposed Local Plan dated October 2016 by NHDC based on two of the "Tests of Soundness" set out in the National Planning Policy Framework ("NPPF"), namely a Local Plan should be:
"Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
The proposed Local Plan falls short in a number of areas, in particular:
the viability and vitality of Baldock;
inadequate plan for transport infrastructure in the North Herts area generally;
inadequate plan for transport infrastructure as a result of the proposed developments in Baldock, in particular BA1, BA2 and BA3;
inadequate plan for the development of core infrastructure such as schools, doctor surgeries, leisure facilities; and
impact on Green Belt
There is clearly a need to increase the housing capacity to allow for the expanding population and the increasing employment opportunities in London and surrounding areas. All areas must contribute to the expansion, however the proposals in the Local Plan are not workable and lack a holistic approach to transport and core infrastructure and will destroy the essence of the historic market town of Baldock.
The letter sets out in more detail the details of the objections and then discusses alternate ways and amendments that could achieve the objectives.
Viability and vitality of Baldock
Baldock is an historic market town with a vibrant community spirit. The centre of the town is characterised by a wide high street, numerous public houses and restaurants, specialised retail outlets including an award winning butchers. There are a number of events throughout the year that bring together the local community, in particular the Baldock festival in May, a free music festival in September, the charter fair in October, numerous farmers markets and other cultural events in the recently refurbished Town Hall and market square.
All of these events allow the people of Baldock to come together as a community and build friendships. The housing in Baldock itself is generally quite modest and therefore the people are of broadly like minds. Over the last 30 years there has been an expansion of housing, primarily on Clothall Common, but in smaller developments of up to 20 houses. This type of expansion enhances the community spirit in Baldock, however the town amenities are at capacity and the proposed increase of 80% more homes threatens to destroy the community spirit and overburden the amenities in the town centre which has limited capacity to expand.
The recreation facilities in the town are limited today. The Town Hall is recently refurbished and is operated by volunteers primarily for art and musical activities. The Community Centre has three function rooms which are used a variety of clubs for all ages. Both have limited capacity and are just about sufficient for the needs of the town, the proposed expansion would render them inadequate. There is a bowls and cricket club located on Avenue Park, which are popular, and Baldock Crusaders netball team use the public courts also at Avenue Park. These facilities are functional but have limited capacity. There is a junior football club (Baldock Town Youth FC) which uses pitches at Hartsfield School and Knights Templar School, the proposed increase in population would mean that more football pitches would need to be made available, preferably with a club house. There is no mention of provision of any additional recreational facilities in the proposed Local Plan.
Baldock has excellent schools, three primary and a secondary school (Knights Templar School). All work together well and receive good or outstanding reports from Ofsted and they are very much part of the community. All of the schools are at full capacity with limited (at best) room for expansion in buildings and facilities, and even less capacity financially, as recently highlighted by an appeal from Knights Templar to parents to help buy
equipment for a newly built science block. The proposed Local Plan sets out a policy for expanding capacity by 8FE, however there are no details on the location or timing of the building of this extra capacity. A condition of any permission must be the building of sufficient school capacity in advance of any housing expansion and that the new schools must be associated with the existing school structures.
The proposed Local Plan has failed to take into account adequately the unique community spirit, recreation facilities and schooling requirements and therefore fails the Test of Soundness to be consistent with national policy, in particular:
NPPF paragraph 70 requires a Local Plan to plan positively to deliver the social, recreational and cultural facilities and services the community needs - the lack of any provision in the proposed Local Plan for Baldock in BA1, BA2 and BA3 demonstrates this has not been done
NPPF paragraph 72 requires sufficient school places are available, the proposed Local Plan for Baldock in BA1, BA2 and BA3 lacks any detail on how and when this will be delivered.
NPPF paragraph 74 requires a Local Plan to provide access to high quality open spaces and opportunities for sport and recreation, in the proposed Local Plan for Baldock there is no acknowledgement of the limited capacity of current amenities or the need to create expanded facilities.
Transport in North Herts
The area between Hitchin, Letchworth and Baldock is already over capacity for the infrastructure that serves it. The employment level in the area is high but with limited jobs available in the immediate area, a significant amount of the people commute to work either by train or by car using transport links that are already at capacity, specifically:
peak time trains into and out of London are always crowded with inadequate seating and regular delays;
the train operating company has recently announced plans to change the service into London, it was reported at recent meeting that the councillor who prepared the plan was unaware of the changes and the adverse impact they would cause, in particular on off peak journey times and overall capacity;
the A1(M) has solid queues every day between 6.30 am and 9.15am from Junction 10 (Baldock Services) to Junction 6 (Welwyn Garden City) caused by only having 2 lanes for the majority of the distance and increase in usage over the last 10 years with the expansion in towns such as Biggleswade, Stotfold, Stevenage and Shefford;
in the evening peak between 4.30pm and 7.00pm there is a solid queue between Junction 5 and Junction 8
the main through road from Baldock to Hitchin (the B656) has queues into and out of Hitchin and Baldock because of the sheer weight of traffic
there is a significant pinch point at Junction 9 coming out of Letchworth, which causes drivers wishing to travel to Royston, Baldock and Buntingford to avoid this and go through Baldock town centre
As a result journey times are at least double what they should be with significant overcrowding on trains. The proposed expansion in housing proposed in the Local Plan will obviously increase significantly the demand on these key transport links, however it does not make any mention of proposals to alleviate the problem, therefore it is not consistent with national policy in a number of areas:
NPPF Paragraph 34 sets out "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised". With limited employment opportunities in the North Herts area the proposed developments have not considered minimising the need to travel.
NPPF Paragraph 36 requires that where there is a significant amount of movement a Travel Plan is published with the Local Plan. The expansion of Baldock by 80% qualifies as "significant amount of movement" and no Travel Plan has been produced.
Transport in Baldock
Baldock is an historic market town of approximately 4500 houses. The proposed Local Plan is seeking to increase the size of the town by 80%. The transport infrastructure does not cope with current demands and therefore an increase of 80% without significant infrastructure development will grind the town to a stop and the consequential impact on the town centre and
environment will increase public health issues and reduce the enjoyment of living in Baldock with its vibrant community spirit.
 The road system in Baldock has been shaped over hundreds of years and has a pinch point at an intersection of the A507 and B656, which is managed by traffic lights and the junction itself is surrounded by listed buildings which prevent any material changes to the junction.
 Traffic at peak times in the morning and evening mean queues onto the junction are regularly in excess of 10 minutes from all directions with the exception of cars coming from Royston.
The railway station is located near to the intersection, it has limited parking, and is accessed from the A507 approached from the North. As has been stated, there are always queues into the intersection and so getting access to the station by car takes significantly more time than necessary.
Approaching from the north of the town along the A507 there is a railway bridge which has very little space for pedestrians and cyclists to access alongside the queuing traffic. This particularly is dangerous, and with the proposed building of 2800 houses in site BA1 the situation will become critical and lives will be endangered. The proposed Local Plan does not have any policy to alleviate this issue.
The capacity of Baldock station is limited, there is not adequate covered area on the platform, parking spaces are limited but adequate, the ticket office is open for a limited time in the morning, there are no retail facilities or toilets, and the train operating company is proposing to change the off peak service times. It is a small station. It is fair to assume a large majority of the people who would move into the new houses will commute to London and therefore the station facilities must be upgraded as part of any proposed expansion in the town.
 Following the recent town centre development, parking in Baldock is limited but adequate for the demand today, and any material expansion in population will cause parking problems and there are no proposals to alleviate this.
The proposed southern link road associated with BA2 and BA3 has no details. Whilst it may alleviate some pressure on the intersection of the A507 and B656, it could create a route through the Clothall Common estate which will increase the safety of the residents who benefit from the estate being a no through road. Any proposed development should
simply create a junction between the A507 and the new A505 Baldock bypass.
In the proposed BA1 development, there is a proposal to create a link road from the A507 between Junction 10 of the A1(M) and the roundabout east of Baldock on the A505. This road will be extremely busy, it must be a dual carriageway and it must be built in a cutting with adequate provisions for noise and air pollution reduction. The proposed Local Plan does not provide any details of the nature of this road
Any one of these points on their own are enough to demonstrate the proposed Local Plan does not take into account the transport needs created by an expansion, but in aggregate they demonstrate the proposed Local Plan is unworkable and therefore fails the Test of Soundness on the grounds of not being Effective and inconsistent with national policy, in particular:
 NPPF paragraph 31 requires neighbouring authorities to be included in the development of strategic solutions for viable infrastructure, this clearly has not happened with the train company, Network Rail or the authority responsible for highways.
NPPF paragraph 35 requires the Local Plan should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. The lack of any proposals in BA1, BA2 or BA3 for improving pedestrian and cycling links, in particular through the railway bridge on the A507 demonstrates no consideration has been taken to encourage sustainable transport for Baldock.
NPPF paragraph 39 and 40 set out policies to ensure there is adequate parking in town centres. There are no proposals in BA1, BA2 or BA3 to address the increase in demand for the parking in Baldock town centre.
Core infrastructure in Baldock
Baldock has one doctors surgery which provides an excellent service but it is notoriously difficult to get an appointment. Parking at the surgery has been removed and there is no physical capacity to expand the practice. The proposed Local Plan for Baldock makes no proposals on the addition of additional GP capacity.
The nearest hospital is Lister in Stevenage. There has been considerable investment in the capacity and services at the hospital but it is still operating at capacity and the proposed increase in housing will place additional burden an already creaking system. There is no discussion on increasing the capacity of the hospital.
Baldock has two care homes for the elderly. The ageing population and increasing demands for social care mean that the existing social care provision will be inadequate for an expanded population. The proposed Local Plan makes no reference to how social services will be expanded to cope with demand of the residents as well as the increasing demands of the existing population.
I have already set out the position that the proposals in the Local Plan contain inadequate details about the provision of additional schooling, but this is another example of the lack of coordinated planning in the proposal.
Taken in aggregate the lack of provision in the proposed Local Plan for the Baldock area fails the Test of Soundness to be Effective and to be consistent with national policy, in particular:
The proposed Local Plan does not consider the broader infrastructure required to service the expanded the Baldock community;
NPPF paragraph 17 set out 12 Core Planning Principles that should underpin plan-making and decision-making, the proposed Local Plan does not apply the following:
o #3 - proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs;
o #4 - take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
o #11 - actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and
o #12 - take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
Impact on Green Belt
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review6 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion, which demonstrates there is no evidence of urban regeneration in this Local Plan.
The proposal in BA1 north of Baldock is clearly urban sprawl, and is exactly the kind of development the Green Belt was intended to prevent. How has this been allowed to happen when the scale of the site is so out of proportion with the size of Baldock? Through research it is clear that the site has been chosen out of political expediency as the land is owned by Hertfordshire County Council and by allocating such a large scale development without due consideration of the impact on the town of Baldock, as demonstrated in this letter, was the path of least resistance, ignoring the NPPF and best practice for planning.
NPPF paragraph 87 and 88 sets out that inappropriate development harmful to Green Belt will not be approved unless there are "very special circumstances". The proposed Local Plan does not make it clear what the very special
circumstances are that mean the significant development proposed in BA1 should be approved.
Alternative Approach
Having demonstrated the proposed Local Plan does not pass Tests of Soundness across a number of elements and therefore does not constitute a sustainable development, there is still the underlying need to increase the housing capacity. I believe a more strategic and holistic approach is needed, not just in North Herts but with associated districts, and such an approach needs to address the following points before any significant housing developments are started:
Increase the capacity of the A1(M) from Biggleswade to Welwyn to have at least 3 lane, but preferably 4 lane carriageways;
Build a bypass for the whole of the Hitchin, Letchworth and Baldock to alleviate the pressure on the B656 (old A505 route) and the associated pinch points such as the intersection between the A507 and the B6565 in Baldock. Wherever possible this bypass will be built in a cutting and be dual carriageway;
Identify a site where a new town, built on Garden City principles, for up to 10,000 houses and associated infrastructure can be built with close transport links to rail and road - the site West of Stevenage is ideal and a tram route can be built to transport commuters to Stevenage station;
Identify the site for a new hospital or significantly expand the capacity at Lister Hospital;
The plans for building on site BA1 should be shelved in favour of the consolidated larger new town;
To accommodate a small increase in housing in BA2 and BA3 in Baldock, there should be a new intersection built on the intersection of the A507 and A505 new Baldock bypass and an expansion of capacity in local schools, community amenities and social care provisions
Summary
The proposed Local Plan does not support the principle of sustainable development and fails Tests of Soundness on a number of levels. There is no fully costed plan because all of the elements such as transport and schooling have no details to be able to fully cost them. The approach seems to be build the housing then worry about the infrastructure later, this is totally flawed and
will destroy the viability and vitality local Baldock community. Finally, the sheer scale of the proposed expansion is out of all proportion and would in and of itself ruin the beautiful town of Baldock.

