Policy SP8: Housing

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

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

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

A number of additional sites were added to the plan in response to an increase of the OAN to 14400. However in the submission plan the OAN has been reduced to 13800, however the new sites have been retained resulting in a vastly excessive oversubscription buffer zone of 7%. This renders the plan unsound and not legally compliant

See attachment

Baldock - Sites BA2, BA3, BA4 & BA5:

There appears to be insufficient linked up planning in relation to the proposed sites for development other than BA1 (i.e. BA2, BA3, BA4 and BA5) in Baldock which could account for an additional 520 houses all located around Clothall Common in Baldock. The 2011 Census has 4491 dwellings within the town, when combined these four developments constitute an expansion of 11.5% on the figures at that time. It has to be expected that these sites will bring additional pressure on the current roads, rail links, schools, doctors surgery and other amenities such as the community centre, library and town centre parking. However as the local plan splits these sites into separate smaller developments there is no mention of providing additional school/doctor services to cater for the additional demand this will bring to local infrastructure and amenities.

The introduction to the local plan states that "Strategic Housing Sites (defined as sites of 500 or more
homes) which will make a substantial contribution towards housing requirements over the plan period." As such the plan must combine BA2, BA3, BA4 and BA5 into one larger development and as treat it as a separate Strategic Housing Site.

As a grandmother to have homes for grandchildren, good, but to have a New Town which maybe larger than Baldock SP14 and adjacent to it will destroy this ancient market town by sheer numbers of people shopping at the non-existent shopping centre created when Tesco moved in here.

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

ConnectedCities believes that effective strategic planning requires a longer time period to be considered, so prevision for new settlements can be included. It considers that every area should have to plan for its pro-rata share of the projected population growth until 2051. Such a timescale enables preparation for the necessary land and infrastructure and to be addressed

ConnectedCities proposes that local authorities work together to consider the growth of a larger unit called a ConnectedCity, which is a voluntary federation of towns combining to plan. See http://www.connectedcities.co.uk/vision-2050/idea

Strategic choices can be compared, presented and democratically decided. See http://www.connectedcities.co.uk/case-studies/choises-for-development and http://www.connectedcities.co.uk/delivery/consultation

The current outline plan is a reaction from the council to the current admission that they have not had a 5 yr housing plan for a substantial amount of time. This has not been a strategically though out plan but an easy reaction to provide housing over a 20 yr period because of the availability of one large land parcel owned by the county council.

Baldock Sites - BA2, BA3, BA4 & BA5:

There appears to be insufficient linked up planning in relation to the proposed sites for development other than BA1 (i.e. BA2, BA3, BA4 and BA5) in Baldock which could account for an additional 520 houses all located around Clothall Common in Baldock. The 2011 Census has 4491 dwellings within the town, when combined these four developments constitute an expansion of 11.5% on the figures at that time. It has to be expected that these sites will bring additional pressure on the current roads, rail links, schools, doctors surgery and other amenities such as the community centre, library and town centre parking. However as the local plan splits these sites into separate smaller developments there is no mention of providing additional school/doctor services to cater for the additional demand this will bring to local infrastructure and amenities.

The introduction to the local plan states that "Strategic Housing Sites (defined as sites of 500 or more
homes) which will make a substantial contribution towards housing requirements over the plan period." As such the plan must combine BA2, BA3, BA4 and BA5 into one larger development and as treat it as a separate Strategic Housing Site.

The plan provides too much housing at the expense of precious countryside. North Herts is supposed to be a rural district, but it plans 14,000 houses for the district, plus 2,000 for Luton plus 3,000 for Stevenage. That makes 19,000 which is about 50% increase in 15 years. In what sense is this objective or sustainable or even common sense? We are privileged in North Herts to still have access to some beautiful countryside and landscape. Is it really good stewardship to base policy on the premise that as long as people want to come here, we should keep building over the countryside until they no longer want to? On that reasoning, it is inevitable that the London conurbation will expand to fill Hertfordshire. Is this going to continue until we reach equilibrium when everywhere in the UK, and eventually the world, becomes equally undesirable? Given the terrible wealth inequality in the world these are tough questions, but have our planners and policy makers really thought this through, and do they have a mandate for such profound decisions? Maybe now is the time to stand up and push back.

The loss of Green Belt as 6 sites have been removed including sites around Baldock which is taking the majority of the housing increasing the current size by 80%
which will effect the community as a small rural town

See attachment

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure:
Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
We are not creating a sustainable environment by compromising all of the surrounding green areas. We as ! individuals must take action.

