Policy SP14: Site BA1 - North of Baldock

Unreasonable for Baldock to be increased by 80% when it's the smallest town, inequitable to accept 23% of total housing requirement for district.
Traffic congestion: A507 currently heavily congested at peak times, additional traffic from site BA1 will significantly increase air pollution, congestion & delays.
Infrastructure: Water-board unable to guarantee adequate water supply for 2,800 homes. Rail services: fast train service to London to be cut in 2018, inadequate capacity of station for increased commuter numbers. No guarantee re: schools, GP surgery, being established as development progresses, no capacity for more pupils/patients in Baldock.
Rural community needs green belt land.

Section 4.185 suggests that the site BA1 hosts "potentially" habitats which support Corn Buntings. The site does provide habitat of regional importance for both breeding and wintering. In addition the site supports populations of Yellow Wagtails and Grey Partridge which are also rapidly declining nationally.
The report from BSG has identified a compensation area however it is unclear how this can be delivered given the various different landowners who would need to be involved and who may need ongoing financial compensation in the case that their farming efficiency was compromised by the need for more effective habitat management

Definite, guaranteed plans, time frames for the implementation of schools, doctors surgeries. Assurances from Herts. police on how the area is to be policed. Definite solutions to the increase in passengers on an already overcrowded rail service. A definite plan for where and when a Road circumnavigating the town will be built.
Assurances from the Environment Agency that pollution levels will remain within legal parameters.
Assurances from Affinity water that the legal level of sanitary sewerage and water pressure can be supplied.
Reason as to why this plan is allowed to go against more than one point within the NPPF.

This goes against NPPF points-
3. Supporting a prosperous rural economy
4. Promoting sustainable transport
9. Protecting Green Belt Land.
No mention of how the area is to be policed.
No mention of tackling extra rail passengers.
When is the necessary infrastructure school, doctors surgeries, roads to be built in relation to the settlement.
What will the links in to town from the settlement be?
What is the benefit to Baldock? NPPF Section 8 Promoting healthy communities.
How will the increase in parking be handled?
How do NHDC plan to keep the pollution level below legal levels when the building is taking place?
There is no coherent plan for sewerage and water supply.

I object to planning in this area - We bought our house from the council which was advertised as having rural views. We have invested a lot of money in to this property for our future and will see a significant loss of value if you surround us with developments.
Development would devastate the local wildlife and our local farming industry.
Traffic on the A505 & A507 is already far too congested. Linking them together somewhere else does not reduce traffic it just causes problems for someone else, us!
This would not benefit Baldock or the people of Baldock.

Having reviewed both the plan and the National Policy Framework, there are a number of points the Local Plan does not address.
1. Delivering Sustainable Development
2. Ensuring Vitality of Town Centres
3. Promoting Sustainable Transport
4. conserving and enhancing an historic environment
5. Infrastructure - ensuring viability and deliverability (page 41 numbers 173 180)

An infrastructure development plan is included in the evidence base but it gives insufficient detail on how the infrastructure will be developed and who will meet the costs (the developers may not). This is not consistent with national policy: NPPF paragraph 177 states that "It is . . . important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion . . . and . . . that local planning authorities understand district-wide development costs at the time Local Plans are drawn up".

Failure to comply (or insufficient consideration) of number of points within the National Planning Policy Framework (NPPF)
Site BA1 North of Baldock and South of Baldock: Failure to promote sustainable transport - The studies have focused on the impact upon the A507 and B656 junction and how to alleviate problems here (given in peak hours this junction is overloaded), however insufficient consideration to wider impact on the routes through the town which the proposed Local Distributor Roads and even the costly additional rail bridge do not completely address. Namely a narrow residential road South Road which will not cope with increased volume of traffic, A507 toward Buntingford which does not currently have sufficient upkeep to prevent significant potholes for any length of time at present, narrow and busy roundabout between High Street and White Horse Street.
In addition there are proposed cuts to trains servicing Baldock and increases of services running time into London of as much as 20 minutes - increasing journey times by over 50% and putting a strain on the transport even without significantly increasing the population.
Failure to promote healthy community: although it is noted there are some open areas and a community centre proposed, it should be noted that the police station in Baldock was closed in 2011 and the town is served by neighbouring forces (the other side of the town to the proposed development). Although crime is currently perceived to be low there should be further consideration the effect of doubling the population will have.
Further consideration required in regards to: Conserve and Enhance the Historic Environment/Vitality of Town Centres: - Although there is a large Tesco - Baldock has I believe, to date, overcome the 'death of the market high street' as coined by the media. There are independent shops and businesses which are frequented by all age ranges in this historic market town. Activities such as fairs, may day historical celebrations, beer festivals and music events bring families into the town and there is a palpable community spirit. There needs to be far more in depth consideration as to the extent to which the population could (relatively) rapidly increase before this is potentially irreparably damaged.

I believe that this is too much development compared to the size of the town. It will significantly and adversely change the character of the town.

It is inappropriate to have a plan that the Planning Officer, three MP's, together with the majority of the local residents do not believe in and have a system that does not address the fundamental principles of the Localism Act and National Planning Policy Guidelines i.e. less complex and more accessible, protect the environment and promote sustainable development.
There is substantial evidence that the Council have made no referral to earlier suggestions made from 'informed bodies' such as the Campaign to Protect Rural England. Neither have they consulted major partners such as Network Rail regarding road infrastructure or other surrounding land owners about the availability of parcels of land for sustainable development.

I feel that this development is totally out of proportion in relation to the size of the existing town of Baldock. I can understand that the town will need to accept some additional housing, but a development on this scale is beyond being acceptable.
Baldock is a fantastic town to live in, but the existing infrastructure is already stretched by the current population. The roads are crowded, without adding a possible 6000+ cars into the equation. We have insufficient dentists and doctors for the number of people. Regardless of what is being promised in terms of a community hub of shops and services, there is still going to be significant negative impact on the existing town.
Turning to schools, we currently have three primary schools, 2 of which are oversubscribed, and a secondary school which is also massively oversubscribed. Despite proposals including new schools to cope with the number of children coming to live in the development, the juvenile population of the town will become bisected. I fear that without additional provision for the young people of the town, we will see a rise in crime and unrest between the 'old town' and the 'new town' factions.
Commuting to work, especially if the new residents have to travel to London, is going to be especially difficult as the railway service is due to be curtailed, and roads are going to hugely congested.
Overall, this should be considered a new town, should be moved away from Baldock and considered a separate entity rather than an extension of a beautifully proportioned and friendly town.

I wish to object to the proposed development at the Blackhorse Farm site BA1 to the north of Baldock as it is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY in the following areas:

- Inappropriate Green Belt development
- Air quality in town centre.
- Traffic congestion in Baldock town centre
- Capacity restrictions at Baldock Station

Additional details on why I believe each of these points are an issue are provided below.

1. Inappropriate Green Belt development: The proposed Blackhorse Farm development is in direct contravention to clearly-stated government policy in relation to the Green Belt. The Department for Communities and Local Government's planning guidance states that:

"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 ... inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."

NHDC councillors have stated that they have no other option than to propose green belt developments in order to meet government housing targets, but the ministerial guidance on Green Belt development published on 6th October 2014 makes it clear that councils are NOT required to build on the Green Belt in order to meet housing targets.

The Blackhorse Farm development is clearly urbanisation of land, and political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt is intended to stop.

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) on this basis the plan not the most appropriate strategy.

2. Air quality in town centre: Baldock sits in a valley which is well known for having poor air circulation causing air pollutants from vehicle emissions to be trapped and concentrated. With the he Eastern Baldock Bypass was built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution.

