Policy SP14: Site BA1 - North of Baldock

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

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

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

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

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

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

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

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

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

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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 houses North of Baldock (site BA1).

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

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

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

4. HIGHWAYS: The local highways network will be severely affected by the development of this site. Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The A507 passes the only access to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac (Icknield Way East) and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which they both deliver traffic.
Station Road passes under the 14ft 6in railway bridge, which historically has suffered frequent hits by lorries (8 or so per year - As a resident in Larkins Close, I feel the vibrations from each hit). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted and two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do.
The Plan is UNJUSTIFIED and NOT EFFECTIVE

5. TRAFFIC: The traffic on the A507 is constant and heavy especially in peak periods, which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
In the IDP the Traffic Baseline (para) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031.
No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. The traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.
All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St.
The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modelling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief that Baldock traffic problems have not been acknowledged and addressed.
The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14).
There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. RAILWAY STATION: Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinch point for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.
The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock, Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.
Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. There is also no access for disabled passengers.
Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not until recently known of NHDC's plans such as building a bridge over the railway from the A505 Royston road into or round the BA1 site.
There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts. It is quite exposed at this point.
This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.
The link road proposed through BA1 will not relieve congestion at the Whitehorse St/Station Rd crossroad if it is not the shortest route into Baldock. It may, however, be used by many people as a shortcut from A505 to A507 and will deliver more air pollution to the site BA1.
There is no modelling of the impacts from developments or their dependency on new infrastructure (AECOM section 7 Summary). No information is given about mitigating measures. It has not been shown that this part of the plan is deliverable. The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites, of which BA1 is the biggest proposed.
The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network.

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

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

9. WATER/WILDLIFE: Water provision at a time when water in this area is scarce and in danger of being inadequate, and the provision of sewerage over an enormous area (BA1) have not been adequately documented. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.
The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on water provision and wildlife.

SUMMARY:
The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a pinch point for traffic and a pulling apart of the community.
Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community" (NPPF 66). NHDC have not sought the views of existing residents.
"By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality NPPF 112.
It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

There are already tailbacks at the Whitehorse Street junction and if BA1 contains 2800 more households, the traffic flow through this junction will increase significantly. The plan mentions that BA1 site is big enough to support a new link road, including an additional bridge over the railway, but the sustainability assessment does not assess what is needed. The Transport Assessment does not consider N of Baldock, only Baldock WITH Letchworth in traffic modelling. Local Plan Model Testing 60271338 says in para 2 Baldock and Letchworth have not been tested to date.

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.