Putteridge Bury is my local area and I would be devastated to see this area built on. From family walks, picnics and evening jogs, this place has been a big part of my life and still is. I don't believe we can educate the younger generation on how to save our planet, by removing all of our green areas and teaching them different forms of wildlife from a textbook or iPad.

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure:
Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
We are not creating a sustainable environment by compromising all of the surrounding green areas. We as ! individuals must take action.

Putteridge Bury is my local area and I would be devastated to see this area built on. From family walks, picnics and evening jogs, this place has been a big part of my life and still is. I don't believe we can educate the younger generation on how to save our planet, by removing all of our green areas and teaching them different forms of wildlife from a textbook or iPad.

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure:The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development/business park/light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
There are better locations that are brown field sites in Luton that should be developed to meet their needs.

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!). The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure: The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development / business park / light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
This will destroy the village communities of Cockernhoe, mangrove green, tea green, Darley Hall, Wandon End and Breachwood Green. Luton had already encroached far enough into the green belt and this expansion would swallow up these communities into Luton which is unacceptable.

With reference to the proposed development (ref 16/02014/1) submitted by The Crown Estate located in Hertfordshire close to the County Border near Tea Green, I should like to make the following observations based on the "soundness" criteria defined in your recent letter dated 17 October 2016. My comments equally apply to the much larger Blore Homes submission of 1500 dwellings, which abuts the Crown Estates site.


Using the tests of soundness identified in the local plan.

Positively Prepared.

Development to meet the requirements of a neighbouring authority should not be met by North Herts. It should be met by the neighbouring authority ie Luton Borough Council itself.

Justified

The proposed site is already in a congested area in terms of the volume of traffic accessing Luton from the direction of Stevenage and vice versa using the lanes adjoining the proposed development. These lanes are maintained at cost to NHDC and this development will only exacerbate the problem and associated additional costs of this increase volume of traffic. Absolutely no cost allowance, in perpetuity, has been allowed for in the proposals for this development. Although there is mention of this in your planning documents, there is no provision for the basic infrastructure needed to support this extra congestion on the plan. It is patently obvious that the vacant land in Luton, west of the M1, would mitigate much of the infrastructure required in the proposed plan as it has much easier access the existing, recently widened, M1 motorway.

Where is the provision for extra school places, retail infrastructure, medical facilities and all the other needs to support the size of this development?

Why should the council tax payers of North Herts be footing the bill for a neighbouring authority, which will continue in perpetuity?

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure: The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development/business park/light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
No way can the current roads in the Wigmore area or country lanes in the surrounding area cope with such an increase in traffic volume. Wigmore Lane is always gridlocked during peak times. There is already insufficient public transport in the area to cope with demand. Local schools in Wigmore and Ashcroft have already had major extensions to cope with increase of current pupil levels and are still at maximum capacity before any more housing developments. The Asda supermarket already struggles to cope in supporting the immediate area and surrounding villages from which people come to do their grocery shopping.

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure: The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development/business park/light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
It will damage the wildlife population and put additional strain on an infrastructure that is already struggling.

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure: The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development/business park/light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
I keep my horses in cockernhoe and ride around the area the traffic is bad enough now without any more being added if these houses are needed in Luton then build them in Luton further afield from green belt land Cockernhoe is a village and a lovely place but if more houses were to be built it would change this drastically.

North Hertfordshire Local Plan 2011-2031 -
Proposed Submission Local Plan Consultation
Wednesday 19 October 2016 to Wednesday 30 November 2016

With regards to the above planning application I wish to register my strongest possible objections to this development of 660 dwellings adjacent to Copthorne, Luton.

No proper regard seems to have been taken in respect of improving the road infrastructure. The minor alterations listed on the planning application would have little or no effect. The existing roads cannot currently cope with rush hour traffic in the mornings and evenings. Eaton Green Road, Crawley Green Road, A505, East Circular are nearly almost stationary. The road network could not possibly cope with any increase in traffic from any developments built in this area. At peak times it can take up to an hour to get to and from Junction 10 of the M1. There is also the added problem of expansion at Luton Airport which would certainly add to traffic problems.

Many local roads in the vicinity of the proposed site are narrow country lanes with single track stretches and they too would be unable to cope with the increased traffic, particularly public transport vehicles and large vans and lorries which will be required to serve the development.