Since then asthma amongst 5-16 year olds has reduced from 15% (in 1994) to 6%. However traffic is on the increase and now the levels pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels. 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, a significant proportion of 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. As a parent and resident of Baldock who lives just off Hitchin Street this is deeply concerning.

3. Traffic congestion in Baldock town centre: The local highways network will be severely affected by the development of this site. Primarily of concern is the junction where the A507 North Road meets the Royston Road (the old route of the A505) at the junction of Whitehorse Street, Station Road, Royston Road and Clothall Road.

All major traffic flows entering Baldock - plus all the corresponding traffic flows heading in the opposite direction - have to pass through this single junction. As a result, the junction is always congested, and congestion during the rush hour can extend back almost as far as the Baldock services.

There are listed buildings on either side of the junction so development of this junction to cope with additional traffic will be a problem. So building 2,800 houses on the Blackhorse Farm site is about the worst possible thing that could happen in this part of Baldock.

Therefore 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 using this junction as well as the proposed new link roads.

4. Capacity restrictions at Baldock Station: In relation to the NPF, Section 4 "Promoting sustainable transport". Paragraph 32 states that "All developments the generate significant amounts of movement should be supported by a Transport Statement ..." and goes on to state that "... development decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit significant impacts of development. "

The NHDC Local Plan makes no significant points other than the convenience of Baldock's location next to a station. It is interesting to note that NHDC had not consulted with Govia the train provider during the course of the preparation of this local plan. Currently Govia are planning to reduce the service to Baldock at off-peak times.

Therefore the Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.

If this proposed development goes ahead it is expected that most new Baldock residents will commute to work outside Baldock. In addition to extra pressure on the roads there will be unacceptable pressure on the already overcrowded railway service. Baldock station is small and would require significant alteration to accommodate additional passengers and the longer trains needed for them.

The train operator (Govia) is currently holding their own consultation on future rail provision for the line and intend to cut "semi-fast" trains stopping at Baldock outside of peak hours. This will not be sufficient serve the thousands of extra journeys that will be made from Baldock. More concerning is that until recently both British Rail and Goiva has not been consulted by NHDC in relation to the local plan in relation to important issues such as building a bridge over the railway from the A505 Royston road into or round the BA1 site or the potential of additional demand in the future.

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 expansion of Baldock goes beyond what is reasonable for any area to accommodate. It sees the town increasing in size by 80%, without any consideration for local amenities such as doctors, police etc. The school provision is lacking in detail and timing consideration.
The current public footpath to the station is dangerous, only allowing one person at a time to use it on what is a very busy road that lorries use. Dispite Network Rail attempts to reduce bridge strikes here they still continue to happen or we have lorries reversing down the road looking for a point to turn around.
The train service to Baldock is also being reduced which will add even more strain to the community.
The loss of the agricultural land will have an environmental impact to the local community at a time when we are being encouraged to support local business and reduce air miles for our food. This does not take into consideration the job and home losses incurred by this action - the council will be creating this but I doubt that they will support the families effected.
I also find it very interesting that over 90% of the proposed land is owned by the council, where is the investigation into this?
This year we have found newts on this land, I could not find the environment impact and mitigation report for any protected species.
It's claimed that affordable housing will be created yet Baldock is a higher property value area. How does this tally?
Finally why was the proposal to create a new town not fully investigated?

The site BA1 North Baldock is completely unsuitable for such a massive development.
The first point I would ask for your consideration on is

POLLUTION - Baldock has been monitored over the years (especially when decisions were being considered for the A505 bypass) - The very high pollution levels were significant in the decision. Baldock is an historic market town that has been the site of a development for many thousands of years and is in fact the OLDEST Town in North Hertfordshire. It has significant archeology in and around the town. It is situated in a natural 'bowl' which is now causing fumes and air pollution to remain in this geography and not being able to disperse naturally. With the onset of fumes from an ever growing vehicle demand. To add potentially 2,500 homes at the North end and a further 1,000 proposed to the south east (approx 2 cars per dwelling on average) to this situation, will send pollution levels beyond the current acceptable guidelines. in fact air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street now. This plan cannot be
justified as being the most
appropriate strategy, when considered against the reasonable alternatives
( Priory Fields) - The Housing and Green Belt Background paper notes that former site 209E (Priory fields in Hitchin) was considered unsuitable for the same
reason! It is not consistent with national policy on account of the likelihood of exceeding air quality limits.
Asthma in the young and old will again rise to an intolerable level. I do not speak lightly on this particular subject as my partners brother died of Asthma and he also suffers with the condition. So i know only too well just how serious this can become. Peak times on North Road have already caused huge tail backs of traffic and one is almost choked by the fumes now when doing the school run with young children.

The number of houses being proposed is grossly disproportionate to the size of the existing town and housing needs within it. The houses will not be there for our children, when they grow up. The numbers proposed far out way the current need locally and will be taken up by people outside of the county.

While not apposed to some housing within the town area and towards the natural boundary of the A505 bypass road. The housing figures proposed here are grossly unfair in relation to the proposed numbers for nearby towns within the county.

GREENBELT -
Greenbelt should NEVER be built on and should be preserved and protected to avoid urban sprawl as agreed in parliament. This proposed development will be built on 'prime arable' greenbelt and will unbelievably be just the width of one road away from Ivel Springs - a local nature reserve and is designated as an 'Ancient Monument'.
In the plan, Housing and Green Belt background paper para 3.14 states
that BA1 site makes a 'significant contribution to Green Belt purposes'.
In the same document, para 5.52 justifies REMOVING BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements "in the first five years following adoption of the plan".

This is contradicted in the Plan itself as the site will only be developed after smaller sites across the town. Policy SP8 makes provision for land in Stevenage West to be
safeguarded for future needs outside of this Local Plan allocation, for up to 3,100 homes, to be used after 2026!
This plan cannot be justified as being the most appropriate strategy, when considered against the 'reasonable alternatives'. The site
West of Stevenage should be reconsidered now and not wait till after 2026.
It may also fail the criteria 4 i.e. it is not consistent with national policy
with regard to the Green Belt. Removing Greenbelt is not a solution, it is there for a reason.


RAILWAY - The rail network at peak times, is already a squeeze. Adding this huge amount of houses to the town and destination is something that will impact further on this.
It is unbelievable to note that NHDC had not consulted with Govia the train provider for Baldock to London Kings X during the course of the preparation of this local plan!
Currently Govia are planning to reduce the service to Baldock at off-peak times by half. This is yet another example of the lack of lateral thought that has been put into this most unsuitable development.
In paragraph 32 it states that
"development decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit significant impacts of development. "
The Plan is NOT effective as it cannot be delivered in the plan period. It also fails the
consistency with national policy test as it does not properly assess the transport
improvements that would be needed for the BA1 site to work.

LOCAL WORK OPPORTUNITIES -
NHDC Local plan states
Policy SP3 describes the additional employment provision of 19.6ha of
land East of Baldock. Building this many homes is certainly no guarantee that these will generate businesses here in Baldock. It is more likely to have thousands more commuters using and filling up an already clogged Rail and Road network. The A1 corridor is completely inadequate now to take the huge volume of vehicles at peak times. How will having a huge number of developments all the way along it be a sensible solution?
The proposal also states that the council will "promote and support the expansion of the knowledge based economy in the District". Paragraph 4.23 states that "Many higher skilled residents commute out of the District for employment. "
Then Paragraph 34 states that "plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimized "
Yet another clear contradiction in policy and reality.
This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives.
West of Stevenage should be reconsidered.
It also fails the criteria 4 i.e. it is not consistent with national policy as West of Stevenage has not been properly considered.

INFRASTRUCTURE
Local plan -
SP14 states that a masterplan must be produced prior to any other detailed matters. No detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added
in September 2016) but it does not give detailed plans!