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I would however like to make some further points why the proposals BA2-4 and SP10 are neither effective nor consistent with other policies.
Many people will point to the transport infrastructure because this is something visible to us all. This is demonstrably not up to the standard necessary to support large scale development. But what about all the other key infrastructure and its capacity that needs to be demonstrably deliverable in a timely fashion prior to development such as sewage, water etc to comply with para 177 of the NPPF. Hopefully the inspector will have expertise and look at this rather than relying on representations. Similarly schools, as far as I can see, proper development of Knights Templar School has for years lagged behind the need and numbers enrolled. I do not think the plan meets the effectiveness test.
There are various comments from the planners about things it is planned will be done. But I am afraid I have no confidence that there is anything of substance and credibility behind the words and I am concerned that if the transport assessment required by the NPPF has been produced as required by NHDC/HCC then it lacks credibility. Opportunities to start doing some of the things are already probably lost. The A507 rail bridge had several weeks of work last year but it changed nothing on the footways or actual bridge width and height. If any of the developments go ahead it will make it more difficult to deal with problems in the future. The bridge is a hazard; recently pallets were strewn about following one of the periodic bridge strikes; the risk of hitting pedestrians will increase if the footfall and cycle miles increased. Delays are already caused by bridge strikes and HGVs attempting to turn when they realise at the last minute they cannot get through. Again, this demonstrates the plan is not deliverable and not effective.
Currently the old car repair site opposite "The Engine" pub is being developed for housing. This and the car sale site could surely have been a strategic acquisition to do something about roads and reducing the traffic light chokepoint. And at the same time put in a smallish multi storey car park as found near quite a few stations to do something about car parking for station users which will become a far greater issue if any of the proposed Baldock developments proceed. Presumably the plan is that there will be less rail users given the current proposals to reduce fast services to/from Baldock. Again, this demonstrates the plan is not deliverable and not effective.
Elsewhere, South Road is also heavily used and any more usage (inevitable from BA2,3,4) will be difficult certainly given the increasing parking already going on there. I don't see that being covered. Another specific example where the plan is silent is Clothall Road; this already has vehicles parked nose to tail and it is barely wide enough for a lorry and a car to pass each other. It will only get worse with BA2-4.
I do not know, but do also worry that SP15 (North Letchworth) will also feed more traffic through Baldock. Undoubtedly this happened with the extensive Stotfold developments that have taken place in recent years. And the talk of feeding traffic onto the A1must be more than a little optimistic and not a realistic solution as the A1 is already a problem certainly when traffic gets south of Letchworth. Once again I consider this demonstrates the plan is not deliverable and not effective. It probably isn't consistent with the national policy requiring sustainable developments.
Baldock has seen a considerable volume of redevelopment and increase in the number of houses in the past 20 years due to use of small plots and redevelopment of old commercial sites etc but there has been no visible infrastructure improvement or enhancement and the consequences are far more on street parking adding to general congestion. I do not think it is appropriate to embark on any of the developments BA1-4 until the infrastructure has been addressed. Taken together B1-4 are sizeable and will significantly impact on an already inadequate infrastructure. The plan is not effective.
I could be persuaded that use of current green belt land for SP14 was appropriate if there were good quality substitutions if all the other minus points were dealt with, but the current NHDC plan seems to me to have too much coincidence of needs given that it proposes to use Herts CC land in the main and no doubt they would like to sell at enhanced development values, and it saves them and NHDC looking properly at other more environmentally and green belt friendly areas. As it stands, I do not see the plan as compatible with para 80 of the National policy framework nor with the NHDC green belt review and think that BA2-4 and SP14 would be examples of undesirable urban sprawl. It is therefore not consistent with the national policy on sustainable development.
Taking the likely increase in stationary traffic, health problems associated with pollution must surely increase and make the policy on healthy communities infeasible.

I am writing this email in response to the NHDC Local Plan
Consultation to express my concerns and objections on the proposed
plan. My comments and concerns are as follows:

1. Spatial Strategy - On review of the proposed Local Plan, the
percentage of proposed housing to and around the small historic town
of Baldock is extremely high. Based on the current size of Baldock,
the proposal to build 3290 new homes will double the size of this
historic town. Baldock has a thriving community as it stands which
would be hugely impacted on with this number of properties. Based on
an average of 3 to 4 people per property, this would equate to between
9,870 to 13,160 additional residents of Baldock, which in turn has further implications as I will identify below.

2. The number of proposed residents if we use the above average (which
could potentially be 4 or more depending on the number of bedroom
spaces proposed for each development), will have an impact on the current town centre of Baldock.
Baldock is a small town with limited parking. The high street has a
good historic feel to it with the St. Mary's church at the end of the high street.
The parking on the high street of Baldock already is insufficient,
with the number of people visiting Baldock during the day and evening
exceeding the number of parking spaces, which proves difficult to park when you need too.
With the proposed number of new residents, Baldock town will be choked.