I noticed on the plans that there are three proposed footpaths, cycle ways adjoining Copthorne to the new estate this will encourage people to use Copthorne as a cut through as well as a safe place to park their vehicles as it says in the plan that there is only one garage/parking per dwelling. As for the ridiculous suggestion that most people will be using cycles and walking, DREAM ON.

I noticed also that surface drainage is going to be collected in three unfenced ponds (SUDS). Government rules state that (SUDS) should not be located close to airports as they could encourage flocks of birds which could endanger aircraft with bird strikes.

I noticed from the layout of the plan that the high density/social housing have been placed closest to the County View estate which mainly consists of 3, 4 and 5 bedroomed detached properties and will most certainly not blend in with these existing properties. I understand that 40% of this development is going to be affordable housing with the possibility of flats which is totally out of character with the area.

I understand that there are no plans for schools or infrastructure upgrades until after the site has been completed. The GP surgeries in the area are over subscribed and one dental surgery is not taking on any new patients. Local schools at Cockernhoe and Wigmore are already over subscribed. The application does not indicate where the additional children will be educated.

I feel that your development, which is in Hertfordshire, should not be entitled to Luton's services and as a local rate payer I should not be subsiding Hertfordshire rate payers. It seems you are dumping all Hertfordshire's problems on the Bedfordshire rate payers. Luton Borough Council have not done any air particulate studies into air quality in our area, in spite of there being a massive airport expansion going ahead. Nor have they conducted traffic studies to address the terrible congestion in the surrounding area.

This development would destroy a large amount of North Herts Green Belt land. Government policy on Green Belt land is completely ignored in this proposal. Green Belt policy is to prevent urban sprawl.

Also, I understand that the area you are proposing to build on is under consideration to be included as an area Area of Outstanding Natural Beauty and was at one time Grade 'A' agricultural land but in your latest bulletin this is no longer the case, how convenient.

Many people from the area use the surrounding countryside for recreational purposes, walking, cycling, and taking an interest in the wildlife. The villages of Tea Green and Cockernhoe should not be allowed to be swallowed up by the town of Luton in this way.

Once again I strongly object to any of the proposed developments as this is an overwhelming number of dwellings for such a small area.

North Hertfordshire Local Plan 2011-2031 Proposed Submission Local Plan Consultation Wednesday 19 October 2016 to Wednesday 30 November 2016

With regards to the above planning application I wish to register my strongest possible objections to this development of 660 dwellings adjacent to Copthorne, Luton.

No proper regard seems to have been taken in respect of improving the road infrastructure. The minor alterations listed on the planning application would have little or no effect. The existing roads cannot currently cope with rush hour traffic in the mornings and evenings. Eaton Green Road, Crawley Green Road, A505, East Circular are nearly almost stationary. The road network could not possibly cope with any increase in traffic from any developments built in this area. At peak times it can take up to an hour to get to and from Junction 10 of the M1. There is also the added problem of expansion at Luton Airport which would certainly add to traffic problems.

Many local roads in the vicinity of the proposed site are narrow country lanes with single track stretches and they too would be unable to cope with the increased traffic, particularly public transport vehicles and large vans and lorries which will be required to serve the development.

I noticed on the plans that there are three proposed footpaths, cycle ways adjoining Copthorne to the new estate this will encourage people to use Copthorne as a cut through as well as a safe place to park their vehicles as it says in the plan that there is only one garage/parking per dwelling. As for the ridiculous suggestion that most people will be using cycles and walking, DREAM ON.

I noticed also that surface drainage is going to be collected in three unfenced ponds (SUDS). Government rules state that (SUDS) should not be located close to airports as they could encourage flocks of birds which could endanger aircraft with bird strikes.

I noticed from the layout of the plan that the high density/social housing have been placed closest to the County View estate which mainly consists of 3, 4 and 5 bedroomed detached properties and will most certainly not blend in with these existing properties. I understand that 40% of this development is going to be affordable housing with the possibility of flats which is totally out of character with the area.

I understand that there are no plans for schools or infrastructure upgrades until after the site has been completed. The GP surgeries in the area are over subscribed and one dental surgery is not taking on any new patients. Local schools at Cockernhoe and Wigmore are already over subscribed. The application does not indicate where the additional children will be educated.