Paragraph 177 states that it is equally important that planned infrastructure is deliverable in a timely fashion.
To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.
This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.

At one meeting I attended it was put to us (residents) that a generation of Baldock children would need to bused out of the town to neighbouring schools as the schools would only be built when the need is already there (IE the houses are built). This is madness and reactionary political decision making at it's worst. The schools in Baldock are all over subscribed now. Effectively doubling the size of the town is going to have a disastrous impact on the schooling in our town. Baldock has an incredibly good name when it comes to schools and the community is incredibly proud of that fact. The lack of thought behind these decisions to facilitate what seems to be planning bullying on a small historic town is outrageous.

The doctors surgery is verging on impossible to get an appointment and our doctors are working to capacity already. They can not facilitate a large increase in local population demand.

The roads in and around this town are already near capacity and to think not long ago a bypass was given the green light to alleviate this problem. Now we are just going to undo all that work. Putting another bypass in to the North East of the town, may well encourage some traffic to use this and avoid the town. But you can not ignore the massive demand on the roads there will be within the boundary of the town. Commuters, coming in from surrounding villages, lorries delivering, commuters from within the town needing to get to the overcrowded station and finding the car park not big enough, the trains not long enough, the services cut.

The sewage works (by the allotments off North Road) will need a complete new site as the current plant is inadequate for 3,500 new homes and the waste they will demand to be processed.

There is a flood risk in Baldock already, surely this number of homes is just unsuitable.

The Lister hospital - This is a general point for such a large number of housing in North Herts. How will it cope? It is a super hospital right now, but absolutely working to near capacity.

BUILDING AFFORDABLE HOMES IN BALDOCK - This is a folly and a myth. NO developer will invest millions into an area that will see its house prices drop.
affordability - There can only be a cap on the first round of selling, then after that the market will determine the price and 'all the homes for our children and our grandchildren', will be as far away as they always were.

Lastly, here is one thing I would like to add on this point, that is not easy to qualify with paragraph numbers etc. This point is 'community, pride, history, caring and a sense of belonging'. I know to many planners these are things that they have told us are not valid points. But as someone who has lived here for 25 years and has chosen to have children here. I can say confidently that should these be adopted, one day we will lament this plan and policy. Talking about how the community rallies together and to see and witness the sense of pride in our historic town will be something long gone if this disproportionate and frankly unfair development is approved. I urge you to reconsider this plan and to apply a sensible and fair number of homes that will give the town chance to grow WITH and embrace. Not be swamped by and lose everything that we hold dear about our town.

I trust you will give these points due consideration and reject the BA1 North of Baldock proposal.

It appears that no transport assessment has been made for Baldock which is taking 80% of the housing development
1. Traffic assessment
2. Failure to inform or discuss with the railway companies as Baldock is to have its rail service reduced in 2018

Although change is inevitable the plans for the changes to Bygrave Road and North Road have not been fully thought out. The plan will permanently destroy farmland and create major problems for the transportation in Baldock and beyond.
The current plan is for over 3000 homes means at minimum an extra 5000 car movements per day on a road that can't cope with the current traffic. This would mean we would suffer years of chaos before a multi-million bypass is built using even more green belt.
When the plans for the work needed to make the Whitehorse junction better suggested a mini roundabout (£20,000). However since then a lorry has nearly destroyed the building on the corner. To really make sure that the junction is better would be to destroy listed buildings.
I understand that the aim is to get people to use public transport but that creates the more issues.
The bus system is in effective as there are buses hourly.
The trains are reducing the times and for the future the platform must be expanded.

This one development will increase the size of Baldock by approx. 50% and be at the end of town. This will have a significant impact on town's current infrastructure that the proposed plan is vague on. This development will need a dedicated primary school, doctor's surgery, dentist, pharmacist, post office and probably other shops as a minimum. The road connecting the A505 will need to cross the rail line by going under or over it otherwise it will create another bottleneck. Then there is the impact on surrounding roads, rail journey growth.
A&E facilities that all need to facted in. The plan mentions these yet there does not link the required infrastructure changes to the proposed development or how the proposed development will minimise the impact on the current local population.

I would like to formally register my views on the proposed plans, and in particular my opposition to certain aspects proposed in the 20 year plan relating to Baldock, which I believe are not sound.

Firstly, Baldock is a unique rural market town in Hertfordshire which has managed to retain a strong local community whilst transitioning to a modern thriving town, with local shops, restaurants, pubs, small businesses and excellent schools. Increasing the size of Baldock by 3,290 new homes would equate to a population increase of approximately 8,000 people, nearly doubling the number of Baldock residents (based upon an average 2.4 people per household, as used by the Office of National Statistics). This will undoubtedly have a major impact to the feel of the town, dramatically changing the character of the town. Baldock does not have the space or infrastructure within its Town Centre to be able to expand and provide the kind of shops comparable to the likes of Letchworth or Hitchin, which would be necessary to support the increased number of residents. Even with careful planning it is hard to imagine how the necessary broader infrastructure (roads, railways, services and schools) could be developed at the necessary pace to support the proposed housing development. As far as I am aware, there is no overall integrated plan with Network Rail and the local rail service provider to cope with likely increase in commuters using the railways. Nor am I aware of any modelling of the impact that the proposed developments would have on the volume of road traffic entering Baldock. There would likely be a significant increase in the volume of traffic passing through the town centre, unless of course the old proposed northern by-pass is also built as part of the new development, though this was considered unsound at the time of the by-pass debate which resulted in the selection and construction if the eastern by-pass. On the basis that all these things do not appear to have been fully considered, then I believe that the proposal is not sound.

The development strategy ought to be to maximise use of existing brown field sites within the boundary of Baldock; minimise the growth of Baldock and protect the countryside, open areas and Green Belt local to Baldock and rather, the planning authority ought to consider the establishment of a New Town in Hertfordshire which can be developed in a more controlled, planned way, with the local infrastructure developing at the same pace as the new town.

I have no objection to the development of Areas BA2; BA4; BA5; BA7 and BA11, but I strongly object to Areas BA3 and BA1 being developed, on the basis of my concerns outlined above. A major additional concern to the development of Areas BA1 and BA3 is that these are prime green belt land, which goes against the principle of checking the unrestricted spread of large built-up areas, and would result in the loss of the rural feel to the existing boundary of Clothall Common, adjacent to the retained Allotments. This is an important feature to the balance of the feeling of the town (modern and old) with its rural surroundings. Any such housing would be very close to the Baldock by-pass, which is not sound from an environmental perspective with the potential for high levels of air and noise pollution for those residents.

I feel strongly that we must not reduce the easy access to open fields and Green Belt land for the local community of Baldock, and rather focus more on re-using and re-claiming existing industrial or brown field sites. On that basis I would also ask the Planning Authority to consider re-using Areas BE1; BB1; BE2 and BA10 for housing and re-locating those existing businesses to other modern industrial capacity in neighbouring towns.

I wish to put forward my comments on the Local Plan 2011-2031, with particular reference to Baldock.

I am strongly opposed to the proposal to develop areas BA1 and BA3 on the plan and believe the plan to be unsound for the following reasons:-

1) The scale of the development is inappropriate to Baldock, which is a small historic market town and one of the oldest settlements in the country. Development on this scale would have the effect of almost doubling the size and population of the town and would spoil its special character.

Although the plan allows for the provision of schools and shops on the BA1 area, there will still only be one Baldock town centre which will become choked by the additional traffic coming in to use its facilities. This will not be alleviated at all by the existence of the Baldock bypass - even today the town continues to suffer from congestion at peak times. Similarly there will still only be one small railway station, which is already very busy at peak times and will not be able to cope with a dramatic increase in commuters.