See attached

I am writing to place my objection about the GA2 development on land to the North of Great Ashby, Herts.

We urge North Hertfordshire District Council to remove GA1 and GA2 from the list of allocated sites for development in North Stevenage and consider the implications to all those involved/affected.

Objections/reasons against GA1/GA2 include:

Greenbelt is precious and should not be developed - building on these sites contravene protected status and this precedence must not be set. Greenbelt areas are important to prevent urban sprawl, stop towns from merging, protect the countryside and promote urban regeneration. The density of the proposed housing is of city nature and not suited to Greenbelt countryside, I believe it is not inline with the 2007 Urban design assessment report commissioned by NHDC.

The land in GA2 houses a rich and diverse amount of wildlife including endangered red kites, barn owls, bats and the currently protected badger. NHDC have a DUTY to conserve the biodiversity of this area. The muntjac deer population has already seriously decreased since Great Ashby was built. Further development would be catastrophic to our wildlife. GA2 would totally encompass ancient woodland and a natural spring, building in this area would destroy valuable wildlife habitats.

A development of this magnitude would be visibly intrusive and harm the character and appearance of an area of outstanding beauty scattered with listed buildings and villages, such as Graveley. This area is used and enjoyed by many people, footpaths and bridleways crossing the proposed sites GA1 & GA2 form part of the historic Hertfordshire way and are frequented by many ramblers, horse riders and dog walkers.

The infrastructure is not suitable for another 2000 homes. Traffic through Great Ashby is already at capacity and congested with many parked cars and can be quite dangerous at peak times.

Doctors surgeries in North Stevenage are struggling with the extra volume of patients already.

Proposed developments are remote from the retail and commercial centres of Stevenage and Hitchin, many businesses are already struggling in Stevenage and a number of shops have closed in the town centre. Extra housing would put severe pressure on an already lack of employment. For commuters, trains are already at full capacity during peak times and the A1 is congested.

Socially affordable housing is not mentioned within the proposals, surely local councils should be considering the needs of people already living in Stevenage & the huge waiting lists .

We understand that housing is needed but feel it would be more sensible to build a completely new settlement/garden city somewhere with reasonable transport links, but away from any towns or villages and NOT at the loss of important Green Belt or woodland. A new settlement that over time can grow to meet the needs of the people with the correct infrastructure designed into it from the beginning and would create thousands of jobs and new employment. We also urge local councils and government to build on brown field sites as an alternative and to look at the many thousands of boarded up council homes that lay dormant across the UK.

Please confirm receipt of this objection.

See attached

I am writing to object to aspects of the proposed Local Plan which relate to the East of Luton development around Cockernhoe and Mangrove Green.
Green Belt
The land in question is protected Green Belt. Reading through the National Planning Policy Framework (NPPF) it states that:
A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
* buildings for agriculture and forestry;
* provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
* the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
* the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
* limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan;
* limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.
The requirement for fulfilling Luton's unmet housing need by constructing 2,100 houses, vastly overwhelming the 205 houses in the villages it will surround, is clearly substantially beyond "limited infilling" and therefore does not fit these criteria. It will also essentially mean that these villages cease to exist and become part of Luton.
According to the NPPF, "inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances". The above points make clear that the development proposed in the Local Plan is categorised as inappropriate above.
The NPPF also states that "'very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations". It also states that "Green Belt boundaries should only be altered in exceptional circumstances". I cannot see how fulfilling Luton's Unmet Need is sufficient to fit these criteria when alternative, less harmful options, exist including undeveloped Brownfield sites within Luton itself which have been identified during previous planning consultations.

Transport Infrastructure
A significant concern is the road infrastructure to support this development. The Local Plan Proposal just mentions that "principal access to be taken from Luton Road and integrated into Luton's existing highway network via Crawley Green Road". There is no mention of access in the other direction to Hitchin where the route would be via single track country roads.
The roads both towards Hitchin and the A1 as well as Luton and the M1 already struggle with current traffic levels, especially during rush hour. The surrounding narrow country lanes are used as rat runs for people trying to avoid the Luton traffic and are becoming dangerous at peak times.
These problems will only increase with the planned extension of Luton Airport and building of a substantial number of houses.
A Freedom of Information request has uncovered that "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". This would presumably be the route towards Hitchin but is omitted in the current proposal and would have a very significant impact on the surrounding countryside.
The statements in the Local Plan Proposal about the required changes to the road network and that "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." is therefore incorrect and misleading. It will also have a far larger impact than the statement in the proposal "Built development contained within the Breachwood Ridge and avoiding adverse impacts on the wider landscape of the Lilley Valley or the Chilterns AONB as informed by detailed landscape assessments" would appear to indicate.

In summary, I believe this proposal:
* does not satisfy the required circumstances to remove Green Belt land
* includes a disproportionate number of houses which will destroy the villages they will surround essentially subsuming them into Luton
* ignores the significant impact on local transport infrastructure and seeks to mislead by not mentioning the additional highway link to the A505 at Lilley which any analysis has been based on. This will impact even more Green Belt land as well as an Area of Outstanding Natural Beauty (contrary to the statements made in the proposal). It also exacerbates the already struggling infrastructure heading into both Hitchin and Luton which is no way remediated by either the disclosed or undisclosed assumptions.

I urge you to reject this unsound proposal and that a more appropriate, viable and transparent option is put forwards.

I object to the NHDC Local Plan 2011-2031 at this Regulation 19 stage. I want to change parts of this Local Plan. I want to participate in the Examination fully.
The plan is unsound. I object to the part of North Hertfordshire Local Plan 2011-2031, which allocates 2,105 dwellings on Land East of Luton.

This plan is not positively prepared, deliverable, justified, effective or consistent with national policy.

The Traffic Surveys have not been carried out to acceptable standards 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 and hasn't even been proposed.

Unsound Reasoning and Incorrect, Inadequate Transportation Studies
There have been a series of Executive Meetings spanning several years up until the current time. LBC has repeatedly discussed points of concern and has concluded the lack of infrastructure and inadequate road network, to be a major and unresolved obstruction point.
Luton was consulted by North Herts District Council three times since 2013 on house building plans East of Luton, in each case Labour run LBC said they wanted either NO HOUSES or MORE. Their reason is that unless there are no less than 5,000 houses, they cannot justify or afford to build a new road from the A505 to the airport and on to the M1 junction 10.
So LBC WANT MORE houses not fewer. Their view is it's MORE or nothing. If it is ONLY 2,105 dwellings then they don't want them.
Most recently, the "2016.07.20. Summary of LBC Decisions/ Cllr David Franks" provides a brief summary of what has been decided by LBC. Their entire case rests on the need to finance a new road which could not be funded by smaller developments. Hence they are looking for a new road from the A505 to the airport and on to M1 junction 10. Yet even if this new road could be achieved it would simplify the journey from the new development to the airport and to the M1 motorway but do nothing to help families from the new homes to get into Luton town centre, to local employment areas, to medical facilities or to schools.
However bearing in mind that the whole of Wigmore is approximately 4,500 houses, building 5000 houses would be asking to build a part of the town LARGER than actual Wigmore itself. This is doubling the size on the area on land. And this is on Hertfordshire's land. They cannot fit 5,000 dwellings on this land.
The Transportation Network
Consider these comments taken from LBC executive meetings:

"With regard to the housing options east of Luton, we urged that any proposals must provide for adequate supporting community and transport infrastructure. This is particularly important in terms of the A505 and also the Luton corridor (serving the airport, Wigmore area and key regeneration sites connected by Vauxhall Way, Eaton Green Road, Crawley Green Road from the M1 Junction 10a) which are already badly affected by peak hour congestion." [Letter dated 10 Jun 2013, Cllr Sian Timoney addressed Cllr T. Brindley Executive Member NHDC about "Luton Local Plan Cross Boundary Issues" [Brindley Letter from Sian Timoney].
"22. The proposal for the major strategic development to the south west of Hitchin would have both benefits and drawbacks for Luton. On the plus side it would dramatically improve road access to Luton from the east, delivering a continual dual carriageway road on to the A1 (M) and beyond. Luton would also welcome the opportunity that such a scheme might offer to provide for the needs of Luton residents which cannot be delivered within Luton. However, on the negative side, the improved road access will undoubtedly put additional traffic pressure onto the A505 within Luton which is already suffering from severe congestions during peak periods." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
"23. While the current development proposals for the East of Luton site provide a local centre, the main retail draw will be Luton and there is expected to be a significant increase in traffic around the Wigmore Asda. Previous proposals for development of the land in this location provided for a more comprehensive scheme which included a bypass that took airport/M1 traffic off the Vauxhall Way corridor and provided some mitigation for the development. The current proposals will not provide such infrastructure. The scope of transport impact appraisal relating to the East of Luton site is currently being agreed between the Council and relevant consultants. It is expected to cover Eaton Green Road, Crawley Green Road, Vauxhall Way, Airport Way, M1J10a and peripheral roads." [Minutes of LBC Executive Meeting/ Agenda Item Number: 23 Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen]
The development plan for Land East of Luton is like a big balloon, with one solitary entry and exit point only - that's the Luton Road leading into Crawley Green Road. If each house has two cars, that would generate 4210 extras cars travelling along that one road.

I object to the NHDC Local Plan 2011-2031. I want to change parts of this Local Plan. I want to participate in the Examination fully.
Infrastructure and Roads requests from LBC
Very specific requests at Executive levels, formed the basis for LBC's formal response to NHDC's Local Plan Consulation.
On 25 March 2013, LBC asked NHDC to:-

"4. Adequately model the impacts and necessary supporting infrastructure, should any
sites progress to the east of Luton. This will ensure that development is of a scale to be sustainable and help to resolve severe congestion:
* on the A505;
* around the Wigmore Asda area;
* along the east Luton corridor serving the airport, Vauxhall Way, Airport Way and
M1J10a;
* along Eaton Green Road, Crawley Green Road and other peripheral roads;
* Work closely with Luton on any cross boundary Community Infrastructure Levy matters"
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]

NHDC Local Plan has not met these requests.
LBC also formally requests:
"16. However, North Herts is urged to ensure that a strategic approach is taken to examine the potential developments. They should secure sustainable communities supported by strategic infrastructure, including transportation, which integrates new and existing communities, links district and town centres, shopping, services and employment areas and tackles traffic congestion."
[Executive Meeting-Luton Borough Council's Response to North Hertfordshire - New Local Plan Further Consultation: Housing Additional Location Options - July 2013]
The NHDC Local Plan does not meet these requests either.
"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" is a document that provides guidance on the content and preparation of Transport Assessments (TAs) and Transport Statements (TSs).

It should be read in conjunction with, and in the context of, relevant Government policies, in particular those relating to transport and planning.

The TAs and TSs for this Local Plan are totally inadequate for numerous reasons. They are not robust nor founded upon a credible evidence base. The reasons for this are, but not limited to, the following.

Alarmingly LBC has undertaken transport modelling to support the preparation of its Local Plan and created an imaginary road that does not exist!

"5.1 National planning policy as set out in PPS1, PPS11 and PPS12 emphasises the requirement for development plans to be founded on 'a robust and credible evidence base'. [PPS 11 (para. 2.49); PPS12 (para. 4.24)]"

"5.2 Development plans will only be credible, authoritative and deliverable if transport
considerations are fully factored into their development from the outset."

In a Freedom of Information Request relating to the transportation studies for East Luton development as conducted so far, LBC states it's Transport Modelling assumes this road that does not exist:

"Luton Borough Council (LBC) has undertaken transport modelling to support the preparation of its Local Plan which includes the development east of Luton which, under the Duty to Cooperate, includes 2100 homes in North Hertfordshire to the east of the town. 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. This is just a high level operational assessment and, as more detailed design of the transport network associated with that development is progressed, a more detailed operational assessment based on current and future traffic conditions will be undertaken as part of the Transport Assessments and Sustainable Travel Plans as proposals for development of that site are brought forward."
[FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

LBC admits their and NHDC's studies are based on totally different basic premises. Whilst LBC used an imaginary exit and entry road, to change the entire outcome of it's TA, NHDC did not include the imaginary road:

"The main difference compared to the LBC report (see response 1 above) is that North Hertfordshire's assessment did not include the new road between the A505 and the northern end of the spine road through the development site." [FOIR #6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016]

There is, and never has been a proposed new road in North Herts. The basis of the transport infrastructure relies on the existing Tarmac historic single track lanes in N Herts, i.e. Chalk Hill and Stoney Lane.

Maybe LBC need to do another Transportation Modelling study that also doesn't include this non-existent road, then it will be more in line with reality. That reality being heavy traffic congestion building up along Wigmore, Crawley Green, Eaton Green and Stockingstone roads.

More importantly, there is no reference to the devastating effect on the inadequate existing roads into Luton, Luton Airport, Train stations, and the M.1.

The Crown Estate application, shows no intention of linking to a new "spine" road, so should it not fail on this alone?

Guidance of Transport Assessment and Environment Ignored

"Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government" lists many issues that haven't been addressed by the Local Plan:

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport
and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience."

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks.

Have LBC and NHDC conducted air quality assessments in the development area or carried out any noise pollution studies.

LBC said: "LBC has not undertaken any detailed assessments of Crawley Green/ Luton Road. Luton Road is situated in North Hertfordshire District Councils Area who may be able to advise regarding this location."
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

"Environmental Protection has not carried out any noise pollution studies along Crawley Green Road. Luton Road as per question 11 is outside the borough boundary and part of North Hertfordshire District Council.
[Freedom of Information Request #3-REPLY-(LBC Ref# 910229)Traffic Special Needs School -5Jul2016].

Furthermore, there has been a big change since the Local Plan Transport Studies were conducted. Heavy goods vehicles have since been re-routed by NHDC, to along the Luton Road and Crawley Green Road. So the TAs now also fall short of another standard too:

"Traffic data and traffic forecast
4.18 The assessment should include recent counts (normally surveyed within the last three
years) for peak period turning movements at critical junctions. In certain instances, for
example, where there is known to be a significant level of heavy goods vehicles (HGV)
traffic, a classified count2 should be provided." [Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]

"Environment
4.38 The environment issues that should be assessed include:
* nuisance to people caused by transport-related noise and vibration generated by the development;
* the emission of greenhouse gases as a result of the transport implications of the development and the impact of changes in local air quality on people;
* the transport-related impacts of the development on areas of designated landscape
importance;
* whether the site is in an air quality management zone or is likely to cause a breach of current legislation;
* the transport-related impact of the development on areas of nature conservation or
biodiversity and Earth heritage interests (such as geology) where they interact with
roads;
* heritage of historic resources where they interact with development-generated transport and/or proposed mitigation measures;
* the transport-related impact of the development on the townscape;
* appraisal of the transport-related impacts of the development on the water
environment;
* the impact of the transport implications of the development on physical fitness;
* journey ambience.

4.39 The potential for environmental impacts that would breach a statutory limit should be addressed. LHAs and the HA have a statutory duty to prevent a breach of statutory limits (e.g. air quality) due to incremental change of volumes of vehicular traffic on their networks."

The number of TA assessment years in respect of capacity analysis for transport network, is not consistent with the size, scale and completion schedule of the other four huge developments going on in the same vicinity of this site. Plans that are already approved are London Luton Airport Expansion, Napier Park and Butterfield Green Business Estate. And verging approval is Powercourt. This is too much for one side of the town to absorb. And it is impossible to predict the consequences upon the transportation systems of these four massive projects alone. All of these developments are considered more vital to LBC's economy than the Land East of Luton. It is necessary therefore to prioritize, and accept development in order to be sustainable must be paced and calculated.

"ASSESSMENT YEARS
4.45 The assessment year(s) in respect of capacity analysis for the transport network should be consistent with the size, scale and completion schedule of the proposed development, and that of other major developments in the vicinity of the site, as well as planned improvements to the transport system.
4.46 The appropriate horizon assessment year should be agreed with the relevant authorities during pre-application consultations.

4.47 In addition to the opening year, one or two further assessment years should be considered.
For the local transport network, a development should be assessed with regard to the LDF, and for a period of no less than five years after the date of registration of a planning application. Should the development take place over a longer period, it would be appropriate to extend the length of the assessment period. The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure improvements are in place."
[Guidance on Transport Assessment (GTA), March 2007, London: TSO - Department for Transport Communities and Local Government]
However in our case this should be reread reversely as "The development proposal should be supported by an acceptable TA, carried out in accordance with the GTA. This will help to ensure that the transport impacts of the development are more accurately applied to a situation where all committed local transportation infrastructure deteriorations are in place."

Traffic Assessments and the Tardis Factor

Literally bumper to bumper, there is only literally physically space to have 4,291 moving average cars bumper to bumper non-stop in one hour on Luton Crawley Green Road. That is non-stop, bumper to bumper however. This would mean a tail-back mostly all the way up the road on a permanent basis during peak times. It doesn't include Heavy Vehicles which also use that road.

What would happen if tomorrow car owning people of the proposed new development, took their cars out onto Luton Road and Crawley Road and into drove into Wigmore Lane in the rush hours?

Vague Traffic Assessments by AECOM

The published data from the Traffic assessments appear to be vague and inconsistent.

We have obtained AECOM's North Hertfordshire District Council Preferred Option Housing Assessment - Transport Modelling Report 2014 - Update 2 (71 pages)

And also the later AECOM study "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Seeking Earlier Versions of "Hertfordshire County Council Transport Planning Contract, Job No: 60279140 - 160" East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) dated 24/02/16 (20 pages)

Regarding the later study Job No: 60279140 - 160/ East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council) there were serious changes made to the first and second versions that passed between council and AECOM, before NHDC settled on a final version. The document passed between AECOM to NHDC several times between parties, at NHDC's request alterations were made. Both parties will have record of this on their email company correspondence at systems level.