I feel that your development, which is in Hertfordshire, should not be entitled to Luton's services and as a local rate payer I should not be subsiding Hertfordshire rate payers. It seems you are dumping all Hertfordshire's problems on the Bedfordshire rate payers. Luton Borough Council have not done any air particulate studies into air quality in our area, in spite of there being a massive airport expansion going ahead. Nor have they conducted traffic studies to address the terrible congestion in the surrounding area.

This development would destroy a large amount of North Herts Green Belt land. Government policy on Green Belt land is completely ignored in this proposal. Green Belt policy is to prevent urban sprawl.

Also, I understand that the area you are proposing to build on is under consideration to be included as an area Area of Outstanding Natural Beauty and was at one time Grade 'A' agricultural land but in your latest bulletin this is no longer the case, how convenient.

Many people from the area use the surrounding countryside for recreational purposes, walking, cycling, and taking an interest in the wildlife. The villages of Tea Green and Cockernhoe should not be allowed to be swallowed up by the town of Luton in this way.

Once again I strongly object to any of the proposed developments as this is an overwhelming number of dwellings for such a small area.

See attachment

See attachment

I strongly object to the outline North Hertfordshire Local Plan 2011- 2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick kiln Lane, for the following reasons: Please tick all of the issues that concern you (all if necessary!) .The 'New Neighbourhood Planning Infrastructure Bill 2016' states that it supports the Government's ambition to deliver one million new homes, whilst protecting those areas that are valued most, including the Green Belt. This area is Green Belt and the application does not meet the 'Very Special Circumstances' required to build on it as stated in paragraph 80 and 83 of the National Planning Framework and also the House of Commons briefing note on Green Belt. The Green Belt boundaries should not be amended in response to individual planning applications (The National Planning Policy Framework, Paragraph 83).

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

1.Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs , a number which hasn't been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure: Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen. Stockingstone and A505 suffer equally.

There is no planned improvement to the already stretched roads/infrastructure: The traffic Survey carried in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal, were based on a road that doesn't exist, hasn't been proposed and has been stated by the council that there is no money to develop.

There is no planned improvement to the already stretched roads/infrastructure: In the shorter term, the projected airport development / business park / light industry, will attract a further 7,000 employees (ref. LBC). The roads cannot cope with this increase in vehicles.

There is no planned improvement to the already stretched roads/infrastructure: The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat-runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin/Stevenage through Offley.

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

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

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

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

In addition to the above the reason I feel most strongly that this development should not go ahead is -
This is unsustainable and short-sighted!

I strongly object to the outline North Hertfordshire Local Plan 2011-2031 especially the sites EL1, EL2 and EL3 which affect the areas of Cockernhoe, Mangrove Green, Tea Green, Copthorne, Rochford Drive, Putteridgebury, Wandon End, Wigmore and Brick Kiln Lane, for the following reasons:-

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

There are 205 dwellings in Cockernhoe, Mangrove Green and Tea Green currently. An additional 2100 dwellings will be an increase of 1124%. This development is completely out of proportion to all other developments in the district - these villages and communities will cease to exist. Of these additional dwellings 150 are for North Herts, the remaining 1950 are to meet Luton's supposed unmet needs, a number which has not been qualified when challenged.

There is no planned improvement to the already stretched roads/infrastructure. Crawley Green Road and Eaton Green Road are backing up over 750 metres at their junctions with Airport Way during the rush hour, without the addition of a further 5,000+ vehicles. The roads through the airport are often gridlocked and with the growth of passengers at Luton Airport, currently 12.75 million (2015) with a projected increase year on year to 22 million by 2030 this is set to worsen, Stockingstone and A505 suffer equally

The traffic survey carried out in 2015 was not done to industry standards i.e. for a month and also the results of this survey showed a negligible or nil effect on local congestion when the results, and thus the underpinning of the proposal were based on a road that does not exist has not been proposed and has been stated by the Council that there is no money to develop. In the shorter term, the projected airport development/business park/light industry, will attract a further
7,000 employees (ref LBC). The roads cannot cope with this increase in vehicles.

The two country lanes with insufficient passing places which lead out of the site into North Herts are already being used as dangerous rat runs. This will increase as residents seek to access the M1 via Lilley Bottom and Lilley, and seek to access Hitchin, Stevenage and the A1 through Offley.

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

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

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

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

In addition to the above the local schools, nursery places, GP surgeries and dental practices are already oversubscribed, having to wait up to two weeks for a doctor's appointment.