2) The development of areas BA1 and BA3 would be on prime Green Belt land. As such it would go against the principle of checking the unrestricted spread of large built-up areas, nor would it prevent neighbouring areas from merging into each other as BA1 would see the merger of Baldock and lower Bygrave. It would also encroach into the countryside, meaning that Baldock would lose its beautiful rural landscapes, which in turn would spoil its rural market town setting.

Development of area BA3 also goes against the original principles of preserving the landscape which were followed when the bypass was built, where the road was built into a hollow so that it could not be seen. The residents of this area, should it be developed, would suffer air and noise pollution from the bypass traffic.

It is well known that access to open spaces enhances the health and well-being of local communities. Development of these two areas would have a detrimental effect on the existing residents of Baldock as the open spaces available to them would be further away, and life in the town centre would be more inconvenient. The open areas are also wildlife habitats and development there would threaten a number of species, including at-risk farmland birds, with no guarantees that they could be successfully relocated.


I do recognise the need to provide extra housing for the area and have no objection to the proposed development of areas BA2, BA4, BA5, BA7 and BA11 on the plan. In fact I would suggest that area BA4 could actually be expanded, in a north-easterly direction parallel with the A505 towards the junction with the bypass, as long as it did not extend as far as the junction or run alongside the bypass.

I have objected to the development of area BA5 in the past, but would rather this area was developed instead of Green Belt land.

Furthermore, I would suggest that extra housing could be built on area BA10 of the plan, as an alternative to developing open land. The possibility of building a new town at a new location in Hertfordshire should also be reconsidered.

My final comment would be that the estimates for the numbers of new homes required were made before the UK voted to leave the European Union, and as such would have had to allow for unrestricted numbers of people coming to live in the UK from Europe. If the UK is to limit these numbers then the forecasts should be re-estimated both locally and nationally, in which case I would expect the estimates to be reduced, including those for North Hertfordshire. As the forecasts are probably now over-estimates I do not believe the plan is sound, based on these numbers, nor that the "exceptional circumstances" rule can be applied to sanction building on Green Belt land around Baldock.

I would be grateful if you could forward my comments to the Independent Planning Inspector and notify me when the Local Plan is submitted.

Baldock, Inadequate traffic planning

The problem

The local plan being proposed, will increase number of houses in Baldock by 80% without providing a road system that will allow the town to operate.
Baldock is unusual, it has little industry or opportunities for employment within the town, therefore the majority of workers travel south to Letchworth, Hitchin, Stevenage and London. The present road system becomes clogged at rush hour but no worse than many other areas. Most people travel south because, in this area, property is cheaper the further north one lives. Therefore people tend to live north and commute south.
The railway runs east and west, to the north of the town and effectively forms the northern perimeter. Very little of the existing commuter traffic has to cross the railway.
But, the local plan requires 2,200 houses to be built north of the railway line, this suggests that there could be over 1,000 additional cars trying to cross the railway in order to get south, between 8 am and 9 am. The majority will try and use the A507. This road joins Whitehorse Street by means of traffic lights controlling a staggered crossroads. Because of the stagger, and the pedestrian crossings at the junction, there is a long delay before the lights turn green again. Four hundred cars per hour are possibly the best that can be achieved and currently the delay at peak times can exceed fifteen minutes. This junction cannot cope with even modest extra traffic and will be difficult to modify because the buildings at this junction are close to the road and have preservation orders. There is no hope of trying to get an additional 1,000 vehicles through these crossroads, during rush hour.
The additional railway crossing, shown in the Local Plan will not work because it routes more cars on to the old A505 and that brings them down to this same Junction.
I have been unable to find any results of Traffic modeling, the plan says, that as Baldock is on the edge of the current area covered by the model, the existing model cannot be used.
Beyond the Whitehorse Street junction, the southerly traffic has to negotiate Hitchin Street. This is so narrow that two HGV's or busses cannot pass and vehicles have to wait so single file traffic can be established. There are then two sets of uncoordinated traffic lights, which create further delays. The plan does not mention how these problems are to be overcome.

Possible solutions
1.Provide roads that will route the traffic round the existing pinch points. Possibly a dual carriageway between the new A505 and the A1(M). Possibly a new bridge over the A1(M) to connect the new properties to the road between Stotfold and Letchworth.
2.Introduce, a one way system round Baldock, so through traffic, which is the vast majority, does not have to come into the town.
3.Provide a bridge over the railway, for cars, cyclists and pedestrians, near to the railway station so travellers do not have to join the queues on the A507 in order to catch a train.
4.Establish a sizable industrial area north of the Railway to soak up a proportion of the new population.

Summary
The proposed plan will not work. The problems must be resolvable. However the council has limited itself to using land it already owns, rather than looking for the best solution. I request that the planners be asked to revisit these proposals and if necessary purchase land for highways.

See attachment

North Hertfordshire Local plan 2011-2031

I feel the proposed plan for area BA1 Black Horse Farm would be extremely unwise.

*Any additional traffic from the site to the town centre would have to enter the cross roads at White Horse street/Station road junction.
This is already extremely congested with queues stretching back towards Baldock services. The junction cannot be altered as there are listed buildings
At this point. If the suggested new road joining the A505-A507 were used to get into Baldock the same junction has to be used.

*The resulting vehicular increase would cause further air pollution.

*The increase in population would completely overwhelm existing services in the town Surgery, Schools, we have no Police station, Rail services are
Likely to be reduced according to recent news reports.

*Ivel Springs nature reserve could well be in danger of pollution/ flooding with all the proposed building.

The idea of the planned first development at BA2 & BA3 without any additional Schools and other services cannot be supported with the towns present amenities.

*The schools are full, in fact some children have to be bused out to neighbouring villages!

*All construction traffic to the two sites would need to pass through the town on already very busy roads.

*Parking in the town is difficult at most hours of the day and night ,no provision for more is planned and there appears to be nowhere for it.

BA7 is allotment land so cannot be built on.

Baldock is a pleasant market town the smallest in the North Herts and the least able to cope with an 80% increase in size.

I am writing to comment on the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016). In particular, I wish to object to the massive proposed development at the Blackhorse Farm site to the north of Baldock. My objections are based primarily on two of the "Tests of Soundness" that Local Plans are required to meet:
"Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities;"
"Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework."
My comments below identify six areas in which the Local Plan clearly fails to meet the requirements of the National Planning Policy Framework:
1. Traffic congestion in Baldock town centre
2. Access to Baldock station
3. Capacity restrictions at Baldock Station
4. Proposed new road connecting A507 and A505
5. Inadequate local infrastructure to support existing needs
6. Green Belt development
Sections 1 to 3 also demonstrate that the planners have failed to consider the transport and congestion issues raised by their plans. It has become clear during recent public meetings that they have no strategy for addressing these issues, and some of the issues raised by the proposed Blackhorse Farm development are so extreme that there is no realistic solution. I therefore believe that the Baldock part of the Local Plan is simply not deliverable, and so fails two of the four Tests of Soundness.

It is shown below that Baldock is already struggling with over-stretched amenities and major traffic congestion, and the Local Plan would increase Baldock's size by 80%. Sensitive infill development in appropriate areas of Baldock would be beneficial, but wholesale dumping of a major part of NHDC's housing requirement on one small town without any attempt to address the inadequate infrastructure will have very serious consequences that have simply been ignored.