Parts where changed, then further parts changed at NHDC's request. We ask the Inspector to obtain these two earlier drafts of East of Luton Urban Extension Stage 2 - Traffic Modelling Results (North Hertfordshire District Council). There were two previous drafts which passed between NHDC and AECOM before this final version.

It is important that we see what information was taken out, and then see if it needs putting back in again.

The newer AECOM Transport Modelling Assessment dated 24 Feb 2016 claims to be "an initial modelling assessment". However there is also a much earlier one by AECOM dated 7 Jan 2015. So we know it is not the "initial assessment" exactly. The earlier one would be the initial assessment. The earlier one was much, much longer however. It was 71 pages in total. The later one has shrunk down to just 20 pages. We think the later TA should be longer than 20 pages and more thorough.

Alarmingly, we think that the Traffic Assessments might not all completely agree with one another.

Transportation, Air Pollution and Child Health

Children are more susceptible to the brain damaging effects of heavy metals than adults.
There are two schools on this congested road - Richmond Hill Special Needs School and Wigmore Primary School.

It is unsafe to expose the children to this degree of heavy toxicity in the atmosphere. You have not consulted either school for their recommendations regarding health and safety impacts for pupils.

The children in Richmond Hill are already suffering a range of disabilities, and the plan is ignoring the damaging effects on disadvantaged children. It is fact that outdoor air pollution is responsible for 20 times more early deaths than the number of people killed on our roads.

The children at Richmond Hill have challenges, disorders and learning difficulties; many which are genetic. They require a healthy non-toxic environment which does not antagonise the various consequences of these disorders and learning difficulties further.

The exhaust fumes along this road collect in the air and you can smell them.

The exhaust fumes plus the jet fuel from the airport is choking and I am concerned about the health effects for myself and my children.

This pollution is unpleasant and dangerous for residents' health, especially childrens'.

No air particulate studies have been done on this road or surrounding areas by either Luton Borough Council or North Herts District Council. This neglect is by their own admission in replies to Freedom of Information Requests [see Appendix: Freedom of Information Request#6-REPLY-(LBCRef923239) Traffic Assessments North Herts Local Plan & Luton Local Plan-21Sept2016].
So they do not know if it is currently within legal limits or above legal limits now. They cannot accurately assume if air quality will be inside legal limits after the building of a new expanded airport.

Remember that legal limits are not necessarily healthy limits. When air particulates are in the upwards zones already, they do not need to be made worse.

Unsafe Entry Roads

The Luton and Crawley Roads are already extremely congested, too narrow, next to two schools and have many residences directly on either side. This will be like making people suddenly live next to a motorway, when they initially purchased/ chose to live here due to it being a quiet, neat, beautiful semi-rural area.

Both schools have access points and entrances upon this one access road.

It is already extremely dangerous as cars race around the corner, and there is no crossing anywhere near either school.

It becomes even more dangerous during winter, when nights and mornings are darker so drivers can't easily see.

Airport Expansion and Air and Noise Pollution Consequences

The Local Plan doesn't address that the London Luton Airport will be expanding and what this will mean for the residents, roads and infrastructure around this whole area.

The government approved plans to expand London Luton Airport to nearly double its capacity from 10 million to 18 million passengers a year.

The air and noise pollution will hit even higher levels once the pending expansion occurs. What will they become? What are the projections? Are the studies covering a wide enough area? It is not enough to simply measure air quality and sound pollution only within the Airport's boundaries - when it affects a much wider district.

The air and noise pollution will not be absorbed by more buildings, so in this part of town authorities should be concentrating upon balancing the impact of airport expansion by planting more greenery, not masking it with more concrete.

The Serious Matter of Traffic Congestion on the Wider Network

The airport will also create a huge quantity of traffic, which will create impact in several directions into the Luton Road's connected networks - Eaton Green Road, the A505, Airport Way, Wigmore Lane, into Stopsley, Crawley and even Stockingstone Road. The site next to Hampton by Hilton London Airport behind Vauxhall known as Napier Park site, is already allocated and also going to generate yet more traffic to add into the estimations that should have been included in the traffic studies, but which were not.

Because traffic studies are not an exact science and only estimates/ approximations are used, they need to actually see what happens to the traffic networks AFTER the airport has been expanded and is running. Only then will they know what the true traffic situation will be after the airport expands. Also since Napier Park is a development which is going ahead, this must also be integrated in the plan. The Airport expansion traffic plus the Napier Park traffic may create more than heavy enough load to absorb.

Mistakes can and do happen if left unchecked. Anyone who first went to Dubai twenty years ago, will know that, what once was a ten minute drive from Deira to Jumeirah, is now a forty to fifty minute wait in traffic. Ten minutes became fifty minutes in just a decade. Beware, it can and does happen. It is already happening though however according to the local people in the Wigmore area. How will 18 million passengers get into and out of this "relaunched" airport?

But it gets even worse, because Luton airport is planned to grow to 22 million passengers by 2030.

The airport has seen huge growth over the recent years adding to the already stretched road network. This growth in traffic has not been taken into account in the traffic surveys carried out, which renders them completely inaccurate.

The Fatality Risk of Birdstrike & SUDS

The drainage of that land is terrible and it has a tendency to waterlog. Therefore they have suggested SUDs, yet the appearance of these things are contrived and inappropriate. The dangers of these in relation to birdstrike risks, have been entirely ignored.

Declassifying Greenbelt not Justifiable

The "New Neighbourhood Planning and Infrastructure Bill 2016" states that it supports the Government's aim to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. The land designated for development East of Luton is Green Belt. The reasons for including this land 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 Policy Framework, Paragraph 83).
The land for these homes is allocated as a 'reserve' (in other words, last resort), and therefore should not form part of the main housing distribution plan. Only if this main plan fails in some way should this reserve area even be considered. However Luton has not exhausted all of the options within it's own boundaries.
There are many reasonable alternatives. There is no train connection into the city this East Luton side of town. How will the city commuters get to work? Other sites have much better transport connections than here.

It is a lie that that there are 1950 homes (the remaining 155 being for Herts needs) that "cannot be physically accommodated within Luton". There ARE enough alternative available/ purchasable NON-GREEN BELT plots inside Luton's own boundaries to meet it's housing needs.

There are several alternatives for Luton's unmet needs that have since come to light; example; plans for residential units have been made AFTER NHDC Local Plan displayed initial calculation and allocation based on Luton's unmet needs. So this unmet need has since changed. So the plan also needs to change to reflect that the unmet housing need that has now been lessened by these new allocations within Luton's own boundaries.

New Allocations, after the writing of NHDC Local Plan, are as follows:

a) 234,138.38m2 next to Hampton by Hilton London Airport behind Vauxhall. This Napier Park site, is already allocated for commercial purposes. However, recently LBC announced that 625 units would be for residential purposes. This reduces "Luton's Unmet Housing need claim" on Hertfordshire's land by 625.
b) 58,264.24m2 M1 Junction 10 to M1. This is the site of the current football club. When the new larger football club is operational in 2021, is the plan for it states, then this site will be available. This reduces the remaining "Luton's Unmet Housing need claim" on Hertfordshire's land, since they will be able to fits thousands of units in this site. The location is also compatible with the cross-sectional breakdown of housing needs, as displayed in Luton's Strategic Housing Management Assessment report.
c) 145,311.15m2 Chaul End Vauxhall Car Park, on greenbelt but as an "infill". - This site has been allocated already. Does the allocation include any residential units? If so they too need to be deducted from Luton's claimed "Unmet Housing Need figure".

Alternative allocations are as follows:

d) 22,009.77m2 at Gypsy Lane/ Kimpton Road Car Parks and Scrubland is an alternative. Although it's considered an industrial zone, it could be re-zoned. Or if it can't be re-zoned the plans for a soft industrial site upon Wigmore Valley Park could be switched to here. Then instead of using Wigmore Valley Park for soft industry, could residential units be placed here instead?
e) Butterfield Green Business Estate - If LBC suddenly found room for 625 extra units on Napier Park, then why can't they also give a little section of the large Butterfield green site to residential units too?
f) 19,781.58m2 Hatters Way demolished site - is an industrial site which could be re-zoned. If not re-zoned it could be used for soft industry and thus free up the Wigmore Valley Park's soft industrial allocation.
g) 289,812.695m2 Dallow Road next to M1.
h) 83,130.63m2 M1 Junction 10 is where they are intending to place a football club and shopping centre. This of course will also lead to additional traffic problems, especially on match days when thousands of people drive into town and try to park their cars.
i) 517,700.94m2 Dunstable Chalk Hill. Dunstable is actually in need of regeneration. This is an opportunity to place regeneration in a place that actually needs it, instead of placing degeneration in a place that doesn't want it.
j) Kennelworth Road - A potential housing site, interdependent upon the stadium of Powercourt.
k) Bushwood - 5,500 residential homes of a range of types and tenures supporting a diverse population could be placed here according to the Bushwood Master Plan [Available at: http://bushwood.info/docs/Bushwood-Masterplan.pdf]. Ten years ago the developer was all ready to build but the plan though fairly far advanced, was put on hold. They had even placed two tunnels between junctions 10 and 11 of the M1. These were put there at the time of building the M1. These tunnels could be used to provide connection points to any development at Bushwood, since they still exist today; one is currently being used by a farmer and the other tunnel is part of a bridle way near - they are near Chaul End and Caddington. The Developer was all ready to begin building here. Unlike land East of Luton, Bushwood has excellent access points in and out from the M1, which it is right next to, and it has train stations nearby to enable populations to commute.

Therefore to destroy the Green Belt next to East Luton is not a necessity at all.

Green Belt Next to Areas of Outstanding Natural Beauty

Land East of Luton is next to two Areas of Outstanding Natural Beauty. Putteridge Bury (AONB) is on one side and then Lilley (AONB) is on the other. The EL development would obscure and radically alter the view of these two AONBs.

