Policy SP13: Historic Environment

The Parish Council strongly supports this policy. With three Conservation Areas in the Parish, there is a particular need to continue with the periodic reviews of these designated areas. The most important historic asset in the Parish is Knebworth House, a Grade 2* Listed Building. The reference to Knebworth Park as an historic asset is also welcomed (paragraph 4.163).

The support for the protection of Scheduled Ancient Monuments is welcome. The Parish contains a number of these assets, including two railway bridges in Knebworth (see our representations on sites KB1 and KB2).

Baldock one of the oldest settlements in Hertfordshire with evidence of occupation since Roman times. The town centre has medieval and Georgian architecture. The town is already congested with traffic and two of the towns oldest buildings have been damaged by vehicles and the proposed 3500 houses in the town an increase of 80% will result in an increase in traffic and the associated polution will impact on this historic town and its buildings

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I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1).
Other policies referred to are SP1, SP4, SP5, SP6, SP7, 9, 10, 11, 12, 13.

1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

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

3. Baldock sits in a valley which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated. The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution. Before the build asthma levels in 5-16 year olds was at 15% and the bypass brought them down to the national average of 6%.
Since then traffic has risen and now the levels of pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.

4. The local highways network will be severely affected by the development of this site.
Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.

The proposed mini-roundabout at Whitehorse St/Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.

The A507 passes the only access road to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac, Icknield Way East, and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact of these new houses at this junction refers only to Icknield Way East, not the Station Approach nor the A507 on to which they both deliver traffic. Inadequate research and modelling.

Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do. See appended photo of lorry hitting bridge just before photo taken at 12.43pm on November 9th 2016 necessitating two police vehicles. Also the screen shot of ongoing congestion as a result at 1.30pm. This is a regular occurrence. Screenshots of the A507/ B656 junction and A1 at other random times show congestion.

The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.

In the IDP the Traffic Baseline (para 5.1) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.

No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. I can report, as a resident of this road, that the traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.

All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock, that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles at least can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.

The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modeling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief
that Baldock traffic problems have not been acknowledged and addressed. There is no Masterplan for BA1.

The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinchpoint for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.

The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.

Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not till recently known of the Local Plan which includes recommendations such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts as it is quite exposed at this point.

This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.

The link road proposed through BA1 will not relieve congestion at the Whitehorse St/ Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505/ B656 to A507 and will deliver more air pollution to the site BA1. Roundabouts through this development would increase air pollution and associated problems as brakes and gearboxes add to particulate production.

There is no modeling of the impacts from Baldock developments BA1-4 and BA10 employment area or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable.

The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

6. The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether.....the opportunities for sustainable transport modes have been taken up" but the Plan does not give information of things such as cycleways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE". I believe that in this case they are severe.

The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development, or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

7. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinchpoint for traffic and a pulling apart of the community.

Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents.

"By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land, going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" NPPF 112.

Water provision, at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.

"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area e.g. Great Ashby have discovered this to their cost.

The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

If indeed development on this scale is really needed in North Herts then I support Sir Oliver Heald in his recommendation to build a new settlement instead of tacking on large areas of development such as these in Baldock which create real problems for the future of existing communities whilst destroying their heritage.

I should like to be kept updated on the Plan's progress
I should like to be invited to the Public Hearing.

Section 1:

Knebworth Estates congratulates North Hertfordshire District Council on a Plan that has - not before time - been positively prepared, and - within its delayed and limited time frame - appears justified, effective and consistent with national policy.

Section 4.9 - Policy SP2:

Knebworth Estates supports Knebworth's inclusion as a Category A village, and Old Knebworth's inclusion as a Category B village - although it argues that there are sometimes cases where it is preferable for a village to evolve outside of its "built environment" rather than on the open and green spaces within its "built environment", and that the Plan should allow for such cases.

Section 4.37 - Policy SP4:

Knebworth Estates supports the Plan's commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Section 4.127:

Knebworth Estates supports the Plan's commitment to deliver appropriate primary and secondary school facilities for Knebworth.