Parking and infrastructure at the local shops/supermarket is woefully inadequate.

I have been a resident of North Herts for ten years and have grown to love this part of the world, having lived in London and Kent previously.
That development is needed in North Herts is axiomatic; it is clear that at this time, demand outstrips supply and ONS figures suggest that the District needs 14,400 new homes built between 2011 and 2031. North Herts District Council (NHDC) has increased this figure by 2,100, to take into account any 'unmet need' in respect of growth from neighbouring Luton, bringing the total number of new homes to be built in the period covered by the Local Plan (LP) to 16,500.
NHDC proposes that around 60% of these homes should be sited within the Green Belt, which will have dramatic effects on well-established communities in the District. The council seems to adopt a pragmatic view of this rolling up of the Green Belt, by simply designating land on more convenient sites as Green Belt. In this way NHDC can say that far from diminishing the Green Belt, they have increased it; this is rather like building a new football stadium in the middle of Dartmoor and recovering that lost moorland by designating a similar area in the centre of Exeter as National Park. It may look good on paper, but it is unlikely to fulfil its original purpose.
NHDC seem to insist on the adoption of a plan that covers the period 2011 to 2031, when legal advice commissioned by the Council has clearly stated that the minimum requirement is a five year plan, which would give time to properly plan for additional numbers. It is this insistence on a plan which covers twenty years which is at the heart of the Council's indecent haste and lack of preparation.
Two Stage Plan
The three MPs for this area, Sir Oliver Heald, Peter Lilley and Stephen McPartland have all endorsed the creation of a two stage plan, initially dealing with the first 10 years (2011 to 2021), which would look at planning for 6,050 sites. Planning permissions have already been given for over 2,600 homes; this leaves 3,450 new homes to be found district-wide before 2021. This period should be well used in identifying and planning a new 'Garden Village' development. We have an opportunity to create something worthwhile, rather than simply adopting a 'bolt on' principle to new homes within existing communities. I appreciate that this could not be included in this plan but the concept is only being included in the next planning cycle after much public opprobrium and protest, demonstrating the paucity of strategic thinking that runs through the whole plan.
Master Plans
NHDC has identified a number of significant sites, including Baldock, Letchworth and Stevenage, where infrastructure will be provided for within a 'Master Plan'.
Unfortunately no details of these plans have been made public. Public concerns about such sites have been met with assurances that concerns will be dealt with "as part of the Master Plan". My reservations concerning the efficacy of NHDC's planning were heightened when it was discovered during the previous consultation period (for the Preferred Options Plan), that Network Rail had no knowledge of the proposed settlement north of Baldock (BA1), that will mean 2,800 homes built on Green Belt land, as a bolt on to the medieval town of Baldock. It is accepted by the Planners that for the development to be viable, a bridge will have to be built over the railway for access and transport. But Network Rail hadn't even been approached at that time!
If the other Master Plans are built on such shaky foundations, I cannot see these plans becoming a reality without significant cost to the public purse. The Local Plan should include, where appropriate, full details of a viable Master Plan, which has the buy in of all stakeholders. At the moment, the Local Plan does not fulfil these criteria.
Transport Strategy
Trains. In September 2016, Govia Thameslink Railway, (GTR) issued a consultation document detailing proposed timetable changes. These changes, as originally published, would result in a significant reduction in trains stopping at Baldock Railway Station. I arranged a meeting with Jane Cobb, the Consultation Project Manager and Peter Lane, Lead Service Delivery Manager, of GTR to discuss the Baldock situation. The meeting was also attended by all the Baldock Councillors and the NHDC portfolio holder for planning and enterprise. This meeting was held on 2 November 2016.
I commenced the meeting by setting out our concerns, particularly in the context of a reduced train service when the Local Plan was intending to increase the size of Baldock by 80%; this would increase passenger flow to/from London from 330,000 journeys (GTR's own figures in the condoc) to 600,000 journeys annually. To my surprise, neither of GTR's representatives knew anything about the Local Plan and had not been included in any consultation/liaison. Both representatives acknowledged that they would now have to take this extraordinary growth into account when doing their modelling. This flies in the face of the NPPF (Promoting sustainable transport, para 31), which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development..." It indicates that this plan was conceived in isolation and that NHDC has failed in its duty to cooperate with other bodies.
Roads. There are a number of gaps in the evidence offered relating to local traffic flows and I shall highlight three of them.
Road bridge. The major development north of Baldock has at its heart, the requirement to build a road bridge over the railway to provide access; indeed the provision of "a new link road connecting the A507 London Road to the A505 Baldock bypass, including a new bridge across the railway" is one of the site specific requirements for development north of Baldock. All enquiries about the provision of infrastructure were met with the response "It will be dealt with in the Master Plan". But when the 'Preferred Options' plan was sent out for consultation (2014-15), Network Rail knew nothing about any plans to build such a bridge. This is what the Senior Planning Officer of NHDC (in charge of the plan at that time), Richard Kelly, called a "show stopper", but NHDC only engaged with Network Rail after intervention from Sir Oliver Heald MP. Again no evidence of cooperation until the plan was sent for public consultation and very little progress made in this area since.