3. Under Policy SP6 - Sustainable transport. The proposal is already
at risk of being flawed. The current rail network company (Govia) are
proposing to reduce the number of trains stopping at Baldock Station.
The current Baldock station platform is at the limit, the number of
passengers boarding the train during peak times is already large and
virtually fills the train. As a commuter, I have noticed that as soon
as the train reaches Letchworth station (being the next stop from
Baldock), there is insufficient seats or space for commuters from
Hitchin, Stevenage and the following stops. The proposed number of new
residents in Baldock will consist of a majority of commuters moving to
the countryside with good links to London. This will mean the trains
will be overcrowded to a point where the trains are unable to function
safely. This in turn will cause a loss in revenue for companies due to
the number of people that will not arrive to work on time. It has become clear that NHDC have not been in consultation with Network Rail or Govia in relation to the proposals.
This was confirm via the Save Baldock Trains petition, when a local MP
discussed the proposals with Govia, which they knew nothing about the
proposed over development of Baldock.

4. The proposed new development is to include a new surgery. Currently
Baldock Surgery has over 12,000 Baldock residents registered, The
proposed new surgery would have to be part of the first phase to be
constructed to enable the practice to be set up sufficiently to
accommodate the proposed number of residents. The surgery would have
to be of a substantial size similar to Baldock Surgery. One concern
here is whether the surgery is able to employ the number of doctors
and medical staff to accommodate the extremely high number of
residents proposed. I believe our country is struggling to find the number of doctors required to run a doctors practice sufficiently.

5. SP11 - Natural Resources & Sustainability - Areas BA3, BA4 and BA5
were prone to flooding prior to the A505 Baldock Bypass being
constructed. The ditch alongside the Old Wallington Road used to
Flood. There was numerous remedial works that had to be carried out to area BA4 after the bypass was constructed.
The Land within Baldock is made up of chalk.

6. SP14 BA1 site North of Baldock - This is the largest area proposed
to construct housing, retail and schools. The proposal for a new link
road between the A1 and the A505 would not work. Has Network Rail been
consulted on this proposal, has Herts County Council actually reviewed
the level change to create a link road, if they have, then the proposal should be issued for public view.
From our understanding at consultation meetings, the proposed bypass
is proposed as a single carriageway road. This will only shift the
traffic jam onto the new road. Before any development on Baldock takes
place the following needs to be constructed:
i) - The proposed new bypass from A1 to A505 needs to be a dual
carriageway
ii) - The A1 to A505 bypass would need to be extended to the A10. The
traffic running through Baldock not only goes to the A505, but a huge
number of traffic and HGV vehicles cut through Baldock and Cottered to
reach the A10. The number of potential residents and traffic that will
take this route may cause the road to the A10 to be gridlocked. The
road through Cottered has not even been considered during the
consultation period. This will have a substantial impact on Cottered,
Walkern and Buntingford. This needs to form part of the consultation,
a traffic assessment needs to be carried out on the Cottered / Buntingford Road o ascertain the traffic levels now prior to any development.
iii) - We understand from media reports that the A1 is subject to
being widened to 3 lanes. This is a good thing, but needs to be
completed before any construction takes place in Baldock. The A1 would
need to be widened from the Baldock Services all the way to Welwyn
where it has already been widened to 3 lanes. As it currently stands,
the A1 is gridlocked between Baldock and Welwyn on a daily basis
during rush hours (6am until at least 9:30am and 3:30pm until 7pm).
This would ease congestion substantially before any works take place
in Baldock which may ease the level of traffic trying to go through Baldock slightly.

Infrastructure - Drainage and risk of flooding. With the number of
houses proposed, the local plan mentions a provision of Sustainable
Urban Drainage Systems will be required. The number of houses proposed
will have a dramatic impact on SUDS. The houses would produce
approximately 105 litres of water per day each (based on Code for
Sustainable Homes values). This will impact on the current drainage
system and potential create a higher risk of flooding over a
15 - 30 year period. The drainage infrastructure would need
substantial improvements to accommodate the number of proposed
properties. This needs consultation with the water authority.

If you have any queries, please let me know.