Section 4.162:

Knebworth Estates supports the Plan's commitment "to find new, appropriate uses and solutions to secure the future of heritage assets."

Section 4.165:

Knebworth Estates does not support the Plan considering serving Tree Preservation Orders within historic parks and gardens as this could run contrary to the Plan's commitments in Section 4.162 and the management of historic parks and gardens - and the preservation of, interpretation of, and access to, the heritage assets within - are unlikely to be any better served than by those to whom it is a day-in-day-out commitment and responsibility. Knebworth Park and Gardens has its own Historic England approved Conservation Plan and an exemplary record in its heritage management, and yet another level of statutory requirement is unjustified, unnecessary and counter-productive.

Section 5.28 & 5.29:

Knebworth Estates supports the Plan's intent that Knebworth village centre should continue to provide a mix of shopping, services and community facilities.

Sections 5.39 to 5.48 and Policy ETC8:

Knebworth Estates supports the Plan's commitment to Tourism and argues that - whilst being an Historic England "Priority Building At Risk" - Knebworth House and Knebworth Park belie Section 5.41's statement that North Hertfordshire is not a major tourist destination. The Visit Herts DMO, VisitEngland, the LEP, and Hertfordshire County Council all recognise the district's strong tourism draw and impact. Knebworth House is one of only two Historic Houses in Hertfordshire with a national profile (the other being Hatfield House in the Welwyn and Hatfield district) and Knebworth Park is unique nationally in its capacity for large music events. The Plan should be aspirational to the benefits and potential of Tourism.

Section 6:

Knebworth Estates broadly supports the Plan's Green Belt policies - although, as in Section 4.9, Policy SP2 above - it argues that there are sometimes cases where it is preferable for communities to evolve outside of the "built environment" rather than threatening the quality of life, open and green spaces, balanced zoning and heritage of the "built environment". Knebworth Estates supports the consideration of "exceptional circumstances" within Green Belt policy.

Section 12 - Policy HE2:

Knebworth Estates supports the Plan's "Heritage at risk" policy.

Section 13.183 to 13.202 - Knebworth:

Knebworth Estates supports the Plan's policy for Knebworth within the context and scope of the Plan's objectives and time scales.

Ref - Knebworth - KB1 & KB2:

Knebworth Estates supports the Plan's Housing Allocation and site specific criteria for KB1 and KB2:

Commitment

As freehold owners of the sites identified as KB1 and KB2, Knebworth Estates reiterates its commitment, as expressed in previous consultation responses - and in consultation responses of the independent charity representing Knebworth House (The Knebworth House Education and Preservation Trust), to which Knebworth Estates is primary donor - that if these sites are brought forward for residential designation, it will move swiftly to work with the Council to deliver the full required housing targets with maximum sensitivity to the community of which it has been a part for over 500 years.

Proof of this commitment is to be found in the Estate's long record of involvement in the evolution of the community of Knebworth - since the settlement's beginnings - and specifically, in its multi-generational quest to restore and protect Knebworth House, its Park and curtilage, for public benefit and access (see "Opportunity" below).

The Estate treasures Knebworth's green spaces and environment - it has been a long term guardian of these - however it also believes that Knebworth should play its part in contributing to housing need identified in the Plan, and in the planned evolution of the District as conceived in the Plan. It recognises, with the Plan, Knebworth's pre-existing infrastructure - "a good range of facilities including a railway station, school, doctors and dentists, library, a range of shops, village hall and churches" - and thus considers it right that Knebworth shares responsibility to provide for residential growth with other communities in the District.

As part of Local Plan residential growth, the Estate supports the provision of affordable housing and schemes to provide homes for those who have grown up in the community. It recognises that new homes generate extra pressure on schools and supports increasing school provision. Increased school provision will strengthen Knebworth's independence of Stevenage and other growing towns, promote community spirit - a deficiency identified in the Knebworth Parish Plan (April 2007) - and ease pressure on road and rail networks at peak times.