Urban Sprawl

The purpose of the Green Belt is to stop urban sprawl; this stretch off Green Belt is already so narrow and if taken away there will be absolutely no separation between Luton and Hertfordshire at all.

The boundaries would have to be moved, which will create it's own new problems.

They are already taking away Green Belt land with the Butterfield Green Business Estate - so the area is already going to be losing that.

The NHDC Local Plan says a site MASTERPLAN for all three sites EL1, EL2, and EL3 must be submitted and approved before the submission of any detailed matters (p.40). So why was Crown Estates permitted to submit one isolated planning application [PA 16/02014/1 for 660 dwellings East of Luton] prematurely BEFORE the Local Plan itself has even been inspected or approved?! It seems that the developers and council are speculating and too confident that the many serious doubts around the soundness of this Local Plan will be overlooked and ushered through.

The East of Luton and West of Cockernhoe communities now question transparency and fairness, since we are unhappy at this premature application, which ignores the MASTERPLAN. Was it a tactical move to divert and disperse our efforts to object previously?

Conservation

The rare wildlife in the Brickkiln Wood will not survive this encroachment upon their habitats. Neither will the humans ultimately survive the attack on their habitat. Already many local residents are thinking of selling up and moving away, since they cannot envisage a life in this area after losing their Green Belt and the character of the area that they love. This Local Plan and it's looming consequences has been spoiling quality of life for lots of people. Many people including myself, have been putting off making any home improvements and feel unsettled since this development has been proposed, since they believe that life cannot go on here were this to go ahead. It is no exaggeration to say that the local people are actually extremely distressed. I describe that seriously and accurately. It is affecting the population's quality of life, they are so worried.

There is an extremely high number of tree preservation orders on this area - higher than nearly all other areas considered. This indicates the ancient and mature nature of this particular Green Belt area.

Archaeological Heritage and Shrinking Later Studies

There are many archaeological sites strewn across the area, and it is noticeable that in older archaeological studies many more sites are mentioned than in the council's newer studies. I would therefore like to see the old studies revisited and those sites missing in the newer studies need to be added back into the newer studies. And I ask why are there so many archaeological sites documented in much earlier archaeological studies commissioned by NHDC, as well as private ones, which are no longer documented on the newer archaeological studies? The archaeological heritage didn't diminish, so let's re-examine and make sure that the later studies are as thorough as the earlier ones.

Unacceptable and Disproportionate Alteration of the Character of an Area

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

Wigmore consists of about 4500 houses, so the size of 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 on the side of it all over again.

Cockernhoe Village will no longer even exist. It would destroy an entire rural community and displace a village.

Infrastructure - Schools and Education Services Undeliverable

From the "Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen":

"24. Discussions on previous plans for the land assumed that secondary school provision would be met at Ashcroft High. Such assumptions will need to be re-tested. If there is surplus capacity at Ashcroft, school buses may be required to mitigate further transport impact."
The nearest Secondary school on the Herts side are: Zero. There are no secondary schools on the Herts side nearby.
The nearest Secondary schools on the Luton side are just: Ashcroft High School and Putteridge High School.
How many extra school children and of what ages will 2,105 new houses typically generate?
The matter of providing infrastructure and costing for mandatory state run education services has not been factored in at all, and on this point the Local Plan is not deliverable and therefore not effective.
Recycling Oversubscribed Schools in Plans

Regarding developer plans "The Crown Estate Land West of Cockernhoe Illustrative Emergency Access Mangrove Road [KH 24/08/2015 A Access relocated in response to updated Site Boundary/ JM KH 25/08/2015]"
Upon their map they have actually presented the three schools, as the already over-subscribed Someries, Wigmore and Cockernhoe primary schools.

Is this the extent of Crown's Education Infrastructure solution? Isn't flooding two already full-up schools with 800 new children, actually making an infrastructure problem?
Social Infrastructure Undeliverable
The current level of social infrastructure can barely support the existing community in that area as it is. So far the councils themselves plus the two developers, have put forward plans for this area, which are totally inadequate to support their proposals in this capacity. There is no detail as to how they will deliver and pay for the basic services.
Infrastructure - Rubbish Collection Services Unaddressed
Rubbish Collection Services are not detailed or deliverable in this Local Plan.
How much will it cost to provide extra rubbish collections on a regular basis on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? Who will pay for these? Will it be NHDC or LBC? Or will it be charged as additional Council Tax levied onto Herts residents or else Luton residents? This has not been addressed.
Who will carry out the extra rubbish collections? How many tonnes of extra rubbish will have to be removed annually? What is the costing for 2105 or more extra houses? Will it NHDC or LBC that will carry out the labour? Do they have the capacity and labour power in their departments to do this extra work?
Infrastructure - General Practitioner Services Unaddressed
How can health services at most basic level be provided to this extra segment of population? How many extra people would be resident in 2105 new dwellings, and in what capacity and to what quality will they need to be given these services?
How much will it cost to provide extra GP services on a continual basis per annum? What will be the total cost until the end of the Local Plan, and beyond that? What GP surgery will the extra residents go to? Will they build a new surgery to service this new population? How much will the building of and running of a new GP Surgery cost? Who will build and pay for it? Will it be NHDC or LBC? Or will it be levied as additional Council Tax to Herts residents or else Luton residents? This has not been addressed. How will costs be divided - if the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate? Which County will pay for this, and how will they figure this ongoing extra cost into their budget? Which services will lose out to make up for it?
The current ones in the area are already over-subscribed and the length of waiting times for appointments is already unsatisfactory. Current residents cannot be expected to lose the quality of their health services yet further. Is it justifiable to diminish the quality of public services in this area, yet still charge people the same, or more for them (via Council and other taxes)?
Infrastructure - Emergency Health Services Unaddressed
The Local Plan doesn't address earlier health budget deficits at all or think how they will address them rather than add to them.
Infrastructure - Water Pressure, Sewage and Thames Valley Concerns
In Luton Water Cycle Strategy, September 2015
[https://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Local%20Plan/Climate%20change/CC%20005.pdf]

Point 3.2.4 says "The Water Framework Directive recognises the potential impacts on water bodies from new development as a pressure that must be addressed."

"The area north of Houghton Regis (which falls within the study area) is covered by the Anglian RBMP. The Anglian River Basin Management Plan (December 2009) identifies Luton as one of the three largest Growth Areas which will see a substantial amount of new development in the next 15-20 years, particularly in areas identified for growth or regeneration. Pressures from the cumulative impacts of planned development, especially those on water resources and water quality mean that actions will be required to achieve good ecological status and ensure that there is no deterioration.
Refer to the RBMP document for more details." [p.8]
Infrastructure - Police and Security Services Unaddressed
The Police budget is already stretched. Many crimes are being left un-investigated due to lack of resources.
Will NHDC or LBC provide adequate resources and budget as a result of the proposed housing development? If the population due to be serviced is within the Herts Borough, but in reality the other Borough is expected to provide the services due to it's proximity to the new estate, has it been agreed which County will pay for this, and how will they figure this ongoing extra cost into their budget?
Changing the Character of an Area and Removal of Vital Green Space
Luton currently has 30% too little greenery for a town of this size.

The community uses the green space here for leisure activities such as walking their dogs, exercise, taking children to play, people ride their horses along the bridal path, enjoy hiking, jogging or simply the views throughout the seasons.

This development will rob many thousands of local people of this simple but valuable and life-enriching treasure.

It is absolutely the view of the community that this development doesn't fit in with it's surroundings. It will uglify the whole area. There are also flats mentioned in the Plans, and this area does not have flats so this is inconsistent.

Wigmore Valley Park is already going to be taken away and placed outside of the Wigmore area. Therefore the people of this area would no longer have any green space and leisure areas other than this bridle path and Green Belt zone. If you take this away too, there will be nothing!

This is an unacceptable level of development forced upon this area, and it would alter it's character too drastically and too quickly for it's population and infrastructure to absorb.

This will have negative health consequences for the community as a whole.

Duty Not to Cooperate

Councils don't always pool their ideas and strategies seamlessly. We have seen many blind-spots occurring where duty to cooperate, gets interpreted as duty to blame the other council. This seems to be the mechanism at work, when it comes to things they don't like.

"27. It will be for North Hertfordshire to fully assess and model the appropriateness of their potential spatial strategy in terms of infrastructure (e.g. A1M capacity junctions 6 and 8) and sustainability (landscape, wildlife, economy and community impacts). However, Luton Borough Council's position is that North Hertfordshire should also make provision for a likely level of unmet need arising within Luton. Currently, the estimated capacity of the borough is believed to be around 6,200 dwellings over the plan period (2011-2031) compared to a trend migration requirement of 10,900 dwellings."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

So LBC is relying on North Hertfordshire to fully assess Luton's transport systems. However Hertfordshire is saying that Luton should be responsible for it's transportation systems. There are many lackings in the Transport Assessments. I don't actually see any mention of Wigmore networks, nor Stopsley, Crawley, or Stockingstone Road. Yet all would be impacted.
"28. The scale of provision will be dependent on cooperation with other neighbouring authorities including Central Bedfordshire. It will also depend on infrastructure capacity serving the east of the borough (e.g. the peak congestion experienced on the A505 and eastern corridor serving the airport) and any improvements that could be secured on the local network and in terms of community infrastructure."
[Minutes of LBC Executive Meeting/ Agenda Item Number: 23
Date: 25th March 2013/ Report of: Head of Planning & Transportation/ Report author: Kevin Owen].

Empty Housing Un-utilised

Despite widespread anxiety about a shortage of housing supply, there are 610,123 empty homes in England, according to the government. Of these, 205,821 have been unoccupied for six months or more, the official definition of "long-term" emptiness. In September last year, Scotland had 31,884 long-term empty properties as of 2 Dec 2015. I understand that there are over 650 empty houses vacant in Luton.

Brexit
The NHDC Local Plan has not given any information about how Brexit will impact migration rates. It claims uncertainty. Yet on the contrary it considers itself able to predict future traffic data, for up to four new major traffic generating projects!
The migration assumptions and projections used to calculate unmet housing needs are going to change.
Inadequate Retail Facilities

In one East Luton development plan it has suggested that Westway shops could meet it's retail needs. However Westway is only four tiny shops: a chip shop, tiny beauty salon, hardware shop, and tiny corner store. These shops cannot provide for 5,052 people's retail requirements. The Local Plan says that there must be 250m2 (net) class A1 convenience retail provision (p.40).