See attached

I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to 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 is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. 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". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

See attachment

See attached

TO THE LOCAL PLAN 2011-2031 BY NORTH HERTFORDSHIRE DISTRICT COUNCIL (NHDC)

(I want to change the Local Plan and I wish to participate at the oral examination)

1. I JUDGE THIS PLAN TO BE UNSOUND

The plan is unsound for the following reasons:

1) The Plan is not Positively Prepared
2) The Plan is not Justified
3) The Plan is not Effective
4) The Plan is not consistent with National Policy

NOT POSITIVELY PREPARED

Plan Policy SP8

Para 158 of the National Planning Policy Framework (NPPF)

1.00 Reliance upon figures, estimates or instructions obtained from the Dept. of Communities and Local Government (CLG) or the Office of National Statistics (ONS) does not remove the obligation of the Local Plan from complying with Para 158 when assessing housing need. The NPPF gives the guidance that the CLG Projections are the appropriate starting point in determining objectively assessed need but the CLG projections are only appropriate when they are in accordance with Para 158.

1.01 It should be noted that Para 158 refers to the economic, social and environmental characteristics and prospects of the area of the local planning authority except for that allowed by Para 182.

1.02 There is considerable reason to doubt the adequacy, up to date-ness and relevancy of the CLG household Projections and whether they provide a full account of relevant and economic signals as required by para 158.

1.03 The CLG household projections call for an increase of 15000 houses for North Herts between 2011 and 2031. This is an annual rate of increase of 1.39 %. These figures are employed as the basis for the Objectively Assessed Housing Need for the Local Plan.

1.04 The CLG household projections are, according to the CLG, based upon the 2014 ONS sub-national population projections for the East of England. These figures are calculated for the period 2014-2024. The population increase over this period is given as 8.9% or 0.89% per annum. Thus the CLG, in their household projections, give a rate of population increase 56% larger than the ONS figures. There is not the adequacy, up to date-ness or relevancy (as required by para 158) in the CLG figures to explain why they ae that much larger than the ONS figures.

1.05 Should some of this 56% increase in households by the CLG figures be to satisfy the unmet housing requirement of a non-neighbouring area, such as London, then in that case the Plan contravenes para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.......

1.06 The ONS 2014-2024 sub-national population figures for the East of England do not themselves take into account the effect of an imminent Brexit event. Robert Goodwill, The Minister of State for Immigration has stated in November 2016 that the government is committed to reducing net immigration to sustainable levels - which he defines as "tens of thousands". This is a considerable reduction on pre-Brexit projections. It would imply a maximum net migration of 90,000. i.e.0.14% per annum (total pop.64.6 million). Brexit is expected to occur some time after March 2017. with some 14 years of the Local Plan yet to follow. Thus a Brexit event is very relevant and should be taken into account under the requirements of Para 158.

1.07 This post Brexit expected lower level of migration decreases the ONS 2014-2024 total annual sub-national population increase for the East of England to 0.46% from the pre-Brexit figure of 0.89%. Thus the reliance on 2014 ONS pre-Brexit population projections by the CLG and therefore also by the Local Plan, does not give the adequacy, up to date-ness and relevancy as required by Para 158.

1.08 It should be noted that the pre-Brexit 2014 sub-national population figures for the Est of England include an annual increase of 0.28% for internal UK migration. If this internal migration is to satisfy the unmet housing requirement of an non-neighbouring area, such as London, then the Plan contravenes Para 182 of the NPPF which states:- The Plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so.....

As London grows at a fast rate it is most likely that this is the source of the internal migration into North Herts. By not stating from where this internal migration originates the ONS subnational projections are not adequate for use by the Plan as required by Para 158.

1.09 The Plan calls for an increase in houses of 16900 over 20 years on a starting stock of 55150, which is an average annual increase of 1.53%. This, in turn, is an increase which, once again, does not meet the adequacy , up to date-ness and relevancy required by Para 158.

1.10 The proposed rate of average annual rate of increase of housing stock employed by the Plan of 1.53% should be compared with the post-Brexit adjusted 2014 ONS sub-national population projections for the East of England of 0.46% (internal migration not included). The difference amounts to 11830 houses - much of which is allocated to be built on Green Belt land. Legitimate internal migration would require some of these.