Delivery

The Estate recognises the extensive evidence base compiled by the Council to support the suitability of sites KB1 and KB2 and looks forward to working with the Council, the community, neighbouring landowners and future development partners to conduct further studies to confirm and expand on this evidence, which it believes to be sound.

The Estate is pleased to have already contributed to existing evidence with input into Knebworth Parish Council's Knebworth Parish Plan (April 2007 - http://www.knebworthparishcouncil.gov.uk/uploads/knebworth-parishplan-1sted-web.pdf) and Knebworth Sites Appraisal Report (December 2007 - http://www.knebworthoptionsreport.org/).

Sustainability

The Estate recognises the Council's Capacity and Sensitivity Studies of 2006, and - as part of the community, and its owners resident within the community - is particularly sensitive to the issues raised by those who oppose development on these sites. It has listened to, recorded, and considered the practical concerns of its neighbours - through previous consultations, involvement in the Knebworth Parish Plan (April 2007) and the Village Appraisals of 1996 and 2007, and at a number of public meetings over the years - and is confident there are practical solutions and mitigations to the issues raised.

The Estate would seek - in working with the Council, any development partners and its neighbouring landowners - to work with Knebworth's new Neighbourhood Plan to promote a balance of achieving the Local Plan's targets, addressing sustainability and infrastructure issues and concerns, and fulfilling community aspirations. Within the parameters of the Plan, it would look to development in keeping with - and improving on - Knebworth's existing Conservation Areas and Edwin Lutyens' original 1910 framework for "Knebworth Garden Village".

Opportunity

Reinforcing the Estate's commitment, and adding to the opportunity of facility and infrastructure improvement in the wider community, is one factor that is unique to Knebworth Estates. Reflecting the intent of the Plan in Policy SP13a - "Maintaining a strong presumption in favour of the retention, preservation and enhancement of heritage assets and their setting" - the Local Plan's requirement of Estate sites for residential provision would present a once-in-a-generation opportunity to solve the Estate's multi-generational quest to endow the Knebworth House Education and Preservation Trust, a charity created in 1984 for the preservation and enhancement of the heritage asset of Knebworth House and its setting.

Residential designation of KB1 and KB2 would result in sufficient funding for this charity to halt the decay of Knebworth House - an Historic England designated "Priority Building At Risk" - complete its half-finished programme of urgent restoration, and secure an endowment for its future survival, and continued and expanded public access and interpretation.

The Knebworth House charity's record over its 33 year history, its established "exceptional circumstances", its Conservation Plan as submitted to North Hertfordshire District Council in July 2001 - and the Estate's record in endowing, and seeking to complete that endowment - is evidence of the commitment of the Estate and the Charity.

The collateral opportunity presented by the designation of KB1 and KB2 within the Local Plan therefore extends beyond the crucial issue of local residential shortfall, to address also major issues of benefit to the whole region and the nation beyond.

Ref - Knebworth - KB4:

Knebworth Estates supports the Plan's Housing Allocation for KB4. Whilst comfortable that KB1 and KB2 could be successfully delivered without KB4, Knebworth Estates expresses its support for KB4. The Estate enjoys a close and mutually supportive relationship with the landowners of KB4 and, in the event that both landowners have sites proposed for development in the final Plan, we would look to work closely with each other to take an holistic view of Knebworth village and, together, maximise infrastructure advantages for the greater benefit of the wider village and its long-term future.

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Site AS1 fails to meet the requirements for Highway safety to protect pedestrians and other road users as defined in both National Planning Policy framework and NHDC's own current and emerging Planning policy for highway safety
It also does not meet requirements to protect valued landscapes under the NPPF
It does not the requirement to protect the Historic environment and is protected by NPPF and NHDC policy Sp13. para 4.151 of the document
There has been no consultation to extend the settlement boundary in locations other than AS1 by NHDC.

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