Please send me a receipt for my objection. I was unable to upload it onto your system because you have a 3000 character limitation.

Representation on the Local Plan 2011-2031 submission document ("LPSD")
Notice
I have many objections to the LPSD and believe that changes are necessary, principally to eliminate the 2,100 new homes proposal for Luton. I wish to participate in the formal oral Examination of the Plan.

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.

I am writing to express my concerns about the 900 dwellings planned for Letchworth.
I am concerned about the soundness of the plan. Letchworth is the template and original Garden City, and I believe the Green Belt is an integral part of that. The plan is in conflict with the national Green Belt policy (section 9 of the NPPF).
I do not believe that there is justification for this excessive target, and think wherever possible dwellings should be built on brown field sites first. Currently this is not the case and doesn't take properly into account the Green Belt constraints. Destruction of the green belt will also have a massive impact on local flora and fauna, much of which is already compromised.

As well as the impact of this particular part, the cumulative effect of all the local building work will lead to many villages merging into one another, and even less countryside being left. These plans will have a majorly detrimental effect on local facilities. It is already almost impossible to get a place at a Dr surgery, and some are already turning people away, those still accepting people have a long waiting time to see anyone. Local schools are over subscribed, and we already have 3 secondary that are consulting on increasing their intake, based on current levels. Roads are often queueing, and the A1 is often queued back to Baldock Road, and at a standstill when you actually reach it.

I am born and bred in Letchworth, and would hate to see an already strained town, put under even more stress. I feel these dwellings would destroy Letchworth as it is now, and was planned to be.

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

I have reviewed and considered the NHDC Local Plan for East of Luton in depth. I have listened to arguments, both for and against, and have tried to keep an open mind, even though I am a member of the Cockernhoe community. I have not just automatically sided with the against side.

I have three daughters, the eldest of which is 22 years old, and the current lack of affordable homes is very problematic for us as a family.

I, from first-hand experience, recognise the need for my daughters to be able to purchase, let alone rent their own homes is paramount and for this to be achieved new homes do need to be built, however, not in the case where the impact is so negative the positives are far outweighed.

The NHDC Local plan, makes too many assumptions and the transport assessments were not robust. I noticed one was started at the start of the school holiday and finished the day before school restarted. I would like to think that this is an honest error, however, I do have to wonder.

The letter below summarises my objection, however, as it is a well written letter, it was not done by myself and will no doubt be sent by others. I just wanted to add my personal thought process as to why I strongly object and I will have to place my faith into the hands of the independent inspector whom I hope will also see the logical decision is to reject the NHDC Local Plan 2011-2031.

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.

See attachment

See attached

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See attachment

Thank you for your letter dated 17th October 2016, regarding the proposed Submission Local Plan consultation.

Broadly speaking, I am a supporter of the LPA's aspiration to adopt a new Local Plan to cover the twenty year period to 2031. It can only be right that at a time when the whole nation is facing an increasingly severe housing shortage, each and every Local Authority helps towards meeting that pent-up demand.

This proposed Local Plan addresses some of the deficiencies missing from the 1996 Local Plan No. 2 with Alterations. The new Local Plan will hopefully ensure a better standard of new-build, although it remains to be seen whether such an increased building programme from 2017-2031 is actually achievable. But, unquestionably, having a Local Plan in place is the single biggest key step, going forward.

However, whilst we would not wish to see any further delays, nevertheless, I consider the current Submission Draft has two serious shortcomings.

Firstly; ever since the 1986 Plan was first adopted, the North Hertfordshire District already has too much Green Belt, covering approximately 38% of the entire District. You will recall the primary purpose of the 1986 Local Plan:- Green Belt was principally designated in order to constrain expansion of Stevenage eastwards and Luton westwards. In addition, Green Belt was also established around the principal towns of Hitchin, Letchworth and Baldock. The fact that some of that original Green Belt now needs to be reviewed is primarily in order to provide housing in the most sustainable locations on the side of Baldock, Letchworth, Hitchin and Luton. Ironically, now to be located in four out of the five places most considered, back in 1986, to be highly sensitive, and where any new housing development was to be resisted.
The courageous decision to review the current Green Belt boundaries by removing approximately 750 hectares of land from the Green Belt is, as your recent reports to Full Council and Cabinet suggests, the "least worst" option, but vital if new house building, sufficient to meet Objectively Assessed Needs is to be anywhere near achieved. But, the past mistakes from 1986, now resulting in the necessity to review the current Green Belt, should not, to my mind, be compounded by the pointless "creation" of a further 4,700 hectares of new Green Belt; which would only appear to be for reasons of pure political presentation/expediency.

Historically, one of the great problems following the piecemeal creation of Green Belt by various local authorities has in the past, been its great overuse. Thoughtlessly, unscientifically and in some cases simply for NIMBY reasons, far too much land has been included in the Green Belt; only now can we really understand, in some cases, to the detriment to some of our communities.


For these reasons, I strongly object to the creation of a further 4,700 hectares of Green Belt. It is I believe, completely unnecessary, largely proposed for a location, most of which would not ever be considered sustainable to build on, would achieve none of the listed purposes at paragraph 80 of the NPPF, and would be entirely contrary to paragraph 82 of the NPPF. Furthermore, if the proposal to remove land immediately to the West of Stevenage from the existing Green Belt is implemented, countryside which will clearly in future be under some threat from new development, simply replacing 4700 hectares of alternative countryside with a quite pointless "infill" of Green Belt is absolutely not the answer.

My second area of concern about the shortcomings of the proposed Submission Draft concerns the lack of provision for self-build. Previously, the Coalition Government took firm action to support and encourage individuals and communities who want to build their own homes. Those who choose to build their own "Custom Homes" often build cheaper, greener, more affordable and more innovatively designed homes than those available on the standard/market housing. The Coalition Government had introduced its "Custom-Build Homes Programme", which was announced as part of The Laying the Foundations: a Housing Strategy for England (published in November 2011), to support and encourage more individuals and communities to build their own homes. The overall aim of the Coalition Government's programme was to double the size of the sector over a decade and make self-build housing a main-stream housing option. It remains government policy to help increase supply, promote economic growth and sustain local jobs. The Coalition's aim was to increase the number of new self-build homes from the 8% nationally of today, to 16% of the new-build total by 2022.


Nationally, interest in self-build continues to grow following the adoption of The Housing and Planning Act 2016, which included at Chapter 2, an entire new section on Self-Build and Custom- house building. In contrast, NHDC's proposed Draft Submission Local Plan is almost silent, whilst suggesting only a derisory 100 self-build homes throughout the period 2011-2031.
Whereas, even taking just the lower-end 8% nationally, this should translate into more than 1100 self-build or custom-build homes by 2031. In fact, North Herts is beautifully suited to the aspirations of local self-builders. Across the four towns and forty other smaller communities, there are widespread opportunities in and around many of our settlements for individual high-quality small-scale homes for local residents. But I'm afraid that without new intelligent policies and support from North Herts Council, many will potentially miss out on these small-scale opportunities, otherwise overlooked by the big builders in their rush to develop large urban extensions.

I hope it is not too late to correct these two deficiencies in the Proposed Submission Draft, and that the Inspector will encourage some further changes/improvements at the Inquiry stage. I would welcome the opportunity to address the Inspector during the Examination in Public. Other than that, I wish you every success, and my support for the overall thrust of establishing a much improved Local Plan as soon as possible.