1.11 The Plan, in proposing so many more houses than are needed for local requirements, acts to encourage migration into North Herts by creating a availability of houses beyond local needs. This effect is the opposite to the requirement of Para 158 which states that the Local Plan should be based on up to date and relevant evidence about the economic, social and environmental characteristics and prospects of the area.

Whether potential migrants exist in other areas capable of being attracted to the NHDC area is no concern of the Local Plan, except where there is unmet need from a neighbouring area. The unmet need from both the Luton and Stevenage areas has not been properly quantified according to the requirements of Para 158 for the same reasons as given above for the NHDC Local Plan.

1.12 A further relevant factor ignored by the Plan contrary to Para 158 is the inability, or lack of desire, of developers to build beyond a certain rate. Ths effect has been pointed out by the CPRE in their paper "Set Up To Fail". On average developers build just 50% (taken over the last 15 years) of what there is land available for. In this respect the Plan does not comply with Para 154 of the NPPF which requires plans to be realistic.

An unfortunate consequence of making too much land available is that developers are given a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to build on.

NOT JUSTIFIED

2.00 The Plan is not the most appropriate strategy as it proposes to build many more houses than are required on the evidence supplied or are likely to be built (see under Not Positively Prepared). Furthermore it breaches the NPPF both in the Foreward, Core Planning Principles and Paragraphs 14, 15, 17, 79, 80, 83, 89, 158 and 182 (see under Not Consistent with National Policy).

NOT EFFECTIVE

Plan Policy SP8

3.00 The Plan is not effective as it ignores the rate at which developers ish to build houses. This effect is described in the CPRE Paper "Set Up to Fail". On average developers build just 50% of what they have land available for. This gives the developers a choice of which site to develop and they usually choose a Green Belt site in preference to a Brownfield site as it is cheaper for them to do so. Thus the expected build rate of developers is a relevant factor in any Local Plan.

The Plan is also not effective as it proposes to build many more houses (16900 in total) than is required (see under Not Positively Prepared above).

NOT CONSISTENT WITH NATIONAL POLICY as outlined in the National Planning Policy Framework (NPPF)

The paragraphs listed below refer to the NPPF unless specified otherwise:

4.00 The Plan contravenes the NPPF in sites BA1, LG1, NS1,HT1, GA1,GA2.EL1, EL2, AND EL3 for the reasons given below:

4.01 The Plan contravenes the 1st Core Principle of Para 14 of the NPPF notwithstanding the statement of community involvement, Para 1.19 of the Plan.

The Ministerial Foreward of the NPPF notes that in recent years planning has tended to exclude, rather than include, people and communities and the NPPF allows people and communities back into planning.

4.02 This is addressed by the 1st Principle in Para 14 which states: Planning should empower people to shape their surroundings

and also by Para 155 which states:- Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged

4.03 The great majority of representations to the earlier stage of consultation (2014) of the Local Plan (7502 objections versus just 559 supports) have been ignored. Despite the many objections against building on Green Belt land, the amount of Green Belt land allocated for housing was actually increased after the consultation at Site NS1.

Plan Policy SP1

5.00 PARA 14 states there is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-making

The word sustainable is given in the Ministerial Foreward of the NPPF to mean:- ensuring better lives for ourselves without making lives worse fr future generations.

and opened to people to experience it, to the benefit of body and soul.

5.01 Para 15 states:- All Plans should be based upon and reflect the presumption in favour of sustainable development

Thus development on Green Belt land - as on Plan sites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3 must, under the above definition of sustainability, make lives worse for those in the future, who would otherwise have enjoyed the Green Belt for walks on foot, by horse, for play/leisure, discovering and enjoying wildlife and for its views as are currently being enjoyed by the present generation.

Thus the Plan contravenes the NPPF both in the Foreward and in Paras 14 and 15.

Policy SP5 - Countryside and Green Belt

6.00 In Policy SP5 NHDC states :- We support the principles of the Greeen Belt and recognise the intrinsic value of the countryside.