1. Traffic congestion in Baldock town centre

Traffic access into Baldock is restricted by two major barriers: the railway line and the A1(M). As a result, a very high proportion of traffic entering or leaving Baldock is forced to cross one particular road junction in the town centre. This junction pre-dates the A1 and the railway by hundreds of years and was never intended to carry anything like the current volume of traffic.
The junction in question is the one where the A507 North Road meets the Royston Road (the old route of the A505) at the junction of Whitehorse Street, Station Road, Royston Road and Clothall Road. This junction is used by:
* Traffic entering Baldock from the north west on the A507;
* Traffic entering Baldock from the north on the A1;
* Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages;
* Traffic entering Baldock from the north east on the A505;
* Traffic entering Baldock from the south east on the A507.
All these major traffic flows entering Baldock - plus all the corresponding traffic flows heading in the opposite direction - have to pass through this single junction. As a result, the junction is always congested, and congestion during the rush hour can extend back almost as far as the Baldock services.
Air pollution levels between the railway bridge and the junction are particularly high during the rush hour, and are probably higher than anywhere else in Baldock[1]. It was stated during public meetings on the draft Local Plan that Baldock has an existing air quality problem, and that the "Baldock bowl" concentrates particulates from traffic exhausts.
There are listed buildings on either side of the junction so there are no simple solutions to this problem - which is why nothing has been done about it. The approach has been to avoid doing anything that makes the problem any more critical than it already is, so building 2,800 houses on the Blackhorse Farm site is about the worst possible thing that could happen in this part of Baldock. Planning should be about enabling the town to expand in a sustainable way, but adding approximately 5,600 cars to an area that is already massively congested will simply lead to gridlock and will further exacerbate the air pollution problem. Objective 2(c) of the Sustainability Appraisal Framework includes the sub-objective: "avoid exacerbating local traffic congestion", but it appears that this requirement has simply been ignored.[2]
Surprisingly, the Draft Sustainability Appraisal by CAG Consultants[3] does not appear to mention this problem, although it does include some generic concerns about traffic such as:
"The density of traffic on the principal road network is high and increasing but the rural nature of the District makes the provision of sustainable travel modes more challenging."
In a response to the consultants' findings, North Herts District Council stated that:
"Detailed policies and / or Transport Assessments (or equivalent) at planning application stage will ensure these issues are considered".
I find it incredible that such a major problem has not yet been addressed by the planners. Since the Blackhorse Farm development will have a massive impact on traffic congestion, the National Planning Policy Framework clearly requires a Transport Assessment to be produced. This is defined as:
"A comprehensive and systematic process that sets out transport issues relating to a proposed development. It identifies what measures will be required to improve accessibility and safety for all modes of travel, particularly for alternatives to the car such as walking, cycling and public transport and what measures will need to be taken to deal with the anticipated transport impacts of the development."
I can see no possible way in which a Transport Assessment that meets these requirements could be produced for the Blackhorse Farm site. Consequently, the Local Plan is not in accordance with the policies of the National Planning Policy Framework and is not deliverable, so it fails two separate Soundness Tests.
NHDC's approach of deferring the Transport Assessment until the planning application stage is simply kicking the issue into the long grass; it stops members of the public from commenting on this critical component of the Local Plan during the current (final) consultation, and it also prevents scrutiny by the Planning Inspector. This is unacceptable.

2. Access to Baldock Station

The problem described in the previous section is made considerably worse by the unfortunate fact that Baldock Station is located between the congested traffic junction and the barrier formed by the railway embankment. As a result, traffic heading towards the station has three options:
* Approach from the north via Station Road. This traffic has to pass through the constriction formed by the railway bridge, and this area is always massively congested during the rush hour.
* Approach from the south via Station Road. This traffic has to cross the congested traffic junction that was discussed in the previous section.
* Approach from the west via Icknield Way or Football Close. Both of these are residential streets with extensive on-road parking, so they are effectively only one car wide.
During the evening rush hour, the arrival of each train from London frequently creates dangerous situations at the bottom of the station approach road as cars from the station try to force their way into the traffic and face resistance from frustrated motorists who have spent a long time in the queue. Cars turning right have to undertake a particularly dangerous manoeuvre.
Despite the suggestions of the planners that a high proportion of "affordable" housing will be included in the development, there is very little evidence that employment in Baldock will grow sufficiently to accommodate this influx of new workers, or that the jobs will be sufficiently highly paid to allow people to pay for these homes. The location of the Blackhorse Farm development so close to Baldock Station inevitably means that many of the houses will be sold to people who commute to London or Cambridge. It was admitted at one of the planning meetings that the developers might try to buy their way out of affordable housing commitments so that they could focus on selling to affluent commuters. If this occurs, then existing congestion problems will be made far worse.
When Cllr. Levett was asked about this at a meeting on 12th July 2016 at Knights Templar School, he said that they were looking at walking and cycling options. It was pointed out to him that the railway bridge on North Road is only marginally wider than two cars, so the only cycling option is to sit between stationary cars in a traffic jam. The walking options are not much better because the pavements under the bridge are extremely narrow. At this point, he declared that this was not a planning problem.
Once again, a fundamental weakness in the Local Plan is simply being kicked into the long grass to prevent the public or the Planning Inspector from commenting on it. Paragraph 32 of the National Planning Policy Framework requires the Blackhorse Farm proposals to be supported by a Transport Assessment to show how these issues will be resolved, and Paragraph 177 of the same document requires infrastructure development policies to be included in the Local Plan. When the Transport Assessment is eventually published, it will demonstrate that this Local Plan is not in accordance with the National Planning Policy Framework and is not deliverable.

3. Capacity restrictions at Baldock Station
The National Planning Policy Framework requires a Transport Assessment that emphasises "alternatives to the car such as walking, cycling and public transport". Clearly, the railway is a major component of the public transport provision in Baldock, so it is important to consider whether it has the spare capacity to carry the additional traffic that would be generated by new developments in and around Baldock.
Baldock only has a small station, and many rail travellers are already forced to stand all the way to London. It has been estimated that the Local Plan will increase the number of rail journeys for Baldock from 330,000 to 600,000 per year[4]. Unfortunately, the additional capacity required in the rail network to support this simply does not exist, and would be massively expensive to create. One of the key constraints is the cost of upgrading the Welwyn Viaduct and the Welwyn tunnels from two tracks to four.
The "Draft Sustainability Appraisal of North Hertfordshire Proposed Submission Local Plan" by CAG Consultants suggests that high density developments should be allowed in close proximity to town centres or railway stations. However, this pre-supposes that the railway station has the spare capacity needed to carry the additional passengers that will be generated by the development. In the case of Baldock Station, there is no realistic expectation of any new capacity becoming available.
Indeed, exactly the opposite seems to be happening. Under plans announced by Govia Thameslink in their 2018 timetable consultation, Baldock is set to lose semi-fast services to and from London in order to free-up capacity for services to other places further up the line with even more pressing needs. They will also be replacing the existing trains with newer models that provide air conditioning - but 30% fewer seats[5]. Far from the integrated approach to housing and transport planning advocated by Paragraph 31 of the National Planning Policy Framework
"Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
the local authority and the transport provider in Baldock are working against each other to make the situation far, far worse.
The Local Plan proposes to increase the population of Baldock by 80%. These new residents will need employment so that they can afford to buy the proposed new houses. Whether they travel to work by road or by rail, it is clear from the arguments above that they will create unsustainable levels of congestion that cannot be mitigated by any realistic investment in new infrastructure. This Local Plan is therefore not deliverable.