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I would like to protest most strongly, on behalf of the members of this Society, about the possibility of massive and disproportionate housing development at Baldock. The following remarks refer to site references BA1, BA2, BA3 and BA4.
1. Historic Environment (HE) & Countryside and Green Belt (CGB):
As a History society the first matter we wish to draw your attention to is the effect any large increase in housing would have on the historic character and culture of Baldock and its setting within the countryside. This historic value of the town has been noted over the years by various authorities and I summarise them below for your information:
* Sir Patrick Abercrombie's Greater London Plan of 1944 considered Baldock to be
compactly developed with little discordant building and with a pleasing
relationship with the countryside, especially towards the north. In other words an
unspoilt, small country town. The report concluded that the town was "not
topographically suited for any appreciable expansion".
* In 1974 the Department of the Environment assessed the Baldock Conservation
Area as being of Outstanding Historic Interest.
* In 1977 NHDC and HCC jointly published the Baldock Town Scheme which
stated that "Baldock is one of five Hertfordshire towns listed by the Council for
British Archaeology as being of National Importance".
* Today the town has over 100 listed buildings in the town centre, equivalent, pro
rata, to an historic centre like Ely. It has one of the finest medieval churches in
Hertfordshire and the relationship of the church with the town clustered around in
its attractive valley setting is an important part of its charm.
Over the years neither BUDC nor NHDC have taken notice of these views or taken much care of the historic townscape and the rural setting which is so vital to it. The town has doubled in population since 1945 but nevertheless has managed to retain some of its rural charm and small-town feel because to the north and north-east there has been little development and because the countryside still reaches into the town from the south-east.
Yet these are precisely the areas that the Council have listed for development.
The Council planners appear to have completely ignored the requirement of the National Planning Policy Framework which requires that councils must "recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance."
Likewise they have ignored the Government's intention that the Green Belt (which, like all the countryside, must surely also be considered a 'heritage asset') should be
preserved. Instead the only discernable planning issue that appears to have been taken into account is availability and political expediency, that is to say, 'let us dump these houses on the smallest town with the smallest vote'. As Sir Oliver Heald, MP, has pointed out, Green Belt land is supposed to be protected wherever possible yet, even though most of the District is not Green Belt, the Council have allocated the bulk of the housing on Green Belt land.
It seems from their Local Plan documents that the Council considers that its
responsibility for the heritage aspect of the towns in its care extends only as far as the boundaries of their conservation areas (this is despite the requirement of the NPPF that there should be 'conservation and enhancement of the natural and historic environment including landscapes' clearly implying that the two are one and the same, and that the setting of one in the other is important.) The Council's Plan is indifferent to this and the likely consequence, as far as Baldock is concerned, can be seen elsewhere all over the country in, what English Heritage calls, 'heritage ghettos': isolated islands of old buildings along a street frontage surrounded by unsympathetic and inappropriate urban development and infilling. Baldock's heritage character is that of a small country town in its country setting and that is the 'heritage asset' that should be preserved and not simply a selection of old buildings.
2. The economic effect on the town (ETC):
To a great extent, the economy of Baldock town centre, such as it is, relies on its
attractive character to draw people into the town. However, if there is to be any
significant return to a prosperous town centre it will need to attract more tourists and visitors from outside the town because the experience of the last 30 years has
demonstrated that population growth does not bring noticeable extra trade to the town centre. The town has only one real asset to attract that further trade and that is its historic character, because it has little else to offer a visitor. Without that asset there is little hope of a recovery. The Plan says that the survival of tourism "depends upon conserving and maintaining the quality of the resources upon which it depends" (ETC5) yet in Baldock the housing proposals threaten to destroy that very quality of attractiveness that is its only relistic hope.
In fact there are signs of prosperity returning to the town centre for the first time in
decades and visitors are being attracted to the town because of its character. The recent improvements to the town centre seem to have played a part in this and, with the new Arts and Heritage Centre project, there are grounds for hope that things may improve further, but it is a tenuous hope and could easily be destroyed by massive, unsympathetic development.
I should also point out that these considerations do not apply, to anything like the same degree, to the other towns in the district which are already of such a size that a few thousand extra houses would make little difference to them. The proposals are more akin to hugely increasing in size an historic village like Ashwell. It will be noted that Council would not countenance such an increase at Ashwell and yet almost precisely the same arguments apply to Baldock as they do to Ashwell.
Natural environment (NE):
Apart from the aesthetic damage to the landscape these proposals will bring and the loss of valuable farmland (which ought to be considered vital for our food security) we are concerned about the potential damage to the River Ivel. It is noticeable that the Ivel, which is an important and rare chalk-stream habitat, as well as an important local amenity, has run dry on several occasions in recent years and there is the possibility of doing irreversible damage to the river, its flora and fauna and environment, if the local water table or the capacity of the sewerage treatment works is overwhelmed by such a large increase of housing. This is not a concern that is really dealt with in the Plan except in vague terms.
There is also the related question as to whether local ground water sources can adequately supply the river and a development of this size with water especially in time of drought.
A great deal of money was spent on carefully landscaping the A505 Bypass to minimise its environmental impact on the lower end of what is surely one of the prettiest valleys in the District with its picturesque views of the town from the hills at its head. This would be so much money - ratepayers' money - wasted if the 'trapped land' is to be developed in BA2, and BA3.
Infrastructure delivery (ID):
Baldock's road network is already under strain despite having two bypasses. For large parts of the day there is congestion in the historic town centre which cannot be relieved because it is caused largely by local traffic. The Council acknowledges that this already causes significant pollution in the Whitehorse Street and Hitchin Street areas which nearly exceeds national guidelines and yet despite claiming that your policy 'addresses the protection of the health of the residents' it will, in fact, make it worse.. A massive increase in housing would exacerbate these problems and, because so much of the traffic is local with local destinations, they are unlikely to be solved by the proposed relief road to the eastern A505 junction in area BA1. If the present town is still congested after the construction of two bypasses then a town 40% larger is not going to be relieved by a third bypass heading in the wrong direction. Wrong, that is, because most of the traffic through the town centre seems to be going to or from Letchworth with school runs also causing extra difficulties at certain times of the day. No one would use this proposed relief road to go to Letchworth, or the supermarkets, or the schools, because of the length of the
diversion and the likelihood of traffic jams on Letchworth Gate.
Area BA1 is a particular cause of concern here because its sheer scale is likely to cause severe congestion at the Whitehorse Street/Clothall Road/Station Road/Royston Road junction which will also have to cope with added traffic from BA2, BA3 and BA4.
Pedestrian access to the town from BA1 would also be severely limited by the
dangerously narrow pavements under the railway bridge and it is hard to imagine that parents would be happy for younger children to use it. This would add to the likelihood of BA1 being cut off from the town and increasing congestion on the school run.
The proposals for BA2, BA3 and BA4, as well as increasing traffic volume at the
abovesaid junction would mostly add to the existing problems in South Road, a
residential road that is already being used as a 'rat run' and is too narrow to deal with greater volumes of traffic The Preferred Options Plan appears not to have investigated the feasibility of the third bypass/relief road for BA1, either as a realistic means of relieving the congestion in the town centre or for its economic viability. In effect the railway holds a ransom strip and may use it to extract a sizeable sum. There is also the cost of building a bridge over the railway. Who would pay these costs? Is it the developer or the Council? If the latter why
should we be throwing ratepayers money at, what the NHDC's own planning portfolio
holder considers, a 'flawed plan'?
The proposed increase is proportionately so large and so rapid that it is going to put
severe strain on schools, medical services, surgeries, water supply and the railway system none of which are likely to be adequately catered for and some of which are beyond the control of the Council but nevertheless need to be considered. It will therefore cause significant problems and severely impact on the quality of life of the residents of this town and neighbouring villages.
As Baldock's treated sewerage flows into the Ivel it is vital that the treatment system is able to cope with a 75% increase in volume and be in place before a problem occurs. Has the cost of this been assessed and, again, who is to pay for the consequent costs?
NHDC's Vision and Objectives for Baldock:
It would seem that there is no discernable vision or viable plan for the future of Baldock beyond dumping the bulk of the District's housing problem here. There is no indication that there will ever be an ultimate capping of population/housing or any alternative to further urban sprawl, just a rush to solve an immediate problem.
There seems to have been no attempt to find alternative sites for housing in order to
spread the distribution more fairly. In particular there is no indication that Herts County Council has been approached about any of its other considerable landholdings within the District. There is a sizeable holding north of Ickleford, for example, on a very unremarkable, flat piece of countryside (unlike the attractive countryside around Baldock); it is convenient to Arlesey Station on the mainline which would be far better able to cope with increased traffic than the Cambridge branch line and it is on the main Hitchin to Bedford road with consequent employment opportunities in those towns, yet it has not been considered.
Baldock, on the other hand, has few employment opportunities, except those offered on the Letchworth Industrial Area, and this fact will be another cause of increased traffic through the town.
The consequence of dumping far more houses than the town needs, or that local
employers require, is that Baldock will become largely a dormitory town with a
consequent detrimental effect on its sense of community and its economy.
All three of our MPs consider the plan flawed, inadequate and unfair; even the NHDC
Planning Portfolio holder apparently agrees. If so, how can it be acceptable to proceed with a flawed plan?
Most people would surely agree that to meet the District's quota each town and village should accommodate its own housing needs and those of the employers and industries within those communities. It is against all natural justice and fairness that the quota should be allocated largely to one town simply because the land has been made available and because it is the smallest town with the least votes and power to oppose it.
This Local Plan threatens to destroy the identity of the last remaining small rural market town in your District and the equally precious sense of community that makes it such a pleasant place to live.

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I want to participate in the Examination Stages for NHDC Local Plan 2011-2030, and wish to change parts of the plan.

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National policy on Green Belts not adhered to. Does not meet exceptional circumstances.
The vast majority of proposed new dwelling are in current Green Belt. (60% proposed dwellings within green belt despite the fact 2/3 of district land is outside green belt).

One of the five purposes of Green Belts as stated in the National Planning policy framework is "To assist in urban regeneration by encouraging the recycling of derelict and other urban land". The NHDC Green belt review part 1 recognises this in "Assessment against Green belt principles" (paragraph 32 and table 2) However this criteria is not included in Table 5: Assessment of Existing Green Belt. The purpose of the proposed removal of Green Belt to the east of Luton (in Sector 2 EL1 EL2 & EL3) is to meet the wider needs of the Luton housing market area. The destruction of the Green Belt to allow the development of 2100 new sites will effectively result in Luton extending into rural Hertfordshire. This significant number of sites will logically have an effect on the will to and cost effectiveness of recycling derelict and other urban land in Luton. Since urban regeneration is one of the five purposes of a Green Belt I feel this factor should have been included before the report recommended the significant destruction of Green Belt to the east of Luton. I could find no evidence of this having been done in any of the documentation. The assertion in the Green Belt review that "the fifth purpose has not been considered as the other four purposes are all deemed to contribute to urban regeneration" does not really hold water when considering destroying a significant portion of green belt which is currently constraining the spread of urban Luton to the east. The stated purpose of destroying the Green Belt to allow development to the east of Luton is to address housing needs of Luton not NHDC so there should be documentation of the effects this development will have on urban regeneration in Luton.
The green belt review is flawed. Luton is not included as a historic town.
The plan is contrary to national policy to prevent urban sprawl. The plan is not in line with Luton Borough council's statements on importance of Green Belt.

For these reasons I object to the Green Belt review and therefore Policy SP5 which references it.

The creation of vast new areas of Green Belt between Hitchin/Stevenage and Luton will make it increasingly difficult to provide for any future housing need.
The current Green Belts are stopping the current urban areas from spreading. If they are allowed to do so and all the land between them is made new Green Belt then the next time there is a need to provide more housing the only option will be to (again) allow the expansion of these settlements by destroying more Green Belt.
A genuinely plan led solution may see benefit in retaining current Green Belts. This would encourage Urban regeneration (of which there is a lot of land to redevelop in Luton). Further need could be provided by expanding current settlements outside of the Green Belt or creating new settlements such as a new Garden City.

NHDC have not demonstrated the exceptional circumstances required to justify destroying the Green Belt east of Luton.
NHDC in 4.221 reference Sir Michael Heseltines "leave no stone unturned" quote as justification (point 69). The report in question relates to growth and I could find no reference to it justifying destroying Green Belt. I did however find the following quote from Sir Michael Heseltine "It does indeed seem ridiculous that we should be scrabbling around for land in the South East - even contemplating the destruction of the green belt - when such a large and strategically-located area is in such obvious need of regeneration."

