Policy SP8: Housing

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
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. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) 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. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at 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 7000 vehicles from Baldock would add to this congestion causing North Herts to become 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 modeling, 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.
There are severe 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 points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is 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.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as 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 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 to have 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; 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 normally 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.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive 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.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when 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.
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 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. 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.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. 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, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive 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.

NE1 Landscape
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 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 to have 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; 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 normally 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.

NE8 Sustainable drainage systems
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.

NE9 Water Quality and environment
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 at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
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 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 Baldock..

See attachment

See attached

See attachment

See attachment

Policy SP5 Countryside and the Green Belt
Policy SPG15 Site LG1 North of Letchworth Garden City
Paragraph 13.215 LG3 Land East of Kristiansand Way and Talbot Way
Where a large areas of existing Metropolitan Green Belt North and East of Letchworth has been re-designated as residential development land and proposals for the use of these sites (LG1 and LG3) for housing development.
These policies are not Legally Compliant as the Sustainability Assessment does not form a suitable assessment of the sustainability of the council's proposals. The SA does not consider the undesignated heritage asset status of the Green Belt which was an integral part of the design of Letchworth, and the first designed Green Belt in England. The Green Belt is an important factor in the setting of the Heritage Asset which is the town of Letchworth.
These policies are not Sound as:
a) They are not positively prepared as they are not consistent with achieving sustainable development as set out in NPPF. 7 pg 2
"There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:"

"an environmental role- contributing to protecting and enhancing our natural, built and historic environment;......"
They are not justified or consistent with national policy as they do not comply with the following sections of NPPF:
a) 9 Protecting Green Belt Land
79 The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. The essential characteristics of Green Belts are their openness and their permanence.
80 The Green Belt serves five purposes:
to check the unrestricted sprawl of large built up areas
to prevent neighbouring towns merging into one another
to assist in safeguarding the countryside from encroachment
to preserve the setting and special character of historic towns
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
The proposals in SP5, SP15 and para 13.215, to re-designate the Green Belt land north of Letchworth, do not recognise or conform to all of the above five purposes.
83"...Once established Green Belt boundaries should only be altered in exceptional circumstances..."
MP Brandon Lewis confirmed in his letter to Boris Johnson of January 2015, that the need to meet Housing Targets did not constitute exceptional circumstances.
"NPPF is clear that Green Belt should be given the highest protection in the planning system and is an environmental constraint which may impact on the ability of authorities to meet their housing need. This Department published guidance on 6 October 2014 which re-affirms that Green Belt boundaries should only be altered in exceptional cases, through the preparation or review of the Local Plan. The guidance also states that the housing need alone does not justify the harm done to Green Belt by inappropriate development when drawing up a Local Plan."
The exceptional circumstances have not been demonstrated and reasonable alternatives to the use of sites LG1 and LG3 have not been identified, described and evaluated before the choice was made. The sites included in the appraisal were only those which owners put forward and the Draft Sustainability Appraisal document sets out in para 5.2.1 that to be considered a site had to be available for development. No alternative sites which would not cause such harm to the significance of Letchworth and its Green Belt were sought.
b) 11 Conserving and enhancing the natural environment

109 " The planning system should contribute to and enhance the natural and local environment."
110 "...Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this framework."
The Green Belt Review Study, sets out a scoring process for the sites put forward by owners which aims to establish which sites make the most significant contribution to the Green Belt. This system is flawed in the following ways and therefore not justified or consistent with national policy:
a) It says on page 30, para 44. "Letchworth Garden City has a relatively strong relationship with the surrounding countryside, particularly to the south where there is a clearer connection to the original footprint of the town."
This statement is not justified, the "original footprint of the town" quoted is simply the first area developed, from Norton Road in the north to Baldock/Hitchin Road in the south. This was by no means the intended size of the Garden City, Howard designed it to have 32,000 residents, that number has only recently been achieved with the addition of the Grange, Jackmans, Lordship, Manor and Westbury Estates. The town's relationship with the surrounding countryside is equally as strong in the north as in the south.
The following quote from Ebenezer Howard's book, Garden Cities of Tomorrow 1902 is relevant:
"Garden City has, we will suppose, grown until it has reached 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a "Garden City"? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then as the town filled up, the agricultural land would become ripe for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately not in the hands of private individuals: it is in the hands of the people: and is to be administered not in the supposed interests of the few, but in the real interests of the whole community."
b) Page 25, Parcel 22, under heading "Preserve setting and special character of historic towns"
"Forms part of countryside between Letchworth and Stotfold in Beds. Performs a more limited function due to landform resulting in limited views of any historic towns".
This analysis is far too simple, the historic town of Letchworth, the world's first garden city, and its integral Green Belt is completely ignored. The built up boundaries of Letchworth are clearly visible and its surviving Green Belt still performs its original design function to allow residents access to the countryside and for the grade 2 agricultural land to be farmed, and to provide the countryside setting for the Garden City as envisaged by Howard.