Gridlocked crossroads. The junction in Baldock where the B656 meets the A507 is a major junction; in many respects, all roads lead to it and it is currently at capacity, with traffic jams both during and outside rush hour periods. No traffic survey has been done at this junction, which is expected to deal with a significant rise in traffic once the new development begins. To cope with such an increase in traffic, the junction must be re-engineered; however, the options for such work are severely limited. Houses on two sides of the junction are listed, the oldest having been built in 1540. This seems to have been ignored by NHDC planners. Without solving the issues around this junction, traffic in Baldock is destined to remain gridlocked for most of the day, with consequential delays for traffic throughout the area. No coherent traffic plan has been put forward at any stage for coping with a massive increase in traffic and parking issues in Baldock town centre.
Deteriorating Bus Service. The removal of the 98 bus service between Baldock, Letchworth & Hitchin and the 391 service to Stevenage has resulted in a significant deterioration of quality of life, particularly for older people in the town of Baldock. There is, of course, no Sunday bus service. The impact of this hits the most vulnerable of our society; the Local Plan's Transport policy focusses almost entirely on private vehicular transport with the barest of nods to the needs of bus users and there is no evidence that NHDC has not failed in its duty to cooperate with transport providers for the provision of viable infrastructure necessary to support sustainable development.
Environmental Matters
The effect of traffic on air quality in Baldock. A Baldock GP recorded his concern some 20 years ago (before the Baldock bypass relief road was built) that "traffic generated pollution is responsible for the near epidemic proportions of asthma cases we see at the surgery." There is only one GP surgery covering the town of Baldock.
On looking at the evidence presented to the Baldock Bypass Public Inquiry the Inspector recognised a link between air pollution and asthma levels in the town, these being above the national average and rising. Despite the road being opposed by NHDC the Inspector approved its construction.
To underline how bad air quality was in Baldock at that time, the subject was raised by Sir Oliver Heald in the House of Commons in 1997, in support of the construction of the bypass to take traffic generated pollution away from the area. In 1994, figures from the local asthma register show that the child asthma rate was almost 12% (twice the national average), going up to 15% before the building of the Baldock Bypass in 2006. This year that same figure has declined to 6% (equal to the national average).
An NHDC draft Air Quality Report of January 2000 itself recognised the topographic influences on the situation (Baldock is, of course, located in a valley) by referring to the "physical character of Baldock inhibiting good dispersal of air pollutants." It also recorded that the annual mean standard (that applied at the time) for nitrogen dioxide had been exceeded in 1999.
North Hertfordshire District Council acknowledges that "no specific assessment (of air quality) using historical data has been undertaken at this stage." (email of 2 November 2016 from NHDC Strategic Planning to John Gingell).
Bearing in mind the inherent weakness of the Transport Strategy, I believe that there is a real possibility of rising air pollution within the Baldock basin as traffic levels rise due to the unparalleled expansion of this medieval town. The local authority is failing in its duty to the residents of Baldock by failing to conduct any meaningful assessment of that risk. In November 2016, Julie Girling, the MEP for South West England affirmed that poor air quality has a huge impact on human health, the environment and the economy, saying "Poor air quality is an urgent public health issue... estimated to cause 400,000 premature deaths across the EU... The UK should be a leader in the fight to tackle bad air quality... With our national health system, we bear the economic consequences of bad air quality directly and we should not allow the progress made in recent years to slip." No specific assessment of air quality is a major flaw in determining the environmental consequences of the Local Plan, which may well result in an increase in premature deaths in Baldock.
Natural Environment
The National Planning Policy Framework (NPPF) states that the purpose of the planning system is to contribute to the achievement of sustainable development with its three dimensions (economic, social and environmental). Development should support the local economy, provide social benefits in the form of new homes and social facilities and protect & enhance the natural environment.
The development north of Baldock (BA1) will seriously and adversely impact on wildlife in the area. The Corn Bunting was once a common, widespread farmland bird (originally called the Common Bunting). Due to changes in farming practices, the Corn Bunting has experienced a dramatic decline of 90% between 1970 and 2010. It has become extinct in Ireland and is possibly extinct in Wales. It is a Red Listed Bird. During 2014 an extensive survey was carried out, which indicated that the area north of Baldock is central to the population of this declining bird. This area also provides habitat for the following Red Listed species: Yellow Wagtail, Grey Partridge and Linnet. Development of this area will destroy the habitat of these protected birds with a disastrous effect on their overall numbers and sustainability.