4. Proposed new road connecting A507 and A505
Although the NHDC planners have not produced a Traffic Assessment for the Blackhorse Farm development, they have proposed a road linking the A507 north of Baldock to the A505 east of Baldock. Paragraph 4.179 of their "Final draft of the Local Plan" states:
"The site is also large enough to support new schools, local facilities and a new link road, including an additional road bridge over the railway so that not all traffic has to use the Station Road bridge and the Whitehorse Street/Royston Road crossroads."
In other words, the road would allow some traffic to avoid the junction that is discussed in Section 1 above. However, it is not explained how this link road will address the needs of the Blackhorse Farm development. People living on the new development are hardly likely to drive across to the other side of the railway line so they can enter Baldock via the same gridlocked junction from the east instead of from the north. The traffic implications of the proposed development are so serious that a Traffic Assessment based on rigorous traffic modelling should be published for public scrutiny and comment before the Local Plan goes to the Planning Inspector.
The link road will, however, be a major benefit to traffic flowing between places such as Ampthill in the east and Royston in the west. Both of these roads are dual carriageway as they approach Baldock, so the link road can be expected to be equally busy. Whether the planners intend it or not, this will become a major trunk road running through the development.
To minimise air pollution problems in the development, the capacity of this road and its associated railway crossing will have to be sufficient to allow the traffic to move freely. Furthermore, to minimise noise pollution, the road will have to be set in a cutting below the level of the surrounding development.
Since the railway is raised on an embankment in this area, a bridge over the embankment would have a major noise and visual impact on the surrounding area. It should therefore be a condition of this development that the road passes under the railway line (in a tunnel) rather than over it (via a bridge). For the residents of the new development and the existing residents of Lower Bygrave, the design of this road and the associated railway crossing is a critical issue.
During the Council Meeting on 24th July 2016, Cllr Levett said that the new road would probably join North Road near the turning for Radwell. However, he also said that they were forced to plan this development on Herts County Council land because no other land had been made available. I do not know whether it would be possible to bring the road as far north as the Radwell turning without leaving Herts CC land. If it has to be brought out further south, it would cause even more congestion during the rush hour and would presumably require existing houses to be demolished.
Another problem with this road is that it effectively accepts that the Blackhorse Farm development can never become an integral part of Baldock. As explained in Sections 1 and 2 above, the railway and the traffic junction form a bottleneck between the new development and the centre of Baldock, and the proposed new road will do absolutely nothing to fix this. As a result, Baldock will develop like an hourglass with two physically-close but largely separate town centres linked by a narrow constriction. There is a real risk that the new road will mean that the Blackhorse Farm development will develop a closer affinity with towns such as Stotfold - which would only be about 2 miles away and linked by a fast road. Although the development would lie within the boundary of Baldock, it would be a ghetto having little involvement with the life of the town. This flies in the face of Section 2 of the National Planning Policy Framework which requires new developments to promote the vitality of associated town centres, and talks about developing on "accessible sites that are well connected to the town centre".
Baldock is one of only five Hertfordshire towns classed as being of national importance for its historic character, and the town centre contains over 100 listed buildings. Nobody - not even the NHDC planners - claims that the Blackhorse Farm development will enhance Baldock town centre.

5. Inadequate local amenities to support existing needs
The number of houses allocated to Baldock will increase the population by 80%. Rather than seeking to preserve the character and heritage of this historic market town by sensitive and carefully-planned development, it has simply been used as a dumping ground for a large number of houses in order to meet an unrealistic quota. The scale of development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched.
At local planning meetings, NHDC planners have been bombarded with questions and complaints about inadequate local amenities. Schools, doctors' surgeries and other basic amenities are already at full capacity. Even water supplies are inadequate (Affinity Water describes our area as being under "serious water stress", and there have been a number of incidents where residents of Upper Bygrave have lost water supplies completely).
During a discussion about the alternative option of a new garden city (as proposed by our local MP, Sir Oliver Heald) it was pointed out that a new city would at least start from a position of no amenities, but a massive development at Blackhorse Farm would be put into an area where the amenities are already in deficit. Furthermore, we can be certain that developers will build houses before building any amenities, so the situation will have to get considerably worse before any action is taken.
Paragraph 177 of the National Planning Policy Framework states that:
"It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. Any affordable housing or local standards requirements that may be applied to development should be assessed at the plan-making stage, where possible, and kept under review."
The Local Plan should not be accepted until residents' concerns about local amenities have been fully addressed.

6. Green Belt development
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review[6] provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion. This omission is interesting, because I have seen very little evidence of urban regeneration in this Local Plan.
The proposed Blackhorse Farm development to the north of Baldock is a classic example of urban sprawl, and is exactly the kind of rapacious development that the Green Belt was intended to prevent. Paragraph 41 of the North Hertfordshire Green Belt Review states that
"Checking unrestricted sprawl of large built-up areas is a component of areas adjoining the three major settlements in North Hertfordshire. This explains the significant contribution scores for all areas surrounding the settlements of Hitchin, Letchworth, Baldock and Knebworth."
It is interesting to consider why this has happened when the evidence presented in this letter shows so clearly that the Blackhorse Farm site is entirely unsuitable for the scale of development that is proposed. The answer seems to be that the normal planning process was bypassed for reasons of political expediency. Herts CC owned the land and were keen to sell it, so the planners were told to focus on this site rather than other more suitable land that might be available. Councillors claim that no farmers volunteered to contribute land for development, but it appears that the farmers were never asked! Since the location of this "strategic site" was determined by political expediency rather than by planning considerations, it is hardly surprising that the site has so many problems. As one councillor put it during the Council Meeting on 20th July 2016, "you can't make a silk purse out of a sow's ear".
I feel very strongly that we should be doing everything in our power to protect the Green Belt - particularly since there are other sites available that DO meet planning criteria and are NOT in the Green Belt. According to the Department for Communities and Local Government's planning guidance:
"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 .. inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
It was stated at the meeting of North Herts District Council on 27th November 2014 that the council has no option but to develop on the Green Belt because they are required to meet housing targets set by the government. However, I have read the ministerial guidance on development in the Green Belt published by Communities Secretary Eric Pickles and Housing & Planning Minister Brandon Lewis on 6th October 2014, and it makes it clear that councils are NOT required to build on the Green Belt just so that they can meet housing targets. At the council meeting on 27th November, councillors consistently stated that they were being forced to develop the land to the north of Baldock, when it seems to me that they are specifically PREVENTED from doing this. My understanding from the meeting was that NHDC believe that they can ignore the ministerial guidance and propose a Local Plan in which most of the construction will be on Green Belt land.
The council also claimed at the same meeting that they can get around the Green Belt problem by removing the Green Belt designation from land where they want to build and applying it instead to land in other places where they do not want to build. This is clearly not a reasonable interpretation of the rules; if it was, then the Green Belt would become completely pointless because it could simply be shifted whenever it gets in the way of development. Maps of the Green Belt in the area indicate very clearly that it was specifically intended to protect the countryside around Baldock and the other local towns - not somewhere else.
The council have claimed that they have no alternative to developing Green Belt land, yet there are other sites available that meet all of the planning criteria and are not in the Green Belt. To my knowledge, the council have offered no explanation as to why these sites have been held back and placed on the reserve list when they should have been prioritised over Green Belt development.
Paragraph 79 of the National Planning Policy Framework states that
"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 spite of this, a large proportion of the development proposed in the Local Plan is on Green Belt land, suggesting that the Green Belt in North Hertfordshire is not permanent at all. Furthermore, the proposed Blackhorse Farm development is a classic case of urban sprawl driven by political expediency - despite the government making it very clear that political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt was intended to stop. It may be a fundamental government aim "to prevent urban sprawl by keeping land permanently open", but it is clearly not an aim shared by NHDC. How can we have any faith in a planning system that allows councils to ignore long-established environmental protections as soon as they become inconvenient?