c) Page 117 section 5.3. Assessment of Potential Development Sites Land East of Talbot Way, and Land North of Croft Lane.
These sites adjoin Norton Conservation Area and Norton should be assessed as a village whose built boundaries should not be extended (in the same way that Willian the village to the South of the town, has been assessed). The statement in the Local Plan 2011-2031 page 181 para 13.209, that Willian has not been absorbed into the Garden City whilst Norton has, is not correct, Norton retains 3 sides of the village in contact with the countryside and it is only the houses on the East side of Norton Road which link it to the Garden City. Willian has a similar link along Willian Road from Letchworth Gate.
d) Page 118 North Letchworth
We do not consider the assessment to be accurate, this potential development site has 3 sides (North, East and West) which do not have development adjacent, if this had been used for analysis, rather than how many sides have development adjacent, then this site would have scored more highly. The wildly different shape of sites means that this method of assessment is not accurate.
There is no mention in the NHDC Local Plan or any background documents, of the proposed 22.5 hectares of residential sites to the East of Hitchin Road, in Central Beds Draft Local Plan, (work has already started on some of the houses). These proposals will bring the proposed development of North Letchworth closer than 500m to this Central Beds development, which as an extension of the Fairfield development will almost link Letchworth and Fairfield. The effect on the Green Belt has not been taken into account and this should result in a higher score under Towns Merging heading. The proposed development would also reduce the Green Belt between Letchworth and Stotfold to 500m in places. It is evident that the development of this North Letchworth site would result in the unrestricted sprawl that Green Belt designation is designed to prevent. The issue of co-operation on strategic and cross-boundary issues is relevant here.
Under the heading of "Preserve setting of historic town" this analysis says "site not within or affecting setting of a conservation area of a historic town". This is not a correct assessment of the importance of Letchworth's Green Belt as an integral part of the town's design and an important factor in its setting. The significance of the historic town of Letchworth, the world's first Garden City, would be seriously harmed by the loss of this area of Green Belt. A higher score should have been given here.
There is no Heritage Assessment Document for Letchworth prepared as part of the Background Papers, although Baldock Hitchin etc. have such assessments. A well informed Heritage Assessment for Letchworth would have identified the special historic character and significance of the World's First Garden City and its Green Belt, the first designed Green Belt in England.

Whilst Letchworth has its designated heritage assets in the form of listed buildings and Conservation Areas, it is also of local heritage importance in its entirety, as designed, with its Green Belt. This has not been considered in this Local Plan exercise.

Policy SP17 Site HT1 Highover Farm Hitchin
This policy is not Sound as it is not consistent with national policy.
NPPF says that green belt should only be altered in exceptional circumstances. Here the green belt between Hitchin and Letchworth will be reduced to 500m if this development goes ahead. No exceptional circumstances have been demonstrated.
The development will result in the unrestricted sprawl that the green belt is designed to prevent.

The modifications we would like to see are the removal of LG1, LG3 and HT1 from the list of proposed development sites and an exercise to identify sites to provide the housing needed in locations which do not harm the significance of Letchworth Garden City and its Green Belt.

We would like to participate at the oral part of the examination.

See attached

See attached

See attachment

See attachment

See attached

See attached

See attached

See attached

See attachment

See attached

See attached

See attached

See attached

See attachment