The assumptions made in the Draft Sustainability appraisal seem very biased and potentially flawed. In Table 4 What would happen without the plan? to sum up most of what could happen without a local plan "national policy might protect you but we might be able to do things better with a local plan". OK - now where's the table listing what could happen with the proposed local plan? (you're village / hamlet is subsumed into a neighbouring councils town and all the buses taking pupils to school miles away are increasing traffic and CO2 emissions). That outcome is a lot more likely than half the possibilities mentioned in the report. The sustainability appraisal is one long extremely biased piece of scaremongering propaganda and a document so lacking in facts or balanced predictions has no place being included in this process. I object to policy SP1 and the sustainability report.

3,590 new homes have been proposed for Baldock. This will increase the size of the town by 80%. It is unfair that Baldock should be expected to take such a large number of dwellings. Baldock is a small historic coaching town. All character of the town will be lost with such a massive expansion. Why has the number of required dwellings not been equally shared throughout the district? The building of such a large number of dwellings in this small rural town has not been properly thought through. This is not democratic or sound.
Green Belt
The proposed sites of BA1, BA2, BA3, BA4 and BA10 are all on Green Belt land and therefore should not be developed unless there are "exceptional circumstances". I have been unable to find 'exceptional circumstances' in the Local Plan which justify the removal of land from the Green Belt. For this reason I consider that the Local Plan is not sound as it is not consistent with National Policy.
Grade 2 Agricultural land - BA1, BA3
This is Grade 2 Agricultural land. If this valuable land is used for dwellings the opportunity to use this as Agricultural land in the future will be gone forever. We cannot continue to build on land as agricultural land is needed to feed the expanding population. The more land we lose the greater the food miles and pollution.

Separate town
The proposed development of 2,800 dwellings at BA1 (Blackhorse farm site) would create a separate town from Baldock. This has already proved a problem for Baldock with the building of the Clothall Common estate, which has never been seen by the original Baldock town community as being part of the town and there was much opposition to its building. Such a large development just increases the urban sprawl from Hitchin and Letchworth. One of the functions in designating land as Green Belt is to check the unrestricted sprawl of built up areas. The Local Plan is therefore unsound as it is not consistent with national policy.
Review of Green Belt
Does Baldock need this number of houses for our families and future generations? Are we instead building to accommodate people from other areas?
The plan states that it is not possible to accommodate all the identified housing and employment needs in sustainable locations outside of the Green Belt. Therefore as a result of these exceptional circumstances a review of the Green Belt has taken place. However the National Planning Policy Framework states that Green Belt boundaries should only be adjusted in exceptional circumstances through the Local Plan process and with the support of local people "the demand for housing alone will not change Green Belt boundaries".
The Local Plan is not therefore consistent with national policy.
One of the key functions of Green Belt is to assist in safeguarding the countryside from encroachment. By rolling back the Green Belt to accommodate dwellings NHDC is actively encroaching on the countryside and more importantly in some places on Grade 2 agricultural land.
Historic Environment
Another function of Green Belt is to check unrestricted urban sprawl. However the over development of Baldock is actually adding to the urban sprawl from Hitchin to Letchworth to Baldock. Baldock is a small historic town with links to the Romans and as far back as the Iron Age. A large Roman settlement has been discovered here. Being an historic coaching town with many old buildings and having a special character, Baldock is a tourist attraction. One of the functions of Green Belt is to preserve the setting and special character of historic towns but this is now threatened by the proposed over development of Baldock and resulting increased population, traffic congestion, insufficient parking and possible increase in pollution.
Use of urban land
A function of the designation of Green Belt is to assist in urban regeneration by encouraging the recycling of derelict and other urban land. There appears to be very little urban land included in the plan. Why is this?
I consider that development in the area of BA1, BA2, BA3, BA4 and BA10 would be inappropriate development in the Green Belt. The Local Plan is not sound in respect to the way in which it has considered Green Belt.
Transport
Baldock is a historic town with in places narrow streets and listed buildings. Roads in the centre of the town are already congested at peak times and have little scope for alteration to take the increase in traffic that 3,590 homes will bring. The junction of Whitehorse Street, Royston Road and Clothall Road is a busy junction. Listed buildings on both sides of the road have been damaged; one building is in a particularly vulnerable position when large HGV's are turning from Station Road into Royston Road.
The Sustainability Appraisal Framework notes "avoid exacerbating local traffic congestion". However, due to the existing congestion, with the additional vehicles provided by 3,950 homes congestion will be greatly increased.
To divert traffic away from this junction a bridge over the railway and a new link road has been proposed through site BA1. It is presumed that this will take a significant amount of traffic as it will avoid the Whitehorse Street, Royston Road, Clothall Road junction. However running through a residential development carrying HGV's as well as cars, with the associated problems of noise and air pollution, this road will have a considerable impact on the surrounding environment. I was unable to find any plans or Transport Statement in the Local Plan on which to comment. It seems unfair that I cannot make proper comment on this road as part of the Consultation, when this road and railway crossing will have such a major effect on the future residents of BA1 as well as the residents of Bygrave.
Transport - air pollution
Baldock is situated in a valley. Concentrations of pollutants can be greater in valleys than for areas of open or higher ground. Since the building of the Baldock bypass air quality which was previously a problem has been reported to have improved. However with the additional cars, often 2 per household and service vehicles that the 3,590 houses will bring there is concern that the level of air pollution will rise again.
Transport BA3
Some of the houses in the area BA3 will be built along the edge of the bypass. The Local Plan states that there will be:
Appropriate mitigation measures for noise associated with the A505 to include insulation and orientation of living spaces.
However noise will remain an issue when windows are open or residents are using their gardens. Air quality in this area also needs to be given consideration.
Access to the station from BA1, BA3
Due to the distance from the station residents living in BA1 and BA3 may use their cars to travel to the station. Additional cars will increase carbon emissions and congestion at peak times and further increase the parking difficulties. Is this sustainable?
Southern link road
The Local Plan states that site BA3 will deliver, in combination with site BA4, a southern link road connecting Wallington Road to the B656 Royston Road.
It is not clear from the Local Plan whether any traffic studies have been carried out to consider the effect of building this road. I was unable to find a plan showing the route of the proposed road or a Transport Statement and it is therefore difficult to be able to make comment on the proposed road. This seems to be an unfair situation, when the proposed road will have considerable impact on the residents of BA3 as well as the existing residents of Clothall Common, most of whom will not be aware of this proposal.
My concern is that the proposed road will:
1. Create a "short cut" for vehicles wishing to avoid the junction of Whitehorse Street, Royston Road and Clothall Road. Traffic, including HGV's, wishing to move between the south of the town and the Royston Road, or gain access to the Buntingford Road will have a quicker route through the area of proposed new housing.
2. Air quality may be affected and noise pollution created, if a significant number of vehicles use the proposed road
3. Increased traffic will be a hazard to residents of Clothall Common as well as to those living in BA3
4. The amount of traffic waiting to enter the roundabout where the Wallington Road joins the Buntingford Road is likely to increase
Slip road from A505 to the Buntingford Road
If the new southern link road is created, building a slip road from the A505 by pass to provide access to the Buntingford Road, would reduce the traffic flow through BA3 and Clothall Common.
Infrastructure
Such large developments as proposed for Baldock requires appropriate infrastructure. However we have only one GP surgery, A & E at the Lister Hospital is frequently full to capacity with long waiting times. Our community Police Station has been closed and the land converted to dwellings. Our library hours have been reduced. We have no Public Toilets. Frequently there is little parking in the town.

Despite the building of the new bypass a great deal of traffic goes through the town. This includes many large lorries travelling between the A1M and the bypass. These have to negotiate the low railway bridge and occasionally become stuck under it.

What studies have been carried out to assess the potential effect that an additional 7,180 cars might have on the town and the surrounding roads? This is assuming 3,590 new dwellings with a minimum of 2 people per household each with a car. I was unable to find this information in the documents provided for Consultation.

BA10 employment sites
Baldock is a small town. Employment opportunities are limited. Due to the railway and position near the A1M many people living in the town commute to other areas for employment.

Employment sites are to be extended at BA10 to provide jobs for occupants of the new dwellings. However there is no guarantee that these jobs will not be taken by people from out of the area. The additional vehicles used by potential employees to access the site, together with delivery vehicles, will further add to the congestion on the existing roads around the town and pollution.

A reasonable alternative would be to locate new dwellings near to areas with higher employment opportunities, such as the West of Stevenage. This would be in line with National Planning Policy Framework which states that "plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised".

Ivel Nature Reserve
The River Ivel and its Springs are a Chalk river. These are rare with about 200 globally. We therefore have a duty to take care of our river and springs. Has the effect on the river and springs of building so many dwellings on nearby land (BA1) been assessed? Any development should not have a negative effect on the river or the wildlife in this area. All Green Belt sites will result in loss of habitat. This is of particular concern for the hedgehog, which is already endangered and red listed arable farmland birds which are present on site BA1
Master plan for BA2/BA3 / BA4/ BA5
A site master plan is to be provided for BA1 as this "will be substantial new community". However with a proposal for 500 houses to be built between sites BA2/BA3/BA4/BA5 a site master plan should also be provided for these areas as together they will also be a substantial development that will have a significant impact on the local road network.

Plan with vision and imagination
North Hertfordshire is the home of the first Garden City. This was planned in 1904 with vision and imagination. Town planning should have moved on from this to provide an even better vision for future housing and yet in Baldock we have a proposal for 3,590 new homes, which will increase the size of Baldock by 80%. There seems to be no clear vision for transport, infrastructure, and the creation of a desirable place to live.
The number of houses proposed should be appropriate for the size of the town, not create a separate town as in the case of the development at BA1. The required number of houses could be built by constructing an appropriate number in Baldock and with the cooperation of South Cambridgeshire District Council, give consideration to building a new town at a site such as Odsey which already has a railway station but no obvious constraints for future development.
General comments
In view of the large scale of development proposed by NHDC in Baldock I have been disappointed that there has been no public exhibition in the town about the consultation detailing the proposals. Documents were provided for viewing in the local library but there was no large signage to indicate to people entering the library that the documents were there.
Making comment on the Local Plan is a complicated process and thank fully we have had the support of the SaveRural Baldock campaign to guide people through this.
NHDC changed their website on the final day that comments were to be submitted, which did not assist the process for those still needing to submit their comments.