Conclusions
The scale of the proposed Blackhorse Farm development is well beyond anything that Baldock could reasonably be expected to accommodate. The very large number of houses proposed, and the natural constriction of the transport corridors, indicates that the development would not be an enhancement to Baldock but a competing economy that will suck economic activity out of the town centre. The planners have not described the Blackhorse Farm development as a new town, but that is effectively what it is. Sensitive infill development in appropriate areas of the town would be beneficial, but the urban sprawl that is proposed will lead to massive traffic congestion and make the town centre almost inaccessible to residents in surrounding villages such as Ashwell. Sadly, the proposed development seems to be driven by political expediency rather than by any coherent plan for the sensible development of the town.
Paragraph 32 of the National Planning Policy Framework states 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 ... improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.
Sections 1, 2, 3 and 4 of this letter demonstrate that the "residual cumulative effects" of the proposed Blackhorse Farm development are indeed severe, and the Local Plan is not supported by any Transport Statement or Transport Assessment for the site. The National Planning Policy Framework therefore requires that the development should be "prevented or refused on transport grounds". Deferring the requirement for a Transport Assessment until a planning application has been received effectively bypasses the scrutiny of the Planning Inspector and should not be permitted.
Section 5 of this letter shows that the scale of proposed development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched. The planners have largely ignored residents' concerns about local amenities, but Paragraph 177 of the National Planning Policy Framework clearly states that "infrastructure and development policies should be planned at the same time, in the Local Plan."
Section 6 of this letter shows that the proposed Blackhorse Farm development is in direct contravention to clearly-stated government policy in relation to the Green Belt. The Department for Communities and Local Government's planning guidance states that:
"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 .. inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."
NHDC councillors have stated that they are forced to propose green belt developments in order to meet government housing targets, but the ministerial guidance on Green Belt development published on 6th October 2014 makes it clear that councils are NOT required to build on the Green Belt in order to meet housing targets. The Blackhorse Farm development is clearly urban sprawl, and political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt is intended to stop.
A Local Plan is required to meet four "Tests of Soundness":
1. Positively prepared - the plan should be 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 and consistent with achieving sustainable development;
2. Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
3. Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities; and
4. Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.
This letter has demonstrated that the Local Plan fails Tests 3 and 4 because it is not deliverable and does not comply with the policies in the National Planning Policy Framework.
I understand that the previous public consultation on the Local Plan generated over 8,000 replies, proving that there is very strong public opposition to it. Since then, the plan has not been revised in any meaningful way to address the primary concerns of the local residents. It may be late in the process, but now is the time to demonstrate that peoples' views really do matter and this "public consultation" exercise is not just a sham.
The council will no doubt claim that people who object to their Local Plan are "nimbys" who will resist any development. That is simply not the case. We would welcome careful, well-thought-out development of Baldock, but not the wholesale devastation proposed by this Local Plan. We need a Local Plan that delivers development in a sensitive and sustainable way so that it is seen as a benefit and not as a threat. We also need a Local Plan that sets out a real vision for the future development of local towns and villages rather than simply focussing on housing targets. For the record, I support the very sensible alternative proposal put forward by our local MP, Sir Oliver Heald[7].

We live in Radwell 1 mile from Baldock it can take over 20 minutes to do that journey by car because of the amount of traffic that uses the A507 as a bolt hole that's without H.G.Vs that regularly hit the railway bridge even after extensive modifications to the bridge, then that causes even more havoc, WE CANT GET DOCTORS APPOINTMENTS NOW it can take up to 2 weeks to get an appointment now because of the population of Baldock now without having thousands of extra residents trying to access our facilities, Their are no plans for any guaranteed infrastructure especially roads or bypasses OUR HOSPITALS CANT COPE NOW, I waited 8 months for a hospital appointment at my nearest Hospital there are no plans for more hospitals in this area. I was critically ill in intensive care for 6 weeks but was taken to the QE 2 in Welwyn Garden City 20 miles away my wife doesn't drive and had to try to get there every day for that 6 weeks.
HOW WILL OUR HOSPITALS & DOCTORS COPE!!!
SCHOOLS, local people can't get their children into local schools now so have to drive them there making more traffic into our already congested small town.
PARKING an absolute nightmare now, parking for the tiny rural station is a big issue hundreds park anywhere they can in & around Baldock & the villages obstructing our narrow lanes while they commute to London & main Cities OUR GREEN BELT, is getting smaller & smaller merging village life into massive style estates, WHERE ARE THE GUARANTEES FOR ALL THESE POINTS THERE ARE NONE.

I wish to register my objection to the proposal to hugely increase the size of Baldock through the building of in excess of 3,000 houses around the town and it's environs.

Until such time as all the redundant brownfield sites across North Herts and Stevenage are developed for housing there is no need whatsoever to encroach onto existing farmland or other green land, whether designated greenbelt or otherwise.

There is plenty of existing redundant brownfield in North Herts and Stevenage to accommodate the required growth. It may not be as attractive to the developers but that's not the planning authority's concern.

The additional population and vehicular traffic if concentrated around a mall town like Baldock will have a significant detrimental impact on an already struggling infrastructure in terms of roads, schools and social and health care facilities around Baldock.

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

As I am sure you are aware the North Herts local plan has caused a great deal of concern amongst local residents and I wanted to include my representations for consideration even though I am sure these mirror those of a great number of local residents. I believe the plan as it currently stands does not comply with the National Planning Policy Framework. Whilst most people could accept some degree of development, proposals which increase the town population by 80% and increase the number of cars by as many as 5000 will destroy the town heritage and overwhelm the infrastructure

Specifically I believe these to be the main issues
1. NPPF Section 4 - promoting sustainable transport.
1. Currently the crossroads in Baldock town centre, linking Whitehorse Street to the High Street is a significant bottle neck. The plan currently has 2800 homes planned for north of Baldock. As things currently stand, a trip across Baldock in morning rush hour, starting in Bygrave takes as much as 45 minutes, with traffic streaming back towards the A1.
2. The significant number of new residents will likely be rail commuters. There appear to be no plans to accommodate extra parking at Baldock station and the rail company, Govia are currently in consultation to downgrade the Baldock service. As things stand many trains into and out of London from Baldock suffer from significant overcrowding. I have doubts as to whether the current rail service and station at Baldock could cope with the addition of additional commuters from more than 3000 new homes in the town
3. In the absence of accessible town centre parking to accommodate more cars, the additional strain on parking capacity will effectively isolate residents from both upper and lower Bygrave, who, unable to walk into town will have nowhere to park should they drive


2. NPPF Section 9 - Protecting green belt land
1. The individuality of the town will be lost by this upsurge in population. In addition the area on which the houses are planned is very scenic. There are alternative brown belt sites in the area which could be used to absorb at least some of the proposed development.
2. Bygrave is a rural community and a scenic, historical village. This identity will be lost with the number of houses proposed at the North Herts site and effectively create 3 pockets of housing


3. NPPF Section 2 - Ensuring the vitality of town centres
1. I have not seen any plans for additional parking in Baldock town centre. Even though it is only a 15 minute walk into the town from the north Baldock site, we know many people take the car even for short journeys. This will strangle the town.


4. NPPF Section 17 - Promoting healthy communities
1. I have not seen robust plans for schooling to accommodate such a drastic uplift in population. This is key. The schools in Baldock are already extremely difficult to gain entry into (the acceptance criteria to Hertsfield Primary school in 2015 was 360 metres distance to the school gates). Knights Templar secondary school is excellent, but is also heavily over-subscribed. Without adequate planning for schools existing resident's children in the rural communities such as Bygrave and Ashwell face horrific commutes. Going out in the direction of the Cambridgeshire villages then having to come back through Baldock
2. The road planned to link Bygrave Road with the A507 roundabout is planned to be above ground. This will create a great deal of noise and destroy the beautiful views. I believe if this road is to be built it should be in a cutting and go under the railway line.

I understand the need for additional development in Baldock, however I strongly believe the scale of planning is disproportionate with what can be coped with by the town. 3,290 homes are simply too many and I do not believe the local plan complies with the NPPF in several areas.