Ivel Springs is a large Nature Reserve in Baldock and a Scheduled National Monument which means the site has national significance and is protected under statute. The springs, which are the source of the River Ivel, provide a diverse area for wildlife, including woodland, wetland and pasture; it is carefully managed to keep a mixed habitat and encourage wildlife to flourish. Chalk Rivers, such as the Ivel, are extremely rare and included in the Hertfordshire Biodiversity Action Plan. The River Ivel and its wetlands are important habitats for a wide range of species; however, for the past six summers, the river at Ivel Springs has dried up. It is contended that the imposition of the north Baldock development will increase the strain on this fragile ecosystem that has existed for at least 5,000 years. The loss of this Nature Reserve will have a catastrophic effect on wildlife and before NHDC embark on the development of north Baldock, research should be conducted to measure the level of threat that such proximity to a large development of 2,800 houses poses.
On 6 February 2015, the Natural Historic & Built Environment Advisory Team informed NHDC that site BA1, north of Baldock, in the Local Plan could contain heritage assets, which could be a constraint on the principle of development. This led to Hertfordshire County Council (the landowner) undertaking an archaeological trial dig evaluation of the site. So far, archaeological remains have been discovered, which probably date to the time of the Roman conquest of Britain; this investigation continues, but I have been informed that a principal archaeologist has stated that some finds may predate the Roman conquest and that indications are that the finds include a Roman villa, with muralled walls, which are incredibly significant. This is still being investigated, but indications are that much of this land may not be suitable for development, and inclusion in the Local Plan at this time is, to say the least, presumptive.
Green Belt
As previously stated 60% of homes in the plan are to be built on Green Belt land. Such land should only be used for development in exceptional circumstances. It is implicit in this policy that Brownfield and non-Green Belt land should be used before building on the Green Belt. Yet North Herts Homes (NHH) Brownfield Regeneration Project has not been included in this plan. This project aims to provide 400 homes, solely from the use of Brownfield sites between 2014-18. I have asked NHDC whether they have done any work to identify similar schemes without receiving any meaningful answer.
The proposed sites in the Baldock, Hitchin and Letchworth area will lead to a ribbon of development from Baldock to Letchworth, to Hitchin, creating unrestricted urban sprawl, with encroachment into the countryside. This proposition counters recent Government statements on the use of Brownfield sites. In 2014, the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside."
Virtually doubling the size of Baldock will damage the setting of Baldock in its natural basin, currently surrounded by countryside. The unique character of the town, dating back to medieval times with a strong connection to the Knights Templar and many listed buildings will be irrevocably and fatally marred.
More and more development is occurring on Green Belt land; in 2008, less than 20% of new homes were built on Green Belt land. In 2011, that figure had risen to 34% and will now be much higher.
Spatial Strategy
This plan focuses development squarely on the four towns within the district, who between them will have to accept 70% of the development. Of these four towns, the smallest and most historic, Baldock, is expected to assimilate 3,590 homes, or 25% of the total. This is not fair, nor is it equitable; neither does it take account any possibility of the development of a Garden Village/City. In this respect, the plan is shown to be short term and tactical, rather than strategic.
This plan relies on land that is put forward by developers and does not seem to be proactive in any way. Rather than look at land that would enhance future development and approach landowners, NHDC seems to have merely reacted to sites offered up by landowners, preferring sites that are Green Belt and owned by another public body (Herts CC).
Other Evidence
During the course of the development of the Local Plan, a number of sites have been put forward and then rejected by the planners of NHDC. The consultation paper related to the Housing Growth Targets consultation run by NHDC from 17 February to 30 March 2012 outlined eight different options for housing growth, ranging from 15,800 to 2,500 new homes. Unfortunately no rationale for rejection of individual sites has been published, which leaves residents frustrated and unable to understand a) what specifically has excluded a particular site and b) whether once a site has been rejected anything can be done to reverse that decision.
The NPPF states that Local Plans must be supported by a local evidence base, which means that NHDC must plan to meet objectively assessed needs for market and affordable housing and identify a five year supply of specific deliverable sites. I have been unable to ascertain why certain sites have been rejected in favour of others.
On the evidence, I believe that the plan, as it stands, is flawed; three local MPs believe the plan is flawed; even the NHDC Portfolio Holder, responsible for the submission of the plan believes it is flawed. There is public condemnation of the plan across the District and an overwhelming desire for a two stage plan looking at deliverable sites for 6,000 homes in the first ten years and working with other housing authorities to provide a new Garden Village/Town style settlement. I urge you to consider the overwhelming public view across the District and adopt a two stage plan, which will embrace localism and demonstrate objective and equitable measure to deliver the right level of development across NHDC.
If you think I can assist, I am willing to attend and give evidence at the Public Inquiry.