6.01 CORE PLANNING PRNCIPLES, Para 17 states the Core 12 Principles for Plan-making and decision-making.

The 5th Principle requires the protection of Green Belts.
The 8th Principle requires the re-using of Brownfield land.

The Plan contravenes the 5th Core Principle ins ites BA1, LG1, NS1, HT1, GA1, GA2, EL1, EL2, EL3.

6.02 Para 79 of the NPPF is crucially important as it defines the Green Belt here:- The Government attaches great importance to Green Belts. The fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.

In Policy SP5 the NHDC accept Para 7 of the NPPF which determines that permanence is one of the essential characteristics of the Green Belt. Yet the Plan intends to remove land from the Green Belt, thereby destroying is permanence and contravening Para 79 and the Plan's own statement of agreement with Para 79.

6.03 Para 80 states that:

Green Belt serves five purposes:

Amongst these:

To check the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns from merging into each other.
To assist in guarding the countryside from encroachment.
To preserve the setting and special character of historic towns.

Hence Para 80 gives the reasons for the establishment of the Green Belt legislation.

The Plan contravenes all four of these purposes in several proposed housing sites. For example:

6.04 The urban sprawl of Stevenage is exampled in sites GA1 and GA2 and also in NS1 which is designed to integrate (Policy SP16) with an adjoining proposed development in the Stevenage Borough (SBC) Local Plan to create a combined urban sprawl from Stevenage to the village of Graveley of 1.3 kms in depth. This is a monstrous contravention of the above four purposes of Para 80.

6.05 The third purpose of Para 80 I breached by sies GA1, GA2, NS1, BA1, LG,HT1, EL1, EL2, EL3.

6.06 The preservation of the setting and special characteristics of historic towns (the fourth purpose given in Para 80) is contravened in particular at Baldock and at Graveley where the proposed number of houses (2800 at BA1 and 900 at NS1) will have an enormous deleterious effect relative to the present number of houses in these two places.

6.07 Para 83 of the NPPF states that once established, Green Belt boundaries should only be altered in exceptional circumstances.

In Para 83 no more explicit definition is placed upon the phrase "exceptional circumstances".

6.08 In Policy SP5 the Plan quotes the judgement of Mr Justice Jay in the Calverton Parish Council v Greater Nottingham Councils (2015) EWHC 1078 case as justification for building on Green Belt land.

Mr Justice Jay stated that:- It would be illogical and circular, to conclude that the existence of an objectively assessed (housing) need could, without more, be sufficient to amount to "exceptional circumstances" within the meaning of Paragraph 83 of the NPPF".

The Plan does not provide evidence to show "exceptional circumstances" other than housing need, which is specifically rejected by Mr Justice Jay.

The following discusses the phrase "exceptional circumstances" in the event that the Local Plan is later modified to include certain circumstances purported to be acceptable within Para 83

7.00 It cannot be the case that a circumstance be considered as "exceptional" within the meaning of Para 83 or "very special" within the meaning of Paras 87 and 88 if the employment of that particular circumstance effectively destroys the fundamental purposes of the Green Belt as described in Para 80, or the essence of the Green Belt as described in Para 79. For if the purpose or the essence of the Green Belt is destroyed then Paras 83,87, and 88 themselves become meaningless.

7.01 The destruction of the essence of the Green Belt occurs when its openness is challenged by erecting buildings upon it. The destruction of the permanence of the Green Belt occurs if any part of Green Belt land is later designated as non-Green Belt land. Even relatively small incursions of the Green Belt have the effect of destroying the essence of the Green Belt when continuously repeated, as they may be.

7.02 The Hon Mr Justice Jay suggests five possibilities for exceptional circumstances:

1) The acuteness of the need
2) Constraints on the supply of available land
3) The difficulty of finding non Green Belt sites
4) The nature and extent of the Green Belt if developed
5) The extent to which the loss of Green Belt may be ameliorated.

7.03 My comment on Mr Justice Jay's ruling is that his 5 permissible exceptions destroy the intent and essence of the Green Belt as described in Para 79 and contravenes the purposes of the Green Belt as described in Para 80 and are therefore not permissible.