Baldock Town does not have enough sports facilities for its present population let alone when the town grows. It is a travesty that Baldock Town have to pay and play in Stotfold when they should be playing in Baldock. Baldock needs the facilities so that Baldock Town FC and Baldock Youth are not being stifled by not having pitches to play on. This would unite the club as one and also provide opportunities to have ladies and girls teams and promote a healthy sporting environment for the whole community. This would also result in jobs being created within Baldock for the people of Baldock and the revenue staying within the Town.
Bring Sport for all ages back to BALDOCK NOW.

I am writing to submit my objection as a resident of the Parish of Bygrave to the proposed draft Local Plan and the designation of Green Belt land to be allocated as housing sites within the parishes of Baldock and Bygrave.
I do not think it has been positively prepared, is justified, or effective and consistent with national policy.
I live in Bygrave and have worked as a doctor in Letchworth for 36 years and also for the same period in the cardiology department at QE2 Hospital. I can vouch for the fact that the current medical services are overstretched and have difficulty filling vacant posts.
I now work at the University of Hertfordshire in the Centre for Research in Primary and Community Care, and travel to continue my medical career in London.
I have seen the quality of life of people who travel down the A1M, and on the trains to London deteriorate due to extreme congestion and overcrowding which will be made much worse by the current housing proposals.
The current strategy does not address the fundamental question of how much development is needed to meet local needs and where these needs are required.
It is simply not fair that Baldock and Bygrave should have 3591 houses from the alleged 12100 required by North Hertfordshire (i.e. 30% of the total allocation)? Thereby, increasing the local population considerably and completely out of proportion.
The Blackhorse Farm site in the plan will be a massive new development, with the need for extensive infrastructure, leading to the destruction of natural habitat and a burden on the existing environment and structures.
This surely, cannot be 'effective use' of land, by re-using land that has been previously developed? The plan contravenes the 'Sustainable Community Strategy' encouraged by the National Planning Policy Framework. The allocated site does not promote and improve the economic, social and environment and will lead to reduced quality of life for all of the current residents and destroy the wildlife.
The plan does nothing to improve Baldock Town centre, which will be destroyed by the building of a new town centre within the planned development with shops and factories? The town centre of Baldock will be grid locked with cars, with no parking and empty of amenities. There is no work locally for all these people who will have to travel on our already overrun roads and railways.
The destruction and reallocation of the Green Belt land contradicts the current Green Belt Policy and the planned reclassification of this area does not mitigate the fact that the plan uses Green Belt land and joins two settlements together. Moreover the destruction of the productive agricultural land will not support 'economic growth' in a rural area nor does it create jobs and prosperity by sustainable development.
The plan does not support sustainable transport. The new road network, major junctions extensions to existing roads and the associated utilities and services required for the Blackhorse site burdens the local area rather than reducing the need for major transport infrastructure.
With careful planning, infill sites already identified would satisfy the requirements whilst also reducing the need for major infrastructure development.
The North Herts housing quota could also be satisfied if there was a fairer proportional allocation applied between the towns of Hitchin, Letchworth and Baldock, together with the site west of Stevenage that is already placed on the reserve list satisfying all the criteria required for development.
Of the RSPB's top ten farmland birds in decline, eight of these have been spotted in our area, namely: grey partridge, skylark, corn bunting, lapwing, yellow wagtail, linnet, yellowhammer and reed bunting. Turtle dove are often in Bygrave and the tree sparrow is making a comeback. All these farmland birds show significant, long term decline - grey partridge down 56% in the last 17 years, skylark down 24% and corn bunting down 39%.
With 3479 houses on Bygrave common, some of the foul water will flow along the Drain ditch to Baldock Sewage pumping station close to Ivel Springs on the right (west), and thence to Letchworth. Likewise the surface water runoff that currently soaks into the green fields, will also flow to the Ivel Springs, into the river Ivel, which will become polluted.
There are almost continuous houses from Hitchin, through Letchworth to the east side of Baldock, with only small green spaces separating them and now Bygrave will be included.
What of impact of Blackhorse Farm site on the Whitehorse Street Junction in Baldock an already problem area? The Railway bridge -causes severe delays already, can it take any more cars/pedestrians?
The town has been described as an hourglass, with the crossroads of A505 and A507 at its centre and the listed buildings at the junction make finding a solution extremely difficult. There are already long tailbacks at this junction during morning and evening peak times and the flow may increase by up to 7000 cars and lorries.
Railway travel at rush-hour is a nightmare, Is there enough capacity for the railway to take a potential doubling of passengers? How will commuters get to the station and where will they park??
Will the railway station itself be developed? Govia are conducting their own consultation about changes to timetabling and new services starting in 2018. Amazingly there had been no communication up until November 2016 between NHDC and Govia about the proposed Local plan or infrastructure
Schools, Doctor surgeries, recreational facilities will all need to be provided and no plans have been provided.
Baldock is located valley, where air pollution can easily develop, there appears to have been little research on this issue. In paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. The Housing and Green Belt Background paper notes that former site 209E (Priory fields in HItchin) was considered unsuitable for a similar reason.
There is section on transport policy SP6 "Sustainable transport". A new link road and some sustainable transport suggestions are made in the SP14 policy for the Blackhorse Farm site. The plan mentions that the site is big enough to support a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road bridge and Whitehorse crossing.
What will be the cost of this and who will pay for it? Railway bridges or tunnels are notoriously expensive.
The transport assessment does not consider north 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.
A mini roundabout and phased lights planned for A505/507 traffic lights has been suggested.SP14 4.180 says safe access needed to north of Baldock but doesn't say how it will be done.
There is also mention of Southern link road in B3 and B4 but again, no details are provided. SP14 states that a masterplan must be produced prior to any other detailed plans and no detailed plans have been provided.
There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give suitable detailed plans in my opinion.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1site to work.
The mini-roundabout is the only cost included in the plan for Baldock, in-spite of the clear need for major transport projects , such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra traffic away from the Whitehorse Street junction. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives ( Priory Fields) and fails the criteria 4 i.e. it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
There is no mention of providing additional school/doctor services within the current plan for BA2 and BA3.
The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of approximately 900m meaning that the majority of children in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic issues and timing issues for working parents. The proposed housing within these sites will generate another class worth of primary school children with no clear options. It is already significant problem within Baldock without the additional houses.
There is no mention of what % green space will be provided for, no mention of tree planting to improve air quality, nor mention of the provision of parks for children.
All construction traffic for the further development of Clothall Common would need to go through the town to some extent causing air quality, noise and congestion issues which have no obvious remedy.
It is absolutely inequitable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20% and yet Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.
The housing site is on a slope. Baldock town already has issues with flooding when there is heavy rain. Building on this site will reduce or possibly even remove the natural drainage that currently exists, resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings. There is no mention of how the developers plan to resolve the drainage issues caused by building on this site and it is often found in recent years that housing developments rarely provide sufficient drainage given the lack of green space, lack of gardens and high density of housing.
If housing is needed, it would be better to develop a town of the same size away from existing communities in order that the road network and other infrastructure can be developed to be suitable for the needs of the community rather than exacerbating existing infrastructure issues?

A very good example of where this has worked well is Milton Keynes!
I hope my case is well made and I do hope you will pass my comments on to the Planning inspector

Having lived in Baldock for 25 years I have seen the number of houses in the town grow significantly, however, the sporting and social facilities have not increased with the demand. Now with a young family, most of my children's sporting activities are outside Baldock, which is fine if Baldock was a small village, but with a population of 10,000 there should be more in the town. We have also seen in recent years neighbouring towns pull well ahead of Baldock in developing sport facilities, particularly around football. Surely its about time the town put itself on the map and built new sporting facilities for is residents.

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