North Hertfordshire Local Plan 2011-2031 Proposed Submission Local
Plan Consultation Wednesday 19 October 2016 to Wednesday 30 November
2016

With regards to the above planning application I wish to register my strongest possible objections to this development of 660 dwellings adjacent to Copthorne, Luton.

No proper regard seems to have been taken in respect of improving the road infrastructure. The minor alterations listed on the planning application would have little or no effect. The existing roads cannot currently cope with rush hour traffic in the mornings and evenings. Eaton Green Road, Crawley Green Road, A505, East Circular are nearly almost stationary. The road network could not possibly cope with any increase in traffic from any developments built in this area. At peak times it can take up to an hour to get to and from Junction 10 of the M1. There is also the added problem of expansion at Luton Airport which would certainly add to traffic problems.

Many local roads in the vicinity of the proposed site are narrow country lanes with single track stretches and they too would be unable to cope with the increased traffic, particularly public transport vehicles and large vans and lorries which will be required to serve the development.

I noticed on the plans that there are three proposed footpaths, cycle ways adjoining Copthorne to the new estate this will encourage people to use Copthorne as a cut through as well as a safe place to park their vehicles as it says in the plan that there is only one garage/parking per dwelling. As for the ridiculous suggestion that most people will be using cycles and walking, DREAM ON.

I noticed also that surface drainage is going to be collected in three unfenced ponds (SUDS). Government rules state that (SUDS) should not be located close to airports as they could encourage flocks of birds which could endanger aircraft with bird strikes.

I noticed from the layout of the plan that the high density/social housing have been placed closest to the County View estate which mainly consists of 3, 4 and 5 bedroomed detached properties and will most certainly not blend in with these existing properties. I understand that 40% of this development is going to be affordable housing with the possibility of flats which is totally out of character with the area.

I understand that there are no plans for schools or infrastructure upgrades until after the site has been completed. The GP surgeries in the area are over subscribed and one dental surgery is not taking on any new patients. Local schools at Cockernhoe and Wigmore are already over subscribed. The application does not indicate where the additional children will be educated.

I feel that your development, which is in Hertfordshire, should not be entitled to Luton's services and as a local rate payer I should not be subsiding Hertfordshire rate payers. It seems you are dumping all Hertfordshire's problems on the Bedfordshire rate payers. Luton Borough Council have not done any air particulate studies into air quality in our area, in spite of there being a massive airport expansion going ahead. Nor have they conducted traffic studies to address the terrible congestion in the surrounding area.

This development would destroy a large amount of North Herts Green Belt land. Government policy on Green Belt land is completely ignored in this proposal. Green Belt policy is to prevent urban sprawl.

Also, I understand that the area you are proposing to build on is under consideration to be included as an area Area of Outstanding Natural Beauty and was at one time Grade 'A' agricultural land but in your latest bulletin this is no longer the case, how convenient.

Many people from the area use the surrounding countryside for recreational purposes, walking, cycling, and taking an interest in the wildlife. The villages of Tea Green and Cockernhoe should not be allowed to be swallowed up by the town of Luton in this way.

Once again I strongly object to any of the proposed developments as this is an overwhelming number of dwellings for such a small area.

See attached

See attached