7.04 One should consider:

1) the acuteness of the need. Firstly, the need for housing must be determined within the restraints of Para 158. Under those circumstances the true need may not be acute, as is the case described in Paras 1.00 - 1.12 above. Need is an objective assessment which has to be considered whether it is exceptional compared to previous occasions eve though subjectively considered currently high.

It is not acuteness that matters it is exceptional acuteness.

2) No matter the constraint on land supply there always exists the possibility of building on non-Green Belt land in the form of a New Town or on Brownfield sites or on other green spaces owned by the NHDC (Barkas [2014]) Any constraint which still exists after all other avenues have been explored in its self has to be exceptional compared to previous constraints.

3) There may be difficulties but all other possibilities must first be considered. Once again the difficulties must be compared to previous difficulties in order to show exceptionality.

4) One exceptional characteristic of Green Belt (Para 79) is its permanence which thus denies the allowance of even small harms.

Thus the nature and extent of the harm is not an issue if no harm may be done.

5) A loss of Green Belt violates the essence of the NPPF as described in Para 79, so amelioration is not an issue.


8.00 Para 89 states a local planning authority should regard the construction of new buildings as inappropriate in Green Belt.

The exceptions listed are not applicable to the Local Plan. This definition of inappropriateness applies to Paras 87 and 88 and elsewhere. Thus the construction of new buildings is not allowed on the Green Belt. Thus the Plan contravenes Para 89 of the NPPF in proposing building on sites. GA, GA2, NS1, BA1, LG1, HT1, EL1, EL2 AND EL3.
.

Plan Policy SP10

8.01 Para 7 of the NPPF - a social role -states that the supply of housing is required to meet the needs of present and future generations.

Thus it is necessary to have an accurate prediction of the type and size of future generations. The inaccuracy of the housing need figures employed by the Plan is addressed under the Section Not Positively Prepared, above.

8.01 The Plan is seriously flawed in that it cannot meet the needs of a future generation as it does not employ the most accurate projection of the size and make-up of that future generation.

Thus the Plan is in contravention of the requirement of the NPPF Para 7.

Plan Policy SP13

9.00 The Ministerial Foreward of the NPPF also states that :
Our historic environment - buildings, landscapes, towns and villages - can better be cherished if their spirit of place thrives rather than withers.

The spirit of the small town of Baldock (BA1, 2800 extra houses) and that of the village of Graveley (NS1, 900 extra houses planned - a 450% increase) and Codicote (CD1, CD2, CD3,CD4, a 24% increase) for example, cannot be expected to survive undiminished if this Plan is implemented.
Thus Para 14 of the NPPF is contravened by the Plan.

10.00 Conclusion

The object of the NHDC Local Plan appears to be to maximise the number of houses built - whether on Green Belt or not - and irrespective of the requirements of the NPPF and the true needs of the current population. The requirements of the NPPF are observed more in its breach than in its observance despite several exhortations to the contrary. It is only logical to assume that the Government's New Homes Bonus - which is designed to encourage more house building- is working very effectively at NHDC.


ADDITIONAL COMMENTS

I wish to draw to your attention to the fact that I have emailed Cllr Levett, Planning Officer about a Green Belt matter which much concerned me and not received a reply at all. See below my email relating to recorded comment in Minutes of Cabinet Meeting July 20th 2016.

David

I still have not had a reply to my email of 21 September 2016 to explain how your comment on 20 July, which was a recorded comment saying that you were increasing the Green Belt.

Yu certainly aren't doing that in Graveley !!!!








I have asked for maps of GA1, GA2 and NS1 not for myself, but for other people at their request, because they could not locate the maps themselves. I was advised of the wrong location on the Local Plan information for these maps by Nigel Smith, NHDC's Principal Strategic Planning Officer.

I noted that Minutes of a Cabinet Meeting which took place in September 2016 were not made available to the public until November 2016 relating to adopting the Local Plan. This seems an excessively long time to publish Minutes. I asked the person responsible for compiling them for a copy but was never sent them.

On the subject of Brownfield sites, I emailed Planners for a map or list of Brownfield sites. The response was that NHDC does not hold such a thing. I then found out that I should have done a Freedom of Information Request to enable me to obtain this information. It is concerning that NHDC will not divulge such information willingly and I have been informed by a District Councillor that brownfield sites have been discussed at NHDC Council Meetings and rejected out of hand.

My over-riding concern is that this Local Plan has not taken account of residents' wishes at all. I went to the public meeting where the Local Plan was voted upon by Councillors, on 20 July 2016 which started at approx. 7.30 pm but did not end until after well after 12.midnight. the following day. The atmosphere, pushed hard by Cllr Levett, the Planning Official who created the Plan was of the very unpleasant type of very hard selling such as the elderly and vulnerable experience when someone intent on obtaining their bank details marches them off to the nearest cash point to take all their money out. He kept forcing Councillors, who had reservations about the Plan, and voiced them at the time to vote in favour of it. Councillors there said they "struggled" with it, and there were abstentions and some against.

I am told by a new LibDem Councillor that he was told he had to vote in favour of the Plan, by a person in the Legal Department of NHDC who was present on the panel at that meeting. Conservative Councillors also actually said that they had been forced to vote for the Local Plan or be ejected from their local party. All very unpleasant to see unfolding before your eyes.


Relevant Recent Case to NS1- November 2016 Planning Inspector P.Major Langley Burrell, Chippenham



There was another recent case where In the final balance, the secretary of state agreed with his Inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. See details below:Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC,

The secretary of state has rejected a large housing scheme in Hampshire, finding the loss of an area of local green gap to outweigh the benefit of new housing in making his decision on a recovered appeal.
The proposed new housing estate of up to 225 homes plus a 60 bed care home and 40 extra care units, in outline, was acknowledged to contribute to housing supply in an area with a 4.86 year supply and to the choice of housing types meeting different needs, in accordance with NPPF policy.
Since the inquiry closed, judgment was handed down by the Court of Appeal in Suffolk Coastal DC v Hopkins Homes Ltd and Richborough Estates Partnership LLP v Cheshire East BC, which led the secretary of state to decide a local gap policy was relevant to the supply of housing, contrary to the inspector's view in the appeal. Although the policy was out of date, it was accorded significant weight in the decision because it accorded with the NPPF and the housing shortfall was only limited.
In the final balance, the secretary of state agreed with his inspector that although the area had no special landscape character, the loss of the gap between the surrounding settlements involved physical intrusion into an area of countryside, and contributed to coalescence and loss of independent identity. This was contrary to those policies of the NPPF which recognised the different roles and character of different areas, and carried significant weight against the proposal. The loss of best and most versatile agricultural land also carried moderate weight against the proposal in the decision.
Inspector: John Chase; Inquiry

Other concerns that I have about development in NS1 is the increase in traffic if development of GA1 goes ahead. It is intolerable already to encounter the queues of traffic outside my house at 7.30 am speeding towards the roundabout (Coreys Mill) and Church Lane is extremely narrow and rural. I will find any further increase unbearable and will affect my quality of life.

A major concern to me is the destruction of wildlife such as fallow deer, badgers and Pipistrelle bats who have setts in the woods such as Roundwood. [...]

It also concerns me that thousands of houses are to be built so that I will no longer be able to go for walks near to where I live. This will have an adverse effect on my wellbeing and health.

I would like to add that everyone I have met who has been doing Representations has found them very very difficult to do. In one area (GA2) even though Cllr Henry lived there only 75% of residents had heard of what was planned in their area. I know that because I called on some of these residents and leafletted these people as they were "horror stricken" when they found out only a couple of weeks ago. Why were none of them informed by NHDC ? I am surprised and amazed that Cllr Henry nor NHDC had bothered to tell them or tell them they should be making a Representation.

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